Questions of science abound, public is clueless, yet USDA seeks ‘public comments’ on labeling of lab-grown cells by Dec 2!

Posted on September 23, 2021 by Agmoos

This infographic is an oversimplified laboratory depiction of the ‘cell cultured meat’ process. On Sept. 3, 2021, USDA Food Safety and Inspection Service (FSIS), which will oversee its harvest, processing, packaging and labeling, announced proposed label rulemaking and a 60-day comment period (NOW extended to Dec. 2, 2021) to prepare for market entry. FDA will oversee the sourcing, collection and growing of this un-natural protein process. These products are expected to hit the U.S. market in 2022 and we might not know if they are included as extenders or replacements if labeling is poor. *Istock image*

UPDATE: The comment period at the Federal Register has been extended an additional 30 days to December 2, 2021

By Sherry Bunting, Farmshine series

WASHINGTON, D.C. — How should ‘cell cultured meats’ be labeled? That’s a loaded question considering how many unknowns surround the commercial production of these lab-grown lookalikes — starting with what are they, really?

USDA Food Safety and Inspection Service (FSIS) announced a 60-day comment period as part of its advance notice of proposed rulemaking in the Federal Register Friday, Sept. 3. The agency seeks “specific types of comments and information that will inform the process of developing labeling regulations for meat and poultry products made using animal cell culture technology.”

Comments are now due by Dec. 2, 2021 and must reference Docket FSIS-2020-0036.

They can be submitted directly here or by going online at the Federal eRulemaking Portal at https://www.regulations.gov and following the on-line instructions; or mail comments to Docket Clerk, U.S. Department of Agriculture, Food Safety and Inspection Service, 1400 Independence Avenue SW, Mailstop 3768, Washington DC 20250-3700.

In a press release, FSIS officials said ‘cell culture meat’ is a terminology the federal agencies use internally, but this is not necessarily the nomenclature to be used in consumer product labeling.

The actual Federal Register notice is lengthy, explaining that the labels for cell culture products fall under FSIS jurisdiction and “will be subject to premarket review under the same process as other special statements or claims. This will ensure that labeling for products developed using cell culture technology are not false or misleading, that labeling requirements are applied consistently as these novel products enter the marketplace, and that the label provides the necessary product information for consumers to make informed purchasing decisions.”

To-date, FSIS has already provided for a “generic approval” of labeling features, statements, and claims based on “demonstrated prevalent industry understanding of the effective application of those features, statements, or claims and consumer understanding of labeling statements.”

However, the document also notes that there is currently “no widespread industry understanding of the labeling requirements for cell cultured meat and poultry products” and that “consumers have not yet had experience reading these types of labels.”

Furthermore, FSIS will have to determine a process for approving additional claims on the labels of these new and combined products.

The docket language suggests that FSIS already considers these proteins analogous as derivatives of the animals from which the original cells are sourced. But are they? Even scientists debate this assumption.

As billionaire-invested startups have joint-ventured with some of the world’s largest food processing companies, much money is being thrown at certain technology hurdles to avoid having to explain the unsavory aspects of the cell culture process to the public — as these lab-grown un-natural proteins inch their way closer to commercial market entry, especially on boneless products like ground beef and chicken tenders and patties.

The label rulemaking step comes two years after the FDA and USDA entered into a joint agreement to each take responsibility for different halves of the ‘cell culture’ process.

The March 2019 agreement came after a summer 2018 public meeting previously reported in Farmshine, for which thousands of comments and two petitions have been logged.

In 2018, the U.S. Cattlemen’s Association (USCA) filed a petition requesting that FSIS limit the definition of ‘‘beef’’ to products derived from cattle born, raised, and harvested in the traditional manner, and thereby prohibit foods comprised of or containing cultured animal cells from being labeled as ‘‘beef.’’ The petition similarly requested the same for the definition of “meat” and other common meat terms on labels.

In 2020, FSIS received a petition from the Harvard Law School Animal Law and Policy Clinic requesting adoption of a labeling approach that “respects First Amendment commercial speech protections” and specifically establishes “a labeling approach that does not require new standards of identity and does not ban the use of common or usual meat or poultry terms.”

This came after over 6000 comments were received on the U.S. Cattlemen’s petition.

In the current rulemaking docket, FSIS states that the comments came from trade associations, consumer advocacy groups, businesses operating in the meat, poultry, and cultured food product markets, and consumers with “most comments opposing the (cattlemen’s) petition overall; however, nearly all generally agreed that cultured meat and beef should be labeled in a manner that indicates how it was produced and differentiates it from slaughtered meat products.”

To some, that kind of interpretation would mean ‘cultured beef without the cow’; to others a better definition would be ‘un-natural beef grown from gene-edited, growth-hormone-promoted laboratory cell cultures.’

Here’s the problem. The lengthy Federal Register docket does very little to explain the real process by which cell cultured un-natural protein is designed and grown before it is harvested, processed and packaged.

The docket includes a description of ‘cell culture’ meat and poultry that fails to specify any of the characteristics, even those that are being questioned by experts in science journals – things that consumers should know and understand via crystal-clear differentiation.

For example, cell culture fake-meat comes from stem cells that are identified and separated from muscle tissue of cattle, pigs, poultry and certain fish. New “continuous cell lines” are being developed from these stem cells using “transformation” processes (gene editing) to make them “immortal.”

In other words, cells normally have a finite end to their growth, but continuous cell lines — under the right controlled environments — are ‘designed’ to keep dividing and growing, continuously, like a malignancy, without an end point.

Also, the ‘growth medium’ for these ‘cell cultures’ contains Fetal Bovine Serum (FBS), growth promoting hormones, and, when needed, antibiotics and fungicides. The controlled environment provides the exchange of oxygen and carbon dioxide akin to animal respiration, and the temperature must be warmed constantly to be the internal temperature of the bovine to keep the cells from dying. At a certain juncture in the process, the growing cells must be ‘fed’ amino acids and carbohydrates.

Reviews of chemical replacements for Fetal Bovine Serum (FBS) are mixed. Some showed the continuation of cell growth was not consistent. Others showed changes happened within the cells when the growth medium included artificial replacements for the FBS. Portions of the veterinary and medical industries also rely on FBS for culturing, and some reports indicate increased importation of FBS, already, for those uses.

Any label claims about nutrition, environmental footprint, possible changes to the actual cells due to the composition of the growth medium, and so forth, are all based on smaller-scale laboratory observation and scale speculation, while consumers have literally zero understanding of the process, and some scientists even question whether the nutrition profiles, taste and texture are similar enough to meet consumer expectations for real meat and poultry.

These are standards of identity issues.

Here’s the other key issue for USDA’s rulemaking on ‘cell cultured meat’ labeling… USDA Food Safety and Inspection Service (FSIS) only regulates the back half of the equation. In March 2019, the agreement between USDA and FDA was to “jointly oversee the production of human food products made using animal cell culture technology and derived from the cells of livestock and poultry to ensure that such products brought to market are safe, unadulterated and truthfully labeled.”

Specifically, this agreement delegates the oversight of cell collection, growth and differentiation to the Food and Drug Administration (FDA). Then, at the stage of “harvest” FDA transfers oversight to USDA’s FSIS, which oversees the cell harvest, processing, packaging and labeling of the products.

According to the FSIS rulemaking notice, the agency believes its current food safety and HACCP systems for real meat and poultry are already “sufficient” to be “immediately applied” to the harvest, processing and packaging of these lab-grown lookalikes and that they are only looking at this final labeling piece. This gives us a clue where the labeling is headed.

Specifically, FSIS seeks comments and information from stakeholders over the next 60 days regarding these key areas of the labeling process:

— Consumer expectations about the labeling of these products, especially in light of the nutritional composition and organoleptic qualities (taste, color, odor, or texture) of the products;

— Names for these products that would be neither false nor misleading;

— Economic data; and

— Any consumer research related to labeling nomenclature for products made using animal cell culture technology.

It will be difficult for true consumer advocacy groups (not meat and poultry industry trade groups who are mostly on board for the mix-and-match) to fully consider their views on the above questions. This is further blurred by the oversimplified FSIS description of the cell culture process that does not include any reference to specific characteristics.

For example, the definition does not mention hormones as inputs, it mentions ‘growth factors’. It doesn’t talk about continuously dividing cell lines, but rather ‘creating food’.

In another section, it doesn’t mention FBS, hormones, antibiotics as inputs but rather simply states: “cells are retrieved and placed in a controlled environment with appropriate nutrients and ‘other factors to support growth’ and cellular multiplication. After the cells have multiplied, ‘additional inputs such as growth factors,’ new surfaces for cell attachment, and additional nutrients are added to the controlled environment to enable the cells to differentiate into various cell types.”

The use of innocent code words belie the specifics.

Of course, states FSIS about the process: “Once produced, the harvested cells can be processed, packaged, and marketed in the same, or similar, manner as slaughtered meat and poultry products.”

Nowhere in this description does it mention the gene editing of the cells to get them to transform for continuous multiplication and growth, nor what evidence exists that consuming such cells is safe. Consumers will want to know what they might be consuming once the world’s largest meat processors begin to use cultured cells as real meat extenders, diluters and substitutes.

Nowhere in this description does it mention the hormones and growth promotants that are the necessary “growth factor inputs” because the cells are growing on their own without the animal’s body, designed by God, to provide the natural hormones for natural growth with natural end points.

Nowhere in this description does the docket mention other clear differences between ‘cell cultured’ un-natural protein vs. real natural meat and poultry. The description suggests they are ‘designer’ derivatives of the real thing, opening the door to claims of being more efficient with less environmental impact. Based on what? A reduction in cattle and other livestock numbers?

Like we’ve seen in dairy with plant-based fakes and lack of standards enforcement by FDA, these ‘novel’ products will get to do the more-than / less-than comparative marketing off the real natural standard while consumers assume all other aspects are equal – when clearly they are not.

Scientific journals such as Frontiers in Nutrition have published scholarly articles pointing out the speculation involved in what this process will look like at commercial scale and what impact it will have on the nutrient characteristics, especially micronutrients like iron and B12, that come from the animal’s interaction with its natural environment. (Even the scaffolds the cells grow on will have methods for stretching cell blobs to simulate movement.)

Some scholarly articles point out that even the environmental claims are suspect because land and water use comparisons for cattle are predominantly what is used in feed production. The lab-grown cell cultures will also have to be “fed”. But they won’t spend part of their ‘lifecycle’ grooming carbon-sequestering grasslands or contributing to planet health in the biogenic carbon cycle.

Furthermore, writes one scientist, the warming required for these cell cultures to grow in bioreactors also create CO2 emissions that are long-lived — potentially adding to the buildup of long-term GHG, whereas the methane emitted from real cattle is short-lived and in fact stable and declining when viewed on a total nutrients per animal basis vs. history. This means, what is seen as a reduction in CO2 equivalents for methane based on the short-term heat-trapping side could be more than lost on the long-term CO2 buildup side, a tough fix down the road.

The problem with climate and environmental label claims is that they are based on speculation about unknowns for un-natural cell culture proteins and are compared to only part of the real story about real natural livestock.

All of these unanswered questions should be part of any USDA FSIS rulemaking process on labeling. These proteins should be labeled as ‘experimental’ and ‘un-natural’ until processes are widely known and understood by scientists, agencies, industry and consumers.

In the Sept. 2 press release, USDA Deputy Under Secretary for Food Safety, Sandra Eskin, states that, “The (proposed rulemaking) is an important step forward in ensuring the appropriate labeling of meat and poultry products made using animal cell culture technology. We want to hear from stakeholders and will consider their comments as we work on a proposed regulation for labeling these products.”

Perhaps what USDA needs to hear from commenters over the next 60 days is that there is not enough public information about how these un-natural proteins are sourced, grown, and gene-edited — or their true nutritional and environmental profiles — to call them beef or meat with a simple qualifying statement few will truly understand.

Proponents of labeling cell culture proteins as meat because the cells are derivative are already whining to FSIS about how new labeling procedures or standards of identity would “stifle innovation.”

Individuals, businesses and organizations should be standing up for the consumer’s right to know what they are consuming and what production processes they are supporting – un-natural cell factories or natural meat raised by farmers and ranchers. There are also consumer health and nutrition questions on the FDA front end that the labeling needs to address accurately on the FSIS back end.

Just because the initial cells come from a cow or a chicken or a pig, doesn’t mean the un-natural ‘culturing’ process and resulting blobs of cells, once consumed, will behave in our bodies like — or contain the same properties as — natural muscle meat from a cow or a chicken or a pig.

Processors will be able to swap a percentage of this for that and barely change their labels if new standards or full descriptions are not used.

Labeling should not give the appearance that this is simply meat without the animal. Some would argue this is Frankenfood. Some would argue this is experimental protein that should have to go through rigorous safety tests on the long-term impacts to health and nutrition. But the climate urgency of the United Nations Food Summit this month is already alluding to fast-tracking these “innovations”, applauding Singapore and China for moving forward most aggressively… to save the planet of course.

Perhaps the question to ask is this: How will labeling clearly differentiate so consumers have a clear choice and farmers and ranchers have a real chance…

The dairy industry is facing this music on its own score with the FDA currently evaluating standards of identity for milk and dairy and looking at the new bovine DNA-altered yeast/fungi/bacteria excrement posing as dairy protein analogs without the cow. Through a process that is in some ways different and in other ways similar to cell culture proteins, the bioengineered yeast excrements are being called “designer proteins from precision fermentation.”

The latest marketing twist is to say the bioengineered yeast are “10 to 20 times more efficient feed converters than cows.” These proteins are already being marketed to global processors of dairy foods as ‘stretchers’ and ‘functional’ ingredients, even as ‘carbon footprint enhancers.’

The economic concern for producers on both counts – meat and dairy – is dilution of their products and captive supply price-control of their ‘markets’.

The concern for consumers is the long-term healthfulness and safety of these ingredients and the increased potential for global food control in the hands of a few, with China already figuring prominently in the protein concentration manufacturing industry, globally.

This labeling discussion is too important to ignore, too important to allow oversimplification. Some in the industry say we must encourage and work beside these new forms of food production to end hunger, control climate change and feed everyone in the future. But the foundation premises of these beliefs are not settled science.

The simple play here, by the tech sector to align and dominate the food industry, is to position these un-natural proteins as helpful analogs grown or cultured or fermented without the animals, that these products are needed to supplement animal-sources and reduce environmental impact of livestock, that climate change urgency requires regulatory fast-tracking, and that simple process-qualifiers on a label will differentiate it while making it palatable to consumers.

Will consumers be led to believe these “innovations” are in all other ways the same as the real thing… when in fact they are not?

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FOOD FIGHT: USDA, Scholastic join billionaire-invested brand-marketing of ‘fakes’ in school meals, curriculum

Posted on July 9, 2021 by Agmoos

The cover story of a recent Junior Scholastic Weekly Reader — the social studies magazine for elementary school students — was dated for school distribution May 11, 2021, the same week USDA approved a Child Nutrition Label for Impossible Burger and released its Impossible Kids Rule report. This label approval now allows the fake burger to be served in place of ground beef in school meals and be eligible for taxpayer-funded reimbursement. Meanwhile, Scholastic Weekly Reader and other school ‘curricula’ pave the marketing runway with stories incorrectly deeming cows as water-pigs, land-hogs, and huge greenhouse gas emitters, without giving the context of true environmental science.

Is USDA complicit? Or ring-leader? One Senator objects

By Sherry Bunting

WASHINGTON – It’s appalling. Bad enough that the brand of fake meat that has set a goal to end animal agriculture has been approved for school menus, fake facts (brand marketing) about cows and climate are making their way to school curriculum as well. The new climate-brand edu-marketing, and USDA has joined the show.

“Schools not only play a role in shaping children’s dietary patterns, they play an important role in providing early education about climate change and its root causes,” said Impossible Foods CEO Pat Brown in a May 11 statement after Impossible Meats received the coveted USDA Child Nutrition Label. “We are thrilled to be partnering with K-12 school districts across the country to lower barriers to access our plant-based meat for this change-making generation.”

U.S. Senator Joni Ernst (R-Iowa), who was born and raised on a rural Iowa family farm, has called on U.S. Agriculture Secretary Tom Vilsack to ensure students will continue to have access to healthy meat options at schools. The Senator’s letter to the Secretary asked that USDA keep political statements disincentivizing meat consumption out of our taxpayer-funded school nutrition programs.

Food transformation efforts are ramping up. These are political statements where cows and climate are concerned, not backed by science, but rather marketing campaigns to sell billionaire-invested fake foods designed to replace animals. (World Wildlife Fund, the dairy and beef checkoff sustainability partner, figures into this quite prominently.)

As previously reported in Farmshine, Impossible Foods announced on May 11 that it had secured the coveted Child Nutrition Label (CN Label) from the USDA. The food crediting statements provide federal meal guidance to schools across the country. The CN label also makes this imitation meat eligible for national school lunch funding.

“This represents a milestone for entering the K-12 market,” the CEO Brown stated, adding that the use of their fake-burger in schools could translate to “huge environmental savings.” (actually, it’s more accurate to say it will translate to huge cash in billionaire investor pockets.)

Concerned about ‘political statements’ made by USDA and others surrounding the CN label approval — along with past USDA activity on ‘Meatless Mondays’ initiated by Vilsack’s USDA during the Obama-Biden administration — Sen. Ernst wrote in her letter to now-again current Sec. Vilsack: “School nutrition programs should be exempt from political statements dictating students’ dietary options. Programs like ‘Meatless Monday’ and other efforts to undermine meat as a healthy, safe and environmentally responsible choice hurt our agriculture industry and impact the families, farmers, and ranchers of rural states that feed our nation.”

No public information has been found on how Impossible Foods may or may not have altered its fake-burger for school use. My request for a copy of the Child Nutrition Label from USDA AMS Food Nutrition Services, which granted the label, were met with resistance.

Here is the response to my request from USDA AMS FNS: “This office is responsible for the approval of the CN logo on product packaging. In general, the CN labeling office does not provide copies of product labels. This office usually suggests you contact the manufacturer directly for more information.”

I reached out to Impossible for a copy of the nutrition details for the school product. No response.

It’s obvious the commercial label for Impossible is light years away from meeting three big ‘nutrition’ items regulated by USDA AMS FNS. They are: Saturated Fat, Sodium, and Calories.

As it stands now, the nutrition label at Impossible Foods’ website shows that a 4-oz Impossible Burger contains 8 grams of saturated fat. That’s 3 more grams than an 8-oz cup of Whole Milk, which is forbidden in schools because of its saturated fat content. The Impossible Burger also has more saturated fat than an 85/15 lean/fat 4-oz All Beef Burger (7g).

Sodium of Impossible Burger’s 4-oz patty is 370mg! This compares to an All Beef at 75g and a McDonald’s Quarter-pounder (with condiments) at 210 mg. Whole Milk has 120 mg sodium and is banned from schools.

The Impossible Burger 4-oz. patty also has more calories than an All Beef patty and more calories than an 8 ounce cup of Whole Milk. But there’s the ticket. USDA is hung up on percent of calories from fat. If the meal is predominantly Impossible Burger, then the saturated fat (more grams) become a smaller percent of total calories when the fake burger has way more calories! Clever.

In her letter to Vilsack, Sen. Ernst observes that, “Animal proteins ensure students have a healthy diet that allows them to develop and perform their best in school. Real meat, eggs, and dairy are the best natural sources of high quality, complete protein according to Dr. Ruth MacDonald, chair of the Department of Food Science & Human Nutrition at Iowa State University. Meat, eggs, and dairy provide essential amino acids that are simply not present in plants. They are also natural sources of Vitamin B12, which promotes brain development in children, and zinc, which helps the immune system function properly.”

She’s right. A recent Duke University study goes behind the curtain to show the real nutritional comparisons, the fake stuff is not at all nutritionally equivalent. But USDA will allow our kids to continue to be guinea pigs.

In May, Ernst introduced legislation — called the TASTEE Act — that would prohibit federal agencies from establishing policies that ban serving meat. She’s looking ahead. Sen. Ernst is unfortunately the only sponsor for this under-reported legislation to-date.

Meanwhile, within days of the Impossible CN approval from USDA, school foodservice directors reported being bombarded with messaging from the school nutrition organizations and foodservice companies, especially the big one — Sodexo — urging methods and recipes to reduce their meal-serving carbon footprint by using less beef for environmental reasons, and to begin incorporating the approved Impossible.

The Junior Scholastic Weekly Reader for public school students across the nation — dated May 11, the same day as the USDA CN Label approval for ‘Impossible Burger’ — ran a cover story headlined “This burger could help the planet” followed by these words in smaller type: “Producing beef takes a serious toll on the environment. Could growing meat in a lab be part of the solution?”

The story inside the May 11 scholastic magazine began with the title: “This meat could save the planet” and was illustrated with what looked like a package of ground beef, emblazoned with the words: “Fake Meat.”

Impossible Foods is blunt. They say they are targeting children with school-system science and social studies (marketing disguised as curriculum) — calling the climate knowledge of kids “the missing piece.”

In the company’s “Impossible Kids Rule” report, they identify kids as the target consumer for their products, and how to get them to give up real meat and dairy.

Toward the end of the report is this excerpt:“THE MISSING PIECE: While most kids are aware of climate change, care about the issues, and feel empowered to do something about it, many aren’t fully aware of the key factors contributing to it. In one study, 84% of the surveyed young people agreed they needed more information to prevent climate change. Of the 1,200 kids we surveyed, most are used to eating meat every week—99% of kids eat animal meat at least once a month, and 97% eat meat at least once a week. Without understanding the connection between animal agriculture and climate change, it’s easy to see why there has been so little action historically on their parts. Kids are unlikely to identify animal agriculture as a key climate threat because they often don’t know that it is. Similar to adults, when we asked kids what factors they thought contributed to climate change, raising animals for meat and dairy was at the bottom by nearly 30 points.“

After showing the impressionable children Impossible marketing, they saw a big change in those “awareness” percentages and noted that teachers and schools would be the largest influencers to bring “planet and plate” together in the minds of children, concluding the report with these words:

“When kids are educated on the connection between plate and planet
and presented with a delicious solution, they’re ready to make a change. And adults might just follow their lead,” the Impossible Kids Rule report said.

USDA is right with them, piloting Impossible Burger at five large schools using the Impossible brand name to replace ground beef with fake meat in spaghetti sauce, tacos and other highlighted meals. This allows brand marketing associated with the name — free advertising to the next generation disguised as “climate friendly” options with marketing messages cleverly disguised as “education.”

In the New York City school system, one of the pilot schools for Impossible, new guidelines are currently being developed to climate-document foods and beverages served in the schools.

Impossible doesn’t have a dairy product yet, but the company says it is working on them.

Impossible’s competitor Beyond Meat is also working on plant-based protein beverages with PepsiCo in the PLANeT Partnership the two companies forged in January 2021. PepsiCo is the largest consumer packaged goods company globally and has its own K-12 Foodservice company distributing “USDA-compliant” beverages, meals and snacks for schools.

How can this brand-marketing in school meals be legal? Dairy farmers pay millions to be in the schools with programs like FUTP60 and are not allowed to “market”. In fact, dairy checkoff leaders recently admitted they have a 12-year “commitment” to USDA to “advance” the low-fat / fat-free Dietary Guidelines in schools, top to bottom, not just the dairy portion.

Pepsico has a long history of meal and beverage brand-linking in schools. Working with Beyond, they will assuredly be next on the Child Nutrition alternative protein label to hit our kids’ USDA-controlled meals.

Like many things that have been evolving incrementally — now kicking into warp speed ahead of the September 2021 United Nations Food System Transformation Summit — the taxpayer-funded school lunch program administrated by USDA is a huge gateway for these companies. Ultimately, will parents and children know what is being consumed or offered? Who will choose? Who will balance the ‘edu-marketing’? Will school boards and foodservice directors eventually even have a choice as huge global companies mix and match proteins and market meal kits that are guaranteed to be USDA-compliant… for climate?

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Producers seek checkoff vote and transparency as fake food transformation ramps up

Posted on May 27, 2021 by Agmoos

Mike Eby introduces Karina Jones who spoke to attendees live and virtually about the beef checkoff referendum petition. Jones was part of a panel of speakers on various topics during the daylong “Empowering Dairy Farmers” barn meeting at Eby’s farm in Lancaster County, PA on April 23.

By Sherry Bunting, Farmshine, May 14, 2021

GORDONVILLE, Pa. – “Beef it’s what’s for dinner.” Remember that line?

For school kids, it could soon be Impossible Meat for lunch. USDA just approved a nutrition label for K-12 schools to substitute beef with the billionaire-invested Impossible Meat. Never mind that a May 2020 Newsweek article reported Beyond Meat, Impossible Meat and their competitors source most of their concentrated pea- and soy-protein from extrusion factories in China, even if the crops were grown in North America.

School foodservice directors report a barrage of supply-chain influencers touting fake meat meal options to reduce carbon emissions on the heels of the USDA nutrition label approval.

A local restaurant discovered last month that their wholesale food vendor added textured vegetable protein (concentrated soy and other additives) to the wholesale ‘Classic Beef Burger’ without warning. It is apparently part of a ‘cutting edge’ menu remake at the wholesale level – not the restaurant’s choice. (This particular restaurant switched promptly to Certified Angus burgers guaranteed to remain 100% beef).

Children came home from school this week with Junior Scholastics declaring “This meat could help save the planet!” accompanied by a photo of fake-beef in grocery packaging.

Junior Scholastic Weekly Reader came out with this story urging kids to eat less beef, just a week before USDA’s announcement this month (May 2021) of approval for the ‘Impossible Meat’ school lunch nutrition label, ushering in the barrage of global foodservice companies hounding school foodservice directors about reducing climate change with this stuff (cha-ching, cha-ching). Companies like Cargill and Tyson that are among the big 4 in BEEF processing — with strong ties to the lobbying side of the separate NCBA / CBB — are also going big into FAKE beef. The beef and dairy checkoff programs also have strong ties to World Wildlife Fund and collect checkoff money on imported beef and dairy so this clouds their ability to use the funds they mandatorily collect from U.S. farmers to promote U.S.-produced REAL beef and dairy.

These are just a few examples in the past three weeks of how rapidly the wheels set in motion a decade ago are hitting the pavement.

How did we get here? For 12 to 13 years, the World Economic Forum (WEF), World Wildlife Fund (WWF), Big Food, Big Tech and Big Ag have been coalescing around this idea of supply-chain “sustainability” leverage to steer global food transformation with cattle clearly in the crosshairs – especially for developed nations in Europe as well as the United States.

By partnering officially and unofficially with national dairy and beef checkoff boards on “precompetitive sustainability and innovation”, for example, WWF has — in effect — been channeling government-mandated producer checkoff dollars toward implementing WWF’s supply-chain strategy for impacting commodities WWF believes need intervention to improve biodiversity, water and climate. The global corporations behind ‘food transformation’ are laughing all the way to the bank while grassroots producers essentially fund their own demise.

By partnering with dairy and beef checkoff national boards in a ‘pre-competitive’ arrangement, WWF implements its “supply-chain” leverage strategy, WWF has essentially used producer funds to implement their message and priorities both to consumers through supply chain decisions and to producers through checkoff-funded programs validating farm practices. The World Wildlife Fund in its 2012 Report “Better Production for a Living Planet” identifies this strategy to accomplish its priorities for 15 identified commodities, including dairy and beef, related to biodiversity, water and climate. Instead of trying to change the habits of 7 billion consumers or working directly with 1.5 billion producers, worldwide, WWF states that this “practical solution” is to leverage about 300 to 500 companies that control 70% of food choices. Image from 2012 WWF Report

In the 44-page 2012 paper “Better Production for a Living Planet,” the WWF Market Transformation Initiative identified dairy and beef as two of the prime commodities they target through supply-chain companies controlling 70% of food choices.

The checkoff-funded sustainability materials coming out of the National Cattlemen’s Beef Board and Dairy Management Inc (DMI) show firsthand this relationship with WWF, by the use of the WWF logo, and in the case of dairy, the acknowledgment that a decade-long memorandum of understanding existed.

Add to this the government policies emerging that align directly with this global food, agriculture and land transformation, and the use of the vehicle of checkoff-funded “government speech,” becomes a bit clearer. It’s a clever way to leverage the supply chain and promote a message to consumers while pushing producers to align.

The WWF 2012 paper explains that in 2010, “WWF convened some of the biggest players in the beef industry to form the Global Roundtable for Sustainable Beef (GRSB). They included the world’s biggest beef buyer, McDonald’s; the biggest beef retailer, Walmart; and two of the largest beef traders, JBS and Cargill.”

While dairy and beef checkoff programs use government-mandated funds collected from producers for valuable local and state promotion programs linking producers to consumers, it is the direction of national checkoff programs – engaged with WWF and the largest processors and retailers in this way — that has producers like Karina Jones, a fifth generation Nebraska cattlewoman concerned.

Jones heads up the petition drive for a producer referendum on the $1/head beef checkoff. The effort began in South Dakota and is spreading nationwide via R-CALF and other national and state organizations.

During the farmer empowerment barn meeting hosted by Mike Eby of National Dairy Producers Organization (NDPO) and Organization for Competitive Markets (OCM) at his farm in Gordonville, Pennsylvania recently, two of the day’s speakers talked about the need for transparency and accountability in mandatory checkoff programs.

Marty Irby of Organization for Competitive Markets (OCM) talked about bipartisan legislation seeking more transparency and accountability for all mandatory producer checkoff programs during the Empowering Dairy Farmers meeting last month.

Marty Irby of OCM talked about the OFF Act, which is bipartisan legislation seeking to amend the checkoff laws to reaffirm that these programs may not contract with organizations that engage in policy advocacy, conflicts of interest, or anticompetitive activities. It would require publication of all budgets and disbursement of funds for the purpose of public inspection and submit to periodic audits by the USDA Inspector General.

“It’s not about taking those promotion dollars away, but to have a just system of checks and balances,” said Irby about the proposed legislation.

But others are taking a grassroots vote approach — concerned about government oversight of what is already determined to be ‘government speech’ funded by producer checkoff.

Jones talked at the barn meeting about the massive effort to gather over 100,000 signatures by July 2021 asking USDA to conduct a nationwide Beef Checkoff Referendum. A vote on the beef checkoff has not been conducted in 35 years. (See checkoffvote.com and the paper insert in the May 14, 2021 edition of Farmshine)

“It’s time to re-check the checkoff,” said Jones about the beef petition. “We want to signal to USDA that as cattle producers we are ready to vote again.”

She explained that in order for the Secretary of Agriculture to consider a referendum request, 10% of producers must sign the petition. This includes anyone who sold a beef animal and paid the $1/head checkoff, in the 12 months from July 2020 through July 2021, including beef cow-calf producers, seedstock producers, backgrounders, cattle feeders, dairy producers, and youth showing and selling livestock.

According to the 2017 Census, 10% of the beef producers would mean 89,000 signatures needed.

“But we don’t know the vetting process the Secretary will use to approve or deny the petition request, so we want to reach over 100,000 signatures by July 2021,” said Jones.

“The cattle landscape today is much different from 35 years ago,” she said. “Our checkoff does not support promotion of American-born-and-raised beef. We want to equalize the power for the grassroots U.S. cattle producer… the power and the dollars are falling into the hands of the few.”

According to Jones, the checkoff referendum petition seeks a return to balance as well as increased transparency and accountability, through the voting process. Proponents of the right to vote believe producers should be able to fund education and promotion that takes a stand for real, USA-produced beef, something the trends and supply chain partnerships emerging today – along with “government speech” rules — make difficult.

She talked about “mavericks” who were elected to the beef board in the past and tried to change the power structure of the lobbying groups and processing industry involvement. Jones said the current structure has gone on so long — uninterrupted — that a referendum petition is the only avenue many beef producers see today as a way to bring accountability back.

“This is a call to action. Many producers are still not aware of this beef checkoff referendum petition,” said Jones as she urged producers to be bold and harness the opportunities to set a direction that changes the balance of power.

To be continued

With science-fiction, they socially herd us like cattle to ‘alternative’ squeeze chute

Posted on March 2, 2019 by Agmoos

By Sherry Bunting, Farmshine, February 22, 2019

All circles lead back to marketing, which is on display right now with the EAT Lancet report in January and the EAT Forums and social marketing that are hitting us in rapid succession, having already filtered into the Green New Deal in Washington and other legislation proposed in California.

Dr. Frank Mitloehner, a greenhouse gas (GHG) emissions expert from the University of California, Davis is not the only one questioning the GHG findings in the report.

He offered proof this week that the science director for the EAT Foundation, in an email (below), admitted the report’s dietary recommendations are not based on environmental considerations, they are based on – you guessed it – a hyper-charged version of the flawed dietary guidelines that have been making us, especially our children, fatter and sicker through ever-increasing government control of food choices!

This is a clear admission that the GHG figures being peddled are, as Mitloehner put it in Lancaster recently “without a single leg to stand on.”

This brings everything back to the common denominator in the ongoing social engineering project: USDA Dietary Guidelines.

In the pages of Farmshine for years (through two dietary guideline cycles, 10 years to be exact), we have warned about the Dietary Guidelines.

For months, we’ve sounded alarms about the genetically-altered yeast making ‘dairy without the cow’.

For weeks, we’ve been tracing the alliances of the Edelman company that has done the marketing and PR for DMI for 20 years and is also doing the social marketing and communication strategies for EAT Lancet.

That story was laid out here last week.

This week the EAT Lancet Commission’s desire for drastic reductions in meat and dairy consumption grew major legs as the Edelman social marketing machine — via staff loaned and now working as employees of EAT’s corporate initiative — have been in full artillery mode with our nation’s dairy and beef cattle in the crosshairs.

The right hand has been telling us we have a seat at the table, while the left hand has been working overtime to pull out the rug.

I’ll borrow this term: Resist! The Science Fiction EAT Lancet report is slowly but surely being spoonfed without a transparent airing in the press.

The EAT Lancet Commission had little actual press since 2019 launch, but not to worry! The global food tranformation effort (EAT Lancet, EAT FReSH) is coordinated by the world’s largest marketing and PR firm — spawning the seemingly random and unconnected legislative and marketing campaigns from the Green New Deal and new global diet ‘wisdom’ (flexitarian / reducitarian) to the outright lies about cows in foundation versions of prominent news organizations like Reuters, Bloomberg, The Economist, The Guardian and positioning of the new PepsiCo’s Quaker Oat beverage launch inprime dairy case real estate this week, to the unveiling of Danone’s new non-dairy yogurt plant in Dubois, Pennsylvania geared to “take plant-based products to the max.”

PepsiCo and Danone are two of the 41 corporate sponsors of the EAT Lancet global food transformation propaganda, and they are launching their ‘solutions’ right now. PepsiCo launched it’s Quaker Oat beverage this week, and it’s showing up prominently in dairy cases like this one. Danone unveiled the largest ‘dairy free’ yogurt plant in the world in Pennsylvania a few weeks ago, with its new ‘sustainable’ yogurt products reaching store shelves also in time to capitalize on the EAT FReSH social marketing campaign. Photo submitted by a Farmshine reader in northwest Indiana

A convergence of the elite. It’s really one big thing, connected. The funding corporations are rolling out their food ‘solutions’ as we speak, hoping unwitting consumers will jump on the food-transformation-train.

I am resisting any brand that participates in this tomfoolery.

EAT FReSH corporate sponsor Danone launched their marketing campaign for the new “dairy free” yogurt now made in Pennsylvania, and it has EAT Lancet taglines written all over it.

Of course, Danone is also a client of Edelman. So is PepsiCo.

Follow the money, folks.

Inside this high-stakes game is the world’s largest marketing and PR firm coining elite catch phrases about “eating within planetary boundaries” — you know — to save the planet, and other such “purpose-driven marketing” they are known for.

(Technically, the account director of Edelman Amsterdam planned and organized for two years as employee on assignment with the World Business Council for Sustainable Development (WBCSD), which is the organization launching the EAT FReSH initiative with the 41 corporate sponsors, including Edelman. When the EAT Lancet Report and EAT Forums did launch in mid-January 2019, Lara Luten left Edelman’s employ at that point to become the full time director of the communications and social marketing plans that have been laid).

Boil it down. The nobles are telling the serfs: Forget animal protein, ‘Eat cake!’

I’m not against dairy alternatives, they should be available. We are omnivores. Plants need animals and animals need plants and we need them both.

What I am against is global propaganda that positions itself as science and is being used to socially herd us like cattle to the plant-based chute without the integrity to tell us it’s a bridge to genetically-altered-laboratory-designer-proteins (aka fake-meat and fake-dairy) grown in vats and bioreactors.

Roughly 70% of the available land for food production is grasslands and marginal lands. It is these lands that cattle can graze or where forages for cattle are harvested in systems much different from row crops and vegetable plots.

Cows upcycle low quality feedstuffs and plant byproducts that we can’t use, and they turn it into nutrient dense, delicious milk and beef. (Those grasslands and forages sequester carbon too!!)

Animal Ag emits less than half of the total greenhouse gas emissions for all of agriculture, and if we look at this per unit of nutrition, it’s amazing.

Animal Ag (dairy, beef, pork, poultry all combined) are responsible for just 3.9% of the U.S. greenhouse gas (GHG) inventory, but EAT Lancet tells a different story, and the lies are being exposed.

Just imagine how much stress will be on our so-called “planetary boundaries” if science fiction and social purpose-driven marketing prevails and more of us are “herded” or fooled into replacing more of our animal-based dietary nutrients with plant-based sources. It can’t be done.

This is a Silicon Valley bridge to the billionaire-funded bioreactor factories to grow (3-D print) replacement protein from gene-altered yeast or gene-edited cell blobs. In fact, Microsoft founder Bill Gates was on CNN with Fareed Zakaaria Sunday talking about “cow farts being one of the world’s biggest problems” and the need for lab-cultured animal protein … to save the world. (Let’s be all the dumber for watching that interview clip here)

What Mr. Gates forgot to mention is his considerable investment in this disrupter technology of fake-meat, and that Microsoft is a corporate sponsor of EAT FReSH / EAT Foundation.

Yes, more science-fiction propaganda in the form of so-called purpose-driven marketing is coming from all sides and hyping up fast because the billionaire investors and food supply chain corporations need this social herding process to launch their new products. It’s not about people and it’s not about the planet, it’s about profit — at our expense!

No thanks here. I’m jumping the gate. The social-herders have gone too far.

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Top photo credit Michele Kunjappu

How did we get here?

Posted on February 21, 2019 by Agmoos

OPINION

By Sherry Bunting, Farmshine, Friday, February 15, 2019

It’s like whack-a-mole. So many converging things are happening rapidly related to a ‘herding’ mechanism for the masses in terms of what we will eat in the future.

Where did it all come from? How did we get here? Why is the science so flawed and against us?

What we see unfold via the EAT Lancet Commission and the Green New Deal over the past few weeks — not to mention the currently ongoing FDA and USDA deliberations on dietary guidelines and labeling for fake dairy and fake meat — has been a disaster gradually in the making.

The wheels were set in motion 10 years ago, or more, and Dairy Checkoff was at the table in more ways than one.

Trouble is, until now, no one really knew about the seat at the table, the foundations, pre-competitive environments, memorandums of understanding and so forth.

The connections, directions and alliances were unclear and clothed in happy talk about breakfast carts that put a half-pint of milk on every plate and maybe some fat-free yogurt and skim-processed cheese, excited talk about helping kids move more to lose weight, enthusiasm about putting farmers face-to-face with school children to teach them how they care for cows and environment (we all know that there are plenty of these efforts paid for by voluntary organizations and farmers themselves, FUTP60 can’t claim the ground on this part).

What we did not see, due to lack of transparency, was the deeper layers of direction where dairy farmers have, in a sense, been funding their own demise.

This is not meant to attack people in the checkoff system working with good intention on behalf of dairy farmers or our nation’s young people. This series of articles I have been involved in has been a peeling of an onion that should have been diced on the table to pass the sniff test from the beginning — but it was not.

In part one of the GENYOUth series in January, we showed the steep nosedive in fluid milk sales from 2010 to the present. There is no shortage of experts who now point to the school milk changes as precipitating this decline and in fact costing dairy farmers a whole generation of beverage decision-makers who have and are now graduated into the New World Order on “healthy diets for a healthy planet” — despite the lack of rigorous science to support either in terms of milk and meat production.

There was no transparency in which primary dairy checkoff stakeholders could question the direction as the track was greased for where we are today.

There was no transparency about alliances developed over the past 10 years — never mind the rather small detail of who paid whom for what and how many football players showed up to christen a school’s new breakfast cart. The IRS 990 figures reported in parts three and four of the GENYOUth series pale in comparison to the lack of transparency in Dairy Checkoff’s role as a participant educating and leading a whole generation of consumers, tied by an MOU to tote the government’s diet message.

There are two crossroads in front of us, and our dairy cows are standing in that intersection — mooing loudly for assistance, I might add.

Dairy Checkoff has taken the dairy industry down both roads — diet and sustainability — without transparency to its funding dairy farmers.

Now, today, these two roads are converging at regulatory, legislative, corporate, media and cow-less protein innovation levels.

And the industry is splintering over what to do about it.

This conversation is at least 10 years past-due, and it is why farmers are fragmented, why they can’t come together.

You see, the template for the future is written for some, not all.

It is written to be complicit in dietary goals that are not supported by rigorous science for our human health or our planetary health.

It has been written, in part, with money taken mandatorily under USDA oversight from dairy farmers of all types and sizes to streamline “U.S. Dairy” into the New World Order of food choices that are on the cusp of substantial change with Silicon Valley in the picture with its billionaire-funded cell and yeast cultured startup companies needing this propaganda to launch their cattle-less dairy and beef protein.

The FDA and USDA are poised to decide (and in the case of some labeling have already decided) how and IF consumers are going to be informed about what they are eating in the future.

As the deeper layers of the past 10 years of GENYOUth and Innovation Center for U.S. Dairy are revealed — with their separate memorandums of understanding (MOU’s) signed with USDA during the Obama/Vilsack era, and in ‘pre-competitive’ alliances with the world’s largest food and agriculture supply-chain companies — anyone publicly revealing or questioning the direction of checkoff on this road, is now cast as a character of division, a spoiler of profitability, a misinformed stakeholder reading the writings of a ‘yellow’ journalist.

In fact, DMI has created a secret facebook group for discussion of Dairy Checkoff questions and concerns. Participation is by invitation. Checkoff staff — hired by all dairy farmers through their mandatory checkoff dollars — are the gatekeepers, deciding who can join the group-think.

To understand where this is all leading, the crossover alliances between GENYOUth and the EAT Lancet Commission are known. (See related story here).

Dairy Checkoff is smack dab in the middle and has been for some time. That’s where you want to be if you want to influence a debate. But thus far, the direction of influence is questionable, naive and opaque at best, and has at worst created winners and losers among our nation’s dairy farmers, individually and regionally.

The global agenda unfolding right now has been years in the making. The deeper layers of the work at that table where Dairy Checkoff has had a seat — and its impact on the dairy farmers who collectively funded that seat — has been quietly pursued… until now.

Consumers have been telling us what they want: simple, flavorful, natural, real food. That’s what dairy and livestock producers do best!

But instead of marketing to that desire, instead of bolstering our consumer ranks by feeding that desire, the industry and checkoff have aligned us with government and corporate and special interests who want to shape and restrain those choices for future generations, by using our children as change agents for an agenda that has not been transparent, nor adequately discussed, by its funding stakeholders… until now.

Now, the global agenda has hit play in the public domain, and many of us are trying to find the rewind button.

Stay tuned. We’re not done.

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How will fake milk, fake meat be labeled and regulated?

Posted on December 28, 2018 by Agmoos

Say, what? New twist on standards of identity: How will fake milk and fake meat be labeled and regulated?

In a time when many people have lost their connection to the values and sustainability of the circle of life, cattle have been getting an undeserved bad rap on everything from diet to environment to compassion. On all three counts, the anti-animal agenda lies behind the false narrative that is leading us down a dishonest path to more fake concoctions of ill-fated science fueling profits at the expense of our physical and emotional health and the health of the planet. Fake meat and fake milk are funded by billionaires, genetically engineered by USDA, initiated as the brain children of Silicon Valley techies, with partnership from the biggest names in corporate agriculture. Noble goals of ending hunger are the defense, but it’s difficult to believe that when we have surplus dairy and meat protein produced naturally with the real problem of hunger coming down to distribution and waste. This so-called solution has the potential to quietly dictate food choices, markets and livelihoods.

By Sherry Bunting, updated since first published in Farmshine, November 21, 2018

WASHINGTON, D.C. – “Dairy reinvented: Sustainable. Kind. Delicious,” is the tagline of Perfect Day’s website.

“Better meat, better world” are the words that jump from the Memphis Meats website.

To be more specific, Perfect Day’s mission is to “create a better way to make dairy protein, the same nutritious protein found in cow’s milk…without the help of a single cow.”

Meanwhile, at Memphis Meats, their mission is “To bring delicious and healthy meat to your table by harvesting it from cells instead of animals… feel good about how it’s made because we strive to make it better for you… and the world.”

On the fake meat side, Memphis Meats received Series A funding from four sources in August 2017: venture capitalist DFJ, billionaire investors Bill Gates and Richard Branson, and Cargill. In January of 2018, Tyson came on board as an investor.

On the fake dairy side, Perfect Day received its Series A funding from Singapore and Hong Kong venture capital and investment companies that have relationships with some of the largest food and beverage companies and brands in the world, according to a company news release. In addition, Continental Grain was part of the early investment, and in November 2018, Perfect Day announced a partnership with Archer Daniels Midland (ADM).

The big question, at present, is how will these proteins be regulated and labeled?

The discussion is converging with FDA’s nutrition innovation strategy and modernization of standards of identity (especially dairy standards of identity), along with parallel hearings and comment periods on how to regulate and label the ‘meat’ version of lab-created cellular proteins.

Make no mistake about it folks: Both of these processes involve genetic engineering start-to-finish.

Perfect Day (fake milk protein), for example, sources yeast from USDA research labs that has been “genetically-altered” to include bovine protein stimulators and synthesizers.

Memphis Meats (fake meat) uses animal cells, mainly bovine and poultry, from cell banks that have been edited to grow only desired muscle cells — separate from their whole-animal source.

The fake dairy protein would be the end-product of the fermentation of the genetically-altered yeast, while the fake meat protein would be the protein blobs that grow from the genetically-edited cells, using neonatal bovine serum — or a plant chemical substitute that is under development — as a growth “on” button.

Both systems would require energy feed sources, using a sugar and/or starch substrate to feed the growth.

Both processes would produce waste streams.

The dairy version are grown in fermentation vats. The meat version in bioreactor towers.

While opinions vary on how quickly these technologies can scale, it is clear that the technologies are well-funded, and that agriculture’s top-tier food supply-chain processors and distributors are partnering.

We must continue to let FDA and USDA know what farmers and consumers — the two ends of the supply chain that need to be talking to each other — feel about the potential of these technologies to create captive-supply market control using interchangeable proteins in common manufactured dairy products or as protein enhancements for plant-based beverages, as well as to stretch boneless beef and poultry products with fake counterparts, namely as ground beef, hamburger, meatballs and chicken tenders and nuggets.

In a press release Friday, November 16, the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture (USDA) announced that they will “jointly oversee the production of cell-cultured food products derived from livestock and poultry.”

There has been no similar FDA PMO-regultory process established for the fake milk proteins.

USDA and FDA had a public meeting in July and October to discuss the use of bovine and poultry “cell lines” to develop these cell-cultured, lab-created foods.

In fact, meat industry stakeholders shared their perspectives on the regulation that is needed to “foster these innovative food products and maintain the highest standards of public health,” said FDA commissioner Scott Gottlieb in an official FDA statement in November.

USDA and FDA announced their “agreement on a joint regulatory framework wherein FDA oversees cell collection, cell banks and cell growth and differentiation. A transition from FDA to USDA oversight will occur during the cell harvest stage. USDA will then oversee the production and labeling of food products derived from the cells of livestock and poultry.”

As FDA and USDA are “actively refining the technical details of the framework,” some of the aspects of the framework are said to include robust collaboration and information-sharing between the two agencies to allow each to carry out our respective roles.

The well-funded startups and their lobbying organization Good Food Institute (a misnomer in this author’s opinion) had pushed for FDA to control labeling and inspection knowing that if USDA were in charge, their efforts to scale production would be slowed.

In view of this joint approach between FDA and USDA, the original public comment period about cell-cultured ‘meat’ had been extended to December 26, 2018. Comments can be seen at the FDA docket at https://www.regulations.gov/document?D=FSIS-2018-0036-0001 and there are thoughts that this comment period could be extended again as has the dairy standards of identity comment period.

Meanwhile, on the lab-created ‘dairy’ protein front, Perfect Day, a Silicon-Valley startup, announced in a press release in November that it has formed a partnership with ADM, an agricultural processor and food ingredient provider with a mission of plant-to-plate collaboration throughout the food industry.

In fact, ADM will provide facilities for scaling this technology as part of the deal.

This partnership is billed as “teaming up” to begin supplying “the world’s first animal-free dairy proteins to the food industry in 2019,” according to Perfect Day.

“Animal-free dairy proteins will not only offer consumers the option to have a lactose-free, animal-free alternative to conventional animal-based dairy, but also provide a portfolio of nutritious and functional, high-purity proteins with similar taste and nutrition profile of dairy proteins for a wide range of food and beverage applications,” Perfect Day said in their press release.

Meanwhile, the FDA has extended — yet again — its invitation for information specifically on “the use of names of dairy foods in the labeling of plant-based products.” So far, 10,043 comments (as of December 28, 2018) have been received on this docket. To comment by the new deadline of January 28, 2019, go to the docket online at https://www.regulations.gov/docket?D=FDA-2018-N-3522.

Dairy checkoff-funded DMI completed a survey of consumers recently showing that 73% are confused about the differences in nutrition between real dairy milk and plant-based alternatives calling themselves ‘milk.’

Other surveys show that more than half of U.S. consumers want healthy foods with ‘clean’ labels having few ingredients and limited or no processing.

It would seem that these findings, among others, would indicate clearly to FDA and USDA that consumers want no more monkey-business when it comes to their food, that they want to see clarity in the enforcement of milk and dairy standards of identity, and that they want to be informed about look-alike ingredients made in laboratories instead of in the time-honored land-and-animal care-taking profession of dairy and livestock farmers and ranchers.

One thing to keep in mind when commenting is to highlight the fact that over half of U.S. consumers want food that does not have a long list of additives and that is minimally processed.

That, on top of nutritional differences and new unproven processes, are enough reason to aggressively label any food containing either the fake dairy or fake meat protein because standards of identity are in place not just for health and safety but also to prevent fraudulent misleading of consumers.

Consumers should know what they are buying and be able to choose food based on their beliefs about what is a better world, not someone else defining what is kind and good and sustainable for them and not using the government’s currently flawed dietary guidelines to decide for consumers what is deemed “healthy.”

Let FDA and USDA know that we as consumers and farmers want clear labeling if these technologies are going to scale into our food system. We want the fake versions to have all of the inspection rigor that real dairy and meat proteins are subjected to.

Above all, we do not want the government quietly removing — via its one-size-fits-all nutrition innovation strategy — our ability to choose foods and production methods with which we want to nourish our bodies and on which we wish to spend our hard-earned money.

This may come down to a battle between fake animal protein ingredients funded by billionaires aligned with Silicon Valley startups and partnered by the biggest names in corporate agriculture vs. a collaboration between individual farmers and ranchers who are the backbone of our nation, the stewards of land and livestock, along with the public at-large, the consumers who are confused by the lines that are blurring.

Now, more than ever, both ends of the supply chain — farmers / ranchers and consumers — need to engage with each other directly — and not through the industry-scripted mouthpieces.

Stay tuned.

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Comment period for milk, dairy identity ends 8/27. Part 2 of 7/26 hearing right here

Posted on August 19, 2018 by Agmoos

By Sherry Bunting, from Farmshine, August 17, 2018

WASHINGTON, D.C. – There are 10 days remaining for public comment on FDA standards of identity for milk and nearly 80 other dairy products, along with the other aspects at stake as FDA launched its Nutrition Innovation Strategy to determine – and stamp – healthy choices for consumers while taking steps to “modernize” standards of identity to “achieve nutritional goals.”

The daylong FDA hearing on July 26 was one of several relating to these issues on the FDA docket, and as previously reported in Farmshine, dairy has taken center stage for several reasons.

First, Scott Gottlieb, head of the FDA, responded to calls for FDA to take a closer look at the dairy industry standards of identity, especially for milk. He opened the hearing saying that the agency must first determine “how consumers understand and use the term ‘milk’ to know if the inherent differences between these products is well understood by consumers so we can understand how consumers are being misled.”

The public comments being received by FDA through August 27, are the first step in its multi-faceted approach.

Individual comments on any of these converging standards of identity issues and the Nutrition Innovation Strategy can be sent to FDA prior to the Aug. 27, 2018 deadline at the docket portal here.

Or, send to: Dockets Management Staff (HFA–305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20857.

The second aspect of this brief comment period is to discuss the standards of identity more broadly.

“We want to hear about changes in science to review and update,” said Gottlieb. “We are hearing the standards of identity can cause the food industry to avoid reformulations that would reduce fat and calories. We want to gather this input and encourage out-of-the-box thinking with the bottom line helping consumers to identify healthier options.”

We covered some of the testimony at FDA’s July 26 listening session in Part One in Farmshine, Aug. 10, 2018.

Here, in Part Two, published in Farmshine August 17, 2018, are more of the elements from that hearing that are so important to know and understand…

Of particular interest on dairy product standards of identity were the hearing comments by Cary Frye, senior vice president of regulatory affairs for the International Dairy Foods Association (IDFA). She commended Commissioner Gottlieb for undertaking the Nutrition Innovation Strategy “to improve nutrition and health.”

While absolutely silent on enforcement of milk’s standard of identity, despite representing the nation’s milk and dairy food processors, Frye said, “the key area we are working on is to modernize the standards of identity for dairy products, which make up more than one-third of the 280 standards of identity currently on the FDA books.”

She said these standards “are outdated and stand in the way of innovations and novel processes. Current systems are not working and definitely need to be reformed.”

Frye noted that the cheese standards have been unchanged while ultrafiltered milk processes have been around for 20 years. “Clearly a new approach is needed for processes like this to be used to create new and healthful products.”

She said “processing milk by filtration to concentrate proteins and remove lactose is embraced around the world, but these new processes are not permitted in our dairy products with the current standards.”

Frye did, however, thank the FDA for what she described as FDA’s “recent guidance allowing ultrafiltered milk as an ingredient for cheeses.”

“But the agency needs to go further and make dairy a top priority for modernized standards of identity,” said Frye on behalf of IDFA. “We must incentify innovation. We can’t make these investments if we must petition for standards that take decades to complete.”

Along with standards, FDA wants to modernize label claims as a key element of the nutrition innovation strategy, to give consumers “quick signals” with important information on the nutritional benefits of food choices.

A key question FDA is looking at is: What claims best stimulate innovation to create products that are better choices?

Speakers at the hearing identified food trends, saying consumers are committed to a more balanced approach between nutrition and function, but also the idea of food, that it is part of how they experience life, with taste becoming more important to consumers than nutritional profile as they move away from “lowfat” foods.

(Unfortunately, this FDA strategy has not yet acknowledged there are health-related and nutritional reasons for consumers to move away from “lowfat” dogma of the past 30 to 40 years. My comment to the FDA docket will include sending by mail, a copy of The Big Fat Surprise, by Nina Teicholz, who will join me in sending copies of this book to FDA?)

As in many of these discussions, the generational shifts in food trends and choices are the most noticeable. Hearing presenters noted that millennials are pursuing “clean eating and natural foods” as more important than a nutrition-based label.

With that in mind, upholding and enforcing the current standards of identity for milk and dairy products becomes important since it is simple compared with concocted imitation formulations with long lists of ingredients unable to provide all of the nutrition milk has – naturally.

Hearing presenters also acknowledged that the declines in consumption of meat and dairy over the past 40 years have just begun to “shift back the other way.” People are returning to the fresh perimeter of the grocery store.

(Again, no mystery here, FDA needs to read the book: The Big Fat Surprise)

With millennial food choices driven by a so-called “return to purity,” my thoughts as I listened to the July 26 FDA Nutrition Innovation Strategy hearing is this: Will FDA move incrementally toward giving consumers what they want, while slipping into that desired food the science and innovation the FDA and food industry believe consumers need… in order to “get” the FDA ‘healthy choice’ stamp – however that is ultimately defined in this multi-year strategy and however it is ultimately designed for packaging?

These are big things to watch and participate in.

This is not to say that some new standards aren’t needed. Rob Post for Chobani, testified that they produce a nutrient dense, healthy, strained Greek yogurt, but because no standard of identity exists for this type of yogurt, they are challenged to have standardized nutrition profiles “that account for the 52% protein content in Greek yogurt” when used in institutional feeding programs like the National School Lunch Program.

“Today’s consumers have evolving demands and a new set of food values,” said Post. “Health is important, but so are other values and drivers.”

Others noted that the current standards of identity “do not allow lower salt content for cheese.”

This could be an issue when it comes to nutritional cheese getting a ‘healthy choice’ FDA stamp in the future, if such stamps are based on what are now questionable low-salt directives for healthy eating.

“Standards are important because they assure the consistency of the product, its authenticity and nutrition,” said Post.

Laura MacCleery, Policy Director, Center for Science in the Public Interest testified that, “Americans overconsume saturated fat.” They are among the contingent of wanting to work on labeling to steer consumers away from saturated fat.

Meanwhile, the American Heart Association testified to FDA that they want the standards of identity “modernized to improve the nutritional value of food by reducing both sodium and saturated fat.”

On the flipside, members of the dairy processing industry said they are looking for standards to be modernized to abolish the milk fat minimums and allow lower sodium on natural cheeses that currently have rigid standards of identity. Dairy processors testified that this is necessary to conform to the nutritional focal points of this discussion – salt and fat – that are still based on current dietary guidelines.

Will FDA grant these wishes and will we see lowfat and low salt cheeses introduced as “the real thing” because the standard has changed based on a dietary guideline many in the scientific community are already saying is a flawed guideline?

You can see the intertwined dilemma this FDA Nutrition Innovation Strategy could spawn.

Taste is king, according to the food processors speaking about low salt claims. They said they go ahead and formulate low salt varieties, they just are not always advertising it on the packaging space.

Will modernization of standards of identity low-salt and low-fat our food – our cheese for example — without our knowing it or being able to choose? Do we care if that happens as long as it tastes good? And how is that happening? With milk protein concentrates, given FDA’s already loosened grip on allowable ingredients in cheese standards of identity?

A representative for Great Lakes Cheese spoke up to say that, “Consumer transparency around label claims and that presents a huge consumer perception issue. We are interested in experimenting to reduce sodium in cheeses, but without having to put a flag saying so on our product.”

Without a change in standards, a low salt or low fat cheese would have to be labeled that way. If the fat and salt standards are abolished, no ‘flag’ is needed and consumers won’t know the fat or salt is lowered – it just may taste different.

One question asked was “If our goal is to impact consumer behavior, how do we empower consumers to look for better choices by looking to the nutrition facts instead of making changes to do it for them (with modernized standards and healthy-choice stamps)?”

Part of this process is FDA’s work to “update” the definition of “healthy” as a “voluntary” claim. What kind of symbol should be used, should it be by food group.

“What’s healthy and not healthy shifts over time, and it’s not the same for everyone. If you’re putting a stamp on something today, you may have to take it off at some time down the road,” said one hearing participant.

Dieticians were on the side of “one size doesn’t fit all” when it comes to using FDA-sanctioned ‘healthy’ stamps or symbols on food labels. They preferred to see a focus on foods and food patterns more than specific nutrients.

In fact, one anonymous dietician has already commented on the public document online to say they have spent 30 years with government food programs and this is his or her observation over those 30 years: “We have done a great disservice to the public in trying to get people to eat 6 to 12 servings of carbohydrates per day while subsisting on a lowfat diet.”

A participant from the Edge dairy farmer cooperative of 800 members in the Midwest (formerly Dairy Business Association Cooperative based in Wisconsin) said that, “Accurate labeling is the first step in FDA’s enforcement of existing standards for milk, cheese, yogurt. High nutrition and taste have come to be expected,” he said.

“Inaccurate labeling is not fair to farmers and their investment or to customers who may have been misled. We’re encouraged by FDA’s announcement and we encourage innovation in the dairy case to keep up with changing wants and needs with options for healthy products, but most people under-consume dairy products. We must have the flexibility to make what competes and to label innovative foods made with milk.”

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FDA admits almonds don’t lactate, but here’s the rest of the story…

Posted on July 27, 2018 by Agmoos

They’re even taking her ‘moo!’ Investor-heavy high-tech startup companies are (with USDA’s help) taking her DNA to give food-grade yeast her protein-producing ability in a fermentation process to make “animal-free milk and dairy.” They’re editing her cells to grow muscle blobs in bioreactors for “animal-free boneless beef” and using her unborn bovine fetal serum as the culture media for the so-called ‘clean’ ‘animal-free’ cell-cultured meat growth. And they are taking her “moo” with website invitations to “join the ‘Moo’-vement or to get ‘moo-ving’ for all the dairy you love with none of the cows.” Meanwhile, FDA is poised — in a multi-year nutrition innovation strategy — to expand standards of identity for milk/dairy and meat/beef to accomplish nutrition innovation goals that, themselves, are being questioned and in the end may give these companies the license to steal. Photo by Sherry Bunting

FDA nutrition innovation strategy poised to ‘modernize’ how milk, beef defined as high-tech labs make cow-less versions of both

By Sherry Bunting for Farmshine, July 27, 2018

WASHINGTON, D.C. — As President Ronald Reagan famously said: “The nine most terrifying words in the English language are: I’m from the government and I’m here to help.”

Last week’s news that the Food and Drug Administration (FDA) will “help” the situation of imitation milk labels was followed by specifics from FDA Commissioner Scott Gottlieb.

He revealed in a live interview with Politico: “An almond doesn’t lactate, I will confess.”

Now there’s the sound bite everyone wants to hear, and the media and social media worlds went wild. But what does it really mean? Here’s the rest of the story and how to get involved.

Gottlieb said publicly that FDA plans to start gathering public comments before taking next steps in “redefining the rules for milk products”.

What he didn’t say in the Politico Pro Summit on July 17 is that FDA has already published a hearing and comment notice in the June 27, 2018 Federal Register for a July 26 hearing that covers three topics related to “modernizing” standards of identity, and the comment period ending August 27, 2018.

Will the government’s offer to ‘help’, in this case, result in more dishonesty and skulduggery, tricking consumers into eating what they may not otherwise choose and allowing investor-heavy startup companies to steal from farmers and ranchers, not only the identity of the products they produce, but also the very commodity-promoting checkoff dollars the government mandates they pay?

FDA already has a standard of identity for milk, and almost 100 dairy products, that it has chosen to ignore for more than a decade on any product except actual dairy milk.

Here’s the rub… If real dairy milk does not have added Vitamin D (when fat is removed Vit D is added to bring it back to full-fat levels of Vit. D), it can be deemed “mislabeled” by FDA and unable to call itself MILK.

But, if there are almonds and soybeans in your milking parlor — by all means, have at it, label it milk — with or without Vit. D — not to mention without real milk’s levels of protein, quality amino acid profile and 9 essential nutrients.

You see, the standard of identity for milk is enforced when it comes from a cow, but not when it comes from a plant. And yet, because there is a standard of identity for milk — a nutritional and functional expectation — the plant-based knock-offs get to hijack that profile without being held to it and can selectively market from it with ‘more xxx’ or ‘free of xxx’ statements without stipulating what they are deficient in. (Example: Almond milk labels should say “88% less protein” if they are going to differentiate from the standard of identity they are hijacking).

By its own admission, FDA has maintained a non-enforcement posture on plant-based imitation beverages. Described as “enforcement discretion,” FDA has looked the other way and the dairy foods industry was either asleep at the wheel or developing imitations on the side, while these imposters were flooding the dairy case.

Meanwhile the companies investing in the imitations were free to do their market development and consumer confusion while securing space in the dairy case.

The timing of Gottlieb’s comments last week is even worse, given FDA’s launch of a multi-year nutrition innovation review as part of the agency’s nutrition innovation strategy revealed in March that seeks to expand standards of identity for products like milk and meat.

FDA meetings are happening quickly and quietly in various areas of imitation animal protein labeling and regulation. Yes, they are public meetings, but no one really knows about them.

Milk and dairy products have already been on the receiving end of identity-theft for more than a decade, and now that griddle is heating up to pancake both dairy farmers and ranchers (cattle are the target) with new plant-based mixtures, but even more horrifying are the genetically-edited cellular protein blobs or white-substance-exuding yeast grown in bioreactors yearning to be beef and milk.

There are new identity-thieves lurking about and guess what? USDA — the government — is the source of the bovine gene-edited cells and bovine gene-sequenced yeast in the heavily-investor-funded tech food startup companies that are the real focus of FDA’s recent moves.

With patents in hand — and funding from their big investors to scale up manufacturing — they seeking regulatory and labeling authority under FDA to be meat/beef and milk/dairy — without the cows.

FDA had a hearing on cell-cultured proteins July 12, and comments on regulation and labeling for this are due September 25.

A hearing on standards of identity was held by FDA on July 26 (after Farmshine press time), and comments are due August 27. (Look for more on this in next week’s Farmshine).

Dairy and beef producers need to become actively engaged in these moves by FDA because the main organizations that represent them — National Milk Producers Federation and National Cattlemen’s Beef Association — are on record stating these cell-cultured products should be subject to regulation under USDA like real meat and dairy. They are mainly seeking a level playing field in the marketplace, not opposing their classification as meat, milk, dairy.

(NMPF is vigorously defending milk’s standard of identity against plant-based imitations on nutritional grounds, but seeking a level playing field on the cell-cultured proteins).

Trust me, food and dairy manufacturing companies and investors have already hired the best and the brightest and are already involved in this FDA process — cheering for the other team.

Here’s an example: Perfect Day ‘animal-free milk’ is on the market after receiving its patent in February and raising $24.7 million in first-round startup funding from investors to scale-up manufacturing.

This company has a business-to-business (B2B) model, according to an interview with Reuters, and is already working with some of the world’s largest dairy food and beverage manufacturers. Its website states that the product is just like milk in terms of proteins, but without the cholesterol, saturated fats, lactose, and environmental impact of cattle. Just think what this portends for the dumping of even more fat-free real milk from the market.

In fact, a primary foreign investor indicated support for the Perfect Day (fake milk) startup because it aligns with United Nations Sustainability Goals for 2030. (There’s that S-word again. I hope we are paying attention to how the S-word and cattle are getting along these days). Continental Grain is a big investor in both the Memphis Meats (fake meat) and Perfect Day (fake milk) startups, while Cargill and Tyson are investors in the Memphis Meats startup.

These high-tech food sciences are attracting big high-tech investors at a rapid rate because they are viewed as “disruptor technologies,” and their websites and promotional materials hold nothing back. Milk, meat, beef, dairy – no words are off limits in their branding and marketing.

In effect, while the government forces dairy and beef producers to pay a checkoff tax for promotion of their commodities, beef and dairy — and the names of products associated with those commodities — the government is looking the other way or now potentially encouraging more identity-theft as techies enter the food space to market proteins using the dairy and beef profiles and images, without paying one dime.

As for Perfect Day, this fake-milk is made by genetically altering food-grade yeast, taking DNA from a cow and sharing its protein-producing qualities with the yeast. (Sourced from the USDA, the genetically-altered yeast are cultivated to produce ‘dairy’ protein).

This process results in a microbe that is combined with a sugar substrate (food for the microbe) to feed, grow and exude in a fermentation process the company says is like “craft-beer-style-brewing,” producing protein “building blocks” for making dairy milk, yogurt and cheese. Perfect Day’s website says: “Dairy reinvented: Sustainable. Kind. Delicious.”

The end game is to provide a ‘base dairy’ protein that looks and tastes like milk, for inclusion in manufactured dairy products like cheese, ice cream, pizza, yogurt, and to work “synergistically” with the dairy foods industry as — according to the website — “a complement to cow-based milk that takes some of the stress away from the factory-farming system, rather than replace dairy cows entirely.”

Enter a caption

Memphis Meats and other companies on the fake meat side are doing similar things with cell-culturing to grow cellular protein blobs in laboratory bioreactors.

In each case, the ultimate goal is to decrease the need for cattle — be they dairy or beef bovines.

Think about this for a moment. Even at a 1 to 3% inclusion rate in common dairy foods or ground beef, these lab-cultured proteins and genetically-altered yeast give processors even more control over supply, demand and pricing of milk as well as boneless beef, and if standards of identity allow this, or if FDA enforcement discretion looks the other way – consumers will never know the integrity of their food has been changed.

If FDA modernizes its standards of identity to accomplish the goals as outlined by Commissioner Gottlieb — including a reduction in saturated fat consumption despite revelations that saturated fats are healthful not harmful — it is entirely possible that FDA’s new guidance could allow these protein “innovations” in standardized dairy and meat products, without being considered mislabeled and with no indication to consumers.

Gottlieb has already established FDA’s desire to accomplish certain nutritional goals by spurring innovation with more “flexible” standards of identity.

Ahead of the July 26 hearing, FDA published its intention to cover three aspects in the standards of identity discussion: 1) Protecting consumers against economic adulteration; 2) Maintaining the basic nature, essential characteristics, and nutritional integrity of food; and 3) Promoting industry innovation and providing flexibility to encourage manufacturers to produce more healthful foods.

FDA’s Federal Register notice also says the following: “Our intent is that modernizing standards of identity to improve the nutrition and healthfulness of standardized foods will promote honest and fair dealing in the interest of consumers and achieve the goals of the Nutrition Innovation Strategy.”

How can FDA pursue this course in the face of what has been revealed in the past three to four years? It appears that bringing these B2B products to market, along with the FDA nutritional innovation strategy, are happening ahead of the battleground brewing for the next round of Dietary Guidelines.

It appears they want to modernize standards of identity for dairy within less than one year, to get them in place before the current flawed dietary guidelines are challenged in the 2020 cycle, which begins in earnest in 2019.

Numerous investigations and scientific reports and studies show that the saturated fat avoidance of more than 30 years was not only never proven to be healthful, it is now shown to be harmful. And the rhetoric from the United Nations and various Sustainability projects continues to focus on cattle as being bad for the planet, despite evidence to the contrary.

FDA wants comments that specifically talk about how the agency can use standards of identity to encourage the production of more healthful foods, to take into consideration technology, nutrition science and marketing trends, and to assess what consumers expect these standards to tell them.

Is FDA about to help the food industry blur the lines of food integrity to trick people into eating according to USDA/HHS flawed set of dietary guidelines (and UN environmental sustainability assumptions)?

That would be the ultimate dishonesty, and much worse than the 10-plus years of ignoring dairy identity theft already happening daily in the supermarket dairy case. Expanding the standard of identity, depending upon how it is accomplished, would give large, powerful, multinational food corporations a true license to steal.

Last week, the American Dairy Coalition (ADC) launched a “Protecting Milk Integrity Initiative” to advocate for the proper use of federally standardized terms established for the word “milk” on product labels. ADC is a coalition of dairy, ag and livestock producers, and they are devoting a branch of their organization to work specifically on “providing clarity and consistency for consumers across the nation,” the organization said in a July 17 news release.

ADC is getting the word out that it believes the dairy industry must speak up to ensure the FDA understands how important it is, not only for the current standard of identity for milk and dairy products to be upheld, but for it to be fully enforced — restricting the use of the word “milk” on all future plant-based or alternative product labels.

They point out that the price of milk continues to decline while sales of plant-based alternatives are up 61% over the past five years with projections of more market share gains in the future.

Don’t be fooled by FDA’s admission that almonds don’t lactate. Instead of the enforcement of milk’s standard of identity that dairy farmers have been waiting for, FDA has already quietly launched its process for modernizing standards of identity to achieve specific (and flawed) nutritional goals.

To comment on Docket No. FDA-2018-N-2381 for “FDA’s Comprehensive, Multi-Year Nutrition Innovation Strategy,” due August 27, 2018, use the docket portal at https://www.regulations.gov/docket?D=FDA-2018-N-2381.

To comment on Docket No. FDA-2018-N-2155 for “Foods Produced Using Animal Cell Culture Technology, due September 25, 2018, use the docket portal at https://www.regulations.gov/docket?D=FDA-2018-N-2155 .

To mail comments for either one, reference the appropriate docket name and number in your letter and mail to: Dockets Management Staff (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852

In addition to commenting, a petition has been developed by the American Dairy Coalition’s Protecting Milk Integrity Initiative, and signatures are being collected to submit with public comments. ADC is also taking donations to raise funds to fight this cause.

More information about Protecting Milk Integrity Initiative, visit American Dairy Coalition

To learn more about the July 12 FDA cellular protein hearing (fake meat) and July 26 standards of identity hearing (fake milk), stay tuned to future editions of Farmshine for full reports ahead of the deadlines for commenting to FDA on both.

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CAPTIONS

FAKE MEAT and FAKE MILK

New Harvest and Memphis Meats testifed to FDA on July 12 that cell-cultured ‘meats’ are inevitable. They showed diagrams of how gene-edited bovine DNA and culture media are combined in bioreactors to make cellular blobs they want to call ‘boneless beef’ — without the cow. Similar diagrams can be found for Perfect Day and their phrase: ‘all the dairy you love with none of the cows’ at their website perfectdayfoods.com. Screenshot of materials displayed during FDA hearing by Sherry Bunting

Ag Moos

Tag Archives: fake meat

Questions of science abound, public is clueless, yet USDA seeks ‘public comments’ on labeling of lab-grown cells by Dec 2!

FOOD FIGHT: USDA, Scholastic join billionaire-invested brand-marketing of ‘fakes’ in school meals, curriculum

Producers seek checkoff vote and transparency as fake food transformation ramps up

With science-fiction, they socially herd us like cattle to ‘alternative’ squeeze chute

How did we get here?

How will fake milk, fake meat be labeled and regulated?

Comment period for milk, dairy identity ends 8/27. Part 2 of 7/26 hearing right here

FDA admits almonds don’t lactate, but here’s the rest of the story…

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