Food Safety News hosted an opinion piece by Sarah Gallo, vice president of product policy for the Consumer Brands Association (formerly the Grocery Manufacturers of America, an industry organization I’ve written about frequently, most recently about its name change).

Ms. Gallo joins consumer food advocates in arguing that the FDA needs reform (see Helena Bottemiller Evich’s account here).

The FDA is released its internal review yesterday (see my post), with insiders doing the reviewing (see Helena Bottemiller Evich’s account here).

Here’s what the food industry says it wants (my selection from Ms. Gallo’s list):

• Quicker reviews of new foods and ingredients.
• Tailored inspections.
• Updated recall processes.
• Flexible food labeling.
• Improved industry collaboration.
• “A transparent regulatory agenda for chemicals in packaging.”
• Better IT systems.

It’s hard to argue with some of these, and I won’t.

Yesterday’s report recommends some of these, not all (see my post on it).

The Coonsumer Brand Association liked the report.  Here’s why:

The FDA is a public health agency; it is part of the US Public Health Service.

I want to see it put public health first in everything it does.

If this means coming up against the food and beverage industry, so be it.  That’s its job.

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The Expert Committee tasked with evaluating the FDA’s human foods program has released its report.

The Committee begins by pointing out that to do its job, the FDA needs adequate resources, sufficient authority, and a structure and culture that breeds success.

In its judgment, the FDA has none of those.  Instead, it is an agency in “constant turmoil.”

The report focuses on lack of leadership.

A leadership skill set, it says, should include:

• Expertise and knowledge in food safety and/or nutrition
• Ability to make decisions in a complex regulatory environment
• Ability to lead in a complex work environment
• Strong demonstrated management capability
• Superb communication skills
• Ability to identify and nurture talent

Instead, the FDA is risk averse, which it admits is “not surprising in a program subject to significant external criticism.”

The committee makes many (too many) recommendations:

Identify vision and mission.

Change the agency’s culture.

Give it more resources.  Food programs are under-resourced; budget and staffing have been flat for at least a decade.

Expand user fees.  [Uh oh.  Bad idea.  The committee even explains why, but ignores the hazard.]

There is also significant skepticism in the public interest community about the potential for “industry capture” of the Human Foods Program if FDA is overly reliant on industry fees.  Efforts to establish structures to secure additional industry funding, such as enhanced registration fees, may address these concerns. While the Panel acknowledges these concerns, the Panel recommends that FDA explore whether common ground can be found on this issue.

Reinstate the Food Advisory Committee.  [I was on the first one in the early 1990s, but our job was to react to decisions the agnecy had already made, not advise it about tough issues].

Reorganize the agency to give the food programs more visibility, integrate them, and give them clear lines of authority [Note: one big weakness of this project is that the committee was instructed not to include the Center for Veterinary Medicine, as if food for pets and food animals has nothing to do with the human food supply, which of course it does].

The report gives five options for reorganization, all of them complicated and undoubtedly politically difficult.  It lists their strengths and weaknesses, but does not state a preference.

• Create a separate food administration within HHS
• Create a Deputy Commissioner for Foods
• Put CFSAN in charge of human food programs
• Puts Commissioner in charge of human food programs
• Create a Deputy Commissioner for Foods

Do more about nutrition labeling, research on consumer behavior.  [Really?  That’s all?]

Comment: The committee only had a couple of months to pull this together and was required to leave out the Center for Veterinary Medicine.  Even so, the report makes it clear that the FDA is in serious trouble, so much so that the committee did not even get into what the FDA ought to be doing about about taking steps to prevent diet-influenced chronic disease.  This, of course, would require it to take on the food industry—an unlikely scenario given everything else that’s not happening.

The next step is to see what the Commissioner does with the report, if anything.  And whether Congress will appropriate more funding.

The report did not say a word about what I see as a major political handicap for the FDA; it’s funding comes from congressional agriculture committees, not health committees, even though FDA is an agency of the public health service.   That too needs to change.

What the press is saying:

• Washington Post: Scathing report recommends major changes at FDA, including possibly breaking up agency
• Bloomberg:  FDA’s Food Program Needs Strong Leader, Outside Reviewers Find
• USA Today:  Report finds FDA’s food regulatory agency lacks leadership, is in ‘constant turmoil’
• Politico:  ‘Constant turmoil’ at FDA’s food regulatory agency, report says

Anda quote from a colleague:

“While we appreciate the Panel’s thoughtful attempt to dig into complicated food issues and their recommendation to elevate nutrition/chronic food illness, creating a seperate, unfunded, nutrition center would have the opposite effect. That’s unacceptable.” Jerold Mande CEO Nourish Science

Everyfive years or so, Congress gets to work on a new Farm Bill.  This is a big job.

I’ve written about the Farm Bill previously.  See, for example, my opinion piece in Politico: “The Farm Bill drove me insane.”

Here are two recent publications to get you started.

The Congressional Research Service has a handy guide with summaries of its full collection of primers for the a 2018 bill.

There are 23 primers summarized in this report and organized under descriptive headings rather than by farm bill titles to facilitate accessibility for those who are not familiar with the 2018 farm bill. The concept behind these primers is to provide relevant information on key programs and policy initiatives authorized by the 2018 farm bill in a concise format that serves as a quick-reference resource for Members of Congress and congressional staff. To this end, the primers describe many of the leading programs and policies within the 2018 farm bill. They also identify some of the higher-profile policy issues that may arise as Congress engages in the process of writing a new farm bill and highlight some policy options that Congress could consider as it undertakes this task. The titles of the primers are hyperlinked for easy access.

The National Sustainable Agriculture Coalition has a statement of principles for congressional reform of the bill.

US food and agriculture policies are in need of reform. Some of the country’s largest agricultural operations receive unlimited subsidies while beginning farmers struggle to afford land. Crop prices recently rose to record highs, but challenging input costs – for everything from fuel to fertilizer – are eating away at profits. Food supply and inflation challenges continue to make headlines. Meanwhile, children go to bed hungry while one-third of food is wasted.

Comment: Here’s one reason why:

Reforming the Farm Bill is badly needed but won’t be easy for reasons of history and politics.  Getting it passed is expected to be exceptionally difficult for the same reasons.  80% or so of its spending is for SNAP—the Supplemental Nutrition Assistance Program (SNAP).  The rest goes largely to producers of feed for animals and fuel for automobiles.  How’s that for vested interests!

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The meat industry is hard at work these days to overcome concerns about the effect of high-meat diets on health and the climate.  Here are two recent examples.

I.  Early Life Beef Consumption Patterns Are Related to Cognitive Outcomes at 1-5 Years of Age: An Exploratory Study.  Victoria C Wilk, Michelle K McGuire, Annie J Roe.  Nutrients.  2022 Oct 26;14(21):4497.   doi: 10.3390/nu14214497.

II. Approximately Half of Total Protein Intake by Adults Must be Animal-Based to Meet Nonprotein, Nutrient-Based Recommendations, With Variations Due to Age and Sex.  Florent Vieux, Didier Rémond, Jean-Louis Peyraud, Nicole Darmon.  The Journal of Nutrition, Volume 152, Issue 11, November 2022, Pages 2514–2525, https://doi.org/10.1093/jn/nxac150

• Background: Shifting towards a more plant-based diet, as promoted in Western countries, will reduce the animal protein contribution to total proteins. Such a reduction may not only impair protein adequacy, but also the adequacy in other nutrients.
• Conclusions: “this study showed that for this French adult population, the lowest animal protein contributions to total proteins that are compatible with nutritional adequacy, affordability, and eating habits vary from 45% to 60%, depending on age and sex, with the highest contributions needed for older populations and young women.”
• Funding: “MS-Nutrition and MoISA received financial support from the French National Interprofessional Association of Livestock and Meat (Interbev)…Interbev had no role in the design, implementation, analysis, or interpretation of the data.”
• Author disclosures: “The authors report no conflicts of interest.”

Comment: These are classic examples of article titles that make me immediately ask: Who paid for this?   Bingo!   They are also classic examples of studies with conclusions that can easily be predicted if you know who funded them.  The authors may believe that they have no conflicts of interest but it sure looks like they do.

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Chloe Sorvino.  Raw Deal: Hidden Corruption, Corporate Greed, and the Fight for the Future of Meat.  Atria Books, 2022.  

This is the first analysis I’ve seen of the meat industry from a business perspective.  Corvino is a business reporter from Forbes and did an amazing research job to do this book, including visiting CAFOs, slaughterhouses (she doesn’t say how she talked her way into it), chicken houses, and alternative meat places.  She also talked to a vast number of experts on all sides of the meat issue.  Full disclosure: she interviewed me and quoted me in the book in a couple of places.

I was happy to do a blurb for it.

Raw Deal is Chloe Sorvino’s deeply reported, first-hand account of how business imperatives drive the meat industry to mistreat workers, pollute the environment, fix prices, bribe, and manipulate the political process, all in the name of shareholder profits.  She argues convincingly for holding this industry accountable and requiring it and other corporations to engage in social as well as fiduciary responsibility.   Raw Deal is a must read for anyone who cares about where our food comes from.

On meat substitutes

I have yet to meet anyone in this industry who says they do not care about climate change.  In fact, many say they are personally driven by their product’s sustainability and environmental potential.  But it’s still all to a certain point.  There’s a reason Impossible Foods is preparing for a potentially $10 billion public listing, and that neither Impossible nor Beyond Meat is registered as public benefit corporations a move that would legally inhibit the companies from putting profit over their environmental mission.  Half of Impossible’s investors come from venture capital firms and the roster even includes a hedge fund, Viking Global Investors. Backers are no doubt ready for an exit, and they want to get Impossible the best deal.  A sustainability halo helps the cause (pp. 169-170).

On support for small local meat producers

Local infrastructure for livestock producers to cook and package products is a key missing link in making local food systems profitable and viable.  Creating lasting impacts wouldn’t cost much.  “We have the information and we have the evidence.  FaWhat we don’t have are the facilities and shared space where multiple people can leverage that at their business’s scale,” Mickie told me.  “It’s just crazy to me to be in a space where we’re trying to meet so many intersecting issues of inequity, and have to prove it one hundred percent, and then in another realm, people are playing with stem cells and getting two hundred million dollars.  We literally feed people and want to do it better )p. 257).

Chloe Sorvino has also published:

• An adapted essay in the Los Angeles Times on universal food access
• An excerpt in Fast Company about whether good meat exists

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The USDA has just published its latest food dollar series.  (And see below for international data.)

And here’s how all that is distributed.

If you are a farmer, you get an average of just over 7 cents on the dollar.

The real money is in processing, retail, and food service—added value, indeed.

The Food and Agriculture Organization is now providing this information for other countries at its new Food Value Chain domain.  This is an interactive site that is not particularly intuitive to use; it will take some fiddling to lmake it work.

The new FAOSTAT domain, which will steadily expand coverage, has information for 65 countries from 2005 through 2015. It shows that around 20 percent of expenditure on food at home accrues to the farmer, around one-fourth to processing, and nearly half to retail and wholesale trade.

Meanwhile, only around 6.7 percent of consumer expenditure on food away from home accrues to the farmer. That figure is steadily decreasing even, highlighting the need to pay attention to the post farm-gate dimension of the food value chains.

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TODAY: @Stphn_Lacey will moderate at 1:00 p.m. ET. Register HERE.

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The Global Health Advocacy Incubator (GHAI) has just released this report.

The report documents how marketing of unhealthy food and beverages is linked to complex political, social, historical, cultural and economic forces that make it a key driver of unhealthy food environments:

• Ultra-processed food and beverage product (UPP) marketers…saturate the marketplace with junk products through tactics that are aggressive, insidious and everywhere.
• Consumers are ambushed with food marketing through the sponsorship of their favorite sports teams, the hidden product placements in their children’s educational shows and the free products that they receive at events.
• The dangers are even more apparent when UPPs target children and adolescents who lack the developmental maturity to distinguish advertisements from entertaining or educational content.
• The UPP industry is notorious for failing to take responsibility for its participation in creating an unhealthier planet.
• The industry instead places blame solely on the individual or the guardian of the child.
• UPP corporations exploit consumers through deception and undue influence, and also gain privileged spaces in policymaking tables.
• UPP marketing threatens public health by decreasing state action to regulate food environments.

More evidence for the need to regulate ultra-processed foods and beverages (see my paper on this precise point).

Let’s get to it !

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Two items about inappropriately targeted marketing.

I.  Online marketing to kids

A coalition of 21 leading advocacy groups, led by Fairplay, a nonprofit children’s advocacy group, and the Center for Digital Democracy, has filed a petition with the Federal Trade Commission to stop online platforms from manipulating children into spending excessive time online.

The petition describes how the vast majority of apps, games, and services popular with kids:

• Generate revenue primarily via advertising
• Employ sophisticated techniques (e.g., autoplay, endless scroll, and strategically timed advertisements) to cultivate lucrative long term relationships between minors and their brands.
• Use platforms like TikTok, Twitter, YouTube, Facebook, Instagram, and Snapchat to keep kids online.
• NYT account NYT on advocacy on adv to kids

The New York Times has a story on this report.

II.  Targeting junk food ads to people of color

The University of Connecticut’s Rudd Center for Food Policy & Health has released a new Rudd Report on food marketing targeted to Black and Hispanic consumers.

Its key findings:

• Food and beverage TV advertising is highly concentrated among a small number of companies; 19 companies are responsible for 75% of all food and beverage ad spending, and 82% of marketing targeted to Black consumers.
• The proportion of junk food ads targeted to Black and Hispanic consumers is increasing.

I particularly appreciate Shiriki Kumanika’s comment (in the U. Conn press release) on industry arguments that it is giving customers what they want:

I challenge that view,” said Shiriki Kumanyika, PhD, MPH,professor at Drexel University, Dornsife School of Public Health, and founding chair of the Council on Black Health.“More likely, racialized marketing of unhealthy products reflects a flawed business model in which leveraging the demographics of social disadvantage to maximize profits from unhealthy foods and beverages is acceptable.”

Resources:

• The Rudd Center 2022 update’s executive summary
• The Rudd Center’s Fast Food FACTS 2021 report.
• Infographics, examples of targeted social media campaigns, and fast facts for advocates available HERE
• A USRTK [U.S. Right to Know] fact sheet on targeted junk food marketing
• An account of the report in  The Guardian

More on junk food marketing tomorrow.

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