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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 Times’ obituary for Dr. Albert J. (“Mickey”) Stunkard, who died last week at the age of 92, describes his work on the genetics of obesity and quotes Dr. Walter Willett’s comment that genetics accounts for only a small part of the “legions of the obese.”

Stunkard was writing about the lifestyle and environmental determinants of weight gain, long before most of us had a clue.

I learned this in 2000 when Michael Jacobson and I were writing a paper on public health policy approaches to obesity prevention.[i]   We were arguing that policies aimed at preventing weight gain focused almost entirely on personal behavior but needed to focus on fixing the environment of food choice.

A peer reviewer scolded us for missing Stunkard’s work.

At last, we discovered Stunkard’s groundbreaking work.  In the published paper, we wrote:

The most notable exception [to the focus on personal responsibility] was the report of a 1977 conference organized by the National Institutes of Health (NIH) to review research and develop recommendations for obesity prevention and management.

In one paper, A.J. Stunkard thoroughly reviewed social and environmental influences on obesity.[ii]  As a result, the conference report included an extraordinarily broad list of proposals for federal, community, and private actions to foster dietary improvements and more active lifestyles.

These ranged from coordinated health education and model school programs to changes in regulations for grades of meat, advertising, taxes, and insurance premiums. Some of the proposals cut right to the core of the matter: “Propose that any national health insurance program…recognize obesity as a disease and include within its benefits coverage for the treatment of it.” “Make nutrition counseling reimbursable under Medicare.” And “Fund demonstration projects at the worksite.”[iii]

He was far ahead of his time and will be greatly missed.

References

[i] Nestle M, Jacobson MF.  Halting the obesity epidemic: A public health policy approach.  Public Health Reports 2000;115:12-24.

[ii] Stunkard AJ. Obesity and the social environment: current status, future

prospects. In: Bray GA, editor. Obesity in America. Washington:

Department of Health, Education, and Welfare (US); 1979. NIH Pub.

No.: 79-359.

[iii] Stunkard A. The social environment and the control of obesity. In:

Stunkard AJ, editor. Obesity. Philadelphia: WB Saunders; 1980. p. 438-

 

Politico ProAg’s Helena Bottemiller Evich has been reporting on the School Nutrition Association (SNA) meeting in Boston this week (and see the video conversation with her editor, Jason Huffman, about the meeting).

One of her points: from the kinds of junk-food products exhibited, you would never know that the SNA was at war with the White House over USDA’s nutrition standards for school meals (see my previous posts).

As she explains, food companies have had no problem coming up with look-alike products that meet USDA standards:

More than 400 exhibitors showed off their innovations designed to meet the Department of Agriculture’s new regulations…PepsiCo, which owns Tropicana, Quaker and Lays, has a long list of products that meet the new rules, including Reduced Fat Doritos and Cheetos, Stacy’s Pita Chips and Munchies. Windsor Foods, which specializes in food service, has come up with whole grain-rich egg rolls that the company says kids love.

General Mills displayed a modified version of Chex Mix, a whole grain Betty Crocker cookie and a Cinnamon Toast Crunch cereal bar: “Snacks so good, kids won’t know they’re nutritious,” according to the marketing flyers.

…while the changes to lunch standards may be giving many school nutrition professionals fits, the food manufacturing industry is drooling over the opportunity to gain more sales inside what has been described as the nation’s largest restaurant: The school lunch program serves 30 million kids each day and represents a $30 billion per year market for the food industry, according to the Center for Science in the Public Interest.

…SNA benefits from the food industry’s enthusiasm in school lunches. The largest chunk of the group’s revenue is generated at its annual conference, which brought in $4.7 million in 2012. The association charges $15,000 to sponsor an education session track featuring a company representative and $20,000 to put company logos on hotel key cards.

Evich quotes Michele Simon, who also attended the meeting.

Walking through that hall, it’s very hard to see where the changes are,” she said. “It’s still pretty appalling to see the types of junk food that can pass as acceptable food for school meals. It seems like there’s a disconnect between the uproar over the improved guidelines and all these vendors who seem to have no problem meeting them.”

Michele sent me a photo of one such product.

 

For photos of other such items, see Michele Simon’s other images on Time Magazine’s site, and Nancy Huehnergarth’s collection of what she calls “The Good, the Bad and The Ugly Food Exhibits.”

To understand what this is about, take a look at the Public Health Advocacy Institute’s report on Copycat Snacks in Schools.  The “better for you” versions are sold in schools, but you can hardly tell the difference between those and the “not so good for you” commercial versions from the nearly identical packages.

How can food and beverage companies get away with this?  This is the result of USDA’s setting nutrient-based, rather than food-based standards for school meals.  Setting nutrient standards allows food companies to tweak the formulas to give the USDA what it requires.

Is a slightly “better for you” option necessarily a good choice?  Surely, schools can do better.

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.

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.