As it promised in response to a petition from the KIND fruit-and-nut bar company (as I discussed in a previous post), the FDA is now asking for public comment on what “healthy” means on food package labels.

You might think that any food minimally processed from the plant, tree, animal, bird, or fish would qualify.

But “healthy” is a marketing term for processed food products (not foods).  

As Politico Morning Agriculture reminds us, things got complicated when KIND, which makes products from whole nuts, said its bars deserved to be called “healthy.”

In 2015, KIND received a warning letter from FDA arguing the company violated federal rules by using “healthy” on its packages. KIND then petitioned the agency, and, after an exchange about why the current definition is outdated, FDA decided to reverse course. For example, it requires that a food be low-fat to be labeled “healthy,” a standard that a nut-based bar doesn’t meet, while products like fat-free puddings do.

The FDA’s rules now say:

The term “healthy” and related terms (“health,” “healthful,” “healthfully,” “healthfulness,” “healthier,” “healthiest,” “healthily” and “healthiness”) may be used if the food meets the following requirements: 21 CFR 101.65(d)(2)

OK.  I know you can’t read this (you can look for it here). The point is that to qualify as “healthy,” a product has to be low in fat, saturated fat, and cholesterol; relatively low in sodium; and contain at least 10% of the Daily Value per serving for vitamins A or C, calcium, iron, protein, or fiber (with some exceptions).  There are also rules for levels of nutrients added in fortification.

The FDA wants input on whether all of this makes sense in the light of the 2015 Dietary Guidelines and the KIND petition.

In its inimitable FDA-speak:

While FDA is considering how to redefine the term “healthy” as a nutrient content claim, food manufacturers can continue to use the term “healthy” on foods that meet the current regulatory definition. FDA is also issuing a guidance document stating that FDA does not intend to enforce the regulatory requirements for products that use the term if certain criteria described in the guidance document are met.

If I correctly understand the meaning of “does not intend to enforce the regulatory requirements,” the FDA, while waiting for your comments, will allow manufacturers to call products “healthy” as long as the products:

(1) Predominantly contain mono and polyunsaturated fats regardless of total fat content; or

(2) Contain at least ten percent of the Daily Value (DV) per serving of potassium or vitamin D.

In other words, if your food product is made with a low saturated fat oil and contains potassium or vitamin D, it is by definition “healthy.”

Correction, September 29: An FDA official wrote to say that I didn’t quite get this right.  

Actually, if a food exceeds the low fat requirement currently in our definition, we will not take any enforcement or compliance action as long as the food meets all of the other requirements in the definition, namely that it is low in saturated fat, cannot exceed the specified levels of cholesterol and sodium, and contains at least 10 percent of the daily value for beneficial nutrients.  

Second, we are not saying that foods must contain potassium or vitamin D to be labeled as “healthy.”  We are simply indicating that potassium and vitamin D can be substituted for the beneficial nutrients now listed in the current regulations, in line with the new Nutrition Facts label regulations.

My apologies to the FDA for misunderstanding the notice.

The FDA’s request is good news for KIND bars.

But it smacks of “nutritionism”—the use of these two single nutrients (as well as others on the short list of beneficial nutrients) as indicators of quality in processed food products (and don’t get me started on vitamin D, which is a hormone, not a vitamin, and best obtained by getting outside in the sun once in a while).

Understand: this effort is not about semantics; it is about marketing.

Would you like to weigh in on what you think qualifies a food as “healthy?”  Here’s how:

• Federal Register Notice for the Guidance for Industry 
• Federal Register Notice for the Request for Information
• Guidance for Industry: Use of the Term “Healthy” in the Labeling of Human Food Products
• Blog: Making Sure ‘Healthy’ Means What It Says on Food Packages
• “Healthy” on Food Labeling 

I try not to waste food.  At worst, I compost leftovers.

Food waste is a huge issue these days, not least because it appears to be an obvious solution to world hunger.

A great many people are working on projects to reduce food waste.

Reducing food waste makes us feel like we are doing something to reduce hunger—in the same way that working for food banks makes us feel good about what we are doing.  Dealing with food waste is even easier.

It’s easy to understand why so many people have jumped on the food-waste bandwagon.  It’s as downstream—close to the individual and furthest away from policy—as you can get.  It’s easy.  It costs nothing.  It feels good.

Whereas: Trying to achieve upstream policies to alleviate poverty to reduce hunger is frustratingly difficult, expensive, and slow, and not nearly as much fun.

This is why I was so pleased to see the commentary from Nick Saul, author of The Stop, his book about his struggles to feed hungry people while directing a food bank in Canada.  I hope he won’t mind my quoting extensively from his piece:

• Food waste will never be able to address hunger because hunger isn’t about a lack of food. It’s about a lack of income. People are food insecure because they can’t afford to eat.
• Waste isn’t about not having enough mouths to feed. It’s about inefficiencies and bureaucracy in the food system that see crops tilled under and lost in the production process; other crops that are overproduced as a result of antiquated agricultural policy and incentive programs; a retail system that has overabundance built into its operation model; and individual consumers who buy food with the best intentions, only to have it spoil in the back of the fridge.
• The food that we throw out unnecessarily gobbles up resources, including energy, water, land and labour to the tune of $100 billion each year. And the food that ends up rotting in landfills fuels climate change by generating 20 per cent of Canada’s methane gas emissions.
• If we want to tackle this monumental problem, we need a whole-system approach — from taxing waste to public education on reducing waste in our own kitchens.
• Instead of incentivizing waste by dangling corporate tax credits, we ought to support employees fighting for fair, livable wages. And let’s put those same tax dollars into building the social infrastructure required to ensure no one will ever again need to rely on someone else’s leftovers for sustenance.
• It’s time to create real, long lasting solutions to poverty and hunger, policies that bring us together, rather than divide us as citizens.

If you are working on food waste initiatives, how about also trying to get some of them focused on upstream approaches such as the ones he suggests.

The White House has issued a report on the Obama administration’s accomplishments in addressing heart disease: “Making Health Care Better.”

The good news is that heart disease mortality has been falling steadily since 2009.

But let’s put this in context.  Here’s the long-term trend.  Impressive!

The report gives reasons why—mainly less cigarette smoking and better health care coverage.  Where nutrition fits into this is curious.  The increasing prevalence of obesity has no obvious effect on long-term trends.  Perhaps the decline would faster without it?

In any case, the White House report points to several of its nutrition initiatives:

• The new Nutrition Facts label with added sugars and updated serving sizes
• Calorie labels on fast food menus
• Calorie labels on vending machines
• Guidance to industry for voluntary sodium reduction
• Healthier school breakfasts and lunches
• And everything else that Let’s Move! has done.

There’s more to be done, but these are steps in the right direction.

Anne Barnhill, Mark Budolfson, Tyler Doggett.  Food, Ethics, and Society: An Introductory Text with Readings.  Oxford, 2016

The back cover has a comment from me that must have been something I wrote when reviewing the manuscript for the publisher, who asked: “Who will want to read or use this?” I said—and meant:

This would be extremely useful for undergraduate courses in food ethics or contemporary food issues.  It would work well in courses on contemporary issues in food systems.  The topics are excellent.

OK, I’m biased.  It has two pieces from me in it, one an update on the report of the Pew Commission on Industrial Food Animal Production, which came out in 2008 (I was on that committee), and the other an excerpt from the 2007 edition of Food Politics.  It has loads of interesting excerpts from the work of lots of other people writing about food and ethics from different perspectives.  I really do think it would be fun to use this in a food ethics course or to read if you are just interested in what people are thinking about food ethics .

Presidential candidate Donald Trump gave a speech to the Economic Club of New York about his tax reform plan to “make America great again.”

The plan would eliminate some programs he finds annoying, the FDA’s food safety regulations among them.

The tax plan, including the FDA provisions, was posted on Trump’s website, but it is no longer there.

Fortunately, @nycsouthpaw did a screen capture and posted it on Twitter.  Among other things, Trump would like to eliminate:

Food safety lawyer Bill Marler, who begs producers of unsafe food to “put me out of business” is getting his wish and notes how well the new food safety rules are working.  He says Trump must love him: Killing the FDA is good for business:

How did “The Donald” know that my business has dropped over the last few years as the regulatory work of our governmental agencies have kicked into gear.

Who knew that food safety would be an issue in this year’s election, let alone Skittles.

If you are in New York or can get to it, go see Julia Cho’s play, Aubergine (“Eggplant”) at Playwrights Horizons.

Ignore the tepid review in the New York Times.  The reviewer, Charles Isherwood, doesn’t seem to be either a foodie or a food studies scholar.

If you are either or both, or just open to the deeper meanings of food in society, you will get the point of this play right away: the emotional significance of remembrance of meals past.

The acting is terrific (even Isherwood says so).  The characters are warm, funny, foodie, and deeply touching.  And you don’t even have to speak Korean to understand them.

It’s only playing until October 2.  Aubergine deserves an appreciative audience.

And while you are there, keep your eye on that turtle.  No spoiler here: you will need to see the play to understand its role (it should get acting credit).

The International Culinary Center announced yesterday that its president and founder, Dorothy Cann Hamilton, died in a car accident.  I’ve heard that the accident was in Nova Scotia, but cannot find details.

Dorothy was a star in New York’s food world.   Her Wikipedia entry tells some of the story.

But I knew her best as someone who dreamed big and made the dreams come true.

I met her in the early days of the French Culinary Institute when we met to work out a partnership—her idea—with NYU’s newly launched food studies programs.

That worked.  So did much else.

She turned ICC into a go-to place for programs as well as culinary arts.  I was privileged to participate in those programs occasionally.

I was even more privileged to be part of her occasional Ladies Who Lunch group at L’Ecole.

I watched her handle ambassadors and dignitaries at Food Expo in Milan.  Back in New York, I saw her receive high honors from the French government.

I have no doubt the press will have much to say about all she accomplished.

To me she will always be the girl from Queens who longed for Manhattan, got there, and made many wonderful things happen.

I cannot believe she is gone.  I will miss her.

Obituaries, September 20

• Washington Post
• Grub Street
• New York Times

Miriam Horn.  Rancher, Farmer Fisherman: Conservation Heroes of the American Heartland.  WW Norton, 2016.

Actually, this book should be titled “Rancher, Farmer, Riverman, Shrimper, Fisherman: Conservation of Life around the Mississippi River.” It consists of deep interviews with one person in each category who is working hard to protect some part of the environment.

My favorite is the shrimper, the truly remarkable woman who is devoting her life to saving the livelihoods of the people engaged in Louisiana’s highly endangered—by hurricanes, floods, oil spills, and regulators—shrimp-fishing industry.

Each of the people highlighted in this book is doing something for conservation, not always in the ways you and I might choose.  As Miriam Horn explains in her introduction,

Which is not to say they have found the perfect way to fish or farm; they would be the first to acknowledge that there is no such ideal.  Rather, their heroism lied in the depth of their commitment to consider the largest implications of what they do, across geographic and generational lines; to forever listen more intently, weight each choice for the impact it will have on their neighbors and all of life, challenge themselves to do better as they understand more and the world changes around them.