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

iStock-544807136.jpgBy 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.”

-30-

A world without cattle?

By Sherry Bunting, published April 22 Register-Star (Greene Media)

A world without cattle would be no world at all.

GL45-Earth Day(Bunting).jpgThe health of the dairy and livestock economies are harbingers of the economic health of rural America … and of the planet itself. Here’s some food for thought as we celebrate Earth Day and as climate change discussions are in the news and as researchers increasingly uncover proof that dietary animal protein and fat are healthy for the planet and its people.

How many of us still believe the long refuted 2006 United Nations Food and Agriculture Organization (FAO) report, which stated that 18 percent of all greenhouse gas emissions, worldwide, come from livestock, and mostly from cattle?

This number continues to show up in climate-change policy discussion even though it has been thoroughly refuted and dismissed by climate-change experts and biologists, worldwide.

A more complete 2006 study, by the top global-warming evaluators, the Intergovernmental Panel on Climate Change, stated that the greenhouse gas emissions from all of agriculture, worldwide, is just 10 to 12 percent. This includes not only livestock emissions, but also those from tractors, tillage, and production of petroleum based fertilizers, pesticides and herbicides.

Hence, the UN Environmental Program disputed the UN FAO assertion to state the percentage of emissions from total agriculture, worldwide, is just 11%, and that cattle — as a portion of that total — are responsible for a tiny percentage of that 11%. While cattle contribute a little over 2% of the methane gas via their digestive system as ruminants (like deer, elk, bison, antelope, sheep and goats), they also groom grasslands that cover over one-quarter of the Earth’s total land base, and in so doing, they facilitate removal of carbon dioxide from the atmosphere to be tied up in renewable grazing plant material above and below the ground — just like forests do!

Think about this for a moment. The UN Environmental Program and the Intergovernmental Panel on Climate Change are in agreement that cattle and other livestock are not the problem the anti-meat and anti-animal-ag folks would have us believe. In fact, they are in many ways a major solution.

Think about the fact that man’s most necessary endeavor on planet Earth — the ongoing production of food — comes from the agriculture sector that in total accounts for just 11 percent of emissions!

Why, then, are major environmental groups and anti-animal groups so fixated on agriculture, particularly animal agriculture, when it comes to telling consumers to eat less meat and dairy as a beneficial way to help the planet? Why, then, has the U.S. Dietary Guidelines Council pushed that agenda in its preliminary report to the U.S. Departments of Agriculture and Health and Human Services, that somehow the Earth will be better sustained if we eat less meat?

They ignore the sound science of the benefits livestock provide to the Earth. In fact, it is no exaggeration to say what Nicolette Niman has written in her widely acclaimed book “Defending Beef” that, “Cattle are necessary to the restoration and future health of the planet and its people.”

Niman is a trained biologist and former environmental attorney as well as the wife of rancher Bill Niman. She has gathered the data to overturn the myths that continue to persist falsely in the climate-change debate, and her book is loaded with indisputable facts and figures that debunk the “sacred cows” of the anti-animal agenda:

  • Eating meat causes world hunger. Not true. In fact, livestock are not only a nutrient dense food source replacing much more acreage of vegetation for the same nutritive value, livestock are deemed a “critical food” that provides “critical cash” for one billion of the planet’s poorest people — many of whom live where plant crops cannot be grown.
  • Eating meat causes deforestation. Not true. Forests, especially in Brazil, are cleared primarily for soybean production. Approximately 85 percent of the global soybean supply is crushed resulting in soybean oil used to make soy products for human consumption and soybean meal for animal consumption. A two-fer.
  • Eating meat, eggs and full-fat dairy products are the cause of cardiovascular disease. Not true. Researchers are re-looking at this failed advice that has shaped 40-years of American dietary policy. Its source was the 1953 Keys study, which actually showed no causative link! Meanwhile, excessive dietary carbohydrates have replaced fats in the diet, which turn to more dangerous forms of fat as we metabolize them than if we had consumed the natural saturated fats themselves. When healthy fats from nutrient-dense animal proteins are removed from the diet, additional sugars and carbs are added and these have led us down the road to increased body mass and diabetes.
  • Cattle overgrazing has ruined the western prairies. Not true. While improper grazing can have a localized detrimental effect, the larger issue is the pervasive negative effect that is largely coming from not grazing enough cattle. Higher stocking densities that are rotated actually improve the health of grasslands. Large herds provide the activity that loosens, aerates and disperses moisture along with the nutrients the cattle return to the soil — for more vigorous grass growth and soil retention — much as 30 million buffalo and antelope groomed the prairies two centuries ago. Meanwhile, the Bureau of Land Management has favored controlled burns over grazing and is taking away land rights our federal government once shared with ranchers. BLM reductions in allowable stocking densities have initiated a land-grabbing cycle of ranchers losing their land and livelihoods while the land is robbed of its benefits.

The anti-animal agenda continues — groundless, yet powerful. Rural economies, farm families, consumers and the Earth pay the price.

The majority of the lifecycle of supermarket beef and dairy products is rooted in grooming the grasslands and forage croplands that are vital to the Earth and its atmosphere. In addition, farmers and ranchers reduce tillage by planting winter cattle forage to hold soil in place, improve its organic matter and moisture-holding capacity, provide habitat for wildlife while providing temporary weed canopy between major crop plantings. Not only do cattle eat these harvested winter forages, they dine on crop residues and a host of other food byproducts that would otherwise go to waste.

Our planet needs livestock and the farmers and ranchers who care for them. They not only feed us — with more high quality dietary protein, calcium, zinc, and iron per serving than plant-based sources — they also feed the planet by providing necessary environmental benefits.

Enjoy your meat and dairy products without fear — certainly without guilt — and with gratefulness and appreciation for the gift of life given by the animals and because of the hard work and care they have been given by the men and women who work daily caring for the land and its animals. This Earth Day, we are grateful for the circle of life and the farmers and ranchers and their cattle, which sustain our existence, our economies, and our environment.

A former newspaper editor, Sherry Bunting has been writing about dairy, livestock and crop production for over 30 years. Before that, she milked cows. She can be reached at agrite@ptd.net.

Learn more about the latest research to measure emissions due to the dairy and livestock industries.

-30-

Images by Sherry Bunting

 

 

 

 

Reinventing milk… promotion

MilkMarketMoosHeader070914.jpg

Reprinted from FARMSHINE, April 8, 2016

Fewer Americans eat breakfast today, adding to the milk consumption woes created when families stopped eating sit-down dinners, for the most part. Both were the staples of commodity fluid milk consumption that have been diminishing over the past two generations and four decades to where we are today.

Forecasters say it will only get worse. They are projecting continued declines in ‘white milk’ consumption while consumption of milk alternatives is predicted to increase dramatically through 2021.

A major reason is that the majority of urban consumers — up to 90% — do not view white milk (aka Vit. D whole milk) as a protein drink, when clearly it is the original, the natural protein drink.

But what is DMI working on? Alternatives. Checkoff dollars continue to flow through DMI to alternatives milks. Yes they are dairy products, but they are further processed, as in the case of Fairlife, which is ultrafiltered, for example.

I have had dairymen involved in these boards excitedly tell me: “We finally have a product consumers want!”

If they are referring to Fairlife, that may be true for consumers we’ve lost to Muscle Milk (which does contain some whey) or Almondmilk (which is the equivalent of eating an almond and chasing it with water full of thickeners, sugar and chemically added calcium and vitamins.)

But I find myself confused. Isn’t dairy promotion supposed to promote what contributes most to the dairy farmer’s milk check? I mean, it is the dairy farmer’s money, is it not?

As long as the Federal Order milk pricing scheme puts the value on Class I utilization, then the milk checkoff organizations should be most diligently promoting regular, straight-from-the-cow (pasteurized of course and maybe even flavored) milk as the healthy high-protein beverage it is, naturally, because I’m sorry to tell you friends, consumers just don’t know this information.

Milk: The protein drink that’s right under our noses and costs a lot less than fancy packaged and advertised alternatives — some of them complete frauds in that they are not even milk!

Why is it that milk alternatives can claim all sorts of things, but milk is not even allowed to advertise itself as 96.5% fat free! Why can’t the milk bottle say “8 times more protein than almondmilk per 8 oz serving!”

Why can’t it say: “Want Protein? Get Milk!”

Do we really need Coca Cola to revolutionize our branding? Or should dairy farmers take the bull by the horns and demand great packaging, savvy catch phrases, eye-catching point-of-purchase education, head-on comparisons to the fraudulent beverages that so wish to be milk that they call themselves milk.

No, USDA does not allow dairy farmers to promote their product comparatively with those other commodities that have stolen some of their market share by stealing the name milk. You dairy folks must play nice of course!

That’s hardly fair since dairymilk is losing market share. If you can’t defend your own market turf with your own collected monies, then what’s the point of collecting the money? All of these joint partnerships to sell cheese on pizza and mixes through frappes at McDonalds might move some more milk, but the value is in the Class I fluid milk, so unless we’re going to change the complicated milk pricing formula and glean more value and a guaranteed minimum for the manufacturing milk via its products, then we might just as well use the money to buy-back our own fluid milk and donate it to the poor to keep the demand for Class I tight vs. the supply.

Or put the money in a kitty to develop better fluid milk labels. Make them cool and splashy with P-R-O-T-E-I-N in large letters.

Milk: The original protein drink!

Milk: Protein drink of champions!

Milk: Why pay more? We’ve got what your looking for!

I could go on all day.

If the growth of our Class I milk markets rely on the USDA school lunch program, then we’re sunk and USDA is once again to blame for this dismal failure by tying the hands of school districts who want to serve 2% and whole milk.

Analysts say that the strong growth in the milk markets of emerging countries like Chile is attributed to their school milk programs.

In the U.S., milk is stigmatized as a “commodity.” We sure don’t help that with plain white bottles and lackluster graphics.

Milk alternatives such as soymilk and almondmilk (aren’t they so tricky in creating their own new words by paring their commodity to the word milk as one word) are increasingly viewed as ‘fashionable drinks’ and a more health-conscious choice compared to white milk.

Let’s reverse this trend by making dairymilk fashionable again!

Let’s call it dairymilk (a tricky combined word!) and come up with a new standard of identity that allows us to say 96.5% fat free instead of “whole.”

Maybe even come up with a standard for protein and say to call it dairymilk it must meet that protein standard and then colorfully package and protein-promote the heck out of it.

Analysts say that consumers like innovation in their drinks and they are finding “innovation” in the “newer milk categories” which are so much more attractive than the “mature” white milk category.

Okay then, let’s give the consumer what they want. Great tasting real milk but let’s reinvent the packaging and the promotion and the name… not the beverage itself.

Just think how much money we can save on fancy equipment if all we have to do is reinvent the promotion of milk, not reinvent the milk itself. After all, it is nature’s most nearly perfect food.

Maybe instead of fighting each other for Class I sales by moving milk all over to get the best price and utilization (see chart on page 13 showing that picture for the beleagured Northeast Order)… we should be fighting, instead, together, to save our beverage from its continued depreciation at the hands of internal politics, external politics, USDA rules upon rules, fraudulent not-milk-milks whom regulators ignore and even patronize, and other assorted casts of characters.