Tuesday, May 26, 2015

Timothy Lytton on the role of litigation in constructive food safety policy

In this recent video interview with Food Safety News, legal scholar Timothy Lytton envisions a more constructive role for litigation in the next stages of development in food safety policy.

Lytton, previously the author of Kosher, describes the three main systems in food safety as (1) regulation, (2) private sector supply chain management, and (3) the liability system (or the tort system). He points out that engagement between regulators and industry supply chain managers has in some ways become more respectful and mutually beneficial. He sees potential in a similar conversation about the role of litigation in food safety policy, including industry managers, the tort system, and insurers at the table.

This topic needed a readable systematic summary. I look forward to Lytton's forthcoming book: Outbreak: the Evolution of the U.S. Food Safety System.

Saturday, May 09, 2015

What crops to grow in California?

In drought-ridden California, 80% of managed water supplies are used for agriculture.

You might think that California must consider severe cuts in agricultural production to conserve water. That would be painful, because agriculture is important to California. Just for starters, think of all the farmers and farm-workers whose livelihoods depend on agriculture.

Fortunately, it would be possible for California to reduce water use by a lot while reducing total agriculture production by just a little.

A new brief (.pdf) from Heather Cooley at the Pacific Institute has two highly relevant figures.

Figure 2 shows that alfalfa is responsible for the most total water use (5.2 million acre-feet). Rice (ranked fourth) and corn (ranked sixth) are also major drinkers of total water.

Figure 2. Applied Water for California Crops in 2010. Source: Cooley (2015). Data: CA Department of Water Resources.

Figure 5 shows that these same three crops -- alfalfa, rice, and corn -- offer the lowest agricultural value per unit of water consumed ($ per acre-foot).

Figure 5. Economic Productivity of Water in 2010 for Select Crops Grown in California. Source: Cooley (2015). Data: CA Department of Water Resources.

Though Cooley's accompanying narrative makes the point exceedingly gently, this report has an important implication. If California agriculture reduced water use in alfalfa, rice, and corn by a large volume (in millions of acre-feet statewide), the value of agricultural production in California would fall by a comparatively small amount (in millions of dollars statewide). Alfalfa and corn are important animal feeds in California, so this change would require dairies and meat producers to bring in feed from other states, or reduce their own production. Yet, that could make more sense than growing water-intensive animal feeds in a dry state.

How could California reduce the assignment of water to alfalfa, rice, and corn? Having some type of government board make the change would be highly controversial. It makes more sense for the state to remove policies that allow these crop producers to claim water at far below its proper economic cost. These three crops would not disappear from California (certainly not!), but this sensible policy change would reduce production in these three crops to a degree.

If there were unlimited water, we would not need to make difficult choices. But there is not enough water, and hard choices are required. For California, reducing total water for alfalfa, rice, and corn seems like one of the least painful approaches.

Thursday, April 23, 2015

Making a living as a farmer?

In a commentary titled, "A Farmer's Double Life," in the new edition of Tufts Nutrition, my Friedman School colleagues Jennifer Hashley and Samuel Anderson reflect on whether it is right or wrong that most small farmers also rely on off-farm income.

They discuss the experience of farmers they met through the New Entry Sustainable Farming Project at Tufts:
While they’d love to scale up to be full-time farmers someday, they know that it will take years to reach that point. In the meantime, they need to keep an off-farm job in order to maintain a livelihood, like the two New Entry graduates who farm their leased land but also work 30 or more hours a week as certified nursing assistants. Many may not have full-time farming income as a goal in the first place, instead seeking to farm parttime for supplementary income and to contribute to their local food system. Perhaps the American small-scale farmer is most often a part-time farmer—but is that necessarily a problem?
The commentary reminded me of a tweet this week, torn between desire to encourage young people in farming and concern about the dubious income prospects.
As always, it's useful to bring some real numbers into the discussion. It is widely recognized that national average farm income statistics can be misinterpreted, because they intermingle such diverse farms of all sizes. Fortunately, USDA provides a helpful typology.
  • Residence farms: Farms with less than $350,000 in gross cash farm income and where the principal operator is either retired or has a primary occupation other than farming.  
  • Intermediate farms: Farms with less than $350,000 in gross cash farm income and a principal operator whose primary occupation is farming.
  • Commercial farms: Farms with $350,000 or more gross cash farm income and nonfamily farms. 
In my rough summary of the USDA data using this typology: (a) "residence farmers" get by with non-farm income, (b) "intermediate farms" with annual farm revenue less than $350k have it most rough, and (c) "commercial farms" with annual farm revenue greater than $350k do well with farm income.

Somewhat in the spirit of Hashley and Anderson's commentary, I find this income table realistic rather than highly distressing. Many small farmers may find they need off-farm income to get by. If you want to go into farming full-time -- whether organic, conventional, or something in between -- it is good to contemplate your capacity for reaching close to the commercial scale in the third column.

Friday, April 17, 2015

Let's call these ingredients "Sometimes Considered as Mostly Safe" (SCAMS)

New reports by the Center for Public Integrity and the Center for Science in the Public Interest suggest that some food ingredients have been falling through the cracks, with nobody in authority confirming that they are safe [slight edit 4/21].

By law, the federal government has long accepted food ingredients that are "Generally Recognized as Safe" (GRAS), without the need for elaborate testing. For example, GRAS rightly allows long-accepted ingredients such as vinegar to be used without unnecessary testing procedures.

The new reports note many examples where ingredients that are classified as GRAS have been allergenic, have been suspected of being carcinogens, or never were submitted for FDA review (becuase such review is sometimes optional). In some cases, ingredients were submitted for FDA review for consideration as GRAS, and then withdrawn because FDA had questions, but these ingredients ended up in the food supply anyway.

The Center for Public Integrity writes:
Critics of the system say the biggest concern, however, is that companies regularly introduce new additives without ever informing the FDA. That means people are consuming foods with added flavors, preservatives and other ingredients that are not at all reviewed by regulators for immediate dangers or long-term health effects.
Overall, most food safety officials with the companies involved quite probably are mostly confident the food ingredients are safe for most people (especially those without allergies), and felt it would be overkill to subject the ingredients to a large volume of testing. In most cases, the companies probably are correct.

In such cases, though, let's stop calling such food ingredients "GRAS." From now on, more truthfully, let's call new ingredients that lack FDA review: Sometimes Considered as Mostly Safe " (SCAMS).

Monday, March 30, 2015

Friedman School Student Research Conference on "The Future of Food and Nutrition" (April 11)

The Friedman School's graduate student-organized research conference on "The Future of Food and Nutrition" will take place here in Boston on April 11 (registration here).

In addition to the excellent student research program, this annual event has particularly notable speakers this year. The topic is especially timely in light of the new Dietary Guidelines Advisory Committee report, which for the first time discussed sustainability issues along with nutrition issues.

I look forward to moderating the plenary discussion panel:
We are excited to announce that this year’s keynote speaker is Angie Tagtow, Executive Director of the Center for Nutrition Policy and Promotion at USDA. Her talk is titled “Nutrition Policy at a Crossroads: Application and Evolution of the Dietary Guidelines for Americans”. We will also have a panel discussionfocused on sustainable diets and implications for dietary guidance in the US. Our panelists include Dr. Miriam Nelson (Member, 2015 DGAC), Dr. Andrew Rosenberg (Director, Center for Science and Democracy, Union of Concerned Scientists) and Julia Pon (Director, Double Value Coupon Program, Wholesome Wave).

Wednesday, March 18, 2015

Dietitians encourage the Academy of Nutrition and Dietetics (AND) to "Repeal the Seal"

The Academy of Nutrition and Dietetics (AND), the professional association for registered dietitians, generated plenty of unfavorable attention this month when it permitted Kraft Singles (a processed cheese-like product) to be the first food product to carry the "Kids Eat Right" logo.

The arrangement adds fuel to long-standing concerns that the academy is too cozy with corporate sponsors.

There has been ferociously skeptical coverage by John Stewart, Marion Nestle, and even Fox News.

The AND argues that the logo and slogan "Kids Eat Right" were never intended as an endorsement of Kraft's product. Rather, the right to use the logo and slogan is a way of gratefully acknowledging Kraft's financial support for the Academy's work. The Fox News story quoted the Academy's statement:
Kraft is putting the 'Kids Eat Right' logo [on its packaging and] saying Kraft is a proud supporter of Kids Eat Right, not vice versa. The Academy has never endorsed any product, brand or service, and we never will.
Still, I find it hard to believe the Academy really failed to understand that the logo and slogan on the product package would be a valuable marketing asset for Kraft, on a product with no particular nutritional merit relative to many others (fresh fruits and vegetables, for example).

An active movement of dietitians, including the Hunger and Environmental Nutrition (HEN) working group and Dietitians for Professional Integrity, has been seeking to reform the professional association (sentence edited 4:45pm). Some dietitians have circulated a petition at change.org. If you are a registered dietitian, consider whether the petition deserves your support.

Tuesday, March 17, 2015

Even the beef checkoff program links environmental sustainability and dietary guidance

Should the Dietary Guidelines for Americans address environmental sustainability issues?

The Dietary Guidelines Advisory Committee (DGAC) report earlier this year included these issues in its executive summary, giving them far higher profile than they ever previously have had in the nation's most august dietary guidance process. The federal government uses this DGAC report as one input into the official guidelines, which will be released later this year.

Here is the sober and sensible passage of the DGAC report that generates all the fuss:
The major findings regarding sustainable diets were that a diet higher in plant-based foods, such as vegetables, fruits, whole grains, legumes, nuts, and seeds, and lower in calories and animal based foods is more health promoting and is associated with less environmental impact than is the current U.S. diet. This pattern of eating can be achieved through a variety of dietary patterns, including the Healthy U.S.-style Pattern, the Healthy Mediterranean-style Pattern, and the Healthy Vegetarian Pattern. All of these dietary patterns are aligned with lower environmental impacts and provide options that can be adopted by the U.S. population. Current evidence shows that the average U.S. diet has a larger environmental impact in terms of increased greenhouse gas emissions, land use, water use, and energy use, compared to the above dietary patterns. This is because the current U.S. population intake of animal-based foods is higher and plant-based foods are lower, than proposed in these three dietary patterns. Of note is that no food groups need to be eliminated completely to improve sustainability outcomes over the current status.
As Dan Charles reported for NPR in December, many in Congress are furious. More recently, Mike Hamm from Michigan State, who served as a consultant to the DGAC, summarized much of the controversy after the report's release.

One of the great things about the U.S. process of developing dietary guidelines is that the public comments are transparent. The DGAC report is generating thousands of comments from supporters and opponents alike.

For example, here is an excerpt from comment #1234, enraged about the inclusion of sustainability issues:
Are you crazy? This is supposed to be a free America - now you want to tell us what to eat, how to eat, how much tv to watch (what about the case of my husband who is disabled - television gives him something to do, yet you want to limit that??

I believe this goes too, too far, especially where you want us to limit meat due to climate sustainability. Climate change, global warming - whatever you have been told to call it so that low-info Americans believe whatever garbage you feed them - is made up. We all know it. Even the UN admitted it is for economic reasons to get rid of a capitalistic society and become socialist which has been proven time and time again to NOT work.
But, is it really so crazy to link sustainability and dietary guidance?

Here is part of comment #3359 from Kim Stackhouse with the federal government's beef checkoff program (the semi-public producer board that promotes increased beef consumption):
Ensuring a sustainable food supply is undoubtedly one of the greatest societal challenges we face. By 2050, we will need to produce 70 percent more food than we do today in order to feed the growing population.

Ensuring a sustainable food supply requires balancing efficient agricultural production with environmental, social and economic impacts. Only by looking holistically at food production practices can our food systems meet demand and minimize unintended consequences. The beef industry recognizes the important role it plays to produce food in a more sustainable manner and has committed to a journey toward more sustainable beef.
Setting aside the selective summary of the actual environmental evidence, these public comments are striking. Even the beef checkoff program acknowledges the value of "looking holistically at food production practices."

There is no doubt that Americans will be discussing environmental sustainability and dietary guidance together -- jointly -- for decades to come. In writing the Dietary Guidelines for Americans, the federal health and agriculture departments may help clarify the evidence, or they may ignore the issue that everybody is thinking about. If they stick their heads in the sand, the public will just turn elsewhere for dietary guidance information that rightly considers the future of the environment.