I thought it might be time for a summary of why USDA’s new requirements for poultry inspection are so controversial.  Some groups think they are a big step forward; others most definitely do not.

The USDA says its new rules, which are largely based on research published in 2011:

• Will place new requirements on the poultry industry.
• Will prevent 5000 illnesses a year from Salmonella and Campylobacter
• Puts trained USDA inspectors where they will do the most good.
• Require poultry facilities to test for Salmonella and Campylobacter at two points during production (USDA will continue to do its own testing).
• Giving poultry producers the option of doing their own inspections.
• Caps the maximum line speed at 140 birds per minute (rather than the 175 the industry wanted).
• Estimates the public health benefit at $79 million.

It also says

More inspectors will now be available to more frequently remove birds from the evisceration line for close food safety examinations, take samples for testing, check plant sanitation, verify compliance with food safety plans, observe live birds for signs of disease or mistreatment, and ensuring plants are meeting all applicable regulations.

To read the Federal Register notice (when it’s ready), click here.

The main issues

Line speed:  this refers to the evisceration line and is the speed at which workers must deal with the chickens.  The current speed is 140 birds per minute.  This means 2.33 birds per second.   It’s hard to imagine that any worker could manage that—or any inspector could see anything—at that speed.

The National Council of La Raza wrote USDA  in 2012 that raising the line speed posed a hazard to worker safety and “would recklessly threaten the health and safety of poultry workers.”  USDA listened.  The NCLR must be pleased.

The poultry industry is not pleased.  The National Chicken Council complains that “politics have trumped sound science, 15 years of food and worker safety data and a successful pilot program with plants operating at 175 birds per minute.”

Politico ProAg points out that the new system will cost the poultry industry $259 million—what it would have gained if line speeds increased to 175 per minute.

Privatization of inspectors.  The new rules shift responsibility for inspecting chickens, no matter how impossible, to company employees—the fox guarding the chickens, as it were. Food and Water Watch argues that this poses a conflict of interest since it’s in the managers’ interest to keep the lines moving as fast as possible and not to find anything wrong.   Food and Water Watch says the new system “will transfer most poultry inspection from government inspectors to the companies so they can police themselves.” Several members of Congress have also complained.   The Government Accountability Office (GAO) issued a report noting that USDA doesn’t really have data on which to base this change.

Change in function of USDA inspectors.  Up to 1,500 USDA phased out of poultry production may have to relocate or retire.  USDA estimates it will save $90 million over the next three years from this reduction.

Turkeys.  The new system allows turkey plants to raise line speeds to 55 per minute, up from 51 birds per minute.  The National Turkey Federation says most turkey plants will comply.

Waivers.  The Washington Post says the new system “provides a waiver to 20 plants that are already in a pilot program, letting them operate at 175 birds per minute.”

Voluntary.  The program is voluntary.  Plants can continue doing things the way they are.  

What to make of all this?  The testing requirements are a huge step forward.  The inspection changes seem mixed. It’s hard to believe that line inspection is useful even at 140 birds per minute.  

I’d rather have USDA inspectors making sure prevention controls are in place and adhered to, the testing is done honestly, and keeping an eye out for unsafe worker conditions (which, alas, is not their job).  

Let’s give it a try and see how it works in practice.

In the meantime, here’s what else is happening on the poultry safety front:

Other related news

Salmonella is not an adulterant, says USDA.  If it were, anything contaminated with it could not be sold.  USDA denied the petition from Center for Science in the Public Interest to have four antibiotic-resistant strains of salmonella declared as as adulterants in ground meat and poultry products.

After thoroughly reviewing the available data, FSIS has concluded that the data does not support giving the four strains of [antibiotic-resistant] salmonella identified in the petition a different status as an adulterant in raw ground meat and raw ground poultry than salmonella strains susceptible to antibiotics.

The Foster Farms Salmonella outbreak is over, says the CDC.

The CDC announced today a total of 634 persons infected with seven outbreak strains of Salmonella Heidelberg were reported from 29 states and Puerto Rico from March 1, 2013 to July 11, 2014.

Epidemiologic, laboratory, and traceback investigations conducted by local, state, and federal officials indicated that consumption of Foster Farms brand chicken was the source of this outbreak of Salmonella Heidelberg infections.

38% of ill persons were hospitalized, but no deaths were reported.

Most ill persons (77%) were reported from California, but cases were reported in other states as well.

And that’s why all of this matters so much.

Jennifer Cognard-Black and Melissa A. Goldthwaite, eds.  Books That Cook: The Making of a Literary Meal.  New York University Press, 2014.

I have a special interest in this book: I wrote its Foreword.  Here’s an excerpt:

Books that Cook brings the food revolution into the study of English literature— brilliantly, deftly, and with no apologies. No apologies are needed. As editors Jennifer Cognard-Black and Melissa A. Goldthwaite explain, Food Studies necessarily encompasses literature. Basic food texts—cookbooks and recipes—are as much a form of literature as are fiction, non-fiction, memoirs, and poetry. And why not? They tell stories. They convey myths. They are replete with drama, symbolic meaning, and psychological insight.

Furthermore, they offer plenty to talk about: culture, religion, ethics, personal identity, and anything else that it means to be human. That food generates profound literary memories is famously known from what ensued after Proust dipped his madeleine in tea.  Writers of all time have used food memories to spark traditional literary texts. Today, we view cookbooks and recipes as equally worthy of literary analysis. Even recipes.

They used the end of the Foreword as a blurb:

Books that Cook propels the food movement and in doing so makes a political as well as a literary statement. It makes a difference. Read it. Savor the writings. Delight in them. Think about them. And if they inspire you to do your own writing about food, so much the better.

I also have a special interest in one of the editors, Jennifer Cognard-Black.  I’ve never met her, but I contacted her after reading an article she wrote for Ms Magazine.  The article, The Feminist Food Revolution, comes with this description:

From farms to community gardens to restaurants, women are taking food back into their own hands.  So why do men keep getting all the credit?

This last phrase got my attention, particularly because she mentions me in the article.  Interesting, no?

The Foreword was fun to write and the book is fun to read.

Thanks Jennifer, Melissa, and NYU Press for this contribution to food studies, published today, and most welcome.

Yesterday, the fabulous Representative Rosa DeLauro (Dem_CT) introduced the Sugar-Sweetened Beverages Tax Act of 2014 (SWEET Act).  Here’s a quick summary of the bill. The SWEET Act (you have to love the name) would put an excise tax of one cent per teaspoon of sugars (a teaspoon is about 4 grams). The bill is clearly aimed at sugary drinks, which account for about half of total sugar intake.  According to the 2010 Dietary Guidelines (page 29),

• Sodas, energy, and sports drinks account for 35.7% of total sugars
• Fruit drinks—a category that does not include 100% juices—account for another 10.5%.
• Sugar-sweetened teas account for 3.5%.

The tax ought to raise about $10 billion a year, and is earmarked for programs to combat soda-related disease. It also ought to further reduce consumption of sugary drinks, as is already happening in Mexico. If you would like to endorse this legislation, contact Kelly.Horton@mail.house.gov in Representative DeLauro’s office. References

• DeLauro Press Release
• CSPI’s Press Release
• Mark Bittman’s July 30 discussion of the bill in the New York Times
• The Prevention Institute’s endorsement
• Reuters’ report
• Food-Navigator.com’s report
• The Hill’s story plus video
• The American Beverage Association statement

 

The big surprise in Michael Moss’s tough look at health claims on coconut water in today’s New York Times—worth looking at online for the terrific video—is this:

One Last Comparison

These days, coconut water’s big rival may be plain old water. How do they compare? Scientists are still wrestling with the question, and while their findings vary, water is starting to look just fine for most people. A 2012 study (funded by Vita Coco) in the Journal of the International Society of Sports Nutrition found that neither coconut water nor sports drinks were better than water in hydrating young men after hourlong workouts.

Really?  An industry-funded study that comes to a conclusion against the interest of the funder?

This requires a look at the original paper.

So a round of applause please for the authors who did this funded study, “Comparison of coconut water and a carbohydrate-electrolyte sport drink on measures of hydration and physical performance in exercise-trained men,” and nevertheless came to this conclusion:

Our data indicate that both coconut water (natural, concentrated and not from concentrate) and bottled water provide similar rehydrating effects as compared to a carbohydrate-electrolyte sports drink.  Moreover, none of the beverages impacted treadmill exercise performance differently during the rehydration period.

Lest there be any ambiguity about what this means, their data clearly show that VitaCoco, a sports drink (not named but I’d bet on Gatorade), and coconut water from concentrate all rehydrated men who spent 60 minutes on a treadmill to the same extent.

In other words: for rehydration, water works just as well as coconut water or sports drinks.   No surprise, really.

VitaCoco must be disappointed, but it still has one thing going for it: coconut water tastes really good.

August 1 is the deadline for filing comments on FDA’s food label proposals.

Two were released yesterday, one for and one against.

The Union of Concerned Scientists (UCS) organized a statement in support of listing added sugars signed by 280 scientists, physicians, and public health officials (including me).

The press release says:

In a letter submitted as a public comment for the agency’s first label update since 1994, the signatories point out that sugar overconsumption contributes to diabetes, cardiovascular disease and other ailments….Many food and beverage manufacturers add excessive amounts of sugar to their products, including those that they market as healthy options. In our current food environment, many people are unknowingly and unavoidably consuming excess sugar. Given our soaring rates of chronic diseases and the link between sugar and these diseases, citizens have a right to know how much sugar has been added to their foods.

People who signed the letter include many from Healthy Food Action, a national network of health professionals founded by Dr. David Wallinga.  I am a co-author of the statement with UCS staff and Dr. Robert Lustig.

In contrast, the American Society for Nutrition (ASN), an organization of nutrition scientists to which I belong, produced a strong statement against labeling added sugars.

ASN also has concerns that the inclusion of added sugars on the label may divert attention away from total calories and other important contributors to weight gain. The inclusion of added sugars on the label may confuse consumers and create the perception that naturally occurring sugars are somehow more beneficial because they are “natural” and do not have health effects similar to added sugars…There is no supporting evidence that indicates that the inclusion of added sugars on the food label will translate into the American public reducing caloric intake from added or total sugars or total energy intake…it is important to consider potential unintended consequences of  reformulation as well. When sugar is removed from a solid food product…The replacement is often fat and/or starch which could lead to a product with higher calories per serving. ASN encourages FDA to carefully consider potential adverse consequences of this proposed determination, including gaining input from food scientists…An investment in consumer education… is likely to be most productive for consumer understanding relative to added sugars, and would assure that consumers do not experience increased confusion, which they may encounter if added sugars are declared on the Nutrition Facts label.

These comments, which read as though written by sugar trade association groups, were signed by the president of ASN.  Although the statement letter gives no indication of the process by which these comments were developed, I’m told it was prepared by ASN’s public policy committee.

If so, it would help to know whether members of the committee have financial ties to the sugar industry or to food companies that use sugar in their products.

I wonder how much of the ASN membership agrees with this position on Added Sugars.   I certainly don’t.

 

The FDA is taking comments on its proposals to revamp the food label through August 1, 2014 (instructions are at bottom of post).

I’ve already filed comments on Added Sugars and on whether Vitamin D should be added to food labels.

And I just filed further comments on the FDA’s proposals for the Nutrition and Supplement Facts Labels.  If you would like to read what I said, click here.

I’ve also filed comments on the FDA’s Serving Size proposals.

These proposals are highly technical and tough to slog through, so I tried to deal with the big picture.

July 27, 2014

TO:                  FDA

FROM:           Marion Nestle, Professor of Nutrition, Food Studies and Public Health, New York University

RE:                  Comments: Serving size proposals, Docket No. FDA-2004-N-0258

In addressing the question of how to change serving size designations on food labels, FDA is faced with an impossible dilemma .  Serving sizes, which are supposed to be based on amounts typically consumed from packaged products, are invariably perceived as recommendations for dietary intake.

To comment on each of the bold-face, italicized points:

• Typically consumed:  This information derives from dietary intake surveys which invariably underestimate actual intake, often by 30% to 40%.

• Packaged foods: Food labels only appear on packaged foods.  RACC amounts on packaged foods are often much lower than amounts served in restaurants or fast-food places (pizza is an obvious example).  It is unclear whether amounts reported as consumed are from packages (with Nutrition Facts labels) or are from restaurants or fast-food places where portion sizes can be much higher than those for foods in packages.

• Recommendation:  Substantial anecdotal information suggests that people view labeled serving sizes as what they should be eating.  They view the serving sizes as meaningless compared to the portion sizes of foods they are accustomed to eating.

What is well established is that overall calorie intake has increased since RACCs were established in 1993 and marketplace portion sizes have also increased.

Therefore, any increase in RACC runs the risk of being interpreted as a validation of current portion sizes and as a recommendation to eat more.

On the other hand, larger portions have more calories.  These must appear on the label.

To address this dilemma, FDA should:

• Make dual-column labeling mandatory for all food and beverage packages likely to be consumed in one sitting.
• Require total calories in the package to be displayed on the front of the package.
• Include a footnote explaining that the serving size is not meant as a recommendation

INSTRUCTIONS FOR FILING COMMENTS

The FDA provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

The role of specific nutrients in brain health isn’t something I think about much.  I’m of the opinion that a reasonably healthy diet takes care of health.  Stop worrying, be happy.

But I’m always interested in what the food industry is cooking up based on current research, and here’s a good sampling to ponder.

For this Special Edition, NutraIngredients-USA has a long hard think about cognitive health…

Cognition spans the lifetime, from development in the womb right through to old age. So, which ingredients have the best science? How are companies approaching this sector and what claims can they make? What’s all this about the gut-brain axis? And what’s happening with botanicals in this space?

• Gallery: The top ingredients for cognitive health: Memory, attention and focus, development, mood; there are numerous ways that a nutrient or ingredient can affect cognitive health. But which have the most science, how do they work, and how are they performing in the market. Check out our gallery of the top ingredients for cognitive health. .. Display
• Cognitive health claims range from sublime to ridiculous, experts say: When it comes to what’s an allowable claim in the realm of cognitive health, ignorance and confusion abound, experts say… Read
• ‘The eye and the brain are connected, so it’s no surprise lutein is important for brain health,’ says Kemin: Lutein and zeaxanthin are well-established in the realm of eye health, but ever emerging science shows the importance of the carotenoids in brain health. And that comes as no surprise to Kemin, with ‘eye health and brain health are coming together as one’… Read 
• Evidence of gut/brain connection piles up, but actual products are a ways off, researcher says: The gut is teeming with bacteria, good and bad, and these organisms and their cousins living elsewhere on and in the body outnumber the body’s own cells by an order of magnitude.  It is only recently that the notion has come to the fore that these microorganisms are doing something other than helping us digest food or aiding in keeping nefarious colonies at bay.  Now researchers are beginning to realize that there is a feedback loop at work between the brain and the gut, with one influencing the other… Read
• Botanical ingredients step up to battle cognitive decline: Botanical ingredients for cognitive health indications abound, and the scientific backing for these ingredients is abundant, too, if you are willing to look, experts said… Read
• NIU’s Cognitive Health Forum: ‘The key is to not have ingredients that stimulate other areas of the body that are not needed for performance’:  Cognitive health formulations must be driven by mechanisms of action, and with cognition being a lifelong issue with many aspects to consider the possibilities are impressive and continually developing, according to experts at the NutraIngredients-USA Cognitive Health Forum… Read
• Fish oil linked to structural changes in the brain: Human data:  Fish oil supplements may produce beneficial structural changes in the brain, according to a new study from Brown University and Rhode Island Hospital… Read

 

The FDA is taking comments on label proposals until August 1 (see info at end of post).  Here’s mine on voluntary vitamin D labeling.

July 17, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Proposed revision to Nutrition Facts Panel: VITAMIN D

This is to argue against permitting food companies to voluntarily label added “Vitamin” D on the Nutrition Facts panel.  Doing so will not promote—and may possibly harm–public health.

Rationale

• “Vitamin” D is not a vitamin; it is a hormone synthesized by the action of sunlight on skin.  For this reason alone, it does not belong on the food label.
• Vitamin D fortification must be understood as a form of hormone replacement therapy.   As such, it raises questions about efficacy, dose, and side effects that should be asked about all such therapies.
• Fortification and supplementation provide hormone Vitamin D by the oral route.  This is not physiological.  Active vitamin D is synthesized in the body through a series of reactions that begin with the action of sunlight on skin.  Sunlight on skin produces ample Vitamin D, is regulated to promote synthesis as needed and avoid toxicity, and may lead to synthesis of other useful biological components; the unphysiologic oral route does not produce the same benefits.[i]
• As a hormone, Vitamin D is found naturally in very few foods (e.g., fish); in them, it is present in small amounts.  It is present in most foods as a result of fortification.
• Permitting Vitamin D to be listed on food labels will encourage fortification, undoubtedly of foods that would not otherwise necessarily be recommended.  To cite just one example: Yum Bunny Caramel Milk Spread fortified with vitamin D at 10% of the DV.  This product is half sugars by weight, marketed as “a good source of calcium and vitamin D,” and clearly aimed at children. See: http://www.yumbunny.com/about-us.   Whether such products should be considered “good sources” also deserves scrutiny.
• The U.S. Preventive Services Task Force concludes that evidence is insufficient to determine how Vitamin D supplementation (and, therefore, fortification) affects fracture incidence.[ii]^,[iii],[iv] 
• Data from the Women’s Health Initiative also are consistent with largely inconclusive findings about hormone Vitamin D supplements and bone health.[v]
• The Institute of Medicine (IOM) does not consider deficiency of Vitamin D to be a serious problem in the United States, except among certain population groups.  Instead, because of widespread fortification and supplementation, it is concerned about the possibility of adverse consequences from overconsumption through supplementation or fortification.[vi]
• Many scientific debates about hormone Vitamin D are as yet unresolved.[vii]^,[viii]  
• The lack of compelling research has permitted Vitamin D to become “trendy.”  It is advertised on boxes of fortified cereals, has its own pro-supplement advocacy group, and generates millions in annual supplement sales.[ix]

In the absence of stronger evidence for benefit from fortification, and some evidence for possible adverse consequences, the FDA should not contribute to further commercialization of this misnamed hormone by permitting it to be listed on food labels.

References

[i] Wacker M, Holick MF.  Sunlight and Vitamin D: A global perspective for health. Dermato-Endocrinology 2013;5(1):51–108.

[ii] Cranney A, Horsley T, O’Donnell S, Weiler H, Puil L, Ooi D, et al.  Effectiveness and safety of vitamin D in relation to bone health. Evidence Report/Technology Assessment No. 158. Rockville, MD: Agency for Healthcare Research and Quality. 2007.  http://www.ncbi.nlm.nih.gov/books/NBK38410. Accessed February 5, 2013.

[iii] Chung M, Balk EM, Brendel M, Ip S, Lau J, Lee J, et al  Vitamin D and calcium: a systematic review of health outcomes. Evidence Report/Technology Assessment No. 183. Rockville, MD: Agency for Healthcare Research and Quality. 2009.  http://www.ncbi.nlm.nih.gov/books/NBK32603/. Accessed February 5, 2013.

[iv] Chung M, Lee J, Terasawa T, Lau J, Trikalinos T. Vitamin D with or without calcium supplementation for prevention of cancer and fractures: an updated meta-analysis for the U.S. Preventive Services Task Force. Ann Intern Med. 2011;155(12):827-38.

[v] Prentice RL, Pettinger MB, Jackson RD, Wactawski-Wende J, LaCroix AZ, Anderson GL, et al.  Health risks and benefits from calcium and vitamin D supplementation: Women’s Health Initiative clinical trial and cohort study.  Osteoporosis Int.  2013;24(2):567-580.

[vi] Institute of Medicine.  Dietary Reference Intakes: Calcium, Vitamin D.  Washington, DC: National Academies Press, 2011.

[vii] Rosen, Clifford J,  Abrams, Steven A,  Aloia John F. et al.  IOM Committee members respond to endocrine society vitamin D guideline. J Clin Endocrinol Metab. 2012;97:1146-1152.

[viii] Holick, Michael F,  Brinkley Neil C, Heike, A et al  Guidelines for preventing and treating vitamin D deficiency and insufficiency revisited.  J Clin Endocrinol Metab. 2012;97:1153-1158.

[ix] Much growth in vitamin sales driven by vitamin D.  Nutr Business J. 2009;14(6/7):5.

Here’s how to file comments:

The proposed revisions are to:

• Nutrition and Supplement Facts Labels
• Serving Sizes 

The FDA makes it very easy to file comments. It provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now