The FDA is taking comments on its proposals to revamp the food label until August 1, 2014.

It has two sets of proposed changes:

• Nutrition and Supplement Facts Labels
• Serving Sizes

Here is the first of my comments on several food label items.  Feel free to copy, edit, or file your own (see directions below).

July 16, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Nutrition Facts panel: ADDED SUGARS

1.  Retain the line for Sugars but call it Total Sugars

2.  Add a line for Added Sugars

Rationale:

• Excessive intake of dietary sugars is well established to raise the risk of obesity and type-2 diabetes.[i]
• Americans on average twice as much as is generally recommended.[ii]
• The amount typically consumed comes close to the upper limit recommended by the Institute of Medicine on the basis of increased risk of nutrient deficiencies.[iii]
• Sugars intrinsic to foods are accompanied by nutrients; added sugars are not.
• Although there is no biochemical difference between intrinsic and added sugars, food and beverage companies know exactly how much sugar they add as part of the recipes for their products.
• Listing the amount of added sugars on food labels would inform consumers about how much sugars are added to the foods they buy.
• Randomized, controlled clinical trials to test the hypothesis that added sugars increase disease risk would violate ethical standards and, therefore, are impossible to conduct.

3.  Establish a Daily Reference Value for Added Sugars of 10% of total calories

Rationale:

• Since the 1977 Dietary Goals, health officials have consistently recommended an upper limit of 10 percent of calories from added sugars.[iv]
• The 1992 USDA Food Guide Pyramid suggested an upper limit of 6, 12, and 18 teaspoons of sugars, respectively, for daily diets of 1,600, 2,200, and 2,800 calories, respectively.  This works out to 7, 10, and 13 percent of calorie intake, respectively, for an average of 10 percent.[v]
• By 1992, health officials in several European countries had recommended much the same.[vi]
• The Institute of Medicine’s 2002 upper safety limit of 25% of calories was based on risk for nutrient deficiencies, not obesity and chronic disease.[vii]
• In 2009, the American Heart Association recommended that women consume no more than 100 calories per day from added sugars (25 grams), and men no more than 150 calories per day (38 grams).  These come to 5 percent and 7.5 percent, respectively, of a 2000-calorie daily diet.[viii]
• The 2010 Dietary Guidelines for Americans state that no more than 5 to 15 percent of calories should come from a combination of solid fats and added sugars.  This implies that added sugars should be less than 10% of calories.^[ix]
• Dr. Robert Lustig says that a “dose” of added sugars up to 50 grams a day poses little risk for metabolic or chronic disease.  This amounts to 200 sugar calories and 10% of a 2,000-calorie daily diet (he says twice that much, the amount commonly consumed by Americans, is toxic.[x]
• The World Health Organization in 2014 said that added sugars should make up less than 10 percent of total calories per day, and less than 5 percent would be even better,[xi] based on two research reviews, one on sugars and obesity[xii]  and one on sugars and tooth decay.[xiii]
• Added sugars as 10% of calories represents about half the amounts currently consumed and comes close to consensus.

References

[i] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohttp://steinhardt.nyu.edu/nutrition/hort studies. BMJ 2012;345:e7492.  doi: 10.1136/bmj.e7492.

[ii] USDA.  Loss-adjusted food availability documentation.  March 11, 2014.  http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/loss-adjusted-food-availability-documentation.aspx#.UzlzcfldU6w.   USDA.  Food availability documentation: added sugar and sweeteners.  http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/food-availability-documentation.aspx#sugar.   The tables used to construct figure 3D are at: Refined Sugar, Corn Syrup, Other Sweeteners.

[iii] Institute of Medicine (IOM) of the National Academies. “Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein, and Amino Acids (Macronutrients), Chapter 6: Dietary Carbohydrates: Sugars and Starches”, Washington, DC: National Academies Press; 2002.

[iv] U.S. Senate Committee on Nutrition and Human Needs.  Dietary Goals for the United States, December 1977.

[v] USDA.  Food Guide Pyramid, 1992.

[vi] Cannon G:  Food and Health: The Experts Agree.  London:  Consumers’ Association, 1992.

[vii] USDA.  Is intake of added sugars associated with diet quality?  Nutrition Insights, Insight 21, October 2000.

[viii] Johnson RK, Appel LJ, Brands M, et al.  Dietary sugars intake and cardiovascular health: a scientific statement from the American Heart Association.  Circulation. 2009;120(11):1011-1120.  doi: 10.1161/CirculationAHA.109.192627.

[ix] USDA and USDHHS.  Dietary guidelines for Americans, 2010.  http://www.cnpp.usda.gov/dgas2010-policydocument.htm.

[x] Lustig RH.  Fat Chance: Beating the Odds Against Sugar, Processed Food, Obesity, and Disease.  Hudson Street Press, 2012.

[xi] WHO.  Draft guideline: Sugars intake for adults and children, March 2014. http://www.who.int/nutrition/sugars_public_consultation/en/.

[xii] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohort studies. BMJ 2012;345:e7492 doi: 10.1136/bmj.e7492.

[xiii] Moynihan PJ, Kelly SAM.  Effect on Caries of Restricting Sugars Intake. Systematic Review to Inform WHO Guidelines.  JDR 2014;93:8-18.  doi:10.1177/0022034513508954.

 

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

• All necessary information in one place.
• A short guide and checklist
• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

I know I live on another planet, and my kids are long grown, but is there really a void in the market that has to be filled by a half-juice, half-herbal tea drink in a box for kids?

According to Food Navigator, the CEO of Drazil (lizard spelled backwards) Kids Tea thinks this product

pinpoint[s] a void in the kids’ beverage marketplace for a naturally healthy, reduced-sugar ready-to-drink beverage line as US consumers started falling out of love with 100% juice….There’s a huge need for healthy beverages that actually appeal to kids, so I thought, why not tea?…“I’ve studied how habits are formed when doing product development,” she said. “How do you get more adult tea drinkers? You get them to start drinking it regularly when they’re young. Tea is perfect because it’s relatively inexpensive to brew, so healthy—all those antioxidants, nutrients. Why not develop those habits young?”

OK.  The concept is adorable.

But is tea really loaded with antioxidants and nutrients?  Not like fruit juices.  This product is a juice drink that dilutes juice and its nutrients by half.   Yes, it also dilutes the fruit sugars by half but the boxes are 6.75 ounces and that much 100% juice is not unreasonable for school-age kids.

What ever happened to tap water?

This product is about marketing, and marketing to kids and hooking them early at that.

As I said, I live on another planet.

Authors employed by the Food Packaging Forum Foundation, funded by the packaging industry but working “independently of donors’ special interests,” have produced a surprising analysis of chemical in food packaging that comes into contact with food during production, handling or storage.

Why surprising?  Because the results are indeed against donors’ special interests.

Such chemicals, the authors say, can contaminate food through migration from the packaging.  About 6000 such substances exist, some of which are associated with disease.  These are Chemicals of Concern (COCs).

This study identified chemicals used in packaging that are considered to be COCs.  It found 175 such chemicals in use.  Of these, 54 are “candidates for Substances of Very High Concern.”

From a consumer perspective, it is certainly unexpected and undesirable to find COCs [chemicals of concern] being intentionally used in FCMs [food contact materials], and thus it seems appropriate to replace substances case by case with inherently safer alternatives.

This comes from people in the industry.  I hope makers of packing materials—and food safety regulators—pay close attention.

I received a press release last week announcing the release of a new meta-analysis of more than 300 studies comparing organically produced foods to those produced conventionally.  The results show that organic foods have:

• Less pesticides: this is to be expected as they are not used in organic production.
• Less cadmium: this also is to be expected as sewage sludge, a probable source of cadmium, is not permitted in organic production.
• More antioxidants: this is news because some previous studies did not find higher levels of nutrients in organic foods.

I was interviewed by the New York Times about this study:

Even with the differences and the indications that some antioxidants are beneficial, nutrition experts said the “So what?” question had yet to be answered.

“After that, everything is speculative,” said Marion Nestle, a professor of nutrition, food studies and public health at New York University. “It’s a really hard question to answer.”

Dr. Nestle said she buys organic foods, because she believes they are better for the environment and wants to avoid pesticides. “If they are also more nutritious, that’s a bonus,” she said. “How significant a bonus? Hard to say.”

She continued: “There is no reason to think that organic foods would be less nutritious than conventional industrial crops. Some studies in the past have found them to have more of some nutrients. Other studies have not. This one looked at more studies and has better statistics.”

Two additional comments:

1. The study is not independently funded.   One of the funders is identified as the Sheepdrove Trust, which funds research in support of organic and sustainable farming.

This study is another example of how the outcome of sponsored research invariably favors the sponsor’s interests.  The paper says “the  Trust  had  no  influence  on  the  design  and management of the  research  project  and  the  preparation  of publications  from the project,” but that’s exactly what studies funded by Coca-Cola say.  It’s an amazing coincidence how the results of sponsored studies almost invariably favor the sponsor’s interests.  And that’s true of results I like just as it is of results that I don’t like.

2.  The purpose of the study is questionable.  The rationale for the study is “Demand for organic foods is partially driven by consumers’ perceptions that they are more nutritious.”  The implication here is that research must prove organics more nutritious in order to market them.  But most people who buy organics do so because they understand that organics are about production values.  As I said, if they are more nutritious, it’s a bonus, but there are plenty of other good reasons to prefer them.

Other resources:

• Supplementary data from the study
• Q and A on the study
• Washington State University press release
• The Guardian story that broke the embargo [nobody was supposed to write about it until July 15]
• The Organic Trade Association’s statement

Courtney White, Grass, Soil, Hope: A Journey through Carbon Country.  Chelsea Green, 2014.

 

Courtney White, whom I do not know but would like to, describes himself as a former archaeologist and Sierra Club activist who became a producer of grass-fed beef, thereby catching on to the importance of grass for restoring nutrients to soil, reducing climate change, and feeding the planet.  Carbon, he says, is key and we can achieve all this with low-tech methods.

He visits a bunch of “new agrarians” who are managing carbon-conserving agriculture, from farms to rooftops.

We’re all carbon.  We live in a carbon universe.  We breathe carbon, eat carbon, use carbon products, profit from the carbon cycle, and suffer from the carbon poisoning taking place in our atmosphere…We could, for example, find ways to support the 2 percent of Americans who actively manage the soil portion of the carbon cycle.  There are a million ways to help them, starting with the power of the purchasing dollar.  Seek out the new agrarians and buy their products.  Better yet, get involved yourself.

He writes well, and convincingly.

OK, everyone is presumed innocent until proven guilty, and executives of the Peanut Corporation of America (PCA) are getting their day in court, accompanied by an aggressive legal defense.

According to Food Safety News, PCA’s lawyers are claiming that the government’s requests for disclosure documents are so egregious that the case should be dismissed.

Here’s a comment on the case from Eat, Drink, Vote: An Illustrated Guide to Food Politics:

Irony alert: “egregious” is precisely the word I used to describe PCA’s actions related to its Salmonella problems more than a year ago:

I’ve been following this particular food safety tragedy for several years now.  The offenses were so egregious—officials blatantly ignored positive tests for Salmonella, for example—that some kind of punishment seemed warranted.

According to the account in USA Today:

The indictment alleges that PCA officials affirmatively lied to their customers about the presence of salmonella in PCA’s products,” said Stuart Delery, principal deputy assistant attorney general.

Delery also said some officials at PCA, no longer in business, fabricated lab results certifying to customers that the products were salmonella free “even when tests showed the presence of salmonella or when no tests had been done at all.”

If you would like to catch up on this endlessly fascinating case, in which contaminated peanut butter made 714 people in 46 states sick, here’s Food Safety News’ year-old timeline of its events.

Over the July 4^th weekend, a reader sent a link to a paper about to be published in the American Journal of Clinical Nutrition titled Increased fruit and vegetable intake has no discernible effect on weight loss: a systematic review and meta-analysis.

I took a look at the abstract:

Studies to date do not support the proposition that recommendations to increase F/V intake or the home delivery or provision of F/Vs will cause weight loss. On the basis of the current evidence, recommending increased F/V consumption to treat or prevent obesity without explicitly combining this approach with efforts to reduce intake of other energy sources is unwarranted.

This would seem to make some sense, no?  But the dismissal of recommendations to increase fruit-and-vegetable consumption sent up red flags.

My immediate question: who paid for this study?

Here’s the conflict of interest statement.

Note the presence of companies making processed foods whose sales would decline if people ate more F&V.

A coincidence?  I don’t think so, alas.

More evidence: just today, Bettina Siegel sent me her post on a paper sponsored by the Corn Refiners Association, once again with a predictable outcome.

When it comes to nutrition research, “guess the sponsor” is a game that is all too easy to win.

USDA has a report out on consumers’ use of nutrition information in restaurants before the menu labeling law goes into effect.

What law?  The menu-labeling provision that is part of the Affordable Care Act still—four years later—waiting for the FDA to get around to issuing final rules (I last wrote about this in April 2013).

In 2011, the FDA proposed rules for public comment, and proposed final rules in 2013:

• Rules for restaurant menu boards
• Rules for vending machines

These too were opened for public comment with the process expected to be completed in February 2014.  Oops.  Missed that one.

Rumors are that the FDA is under pressure from pizza chains and movie theaters to be exempt from the final rules, and that the White House is holding them up.  The White House has had them for 90 days.  That’s supposed to be the limit.

According to Politico Pro Agriculture

It was three months ago today that the White House first received FDA’s final rules for calorie labels on menus and vending machines, and by the Office of Management and budget’s own rules, that means time is up. Interagency review at OMB is supposed to take no more than 90 days before the final release of a measure, though that timeframe is often extended with little explanation on more controversial initiatives. While OMB is always mum on its schedule for rule reviews and releases, the end of the standard review period is sometimes a hint that something will be coming, if not today — the day before a long weekend — then soon. In the meantime, brush up on the issue here: http://politico.pro/1mKNcFr and here: http://politico.pro/1lzZLDe

In the meantime, the USDA has done some research and come up with some interesting findings:

Among people who eat out, the ones most likely to use nutrition information on menu boards are those who:

• Eat out less frequently
• Have other healthy behaviors (such as having dark green vegetables at home).
• Rate their diets as good.
• Are women.
• Participate in SNAP.

SNAP participants?  Really?  If true, SNAP participants are more eager for calorie information than the general population, and good for them!

These results explain much about the confusing findings from studies of New York City’s menu labeling law.  These generally find no overall effect although calorie labels have a big effect on people who are conscious of health to begin with (me, for example).

FDA: how about getting out the final rules?  Then we can sit back and watch USDA economists compare what’s happening to these baseline results.