Peanut Butter Maker ConAgra Polices Itself

This was news to me:¹

"In 2005 the [FDA] suspected that peanut butter manufactured by ConAgra Foods under different brand names might have been contaminated with salmonella. When agency inspectors went to the plant that made the peanut butter, the company acknowledged it had destroyed some product but declined to say why. The inspectors asked ConAgra for its records. According to the Congressional testimony of David Colo, the senior vice president for operations at ConAgra, the company refused, telling the inspectors they needed to put the request in writing.

Mr. Colo said the inspectors never followed through.

The public did not become aware of the contamination until February [2007], when the Centers for Disease Control and Prevention noticed a spike in salmonella-related illness and notified the F.D.A."

As of February 23, "329 individuals have become ill from consuming the contaminated peanut butter, and 51 of those persons were hospitalized."
- FDA Update on Salmonella Outbreak Linked to All Peter Pan Peanut Butter and Certain Lot Numbers of Great Value Brand Peanut Butter

(Update: The CDC reported "As of May 22, a total of 628 person [were] infected." See Peanut Butter From One Plant Reached 47 States.)

None of this looks like a deliberate attempt to harm. What it looks like, to my inexperienced eye, is some panic on the part of ConAgra, and carelessness all around. We need to see more care, if not real care, at least the appearance of care. To that end...
________
Dear ConAgra,

You make it difficult for me to lay out a case for industry self-regulation when you resist disclosure to an agency tasked with the job of protecting public health, and when that lack of transparency appears to have contributed to hundreds of cases of bacterial infection. Now, I'm no PR expert, but I have a feeling that if you'd like to continue to enjoy freedom from regulation, you might want to, in the future, come clean about any apparent lack of cleanliness - right off the bat. It will, at the minimum, look like you care.

With all good intentions,
________
Dear FDA,

I want to go to bat for you, I do. But please, when you start a job, finish it. Do you realize how wonderful it would have been in the eyes of the public, if ... mind you, I'm no PR princess ... if you appeared to be acting proactively instead of reactively? This was your opportunity! Now, I can't say what other crises you may have been reacting to, or how tightly allocated were your meager funds, or even what is entailed in putting a request in writing. But, you had this baby sniffed out and it looks like you just gave up when somebody dropped a meatier bone. There's a big election next year, one that could result in a nice windfall for your agency. If you don't want to see your food safety function (and its attendant dollars) absconded by a more take-charge Administrator, you're going to have to be more competent, or, at least, look like you care. So, next time ... "Dear ConAgra, Show us your records. Yours Truly, Food and Drug Administration." ... get that bone.

Respectfully,
________¹ "Who’s Watching What We Eat?", Marion Burros, NYTs, May 16.
Photo: Homegrown. Boy, did I enjoy licking that knife.

Doctrine of Signatures

The Doctrine of Signatures (DOS) is a philosophy from ancient Europe that:

"... held that plants bearing parts that resembled human body parts, animals, or other objects, had useful relevancy to those parts, animals or objects."
- Wikipedia: Doctrine of Signatures

Some still hold to this belief. Me, I'm a believer in clinical trials. But the DOS makes for great conversation. And I see its utility for, not exactly determining a medicinal purpose for a plant, but helping to remember an established purpose, a kind of utilitarian taxonomy. A visual cheat sheet.

Here's the flower of a plant known as ______. Can you guess, given it's shape, the ailments for which the DOS (not I) suggests this plant can be used?

Here's another plant that grows voraciously in my backyard.


Only recently I learned its name: pilewort (Ranunculus ficaria). I'm sorry I only have a photo of the leaves and flowers, for it's the roots of this plant that have earned it its DOS classification:

"If you dig up the root of it you will perceive the perfect image of the disease commonly called the piles."¹

I've heard that an infusion of the root could be used as an ointment, but...

"... there be also who think that if the berbe be but carried about one that hath the piles, the pain forthwith ceaseth."
- Quotes from Botanical.com: Celandine, Lesser.

Does that mean if I see someone wearing a wreath of pilewort, I can assume... ________¹ Piles: hemorrhoids.
Photos: Homegrown.

Safe Food Act 2007 vs. Let Industry Police Itself

In an effort to air both sides of this story (the story that addresses how to amass, through production or importation, the healthiest food supply) I offer this:

Food Poisoning For Profit? Companies Are Acting For Their Own Benefit When It Comes To Product Safety

As evidenced by my recent posts on the subject, I lean towards more regulation, both for food (Safe Food Act) and supplements (Good Manufacturing Practices), not less. That doesn't mean I'm not open to other viewpoints.

Steve Chapman, in his article above, offers another viewpoint. Perhaps an effective way of filtering out unwanted microorganisms, heavy metals, pesticides, herbicides, fumigants, and other contaminants from what we consume is to let industry police itself. Litigation or loss of sales does seem to be a potent motivator. Although Upton Sinclair's portrayal of Chicago's turn-of-the-century meat-packing industry (in The Jungle) would make one question the effectiveness of self-regulation.

Would spinach producers have thought to investigate their own product in response to last year's E. coli O157:H7 outbreak? (In this case, the FDA, CDC, USDA, and State of California investigated.) Would they have voluntarily removed all their affected and suspect product from store shelves? Maybe they would have if they feared customers running to a competitor.

If we did increase regulation, how effective would it be? From Mr. Chapman's article:

"David Acheson, recently named to the new job of FDA commissioner for food protection, told the Baltimore Sun, "Right now, we inspect 1 percent of food imports. If we were to inspect 2 percent, would that problem go away? I don't think so." "

Mr. Chapman's Chicago Tribune article was posted on Reason Magazine's blog. It generated quite a few comments, which you can peruse here. Many of them support less regulation, which isn't surprising given Reason Magazine's (from what I can tell) Libertarian stance.

What do you think?

Safe Food Act 2007, Congressional Cosponsors

I was excited to see that Senator Hillary Clinton recently decided to cosponsor Senate bill S. 654: Safe Food Act 2007.¹ It makes me feel like all our writing is paying off.

A refresher:

The Safe Food Act 2007 would:

• Create one Food Safety Administration (FSA), consolidating the food safety functions of various agencies (FDA, USDA, FSIS, CFSAN, CVM, EPA, etc.).
  
• Increase inspections, both domestic and foreign.
  
• Implement a sampling program. (Boy, would I like to see some meaningful seafood sampling.)
  
• Increase enforcement powers. (The FDA currently has no mandatory recall authority. They can just ask nicely.) The new FSA could:
  • Detain, seize, or condemn food.
    
  • Order a recall.
    
  • Increase inspection frequency.
    
  • Withdraw the mark of inspection.

The above list is not inclusive. You can read the entire bill or a summary here.

Cosponsorship Slowly Growing

Along with the Senate sponsor of the bill, Senator Richard Durbin [IL], there are today 3 Senate cosponsors:

Senator [State] - Date of Cosponsorship
Sen Schumer, Charles E. [NY] - 2/15/2007
Sen Casey, Robert P., Jr. [PA] - 3/21/2007
Sen Clinton, Hillary Rodham [NY] - 5/8/2007

Along with the House sponsor of the bill, Representative Rosa DeLauro [CT-3], there are today 15 House cosponsors:

Representative [State - Congressional District] - Date of Cosponsorship
Rep Kaptur, Marcy [OH-9] - 2/16/2007
Rep McDermott, Jim [WA-7] - 2/16/2007
Rep Miller, George [CA-7] - 2/16/2007
Rep Matsui, Doris O. [CA-5] - 2/16/2007
Rep Berkley, Shelley [NV-1] - 2/16/2007
Rep Grijalva, Raul M. [AZ-7] - 2/16/2007
Rep Woolsey, Lynn C. [CA-6] - 2/16/2007
Rep McCollum, Betty [MN-4] - 2/16/2007
Rep Capuano, Michael E. [MA-8] - 3/7/2007
Rep McGovern, James P. [MA-3] - 3/19/2007
Rep Clay, Wm. Lacy [MO-1] - 3/19/2007
Rep Lofgren, Zoe [CA-16] - 4/20/2007
Rep Green, Gene [TX-29] - 4/23/2007
Rep Schakowsky, Janice D. [IL-9] - 4/25/2007
Rep Jackson, Jesse L., Jr. [IL-2] - 5/16/2007

If your Senators or Representatives are not listed, and you'd like to see some of the above actions implemented, drop them a line. The more cosponsors a bill has, the more likely it is to get out of the cobwebs of a Committee and on to the floor for a debate.

While you're at it, drop an email to President Bush too. After all, he's the one that will eventually sign it.
________¹ See the Library of Congress' thomas.loc.gov site for updates to this bill.

Fifi's Carrot Cake

"Fifi, the oldest chimpanzee at Sydney's Taronga Zoo, munches on carrots to celebrate her 60th birthday."

Happy Birthday, Fifi!

________Photos and caption via BBC: In Pictures and Getty Images.

When Is Organic Sausage Not Organic Sausage?

When the USDA permits use of non-organic "casings from processed intestines."

"... the intestinal casing may be from an animal that lived its life on a factory farm in intensive confinement, consuming pesticide laden foods, and treated with an assortment of antibiotics and drugs."
- Organic Consumers Association (OCA), USDA To Allow More Conventional Ingredients In Organics

Why not use organic casings?

"The [USDA's] justification for adding non-organic casings to the National List is based upon insufficient availability of processed intestines from organically produced animals."
- USDA, National Organic Program (NOP) - Proposed Amendments to the National List of Allowed and Prohibited Substances (Processing), [Docket No. AMS-TM-07-0062; TM-07-06]

Let me see if I understand. There isn't enough organic product so you allow manufacturers to use inorganic product and call it (and profit from calling it) organic. Am I making a fair read on that? I can't say I'm a big fan of meat encased in intestines, but it seems the respectable thing to do would be to require organic casings on a meat product labeled "USDA Organic". What in blazes does organic mean anymore?

The USDA is accepting public comments on this proposal until Tuesday, May 22, at Regulations.gov. Or you can visit the OCA's site and sign their petition.
________Photo of sausages from Lex Culinaria

When Is Organic Beer Not Organic Beer?

When the USDA permits use of non-organic hops, grown with synthetic pesticides and fertilizers.¹

The Organic Consumers Association (OCA) disparages the USDA for considering this change since it ...

"... offers unfair advantages to large-scale breweries. There are many micro-breweries now selling truly organic beers (with organic hops). These companies cannot compete with the prices of larger companies stepping into the "organic" beer business, like Budweiser, who will be allowed to use less expensive, conventionally grown hops (non-organic hops costs less than half as much as organic hops)."
- Organic Consumers Association, USDA To Allow More Conventional Ingredients In Organics

Budweiser is owned by Anheuser-Busch, who recently debuted two new organic beers, Stone Mill Pale Ale and Wild Hop Lager.

The USDA is accepting public comments on this proposal until Tuesday, May 22, at Regulations.gov. Or you can visit the OCA's site and sign their petition.
________¹ USDA, National Organic Program (NOP) - Proposed Amendments to the National List of Allowed and Prohibited Substances (Processing), [Docket No. AMS-TM-07-0062; TM-07-06]

Safe Food Act 2007, CNN Gives Airtime To Food Safety

On the eve of Dr. Sanjay Gupta's CNN program Danger: Poisoned Food, What You Eat Could Make You Sick (May 19 and 20, 8:00 pm ET), CNN has run an article addressing the Safe Food Act 2007:

Lawmakers Push For Change In Food Safety Oversight

We're writing. They're listening.

________

Safe Food Act 2007, E. coli In Meat Is Not OK

The USDA announced another recall of beef products.

How could E. coli in this quantity of meat escape detection before it was distributed to 15 states for consumption?

129,000 Pounds Of Beef Recalled For E. Coli

The USDA's Food Safety and Inspection Service (FSIS) posted the following press release which includes a list of affected products:

Michigan Firm Recalls Beef Products Due To Possible E. Coli O157:H7 Contamination

It's not OK. Support the Safe Food Act 2007. Write your representatives today.

________

Good Manufacturing Practices for Dietary Supplements, Waiting For The Nod

It's not as if the FDA hasn't addressed the issues about supplements I discussed in my previous post.

On March 13, 2003, the FDA published a proposed rule that "would require manufacturers to evaluate the identity, purity, quality, strength, and composition of their dietary ingredients and dietary supplements." It's lengthy and detailed. Although the longer it sits, the less applicable that cost analysis will be. I think it's high time these good manufacturing practices are implemented.

Here's the FDA proposed rule (not currently in practice):

Current Good Manufacturing Practice (CGMP) in Manufacturing, Packing, or Holding Dietary Ingredients and Dietary Supplements

Here's a summary:
FDA Proposes Manufacturing and Labeling Standards for all Dietary Supplements

"Congress gave FDA the authority to develop and implement CGMPs as part of the Dietary Supplement Health and Education Act of 1994 (DSHEA)."

That was 13 years ago. Who's holding up the approval of this rule? Why?

As far as I can tell, the FDA, having completed their rule governing CGMPs for dietary supplements, sent it on to the White House. It's been sitting there, in the Office of Management and Budget (OMB), since at least November 2005:

Meeting Record Regarding: Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Dietary Ingredients and Dietary Supplements, Date: 11/29/2005

Update, June 22, 2007: Good Manufacturing Practices For Dietary Supplements, Gets The Nod
________

The Truth About Supplements

Buyer beware.

In the site T-from-F sent (the one that culminated in a letter you could add your signature to and forward to the FDA), the Natural Solutions Foundation, via Mr. Stubblebine, "urges the FDA to reduce regulation [of dietary supplements]" ... since ... "we are dealing with foods which, as foods, are presumed to be safe."

Safe? Are foods that contain E. coli O157:H7, salmonella, melamine, mercury, and PCBs safe?

For all a consumer knows, their unregulated dietary supplements may be contaminated with pesticides, herbicides, heavy metals, bacteria, insect parts ... and their potency may be squat.

I invite you to pick up a bottle of any vitamin or supplement you have lying around and find a guarantee on the label that what the manufacturer claims is inside the bottle is indeed inside the bottle ... and that chemicals you may not wish to be inside the bottle, especially hazardous ones, are indeed not inside the bottle.

• Was the glycerin used as filler in your vitamin E imported from a Chinese factory that sold toxic diethelene glycol as glycerin?
  
• Does your multivitamin really contain 100% of the DV (Daily Value) for designated nutrients?
  
• Does your St. John's wort contain heavy metals and pesticides?

Here's one analysis I found from 2001¹:


Click for larger.
Why is there DDT in St. John's wort?

Speaking of St. John's wort, an independent lab (Consumerlab.com), tested 16 products containing the herb:²

• "Three failed to pass independent testing due to cadmium contamination."
  
• "One of the three also had lead contamination above the limit established by the State of California."
  
• "Two products were dropped from testing because they did not identify the part of the herb used, as required by the FDA."
  
• "A sixth product failed for suggesting a dose that was likely to be too low to be effective - less than one quarter of the standard dose."

That same lab tested 23 fatty acid supplements (black currant oil, borage oil, evening primrose oil, flaxseed oil - for omega-3 and omega-6 content) and found:³

• "Four products to contain less fatty acids than claimed."
  
• "One almost completely lacked the ALA (omega-3) stated on its label."
  
• "Three others had only 57% to 79% of the expected fatty acids, including one that provided a "Guaranteed Analysis" of its contents."

There goes any trust I've placed in that claim ("Guaranteed Analysis").

In the last few years, The FDA encountered:⁴

• "Five of 18 soy and/or red clover-containing products were found to contain only 50% to 80% of the declared amounts of isoflavones." ⁵
  
• "Of 25 probiotic products tested, 8 contained less than 1% of the claimed number of live bacteria or the number of bacteria that would be expected to be found in such a product."
  
• "One firm recalled its dietary supplements that were contaminated with excessive amounts of lead, which may have posed a health risk to many consumers, especially children and women of childbearing age."

Dietary supplements in this country are woefully under-regulated, and supplement manufacturers like it that way.

It's my opinion that we'd benefit from more regulation, not less, as "health freedom" groups such as the one above advise. I don't believe that regulating supplements would reduce access to them. I didn't always feel this way, but my experience with the quality of supplements being sold in this country has taught me otherwise.

Complementary and Alternative Medicine (CAM) is a large and rapidly growing business in this country. Sales of dietary supplements alone reached $22 billion in 2006. I would not be surprised if Mr. Stubblebine and his "health freedom" associates who advocate minimal regulation profit from the sale of it.
________¹ Bulletin of Environmental Contamination and Toxicology, 2001, Organochlorine Pesticides and Metals in Select Botanical Dietary Supplements
² St. John's Wort Fails to Meet Quality Standards
³ Some Supplements Lower In Omega-3 And Omega-6 Fatty Acids Than Claimed
⁴ FDA Proposes Labeling and Manufacturing Standards For All Dietary Supplements
⁵ The sale of these products suggests that isoflavones are healthful. In fact, the American Heart Association wrote, "The use of isoflavone supplements in food or pills is not recommended.", a topic I discussed here.

New York Times No-Knead Bread Bagel

This was unplanned:

I've been making the NYTs No-Knead Bread regularly, and this is the first time it happened - a sink hole. Really, it's not a bagel. It's a full loaf that didn't rise in the middle.

I think I know what happened. Spring has arrived with 80-plus degree temperatures. Instead of an overnight rest at 67 degrees, this loaf spent about 20 hours in the high 70s/low 80s. I suspect the yeast overpopulated their environment - exhausting starch resources then dying from starvation. I reinvigorated the outside by turning it with flour before letting it rise a second time. But not kneading meant not getting the new starch infusion spread throughout.

Still, it baked OK:

And it's very good. Chewy, crusty, tasty ... everything you could want in a bread, except whole grains. What can I say, a good loaf is my weakness.
________Photo: Homegrown

Update On Melamine 5, What To Do With All That Pet Food

I loved this question from a CNN reporter at a media briefing Tuesday, held by the FDA and USDA. (If ever a question was leading.)

CNN REPORTER: "Okay, and follow-up question, now that the risk assessment for melamine in feed for livestock is low, does that mean that you will then allow the pet food companies to sell all their recalled food to livestock companies as long as it's used in a small amount?"

DR. STEPHEN SUNDLOF (Director, Center for Veterinary Medicine at FDA): "The answer is no, - that we consider any of the tests positive to be adulterated and could not be used to further process into feed."

Was there a contradiction there?

It makes you wonder the fate of 60 million containers of pet food contaminated with melamine and related nitrogen-rich compounds. Will it be disposed of? (Does somebody open all those individually packaged pouches and cans?) I sure hope landfill liners are intact. Although the problems posed by e-waste are probably more challenging.
________
On a related note, I found this while reading. (This is a good place to mention the point Family Nutritionist makes, that melamine resin is distinct from melamine as found in pet food.)

Resin identification codes (notice number 7):¹


Click for larger.________¹ From Waste Online. More information on these codes can be found on the following chart (pdf) provided by the American Chemistry Council: Plastic Packaging Resins

Safe Food Act 2007, What People Are Saying

I've been stumbling across, or people have been sending me, blogs and other sites that are discussing the Safe Food Act 2007. Well written, informative, persuasive. I love that citizens can make a difference this way.

Because I like to make lists, here's a list. Let me know who I missed. I'll add more as I find them:

• Rhode Island Safe Food Initiative: Improve Food Safety & Demand Accountability: Support The Safe Food Act Of 2007 (Strong support here.)
  
• Daily Kos: What can I eat? (Nice, Doug!)
  
• Angry Toxicologist: Safe Food Act of 2007 (Thank you, B.)
  
• The Ethicurean: More on the Safe Food Act of 2007 (Thank you, Justin.)
  
• The Glittering Eye: Today’s Update on the Pet Food Recall—5/8/2007 (Who mentions the following link to a Chicago Sun-Times commentary that supports the bill.)
  
• Chicago Sun-Times: Decline In Food Safety Is Difficult To Swallow
  
• truthout: Food Safety Concerns Grow as Imports to US Surge
  
• Consumer Reports: Peanut Butter Recall Highlights Food-Safety Challenges (Consumers Union, the non-profit publisher of Consumer Reports supports the bill.)
  
• ** Center for Science in the Public Interest: USDA Wrong Place to Consolidate Food Safety, Says CSPI (It seems the House Agriculture Committee is holding a hearing today to consider nominating the USDA as THE food safety agency. CSPI opposes this.)

________

Update 4 on Melamine, Farmed Fish and Wheat Flour

Back in April, I fretted:

"It dawned on me that if one company could be responsible for supplying a contaminated ingredient to so many dog and cat food manufacturers, maybe they could be supplying it to poultry food manufacturers too, and cattle food manufacturers, and the pigs, and oh, the farmed salmon, not the salmon."

Yes, farmed fish:
Farmed Fish Fed Contaminated Material

The FDA declined to say which fish exactly. Please, not the salmon. (Photo not representative of affected fish.)

There are 2 more sizzling sentences in that news report:

1. "US investigators also have learned that the purported Chinese wheat gluten and a second ingredient, rice protein concentrate, were actually simple wheat flour. The flour was spiked with melamine and related, nitrogen-rich compounds to make it appear more protein rich than it was."

So, am I being exposed to melamine and other industrial chemicals by eating wheat flour? Which wheat flour? Bread? No, not the bread. I ask again, what is the cumulative effect of chronic ingestion of low levels of "melamine and related nitrogen-rich compounds"? The government has only addressed an acute situation - one pork chop.

So far, we know that melamine was found in lemon juice, orange juice, coffee, curdled milk¹, pork products, chicken products, fish products, vegetable proteins, and wheat flour. Those foods make up a nice slice of a Bix diet. Should I be checking my urine for crystals?

2. "Farmed fish typically are sold for direct consumption or for stocking lakes and streams."

I had no idea ... Farmed fish are used to stock lakes and streams. How in blazes will we be able to tell if a fish is farmed or wild? If a fish has been fed grain, artificial coloring, fake protein, and antibiotics?

I have lost faith in the adage, "An educated consumer is our best customer." I'm now more inclined to believe that an uneducated consumer is a better customer.

(Have I mentioned the Safe Food Act 2007 today? Food Contamination - It's Not OK. Write your Elected Officials.)
________¹ To clarify: these four foods were not contaminated in the recent incident involving tainted ingredients imported from China. These foods were found to be contaminated in an experiment that placed them in contact with a melamine-containing polymer, for 30 minutes, at about 200 degrees F. This experiment demonstrated that melamine can migrate from a container into food, at temperatures less than boiling, and when those foods are acidic. It begs an answer to the question: "What is the cumulative effect of chronic ingestion of low levels of "melamine and related nitrogen-rich compounds?" See International Programme on Chemical Safety: Melamine for more info.

Photo: Homegrown. Please don't think I'm implying that Bumble Bee canned salmon is contaminated with melamine. I only show this to represent my fears, not fact.

FDA Guidance for Industry on CAM

I apologize for not posting this sooner. T-from-F sent this to me last week, but I got so caught up in bad-food-anger, and then immersed in the tedium of a 94-page piece of fix-the-bad-food legislation that I let it slide.

While I was letting it slide the FDA comment period for it passed ... maybe.

Here's the site T-from-F sent:
FDA Regulators Using Legal Trickery to Jeopardize Alternative Procedures and Products

Unfortunately, the site and its message are more about an anti-government group crying wolf than about reasoned thinkers distributing level-headed advice. Just because something is hosted by the democracyinaction.org site doesn't mean it's sensible. In this case, I think it's unduly inciting and meant to scare.

As you can see, it culminates with a pre-completed comment form, compliments of the Natural Solutions Foundation, to the FDA, insinuating that the FDA is trying to squelch "health freedoms".

I wonder if people who are signing this have read the words in the box, and if they truly endorse their message. It's long (about 2000 words), meandering, and full of curious, unsubstantiated phrases:

• "Many health problems [are] caused by government intervention."
  
• "[Regulated prescription] drugs are a major cause of death in every developed country while CAM remedies are an insignificant-to-absent cause of death world-wide."
  
• "Invasive techniques and toxic drugs are the sole provenance of licensed medicine."

The author, Albert N. Stubblebine, offered no clinical or epidemiological backup for his broad and biased claims. That substantiation may be hard to come by though, since CAM remedies are not studied as rigorously as conventional (allopathic) remedies for efficacy or side effects, so data on their impact to populations is sparse.
________
Background

On February 27, 2007, the FDA posted a document-in-progress called a "Draft Guidance", directed at "industry" and intended to clarify how the FDA regulates products and therapies that fall under the heading of "Complementary and Alternative Medicine", CAM for short.

Here's their draft document:
Docket No. 2006D-0480:
Draft Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration

Here's a summary:
Draft Guidance for Industry on CAM Products and Their Regulation by the FDA

I read it and found it did nothing more than provide definitions and clarify which products are subject to regulation under the Federal Food, Drug, and Cosmetic Act, and which fall under the Public Health Service Act. Nothing new here.
________
Pandemonium Ensued

After it was posted, the internet burned with conspiracy theories, many spawned by T-from-F's site and their supporters. Fears were generated that the FDA, via this Draft Guidance, was out to shut down chiropractors and confiscate cranberry juice and holy water.

One conspiracy theorist, Mike Adams at NewsTarget.com, says that the FDA's document may cause the following things to occur:

• Growing and selling common garden herbs will get you arrested as a drug dealer.
  
• Yoga props will be regulated as "medical devices" and require FDA approval before being sold or used.
  
• Bottled water that "treats" dehydration will be regulated as a drug.
  
• Green tea will be outlawed and confiscated.
  
• Citizens owning personal inventories of "unapproved drugs" (vitamins and herbs) may have their homes raided at gunpoint and their inventories confiscated by armed law enforcement agents.

These are not true. This Guidance Document clarifies present law. It does not change law, only Congress can do that. In fact, if you are concerned about the direction the FDA is taking regarding CAM, it would be more effective to write to Congress, not the FDA. Congress created the FDA; Congress finances the FDA; Congress directs the FDA.

Below is an interview with Philip Chao, a senior scientific advisor at the FDA and one of the authors of the FDA document. In it, he says the FDA document:

• Does not change any law. (Only Congress can do that.)
  
• Does not "turn supplements into drugs". (Drugs undergo more stringent regulation.)
  
• Does not regulate practitioners. (The FDA never regulated health practitioners.)
  - The FDA's CAM "Guidance" - Interview with Senior FDA Science Advisor Philip Chao

"Activism" as promulgated by groups such as the Natural Solutions Foundation (who sell vitamins, supplements, and other healthcare products on their site) is unfortunate. It revs up the hearts and minds of a limited (and necessary) group of well-meaning, health-minded enthusiasts. It then exploits their energy for selfish purposes. Also, in mobilizing their (our) power to achieve their ends, it distracts from more important issues regarding supplements and other CAM products.

I'll be back with more soon. (Okay, here's more.)
________Illustration of materia medica from ibiblio.org
The illustration (rose) is from a picture book, the Circa instans, thought to be produced at the medical school of Salerno, Italy in the mid-twelfth century. It depicts natural, medicinal remedies from Latin and Arabic sources.

Safe Food Act 2007, Imports

Had the Safe Food Act been passed and implemented in 2005, foods intended for human consumption (which ultimately includes pet food ingredients since it appears to be an acceptable practice to sell same to livestock farms¹) which contained industrial chemicals such as melamine would never have been imported. They would have failed to pass inspection in China.

From Title II, Section 208 of the yet-to-be-passed Safe Food Act 2007:

(b) "A foreign government or foreign food establishment requesting a certification to import food to the United States shall demonstrate ... that food ... has met standards for food safety, inspection, labeling, and consumer protection that are at least equivalent to standards applicable to food produced in the United States."

(c, 2) "Prior to granting the certification, the Administrator shall certify, based on an onsite inspection, the food programs and procedures of a requesting foreign firm as at least equivalent to the food safety programs and procedures of the United States."

(g) "The Administrator shall routinely inspect food and food animals (via a physical examination) before it enters the United States to ensure that it is safe."

________
While the FDA, USDA, and EPA are scrambling trying to find and contain contaminated foods, and assessing whether these foods pose a threat to human health if eaten, millions of shipments of uninspected foods continue to arrive and be distributed.

From the NYTs May 1 article Food Imports Often Escape Scrutiny (Thank you, Melinda.):

In 2006, "an estimated 9.1 million" shipments of food arrived in the US."

"The FDA, which is responsible for monitoring 80% of the country’s food, inspects barely 1% of the food shipments arriving annually at hundreds of ports throughout the country." And that percentage of inspections is declining:

Some former Health and Human Services (HHS) officials see it like this:

"The public thinks the food supply is much more protected than it is," said William Hubbard, a former associate commissioner who left in 2005 after 27 years at [the FDA]. "If people really knew how weak the FDA program is, they would be shocked."

"Tommy G. Thompson, the former secretary of HHS, expressed deep concern about the nation’s food supply when he resigned, for unrelated reasons, in December 2004:
“For the life of me I cannot understand why the terrorists have not attacked our food supply because it is so easy to do." ... He said he worried “every single night” about threats to the food supply."

"The word is out," Hubbard said. "If you send a problem shipment to the United States it is going to get in and you won’t get caught, and you won’t have your food returned to you, let alone get arrested or imprisoned."
- Food Imports Often Escape Scrutiny

More stringent import standards exist. They are not law today because our lawmakers chose otherwise.

Pets didn't have to die. Livestock did not have to be sacrificed. Human food did not have to be contaminated. It's not OK. Support the Safe Food Act 2007.
________¹ "Rep. Rosa L. DeLauro, D-Connecticut, the chairwoman of the House Appropriations' agriculture subcommittee and co-chairwoman of the Congressional Food Safety Caucus, said the link between the tainted pet food and chicken feed "highlights the egregious holes in our food safety system."
Officials Order 20 Million Chickens Held From Market

Nebraska Farm Bureau Thinks the Safe Food Act is a Bad Idea

Farm Bureau Opposes Creation of a New Food Safety Agency
Focus- New Food Safety Agency Is Bad Idea /Commentary

Why would a Farm Bureau oppose a Safe Food Act?

Here's a little background on Nebraska's agricultural business, from their site:

• "Nebraska's farms and ranches use 45.9 million acres - 93 percent of the state's total land area."
  
• "Nebraska's livestock industry [beef, hogs, poultry, eggs] accounts for more than 60 percent of the state's total agricultural receipts each year."
  
• "Corn, soybeans, winter wheat and grain sorghum are Nebraska's leading crops."

According to Michael Pollan's recent NYTs article, You Are What You Grow, the US government, via the Farm Bill, subsidizes the growing of, or as Pollan says, "promotes the overproduction of", 5 crops - corn, soybeans, wheat, rice, and cotton - "to the tune of some $25 billion a year."

Now, this is just a hypothetical case, but let's suppose that the Safe Food Act, via its increased funding for research into hazardous food ingredients, finds an association between consumption of high fructose corn syrup (HFCS) and metabolic syndrome (obesity, diabetes, high blood pressure, high blood lipids, heart disease). And let's say that, as a result, consumption of HFCS in this country wanes. What would happen to that multi-billion-dollar subsidy for corn?
________

Safe Food Act 2007, Write Your Elected Officials

If you've been following my recent posts on the Safe Food Act and you'd like to support the bill by emailing your representatives, Congress.org (a private, non-partisan group that "specializes in facilitating civic participation") makes it easy:

1. Go to Congress.org
   
2. Enter your 9-digit zip code to find your officials.
   
3. Click the appropriate link in "Write to your Federal or State elected officials with one click."
   
4. Select recipients.
   Subject: "Safe Food Act 2007"
   Issue Area: Agriculture
   
5. Enter your message in the "Editable text" box.

A quick scan of the "Letters to Leaders" shows this one sent in by someone from Providence, RI. I suspect it was written by the Rhode Island Safe Food Initiative (RISFI) who offers it as suggested text you may use in support of the bill. I like it, although I think I may write something a little more personal, include a few more facts, maybe cut and paste my "It's Not OK" diatribe :)

Suggested text from Rhode Island Safe Food Initiative (RISFI):

"I'm writing to urge you to support the Safe Food Act of 2007 (HR 1148/S 654). The safety of our nation's food supply is increasingly at risk, as evidenced by the recent widespread outbreaks of foodborne illness and the February 2007 GAO report which determined that federal oversight of food safety is a high risk area which needs to be made more effective and accountable.

The Safe Food Act of 2007 will address many of the problems plaguing our current fragmented and antiquated federal food safety system by establishing a single Food Safety Administration and modernizing, consolidating, and strengthening Federal food safety laws and their enforcement. Please support the Safe Food Act of 2007 so that an effective Food Safety Administration may be established to resolve the growing, but preventable, epidemic of foodborne illness."

________

Safe Food Act 2007, Full Text

Below is the Senate version of the Safe Food Act 2007 bill, reintroduced in February of this year by Senator Dick Durbin (D-IL) and Representative Rosa DeLauro (D-CT).

pdf file:
Safe Food Act 2007

html:
Safe Food Act 2007

Representative DeLauro has an excellent summary of the bill, in its 2005 form, on her website:
Summary: The Safe Food Act of 2005, H.R. 1507

The Center for Science in the Public Interest (CSPI) had this to say about the bill when it was reintroduced in February:
Congressional Leaders Call for Single Food Safety Agency,
CSPI Supports Effort to Modernize Food Safety Laws

If you'd like to support this bill, you can contact your representatives.

________

Safe Food Act 2005, 2006, 2007

Ruby says to make food an issue in 2008. Well, I'm going to.

I found a piece of legislation that has been languishing in a committee since at least 1999. It was written to address many of the issues I see as important here. Had it been made into law back then, it might have contained the recent contamination cases better; if not prevented them. And we wouldn't be reading joint statements from a few of the numerous government agencies responsible for the safety of our food. That's because the Safe Food Act would create one Food Safety Administration (FSA).

I've just begun to explore this route for action. It may not turn out to be the best route, but it's one I'm going to focus on. I'll update as I become more informed.

In the mean time, here's the bill:

Senate version:
S. 654: Safe Food Act of 2007

House version:
H. R. 1148: Safe Food Act of 2007

It's my intention to write to the presidential candidates, as well as my state senators and representatives, to ask each of them where they stand on this bill.
________Image of GovTracks.us from GovTrack.us.
GovTrack.us is an independent, non-partisan, non-commercial website created and maintained by Joshua Tauberer.

Food Contamination, It's Not OK

I was in the grocery store yesterday and opted against buying meat. I've been put off by these recent findings of contamination, and more importantly, by the knowledge I've been acquiring about how our livestock are raised. Why are pet food ingredients, items that receive low priority on the FDA's watchlist, being sold to farms that raise food for human consumption? What meat can I trust? I see cows grazing in fields along highways, is there pesticide runoff in that grass? Organic, grass-fed, pasture-raised, humanely-handled meat and poultry aren't widely accessible, not financially, not logistically.

This is not OK. It's not OK that lettuce, spinach, and meat were contaminated with E. coli O157:H7. It's not OK that peanut butter was contaminated with salmonella. It's not OK that government agencies responsible for the safety of our food don't talk to each other, aren't adequately funded, and appear to be more beholden to industry and political interests. We pay for these federal agents to keep our food safe. They work for us. If the current set-up can't handle the requests made of it, it needs to be changed. This is not OK, and I'm going to do something about it.

________Photo: Marion Nestle's 2003 book Safe Food: Bacteria, Biotechnology, and Bioterrorism

Update 3 on Melamine, Cause of Pet Death

First, the pet death toll is rising, from 16 to possibly over 4000:

"The FDA said Friday it had received more than 17,000 consumer complaints about the tainted pet food, including the deaths of 1,950 cats and 2,200 dogs."
- Mix Of Chemicals May Be Key To Pet-Food Deaths

Now, more info on how these animals may be falling ill. A university in Canada (Canada?) conducted some experiments:

"... if you take cat urine and you add melamine to it and cyanuric acid, the crystals will form in the cat urine in a test tube as we're watching them." ... "The crystals are suspected of contributing to kidney failure in pets." ... "I think we've identified what we feel is an important and likely underlying positive agent of why the animals are getting sick."
- Mix Of Chemicals May Be Key To Pet-Food Deaths

Cyuranic acid is a metabolite of melamine, that is, our body can produce cyuranic acid from melamine during digestion. Cyuranic acid could also be present in tainted food.

As Russ said in comments this association is still circumstantial. Nowhere have I read that melamine and/or its derivatives were the cause of pet death. As I've said, there seems to be a disconnect between ingestion of what's described as a "not-particularly toxic" chemical and kidney failure.

Still, the evidence from experiments such as the one above indicate there may be greater risk to consuming melamine than was previously believed.

There's a question of amounts that I don't see being addressed. The government said that the likelihood of illness after eating pork or chicken fed melamine is low. That addresses an acute situation. What is the effect of chronic low-level ingestion for humans? And if melamine from one source may not contain enough to do damage, can the intake of melamine consumed simultaneously from numerous sources (contaminated meat, contaminated vegetable protein, environment, etc.) do damage?
________Photo and caption from FabCats.org.

Update 2 on Melamine, More Food Sources

It's now in poultry that has been distributed:

"At least 2.5 million broiler chickens from an Indiana producer were fed pet-food scraps contaminated with the chemical melamine and subsequently sold for human consumption, federal health officials reported Tuesday."
- FDA Says Chickens' Food Had Melamine

And ...

"At this time, the investigation indicates that approximately 30 broiler poultry farms and eight breeder poultry farms in Indiana received contaminated feed in early February and fed it to poultry within days of receiving it. All of the broilers believed to have been fed contaminated product have since been processed. ... FDA and USDA anticipate that as the investigation continues additional farms will likely be identified that received contaminated feed."
- Joint Update: FDA/USDA Trace Adulterated Animal Feed to Poultry

And now, it's not just meat:

"The FDA says it has collected 750 samples of wheat gluten and products made with wheat gluten and found that 330 -- about 44 percent -- tested positive for melamine or melamine-related compounds."
- Mix Of Chemicals May Be Key To Pet-Food Deaths

________Photo from an absolutely beautiful cooking site, FXCuisine.com. Check out his recipe for Chicken Tandoori.

Cone Scales

________Photo: Homegrown