The Government Accountability Office has analyzed the current status of food assistance programs in a recent report, “Domestic Food Assistance: Complex System Benefits Millions, but Additional Efforts Could Address Potential Inefficiency and Overlap among Smaller Programs” (GAO-10-346, April 15, 2010).

The GAO says that the prevalence of food insecurity rose to nearly 15 percent (or about 17 million households) in 2008, and that the federal government spent more than $62.5 billion on 18 different food and nutrition assistance programs that year.

Although the programs are poorly coordinated and often overlap, streamlining them is not easy and involves trade offs.  The GAO recommends that USDA:

identify and develop methods for addressing potential inefficiencies among food assistance programs and reducing unnecessary overlap among the smaller programs while ensuring that those who are eligible receive the assistance they need. Approaches may include conducting a study; convening a group of experts…considering which of the lesser-studied programs need further research; or piloting proposed changes.

More research needed!

Fortunately, we have some.  The Robert Wood Johnson Foundation has studied the question of whether food insecurity is linked to obesity.  Past research suggested that it is.

Foundation researchers reviewed studies examining a possible relationship between food insecurity and obesity, and those examining links between federal nutrition assistance programs and an increased risk of obesity.

The report, “Food Insecurity and Risk for Obesity Among Children and Families: Is There a Relationship?, finds no evidence of a direct relationship between food insecurity and obesity.  It also does not find a direct relationship of use of food assistance to obesity.

Food insecurity is linked to a host of physical and mental health problems and it is difficult to distinguish the effects of lack of reliable food from those due to the lack of money, education, transportation, stable housing, and health care also common among low-income households.

Earlier this month, I went to New York State’s Woodbourne Correctional Facility to accept the John Dewey Award for Distinguished Public Service from Bard College and to deliver a brief commencement address to incarcerated graduates of the Bard Prison Initiative.

Bard’s program is one of the few privately supported prison education programs in the country (the New York Times recently discussed a similar program at Sing Sing).

Bard started the program after the government cut off funding for prison education programs in the mid-1990s.

Bard has awarded liberal arts associates’ and bachelors’ degrees to nearly 200 men and women inside three long-term maximum security prisons and two transitional, medium-security prisons (Woodbourne is medium security).

None of these graduates—not one—has returned to prison after being paroled.

Why me, why there, and why discuss it here?  Participants in this program started an organic garden and are growing food for the prison with the surplus going to local food banks.

In my speech, I said:

“John Dewey was a passionate champion of liberal democracy.”

“Dewey argued that education is good for individuals, but that it also has an important social purpose—that of encouraging students to become active and effective members of a democratic society….”

“In growing a garden and producing food for yourselves and for others under these particular and peculiar circumstances, you are carrying out John Dewey’s ideals better than he ever could have imagined.”

I was not kidding when I said that no award has ever meant so much to me.  It was a privilege to be there.

Yesterday, I got a last-minute invitation to listen in on a USDA conference call announcing the release of the report of the joint USDA-DHHS Dietary Guidelines Advisory Committee (see www.dietaryguidelines.gov).

The call was remarkable for how little information it produced.  It was scheduled for half an hour, but started 12 minutes late.  Officials used most of the time to talk about how the committee was appointed, how the committee process worked, how transparent everything was, and how staff of USDA’s new Evidence-Based Nutrition Library (NEL) provided much of the research basis for the guidelines.  This left hardly any time for asking questions, and only five got asked.

From what I heard, the committee report says pretty much what previous accounts said it would (see my post on this).  If my notes on the call are correct, the committee report will recommend:

• Maintain appropriate body weight through diet and physical activity
• Shift to a more plant-based diet
• Eat more seafood; eat more low-fat dairy products; limit meat intake
• Eat less solid fats; eat less of added sugars
• Reduce sodium; eat fewer refined grains
• Follow physical activity guidelines

Is this news?  Isn’t this always what the dietary guidelines say?  Here, just for fun, are the first set of guidelines that came out in 1980.

The main difference seems to be the way the evidence was judged and in some of the details: the target for saturated fat is 7% and for sodium a gradual reduction to 1500 mg/day.

If so, that’s a lot of trouble to go through to get to basically the same place.  I summarized that place in What to Eat as “Eat less, move more, eat plenty of fruits and vegetables, and don’t eat too much junk food.”  Michael Pollen did it even more succinctly: “Eat food.  Mostly plants.  Not too much.”

So why would two federal agencies and 13 committee members go to all this trouble?

The quick answer is that the agencies have to.  Congress says they have to review the guidelines every five years.

The longer answer, which I discuss in Food Politics and What to Eat, is that every word of the dietary guidelines is fraught with politics.

According to Food Chemical News (June 14),

The document is frequently the source of much controversy in the food industry because of the way it is used to promote certain ingredients and eating habits…Observers expect some controversy this year over recommendations made with regard to salt, a subject discussed frequently in committee meetings, as well a possible suggestion to replace two servings of grain with two servings of vegetables.

Another controversy is brewing in regards to the information on which the report was based. On Friday, the American Meat Institute, the National Cattleman’s Beef Association, the Grocery Manufacturer’s Association and the Grain Foods Foundation were among 23 groups that asked USDA and HHS to provide access to the Nutrition Evidence Library, which contains all the research used by the Dietary Guidelines committee when making their recommendations. “Without access to the data from which the DGAC drew its conclusions and recommendations, the public may not be able to provide meaningful comments,” the letter states.

Right. And now let’s see what the agencies do with this report (here’s the USDA press release on what happens next and how to comment).  This report is, after all, merely advisory. Now, the real politics begins!

Additions:

Here is all the information about the Advisory Committee’s report, and the report itself (but why didn’t they put it in one easy pdf file?).

And here is USA Today’s take on it: “Panel: obesity is century’s greatest public health threat.”

Further addition, June 16: Thanks to Daniel Green (Cornell) for putting the report together in one enormous (19MB) file.

In a move that should bring cheer to anyone who cares about the integrity of organic certification, the USDA has banned the Organic Crop Improvement Association (OCIA) from certifying foods from China as organic.  According to the accounts in today’s New York Times and the USDA’s enforcement announcement, OCIA used employees of a Chinese government agency to inspect state-controlled farms and food processing facilities.

Oops.  This is sending the fox out to guard the chickens (organic, hopefully).  The Chinese government has a vested interest in selling certified organic foods and can only be expected to be lenient in enforcing rules for organic production.

Honest, reliable, consistent inspection is the cornerstone of consumer trust in organics.  If producers aren’t following the rules to the letter (and, we wish, the spirit), why would anyone be willing to pay higher prices for organics?  Since it’s impossible to prove that organics are more nutritious than conventional foods, the entire system rests on trust.  And the value of trust rests with the inspectors.

Advocates of organics have been worried for ages about the credibility of organic foods from China and whether cheap organics produced according to high standards.  Now we know, and the answer is not pretty.  With respect to OCIA’s arrangement with Chinese government inspector, the New York Times explains:

The department objected to the arrangement after a 2007 audit, saying the partnership violated a rule barring certifiers from reviewing operations in which they held a commercial interest.  The department moved to revoke the association’s accreditation and the group filed an appeal. The department’s disciplinary process is conducted in secret, and negotiations often drag on. In O.C.I.A.’s case, it took nearly three years to resolve.

This cozy arrangement has been going on for at least the last three years?

It’s good that USDA is taking this on now.

But USDA really needs to take a hard look at conflicts of interest in organic certification, domestic as well as foreign.  Some USDA-authorized certifying agencies are much more lenient than others.  Witness: certification of fish and pet food as organic, despite the lack of final rules for such certification.  Some certifying agencies manage to find ways to do this; others refuse.

The organic industry ought to be pushing USDA as hard as it can to establish and enforce the highest possible standards for organic certification.  I’m looking forward to reading what the Organic Trade Association—and OCIA—have to say about all this.

A reporter sent me this message from Christopher Perille, Mead-Johnson’s Vice President – Corporate Communications & Public Affairs, about the company’s Chocolate and Vanilla sweetened Enfagrow toddler formula, advertised with health claims.  It seems only fair to present the company’s defense of its products.  Here’s what he says:

Enfagrow Premium products contain a balanced blend of protein, fat, carbohydrates and other key nutrients, offered in a form designed to be appealing to even the pickiest eaters. These products were introduced in the U.S. to provide additional nutrition as part of a normal healthy diet for toddlers who have been weaned off breast milk or infant formula. While we recognize that each toddler — and his or her eating habits and nutritional needs — are different, they can often have rather narrow palettes and relatively short lists of acceptable foods. My daughter, for one, had an extended period of time during which hot dogs, chicken fingers and french fries were three of her primary food groups. Happily, her tastes eventually expanded, and she is now a healthy and happy sophomore at Washington University in St. Louis — but there was certainly a time when I was concerned whether or not she was getting all the nutrition she needed.

Enfagrow Premium vanilla has been in the marketplace for nearly a year and has elicited numerous positive comments from grateful parents. They have told us that they consider these products an important option for helping to meet their child’s overall nutritional needs, especially those who are picky or erratic eaters, so as to help provide additional assurance that toddlers achieve their recommended nutrient intake.

As we discussed, you were looking at older packaging. The current labeling for Enfagrow Premium vanilla, indicates 17 grams of total sugar, but even that is overstated due to precautionary rounding — the real figure probably falls closer to 15 (14-16). The majority (approximately three-quarters) of the sugar in our product comes from lactose (that is naturally occurring in milk). So while we do add a small amount of sugar (about 4 grams or 1 teaspoon in a 7 fl. oz. serving) to our Enfamil Premium vanilla product to improve the for finicky eaters, the sugar in our flavoring equates to about 15 calories and is less than 2% of a toddler’s daily allowance of calories.

By comparison, the chocolate-flavored version contained less lactose and required more added sugar to overcome the bitterness of cocoa to make it palatable, so the sugar from lactose accounted for just over half the total sugar.

Even with the added 15 calories of sweetness, Enfagrow Premium vanilla has a superior nutritional profile to many other beverages regularly consumed by toddlers – including apple juice, grape juice and similarly flavored dairy drinks.

Enfagrow products also have beneficial ingredients include iron to help support brain growth and antioxidants and other nutrients to help support the immune system. Additionally these products are also a source of Omega-3 DHA and prebiotics, both of which are lacking in milk. Finally, these products exceed whole milk – serving for serving – for important vitamins such as A, B1, B6, C and E.

Enfagrow Premium products – flavored and unflavored – can be part of a balanced diet, which in combination with routine physical activity and an overall healthy lifestyle, can help avoid obesity. In fact, a peer reviewed article published in April 2008 in the Journal of the American Dietetic Association – based on a study of over 7,500 children and adolescents from ages 2 to 18 – found that consumption of either flavored or plain milk is associated with a positive influence on nutrient intakes by children and adolescents. Additionally, consumption of flavored milk was not associated with adverse effects on Body Mass Index (BMI), a commonly used indicator of obesity.

Convinced?  I’ve said all I have to say about these products in previous posts.  You decide.

I keep complaining about the health claims on Enfagrow toddler formula, a sugary product aimed at children from ages one to three:

These claims, for the uninitiated, are a special kind called structure-function.  Congress authorized such claims when it passed the Dietary Supplement Health and Education Act (DSHEA) in 1994.

Structure-function claims do not say that the product can prevent or treat disease. They merely suggest that the product can help in some unspecified way with some structure or function of the body.

When Congress passed DSHEA, it meant the claims to apply to dietary supplements, not foods. Enfagrow is marketed as a food, not a supplement.  It displays a Nutrition Facts label, not a Supplement Facts label.

Over the years, the FDA has issued cease-and-desist warnings about foods that bear structure-function claims.  In recent years, it has simply stated that manufacturers are responsible for ensuring that the claims are “truthful and not misleading.”

One reason for the shift is what the Courts have ruled.  The Courts say that structure-function claims are protected by First Amendment guarantees of free speech.  The most recent case is Alliance for Natural Health USA v. Sebelius. As described in Food Chemical News (June 7), a D.C. District Court judge ruled that the FDA cannot deny health claims that link selenium supplements to reduced risk of several diseases, or require those claims to be qualified, just because the claims lack adequate scientific substantiation.

In other words, supplement makers can say anything they want to about the benefits of their products—on the grounds of free commercial speech—whether or not science backs up the claim.

Recently, the FDA issued a warning letter to Nestlé, the maker of a Juicy Juice product aimed at toddlers, which displays a claim that its content of added omega-3 DHA improves brain development.  The FDA did not take on the claim, even though research seems unlikely to find that such drinks have any special benefits for brain development.  Instead, the FDA focused on a technicality:

The product makes claims such as “no sugar added,” which are not allowed on products intended for children under 2 yrs of age because appropriate dietary levels have not been established for children in this age range.

I’m guessing—this is speculation—that the FDA is reluctant to take on Enfagrow’s brain or immunity claims because Mead-Johnson has deep pockets and might well be willing to fight this one in court as a First Amendment case.

I am not a lawyer but I thought that intent mattered in legal cases.  Surely, the intent of the founding fathers in creating the First Amendment was to protect the right of individual citizens to speak freely about their political and religious beliefs.  Surely, their intent had nothing to do with protecting the rights of supplement, food, and drug corporations to claim benefits for unproven remedies, or to promote sales of sugary foods to babies.

I think it is time to give these First Amendment issues some serious thought.  How about:

• FDA: Fire those lawyers and hire some who will protect the FDA’s ability to use science in its decisions.
• FTC: Take a look a the immunity claim on the Enfagrow Vanilla toddler formula, now that the Chocolate is off the market.
• Legal scholars: Surely there are ways to protect real First Amendment rights while restricting unsubstantiated health claims?

Other ideas are most welcome.  Your thoughts?

Mead Johnson announced yesterday that it was withdrawing its Enfagrow Chocolate Toddler Formula–just the Chocolate version–from the market:

Like all our Enfagrow Premium products, the recently introduced chocolate-flavored version has a superior nutritional profile to many other beverages typically consumed by toddlers — including apple juice, grape juice, and similarly flavored dairy drinks. Unfortunately, there has been some misunderstanding and mischaracterization regarding the intended consumer for this product and the proper role it can play in a child’s balanced diet. The resulting debate has distracted attention from the overall benefits of the brand, so we have decided to discontinue production of Enfagrow Premium chocolate toddler drink and phase it out over the coming weeks.

I can’t resist quoting the Chicago Tribune’s explanation of the origin of the debate caused by “misunderstanding and mischaracterization:”

Introduced in February, the chocolate-flavored formula was widely criticized in the blogosphere after Marion Nestle, professor of nutrition, food studies and public health at New York University, wrote that the drink would lead children to crave sugary beverages on her influential blog, www.foodpolitics.com.

Influential?  Maybe, but it seems that my comments on this formula did not go nearly far enough.  Mead-Johnson may be withdrawing the Chocolate version, but it is keeping the Vanilla (as explained by Susan James on ABCNews.com, which also quotes me).

What’s the difference?  The Vanilla has exactly one gram less sugar than the Chocolate, 18 grams per 6-ounce serving, rather than 19 grams.  In contrast, the milk in my refrigerator has 9 grams of sugar (natural, not added) in 6 ounces.

Clearly, Mead-Johnson doesn’t get that it’s the sugars, stupid.

Why do I think this is a PR stunt?  Three reasons:

• The Vanilla doubles the sugars in regular milk.
• The Vanilla has the same health claims as the Chocolate: growth, brain development, and immunity.
• Mead-Johnson’s stock went up after the announcement.

One more time: Where are the FDA and FTC on this product?  This Immunity claim is no different from the one on Kellogg’s Krispies cereals that the FTC went after a couple of days ago.

Tomorrow: Some speculation on why the FDA is reluctant to take on things like this.

Addition, June 11: Here is Melanie Warner’s take on this on her BNet Food Industry blog site (she quotes my post).

If you don’t have a small baby, or your baby is breastfed(and see note at end) you no doubt are missing the furor over “functional” ingredients that companies have been adding to infant formulas.

DHA (an omega-3 fatty acid) came first.  As I discuss in my book, What to Eat, infant formula companies could not wait to add it.  They knew they could market it on the basis of preliminary evidence associating DHA with visual and cognitive benefits in young infants.    Although evidence for long term benefits is scanty, the companies also knew that they could charge higher prices formulas containing DHA.

The FDA approved the use of DHA in infant formulas on the grounds that it is safe, but did not require the companies to establish that DHA makes any difference to infant health after the first year.  Because of its marketing advantage, virtually all infant formulas now contain DHA.  Surprise!  They also cost more.

Companies now want to add other ingredients, such as prebiotics, probiotics, lutein, lycopene, and betacarotene, which also can be marketed as healthier and at higher prices.

In response, the Center for Budget and Policy Priorities (CBPP), has issued a report on the lack of evidence for the benefits of functional ingredients and the substantial harm they will cause to the economic viability of the WIC program, the USDA’s assistance program for low-income mothers and children.

WIC buys about half the infant formula sold in the United States each year.  WIC is not an entitlement program, meaning that the number of participants is limited by available funding (a GAO report explains how this works).

The CBPP report says:

As pressure mounts to limit federal discretionary spending, it is critical to ensure that WIC not spend funds on foods with functional ingredients that do not deliver clinically significant benefits. WIC spent approximately $850 million on infant formula last year, and a recent USDA study found that more than ten percent of that spending ($91 million annually) is attributable to higher-priced formulas with functional ingredients.  Under current law, the additional cost to WIC of providing foods with these ingredients is likely to grow substantially as such foods proliferate.

As the report explains, formula companies do not have to demonstrate that the added–and more expensive–ingredients do any good:

There is no mechanism within the national WIC program that requires USDA to review the research evidence on the claimed benefits of these functional ingredients or to base decisions about whether to offer foods containing such ingredients on their benefits and the specific needs of WIC participants. Currently, instead, infant formula manufacturers themselves decide whether WIC offers infant formulas with new functional ingredients, while state WIC programs decide whether WIC should offer other foods with such ingredients.

As I keep saying, functional foods (and ingredients) are about marketing, not health.  If companies are going to add functional ingredients–and charge higher prices–they need to have some convincing scientific evidence to back up their claims.

Postscript: Laurie True of the California WIC program writes:

Congressman George Miller, Chair of the House Education and Labor Committee, is writing the bill that reauthorizes the WIC Program this week. He should include a provision requiring independent scientific review of the efficacy of these “functional ingredients” before USDA allows them in WIC foods and infant formula.

Note:  Lori Dorfman sends a Berkeley Media Studies Group issue paper on how to advocate for hospitals and workplaces to make it easier for moms to breastfeed.