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At a talk I gave for CQ Roll Call in Washington, DC last week, an audience member asked about the definition of “natural.”  I thought I had said everything there was to say about it (see post from August).  Wrong.

Another member of the audience sent me the definition of “natural” produced by, of all things, the  Treasury Department’s Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).

Three federal agencies deal with “natural.”

The FDA

In answer to the question, “What is the meaning of ‘natural’ on the label of food?,” the FDA says:

From a food science perspective, it is difficult to define a food product that is ‘natural’ because the food has probably been processed and is no longer the product of the earth. That said, FDA has not developed a definition for use of the term natural or its derivatives. However, the agency has not objected to the use of the term if the food does not contain added color, artificial flavors, or synthetic substances.

The USDA

The USDA discusses “natural” in the context of organic foods, in order to distinguish “natural” from organic:

Natural. As required by USDA, meat, poultry, and egg products labeled as “natural” must be minimally processed and contain no artificial ingredients. However, the natural label does not include any standards regarding farm practices and only applies to processing of meat and egg products. There are no standards or regulations for the labeling of natural food products if they do not contain meat or eggs.

The ATF

This agency is in charge of regulating alcoholic beverages, largely for tax-collection purposes.  Its “ATF Ruling 85-4” does not actually define the term “natural,” but instead says when ATF takes no exception to its use.

(1) Any grape fruit, citrus or agricultural wine may be designated “natural” if it is made without added alcohol or brandy…No other type of wine may be designated as “natural.”

(2) A distilled spirit may be designated as “natural” if is solely the result of distillation, with or without mingling of the same class and type of spirits or simple filtration which does not alter the class or type of the product.

(3) A malt beverage may be designated “natural” if it is made without adjuncts (additives) other than those additives which do not remain in the finished product, either by precipitating out or by combining with other components of the product and the resulting compound precipitates or is filtered out.

I am not making this up.

CSPI thinks it’s time to phase out the use of “natural.”  OK by me.

Addition: Michele Simon, who blogs at Eat, Drink, Politics, writes (she’s not making this up either):

In fact, ATF is how housed within the Department of Justice.

Historically, ATF had all jurisdiction over alcohol (and was within Treasury), which is where that rule must have come from.

ATF still maintains jurisdiction over criminal activity, but now, the Alcohol and Tobacco Tax and Trade Bureau oversees labeling. That’s housed within Treasury.

This explains the split in 2002 (click here).

Clear as mud? So maybe you can add a fourth agency to your list!

The American Society of Nutrition (ASN) is not the only nutrition society raising issues of conflict of interest (see yesterday’s post).  The Academy of Nutrition and Dietetics (AND) is the subject of two recent analyses of this problem.

• The Food Ties that Bind
• And Now a Word From Our Sponsors

FoodNavigator-USA interviewed a number of people, including me, about the implications of these reports.  Opinions differ, to say the least.

But here’s what I said:

Sponsorship perverts science

However, Dr Marion Nestle, Paulette Goddard professor of nutrition, food studies, and public health at New York University, said it was wishful thinking to assume that companies that make their money selling soda and chips as well as water, juice and oatmeal could provide a “full” picture.

The issue, she said, was not whether FNCE delegates were capable of distinguishing facts from sponsored spin in conference handouts.

She told us: “That’s not the right question. Most people are unaware of how such things influence their opinions. Substantial research on sponsorship by tobacco, drug, and chemical companies provides such evidence. There is not yet as much research on the effects of food industry sponsorship but the few studies that exist are completely consistent with research on other industries.”

It’s stunningly easy to design studies that accomplish these goals

Asked whether it was unfair to automatically dismiss industry-funded research and information rather than judging it on its merits, Nestle said: “In my opinion, agriculture, food, nutrition, and health professionals should dismiss industry-sponsored research out of hand, and journals should not accept industry-sponsored papers. 

“There is only one reason for food companies to sponsor research—so they can use the results in their own interests. 

“Sponsorship perverts science.  Sponsored research is not about seeking truth or adding to public knowledge.  It is about obtaining evidence to defend or sell the sponsor’s product, to undermine research that might suggest that a product is unhealthy, to head off regulation, and to allow the product to be marketed with health claims. 

“It’s stunningly easy to design studies that accomplish these goals and to conduct them in ways that meet the scientific criteria of peer-reviewers.”

She added: “Peer reviewers, journal editors, and readers ought to be asking: Why did the sponsor fund this study?  Was the research question designed to permit an answer that might not meet the sponsor’s goal?  Was the study conducted in a way that permitted an answer against the sponsor’s interest?  Sponsored studies almost always fail these tests of independence.”

I think corporate sponsorship poses huge problems for the credibility of nutrition researchers and nutritionists in general.  The issue requires much more discussion than it has received to date.

Let the debates begin!

I’ve just been sent a copy of  the opening address given by the Director-General of the World Health Organization, Dr Margaret Chan, to a Global Conference on Health Promotion in Helsinki on June 10.

Here is an excerpt from her extraordinary remarks:

Today, getting people to lead healthy lifestyles and adopt healthy behaviours faces opposition from forces that are not so friendly.  Not at all.

Efforts to prevent noncommunicable [chronic] diseases go against the business interests of powerful economic operators.

In my view, this is one of the biggest challenges facing health promotion…it is not just Big Tobacco anymore.  Public health must also contend with Big Food, Big Soda,and Big Alcohol.

All of these industries fear regulation, and protect themselves by using the same tactics.

Research has documented these tactics well. They include front groups, lobbies, promises of self-regulation, lawsuits, and industry-funded research that confuses the evidence and keeps the public in doubt.

Tactics also include gifts, grants, and contributions to worthy causes that cast these industries as respectable corporate citizens in the eyes of politicians and the public.

They include arguments that place the responsibility for harm to health on individuals, and portray government actions as interference in personal liberties and free choice.

This is formidable opposition. Market power readily translates into political power…

Not one single country has managed to turn around its obesity epidemic in all age groups.  This is not a failure of individual will-power. This is a failure of political will to take on big business…

I am deeply concerned by two recent trends.

The first relates to trade agreements. Governments introducing measures to protect the health of their citizens are being taken to court, and challenged in litigation. This is dangerous.

The second is efforts by industry to shape the public health policies and strategies that affect their products. When industry is involved in policy-making, rest assured that the most effective control measures will be downplayed or left out entirely. This, too, is well documented, and dangerous.

In the view of WHO, the formulation of health policies must be protected from distortion by commercial or vested interests.

Dr. Chan was courageous to say this so clearly.  Would that our health officials would be as brave.

I was fascinated to read Michael Mudd’s piece in the New York Times on Sunday, “How to force ethics on the food industry.”  Noting that the court overturned Mayor Bloomberg’s 16-ounce soda ban, he said:

But governments should not be deterred by this and should step up their efforts to protect the public health by limiting the marketing tactics of food companies. Anyone who believes these interventions are uncalled-for doesn’t know the industry the way I do.

…The industry is guilty because it knew what the consequences of its actions might be. Large food processors employed a flock of Ph.D. nutritionists and food scientists. The connection between calorie consumption and weight gain was always as plain as the number on the bathroom scale. But instead of acknowledging this and taking corrective action to sell a better product more responsibly, food processors played innocent by blending in with the crowd of causes.

This sent me to dig through my files to search for what I’d saved about Mr. Mudd’s efforts at Kraft.  Here, for example, is the front page of USA Today, July 1, 2003.  Kraft chose USA Today to announce its new anti-obesity initiatives, and gave it an exclusive to do so.

The initiatives included, among a long list, elimination of all in-school marketing, setting nutritional criteria for marketing practices, and establishing meaningful criteria for health claims.

Even at the time, I was dubious:

They have to demonstrate what it is they’re actually doing before I can start turning cartwheels about this…Kraft has other credibility problems when it comes to marketing healthier products…Philip Morris Co., the tobacco giant now called Altria Group, owns 84 percent of Kraft [Altria sold off Kraft in 2007].

One year later, Kraft announced  that  it had begun to act on its promises.  After another six months, Kraft introduced its Sensible Solution  program  to label “better-for-you” products. leaving plenty to be dubious about.  By 2004, Michael Mudd was no longer with Kraft.

In 2007, I sent a couple of students out to see whether Kraft had kept its promises.  Not a chance, as we documented.

How come?  Food companies are not social service agencies.  Their job is to sell products.  And, as Michael Moss explains in Salt, Sugar, Fat, they must do whatever it takes to achieve that goal.

As Mr. Mudd now puts it,

It’s time to end the charade and mandate the needed changes that the industry has refused to make. 

The Lancet has just published a series of articles on non-communicable diseases (NCDs) the collective term for heart disease, type 2 diabetes, and other chronic conditions caused in large part by poor diets, lack of physical activity, or cigarettes or alcohol.

Since food politics is a big part of this discussion, these papers are worth a look.  For example, as editor Richard Horton explains in his editorial:

If I were teaching public health nutrition right now, here’s what I’d want students to read:

Geof Rayner and Tim Lang, Ecological Public Health: Reshaping the Conditions for Good Health, Routledge Earthscan, 2012.

Our case is that public health is an interdisciplinary project, and not merely the preserve of particular professionals or titles.  Indeed, one of the themes of the book is that public health is often improved by movements and by people prepared to challenge conventional assumptions and the status quo…In these cynical academic times, when thinking is too often set within narrow economistic terms—What can we afford? What is the cost-benefit of health action?—and when the notion of the ‘public’ is often replaced by the ‘individual’ or the ‘private,’ this book offers an analysis of public health which is unashamedly pro bono publico, for the public good.

David Stuckler and Karen Siegel, eds.  Sick Societies: Responding to the Global Challenge of Chronic Disease, Oxford University Press, 2011.

Sick Societies argues that we are building environments that are poorly designed for our boides: we create societies where tobacco, alcohol, and foods containing high levels of salt, sugar, and fats are the easiest, cheapest, and most desirable choices, while fruits, vegetables, and exercise are the most expensive, inaccessible, and inconvenient options.  The rise in chronic diseases is the result of a model of societal development that is out of control: a model that puts wealth before health.

Wilma Waterlander, Put the Money Where the Mouth Is: The Feasibility and Effectiveness of Food Pricing Strategies to Stimulate Healthy Eating, Vrije Universiteit, Amsterdam, 2012.

This one is for policy wonks and change agents.  This is Waterlander’s doctoral dissertation done as a published book but it is written clearly and forcefully.  Her conclusions:

The studies presented in this thesis show that the healthy choice is the relatively expensive choice; that price fundamentally affects food choice and may even form a barrier for low SES consumers in selecting healthier foods.  These findings make pricing strategies a justifiable tool to stimulate healthier choices…making healthier foods cheaper was found to be the most feasible pricing strategy to implement.

Most of you probably don’t read the Journal of Public Health Policy, but I’m on its editorial committee.  Nevertheless, this editorial came as a surprise.*   I thought I would share it with you.  Enjoy!  (I did).

Big food

Anthony Robbins M.D., M.P.A., Co-Editor

I first encountered Marion Nestle in the late 1990s when I edited Public Health Reports, the scientific journal of the US Public Health Service. We published a provocative piece of hers about the marketing by Proctor and Gamble of Olestra, a zero calorie fat substitute. Marion taught me a great deal about how the food industry markets its products that are tasty, convenient, and relatively inexpensive. It markets intensively to children and continues to do so long after overeating and obesity have been shown to have deadly health consequences. Sound familiar? Perhaps like the tobacco industry.

In 2003, I invited Marion to Public Health Grand Rounds to describe the obesity epidemic to my public health students at Tufts Medical School. To follow Marion, I invited Richard Daynard from Northeastern Law School, who had litigated extensively against the tobacco industry. Dick carefully noted the differences between tobacco, which has no healthy use, and food. But he suggested that the anti-health behavior of the two industries might be similar: continuing to market products in a way that certainly harmed health.

When the public health faculty at Tufts and the law faculty at Northeastern joined forces to establish the Public Health Advocacy Institute, one of our first projects was Legal Approaches to the Obesity Epidemic¹, a symposium published in the Journal of Public Health Policy, in 2004. It attracted a great deal of attention and JPHP became a favorite place to publish research on obesity.

But I was not entirely pleased, because although the research was usually methodologically sound, it often missed Marion’s point and the focus of the PHAI symposium. Most submissions concentrated on individual behavior and personal responsibility. In 2010, I asked Marion, who was on the JPHP editorial board to join me in writing an Editorial: ‘Obesity as collateral damage: a call for papers on the Obesity Epidemic’.² We had ‘come to believe that research studies concentrating on personal behavior and responsibility as causes of the obesity epidemic do little but offer cover to an industry seeking to downplay its own responsibility’. We urged ‘authors to submit articles that consider how to understand and change the behavior of the food industry’.

Imagine our pleasure in learning that starting this June, PLoS Medicine will publish a series of articles exploring the food industry’s involvement in health with Marion Nestle as a guest editor. To PLoS Medicine, we say bravo!

References

1. Journal of Public Health Policy (2004) Special section: Legal approaches to the obesity epidemic. 25(3&4): 346–434.
2. Robbins, A. and Nestle, M. (2011) Obesity as collateral damage: A call for papers on the Obesity Epidemic. Journal of Public Health Policy 32(2): 143-145.

 *Journal of Public Health Policy (2012) 33, 285–286. doi:10.1057/jphp.2012.25