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The Environmental Working Group has just published its annual lists of Dirty Dozen and Clean Fifteen.

• The Dirty Dozen—those with the highest levels of harmful pesticides:  Strawberries, spinach, kale/collards/mustard greens, peaches, pears, nectarines, apples, grapes, peppers, cherries, blueberries, green beans.
• The Clean Fifteen—those with the lowest levels of harmful pesticides: Avocados, sweet corn, pineapple, onions,papaya, sweet peas (frozen), asparagus, honeydew melon, kiwi, cabbage, mushrooms, mangoes, sweet potatoes, watermelon, carrots

What always interests me about these lists is how nobody except the EWG wants to deal with pesticides on produce, and how much pushback the EWG gets from industry.

IFIC, the International Food Information Council (an industry front group), criticizes the EWG for promoting “organic produce as being safer and healthier than conventional produce.”  It says (my paraphrase except for direct quotes):

1. You don’t need to avoid any kind of produce.
2. Regulators ensure all foods are safe.
3. Regulators inspect and monitor all foods.
4. Residues are on all foods but “they are not to be feared.”
5. “Giving elite status to organic produce is detrimental to people’s health.”
6. Everybody agrees people need to eat more produce.
7. “Shelf-stable foods, organic or conventional, present relatiable and healthy foods for all of us.”

My translation: Don’t bother with organics, ultra-processed foods are fine.

The Alliance for Food and Farming (a produce industry trade group) says:

Despite peer reviewed research showing it is scientifically unsupportable and negatively impacts consumers, the so-called “dirty dozen” list will be released soon  This list was developed to invoke misplaced safety fears about fruits and vegetables – the food group we are encouraged to eat more of every day to improve physical and mental health, prevent illness and increase lifespan.

This group says the “Dirty Dozen” recommendations are “unsupportable” and “negatively impact consumers and produce consumption.”

It says,

• Just wash it! According to the FDA, washing produce under running tap water can reduce and often eliminate pesticide residues, if they are present at all.
• A farmer’s first consumer is their own family so food safety is always their priority.

Comment: We use a lot of pesticides, more than 400 in the US alone, and more than 2.5 million metric tons annualy, worldwide.

We can debate the degree of harm caused to individuals, especially children, but there is no question they are bad for soil and the environment, and I’ve never heard anything suggesting they are good for us.

We would be better off eating fewer of them and producing food in ways that use less of them.

If EWG pushing farming in that direction, it needs it.

Choose organics as a means to encourage more sustainable production practices (vote with your fork).

Advocate for policies to reduce pesticide use (vote with your vote).

And thank EWG for holding industry’s feet to the fire.

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My post last week on the FDA’s lack of action on ensuring the safety of infant formula elicited this response from Taryn Webb, Health Communications Specialist at CFSAN/FDA:

Hi Marion,

In your article below, “Alarming (in)action from the FDA,” you assert that “If FSMA did not require companies to notify the FDA when they found contamination, the FDA should be going to Congress to get that authority to announce its rulemaking to get that authority.” These statements could mislead readers to believe that the agency has not taken action to obtain this authority from Congress. In fact, the FDA is specifically seeking new authority to compel reporting of product positive test results for relevant pathogens (see FY 24 FDA Legislative Proposal titled, “Product Testing Requirements for Foods Marketed for Consumption by Infants and Young Children,” available at: https://www.fda.gov/about-fda/reports/budgets). Furthermore, the statement “FDA should…announce its rulemaking to get that authority,” is factually incorrect as without statutory authority, we are not in the position to undertake rulemaking to require such reporting. To reiterate what appears to be a point of confusion, the FDA cannot create authorities that we do not have through rulemaking. We did notice that you later updated your article at the very bottom to note that FDA did request such authority. However, your initial article and email distribution to readers contained incorrect information.

We are seeing a troubling pattern of articles with erroneous information that then get amplified. In the future, we would appreciate it if you contacted us before publishing articles that are solely about FDA so that we can provide you with the most up-to-date, correct information. You can reach out to our communications staff, which include myself and Jen Dooren (copied here) or by emailing CFSANTradepress@fda.hhs.gov.

As I see it, the “troubling pattern” here is FDA’s responses to advocates like me who want to support this agency’s role in making sure food companies in general—and infant formula companies in particular—do not produce unsafe food.  I want to encourage the FDA  to put public health as its first and immediate priority, as it is supposed to as an agency of the US Public Health Service.

I did not know about the FDA’s request to Congress.  The agency did not publicly announce it was asking for that authority.  I only learned about it from Helena Bottemiller Evich’s Food Fix newsletter, to which I subscribe.  I corrected my post as soon as I could.

Evich has her own issues with the FDA.  In her Food Fix letter last Friday, she said:

I updated last week’s post on FDA asking (not telling) infant formula makers to disclose contamination to clarify that the agency has determined it doesn’t have the authority to require this disclosure.  It’s perfectly normal for an agency to seek a clarification on something, as FDA did here, and I was happy to update the post – no problem. What I did take issue with, however, is FDA Commissioner Robert Califf characterizing the coverage as “misinformation” on Twitter.

…As I reported in Tuesday’s newsletter, FDA asked Congress last week for this test reporting authority in a budget document. This is notable, but it raises another critical question: Why didn’t the agency formally make this request earlier? It wasn’t in the agency’s budget request last year. It’s been more than a year since the massive Abbott Nutrition infant formula recall, and we’ve seen a handful of smaller recalls over Cronobacter concerns in recent months. And infant formula shortages and disruptions continue in many parts of the country.

If she didn’t know that FDA had asked Congress for test-reporting authority, it’s because the FDA wasn’t screaming for it as it should have been doing from the moment the infant formula crisis began.

The lives of infants are at stake.

Here what I wish the FDA had said from the beginning of the infant formula crisis and would still say:

“Marion, we are devastated by what has happened with infant formulas.  We can’t sleep for worrying about how we can protect infants from harm.  We are doing everything in our power to force formula producers to make sure their prevention controls are in place and monitored.  We never want this to happen again and won’t stop pushing them until we are sure infant formula is safe.”

I apologize for my error.  But I stand by my concerns.  FDA: If you want the troubling pattern to go away, fix the problem.

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I’m often saying that industry-funded studies tend to produce results that favor the funder’s commercial interests.  This is true, but there are occasional exceptions.

Here, for example, are two studies based on grants from the American Pistachio Growers to the same group of investigators.  Both are randomized clinical trials with results that must have disappointed the funder.

I. Effects of short-term pistachio consumption before and throughout recovery from an intense exercise bout on cardiometabolic markers

Results: Two weeks of pistachio consumption failed to elicit changes in any biomarker (p < .05).. .Overall, in healthy young men with normal blood lipid and glucose metabolism, little effect of either pistachios or intense exercise on cardiometabolic risk indicators was detected.

II. Influence of pistachios on force production, subjective ratings of pain, and oxidative stress following exercise-induced muscle damage in moderately trained athletes: A randomized, crossover trial.

Results: Creatine kinase, myoglobin, and C-reactive protein increased over time following exercise (p < 0.05); however, there were no advantages following pistachio consumption. No significant changes in vertical jump or superoxide dismutase were elicited during any trial.

Comment:  The second paper put a positive spin on the basically null results: “This study demonstrates that 3.0 oz/d of pistachios can reduce delayed onset of muscle soreness and maintain muscle strength, potentially promoting exercise tolerance and training adaptations.”  My question is why anyone would think that pistachios would make any difference anyway.  They are one food in the diets of people who eat many othere kinds of foods.  I’m all for eating pistachios, if you like them, along with lots of other healthy foods.  There is only one reason to do this kind of one-food research—for marketing purposes.

You don’t believe this?  Check out the nutrition and health section of the Pistachio Growers website.  You can’t make this stuff up.

Hey.  If that’s all it takes, give it a try (I guess).

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If you aren’t familiar with IPES Food, here is your chance.

IPES-Food – the International Panel of Experts on Sustainable Food Systems – is a diverse and independent panel of experts guided by new ways of thinking about research, sustainability, and food systems. Since 2015, IPES-Food has uniquely shaped the debate on global food systems reform, through policy-oriented research and direct engagement with policy processes.

The IPES Food panel is an impressive bunch, starting with its co-chairs, Olivier De Schutter, currently UN Special Rapporteur on extreme poverty and human rights, and Maryam Rahmanian, independent expert on agriculture and food.

Their two most recent reports:

I.  Smoke & Mirrors: Examining competing framings of food system sustainability 

This comes with a background report: Agroecology, Regenerative Agriculture, and Nature-Based Solutions: Competing framings of food system sustainability in global policy and funding spaces.

Together, these cover those key terms, their emergence and evolution, and the ways they are used in global policy and funding.

The report favors use of Agroecology:

Agroecology, and in some uses regenerative agriculture, offer a more inclusive and comprehensive pathway toward food system transformation because they connect social
and environmental aspects of sustainability, address the whole food system, is attentive to power inequalities, and draws from a plurality of knowledges emphasizing the inclusion of marginalized voices.

II.  Special Report: Debt & Food Crisis: Breaking the Cycle of Unsustainable Food Systems, Hunger and Debt

Unsustainable food systems, this says, are major drivers of “the debt crisis. Import dependencies, extractive financial flows, boom-bust commodity cycles,” leaving countries exposed to shocks and unable to invest in climate-resilient food production and food security.

The IPES panel calls for:

• Debt relief and development finance
• Reparation of historical food system injustices and the return of resources to the Global South.
• Putting the interests of the world’s poorest countries and marginalized populations first.

The documents

• The special report
• The press release
• A one page summary for policymakers

IPES Food deals with Big Picture issues.  What they say is worth attention.

Here’s what the FDA is doing these days.

To  my astonishment, the FDA says it will allow a health claim for cocoa flavanols and reduced risk of cardiovascular disease.

OK, it’s a qualified health claim, but still.  The whole thing is absurd.

Qualified health claims are just that; they have to include the qualifier which usually says there’s no or not much research to back up the claim.

The FDA gives several examples of what it will allow.  Here are two:

• “Cocoa flavanols in high flavanol cocoa powder may reduce the risk of cardiovascular disease, although the FDA has concluded that there is very limited scientific evidence for this claim.”
• “Very limited scientific evidence suggests that consuming cocoa flavanols in high flavanol cocoa powder, which contains at least 4% of naturally conserved cocoa flavanols, may reduce the risk of cardiovascular disease.”

The FDA also says:

This qualified health claim only applies specifically to cocoa flavanols in high flavanol cocoa powder and foods that contain high flavanol cocoa powder. The claim does not apply to regular cocoa powder, foods containing regular cocoa powder, or other food products made from cacao beans, such as chocolate.

Not that anyone can tell the difference.

This silliness came about because  of a petition from the chocolate company, Barry Callebaut AG in Switzerland.

My surprise was that Callebaut was behind the petition, not Mars.

Mars, after all, has been funding this kind of research for years (see my industry-funded study of the week from March 2022).

I can’t wait to see how Callebaut or Mars will use this claim.  I haven’t seen it anywhere yet.  Let me know if you do.

The World Obesity Atlas 2023, published by World Obesity Federation, predicts that unless preventive interventions succeed, by 2035:

• The global economic impact of overweight and obesity will reach $4.32 trillion annually and constitute nearly 3% of global GDP.
• The majority—51% or more than 4 billion people—will be living with overweight or obesity.
• One in four people—nearly 2 billion—will have obesity.
• The economic impact of overweight and obesity is estimated to be over $370 billion a year in low and lower-middle income countries alone.
• Childhood obesity could more than double.

Here’s the prediction for the U.S.

In the report, the World Obesity Federation:

• Notes that member states of WHO committed to halt the increase in obesity rates at 2010 levels by 2025. No country is on track to meet these targets.
• Calls on governments to develop national action plans.
• Calls on governments to improve health care.
• Calls for building on the ROOTS framework for tackling obesity: Recognising the root causes, monitoring Obesity data, investing in Obesity prevention, ensuring access to Treatments, and adopting a Systems-based approach.

The documents:

• The press release
• The World Obesity Atlas 2023  (this includes predictions for WHO member nations) 

Comment

This is a global problem requiring global solutions., and actions by every government, including ours.   We need a national obesity prevention plan focused on strategies like to work (reduction of food insecurity, improved health care, better education, restrictions on marketing junk food, etc).

Otherwise,  we are all headed to Wall-E, which will turn out to be prescient, rather than dystopian.

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 A few months ago, I wrote about the FDA’s proposal for allowing the use of the word “Healthy” on food labels.  I said:

If we must have health claims on food packages, the FDA’s proposals are pretty good. They require any product labeled “healthy” to contain some real food (as opposed to a collection of chemical ingredients or, as author Michael Pollan calls them, “food-like objects”), and for the first time they include limits on sugars…These proposed rules would exclude almost all cereals marketed to children.

Now, the Consumer Brands Association (formerly Grocery Manufacturers Association), which represents Big Food, and which objects to the FDA’s proposal, has proposed an alternative framework.

The CBA is clear about its objectives.  It worries that

consumers could second guess or even reject items that might no longer be qualified to bear the “healthy” claim that can bear the claim today…As it stands, the proposed rule would eliminate an inordinate number of packaged products from being considered “healthy.”

That, of course, is its point.

The CBA issued what I read as a clear threat:

FDA’s proposed changes to its “healthy” definition will contradict the current Dietary Guidelines, causing confusion among consumers and potentially inviting legal challenges for the agency.

In other words, if the FDA does not back down on this, CBA intends to go to court over it.

This was also clear from the CBAs 54-page set of comments to the FDA.  As quoted in the Washington Post, the CBA said:

We are particularly concerned by the overly stringent proposed added sugars thresholds. We appreciate FDA’s interest in assessing added sugars intake. We believe, however, that FDA’s restrictive approach to added sugars content in foods described as healthy is unwarranted and outside FDA’s authority given the lack of scientific consensus on the relationship between sugar intake and diet-related disease.

Ted Kyle, who writes the excellent newsletter, ConscienHealth, also quoted the CBA:

Manufacturers have the right to label foods that are objectively ‘healthy’ as such, based on a definition of ‘healthy’ that is truthful, factual, and non-controversial. We are concerned that limiting the truthful and non-misleading use of the word ‘healthy’ in product labeling could harm both the consumer and the manufacturer.

As Kyle put it, “If you did not catch it, this is a freedom of commercial speech argument. Any guesses how the current Supreme Court might rule on that one? Yep, corporations are people too.”

As I am ever saying, food companies are not social service or public health agencies.  They are businesses whose first priority is returns of profits to shareholders, regardless of how their products affect health (or the environment, for that matter).

The pushback on the FDA’s seemingly trivial “Healthy” idea, is enought to make me think it might actually have some impact.

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Really, I can’t make this stuff up.

Thanks to Jim Krieger of HealthyFoodAmerica.org for sending me to Food Navigator-USA: Post launches the first-ever cereal designed to promote sleep.

A cereal meant to be consumed at bedtime?  I wanted it for my cereal box collection, and there hasn’t been a good one like this for a long time since the FDA started discouraging ridiculous health claims.  I went straight to the Ithaca Walmart and scored a box.

Sweet Dreams, the box tells you, is “part of a healthy sleep routine.”

The front-of-package claims:

• Made with whole grains
• Supports natural melatonin production with zinc, folic acid, and B vitamins
• Excellent source of Vitamin E for neuroprotection

The back-of-package claims:

• Sleep…We want to help you enjoy it.  With delicious wholesome ingredients, curated vitamins and minerals, and a specially formulated night-time herbal blend, our dreamy cereal is part of a healthy sleep routine.
• Made with a night-time herbal blend containing a touch of lavender and chamomile

I looked up the website:

For 130 million American adults, a good night’s sleep is elusive. You deserve good sleep, and we want to help you enjoy it! So, we made Sweet Dreams cereal, the first ready-to-eat cereal specially designed to support a good sleep routine and a fresh start to the next day…Available in Blueberry Midnight and Honey Moonglow flavors, make Sweet Dreams cereal a part of your bedtime routine and enable a better sleep cycle while satisfying those nighttime food cravings.

Comment:

I hardly know where to begin: “curated vitamins and minerals”?  “Supports natural melatonin production”?

This last is a structure/function claim like those for supplements.  It requires only the barest hint of scientific substantiation.

Reader, I ate it.

The cereal is crunchy, with occasionally visible almonds, but is cloyingly sweet (to my taste): A cup of cereal has nearly a tablespoon (13 grams) of added sugar– 24% of a day’s total sugar allowance.

No wonder it’s so sweet.  Sugars appear seven times on the ingredient list.

Whole Grain Wheat, Rice, Cane Sugar, Almonds, Whole Grain Rolled Oats, Canola and/or Soybean Oil, Flavor Clusters (Sugar, Corn Syrup, Degermed Corn, Palm Oil, Natural Flavor, Cocoa (processed with alkali)(for color), Blueberry and Carrot Concentrates (for color)), Salt, Honey, Corn Syrup, Barley Malt Extract, Molasses, Tocopherols (Vitamin E) to maintain freshness, Natural Flavor.

Post must be trying to sell more cereal.  Eat cereal at night?  Well, if you have sleep problems I suppose you can give it a try.

I ate this cereal in the morning.  It did not make me feel sleepy.

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