public policy update
TRANSCRIPT
FROM SNE
I President's Message I Myron Johnsrud, Administrator of the
USDA Extension Service, is quoted as advising each of us to "Be a student of history and a creator of the future." His address at the National Extension Leadership Development Program (June 1991) entitled "Effective Leadership: Now and in the Future" contained other advice that is most appropriate for the Society of Nutrition Education as we chart our future course. As Johnsrud stated, "There is much to be learned from the past; put this wisdom to work in creating a new vision of the future." Also, "Visions only get implemented when leaders and followers share the same view of what must be at the end of the effort."
It is my hope that this will be true of SNE as we commence work on our new strategic plan. The Strategic Planning Committee will be working diligently this year, consulting with divisions of our Society and various groups from among the members. At each of the last two annual meetings, focus groups have provided
thoughtful ideas and a wealth of information. We have also gleaned ideas from members and non-members through surveys and calls to the SNE office, as well as through the focus groups that the Executive Director has organized in local affiliates and from among SNE members around the country. The views and ideas of our international members will also add to the information we will use to create a new vision for SNE's future.
The leadership of SNE has taken some Significant risks during this past year. By the time you read this column, the first few vignettes developed by McDonald's and CBS with technical assistance from SNE members will have been aired on Saturday morning television. At the same time, you will be receiving a membership survey in the mail, and some of you will be selected on a random basis for an indepth interview.
I hope it is clear that all of us in the leadership of your Society look forward to hearing from you and welcome your input.
I Public Policy Update I When was the last time you read the
Journal of Nutrition Education at the beach? That's exactly what Edward Barron, Deputy Chief Counsel of the Senate Committee on Agriculture, Nutrition and Forestry Committee did on his summer vacation. In fact, Senator Leahy may quote from the JNE Hunger Supplement during Senate floor statements, according to Ed. As the final days of the 102nd Congress race by, the hunger issue remains unfinished business. The Mickey Leland Childhood Hunger Relief Act, while garnering corporate support for its passage, has failed to find an acceptable mechanism to finance the increases in food stamps.
Nutrition Education and Training. By the time you read this column, election results will be final. The race being settled, it's time to prepare for a new Congress and a new administration or a new term for the President. The Society has begun work on reauthorization of the
Nutrition Education and Training Program (NET) by convening a meeting between representatives from key professional groups interested in the NET program and key Congressional staff. The groups will recommend revisions to the program that will address, among other things, program coordination with Comprehensive Health Education, state level staffing requirements, and integration of the program with all child nutrition programs. Many of these ideas materialized during NET strategic planning conferences sponsored by USDA's Food and Nutrition Service. Looking at FNS's new mission statement, it's clear that the agency supports NET and will assist greatly in developing NET legislative language. "The mission of the Food and Nutrition Service is to safeguard the health and nutritional well-being of the nation through administration of nutrition education and domestic food assistance programs."
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However, I do believe that truly effective leaders must be risk-takers, if what SNE does in the future is to make a real difference in the world. I know that there is much that we can learn from history, but we must not always look in the rear-view mirror, because if we do, we will not drive very far. Rather, let us steer straight ahead and create a future for SNE that all of our members will be excited about and others will want to become a part of.
The Society for Nutrition Education must position itself as the premier association linking the fields of nutrition, food, and education. If we do so, we can have a lasting impact on the lives of others, and the Society will be in a position to help its members meet the needs of the people they serve.
Changes challenge both private and public professional organizations alike. Our Society needs to be flexible, proactive, and visionary to accomplish more with less. We can get started on these challenges by trying new ideas, testing new strategies, and capitalizing on our diversity.
Jennifer E. L. Anderson, Ph.D., R.D. SNE President, 1992-93
Food Labeling. The final version of the new FDA/USDA food label regulations will have emerged by early November. Warnings to date foretell a volume of reading material larger than the 2,000 pages of proposals. While the government authors go on vacation, nutrition educators everywhere will pore over the new rules, trying to find a simple way to explain the new dictums to the public.
At the end of August, the USDA proposed two additional possibilities for the label format. One builds on the current label and adds the USDA/FDA dietary guidelines at the bottom. The other proposed format lists the Daily Reference Values (DRV) or Recommended Daily Intake (RDI) for each nutrient in a range that reflects the nutrient needs across all population groups. For example, the RDI for calories would be listed as "1600 to 2800." SNE believes these two approaches would be intrinsically confusing, to say nothing of how consumers would interpret information from two separate formats, one for meat and poultry products and the other for all other packaged goods. SNE submitted comments urging USDA to har-
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monize its format with FDA. SNE opposed both of USDA's proposed formats, since neither had been consumer tested. SNE strongly supported the use of single Daily Reference Values or Recommended Daily Intake value on the labels.
The need for food labeling education was once again stressed in SNE's comments. To foster private and public collaborations on food labeling education, the FDA and the Food Safety and Inspection Service of USDA sponsored a National Exchange for Food Labeling Education in early September. Cheryl Achterberg, Laura Sims and Susan Welch, three SNE members, provided research-based advice on how to educate consumers on the use of the food label. To solicit, catalog and distribute food labeling education information, the FDA/USDA Food Labeling Education Information Center will be operated through the National Agricultural Library, Food and Nutrition Information Center. If you have or are developing labeling education programs or if you want to know what is being created, please call Gina McNeal, 301-504-5719.
Nutrition Labeling of Dietary Supplements. Efforts of the dietary supplement industry convinced Senator Hatch to introduce the Health Freedom Act, which
would exempt dietary supplements from the health claims requirements of the Nutrition Labeling and Education Act of 1990. This bill makes it more difficult for FDA to takt;: enforcement action against dangerous or misleadingly labeled supplements. Congress passed NLEA, in part, to curb misleading health claims by members of the food and supplement industries. The NLEA does not restrict legitimate health claims. The Act simply sets a standard whereby health claims can be made only if significant scientific agreement exists. The Health Freedom Act would allow the supplement industry to make claims supported only by a "reasonable basis" that could consist solely of unpublished scientific studies. Under this type of double standard, consumers could be persuaded that only supplements hold the solution to health problems. SNE has been working to assure that consumers are not misled by the adoption of such legislation and that NLEA applies equally to packaged goods and dietary supplements.
Food Biotechnology. On May 29, the Food and Drug Administration (FDA) published the government's position on biotechnology-derived foods. Proposed rules would regulate genetically engineered foods on the same basis as other
SNE Comments on the FDA Proposed Nutrition Label Format Regulations
Comments prepared by Fran Cronin, Ph.D. and Cheryl Achterberg, Ph.D., with the assistance of SNE Food Labeling Task Force members Janet Tenney, Janet Witt, Pat Snyder, Laura Sims, and Kathleen McMahon.
Docket No. 91N-0162 Food Labeling: Fonnat for Nutrition Label
As the leading national professional association committed to linking nutrition, food, and education, the Society for Nutrition Education (SNE) welcomes this opportunity to comment on the proposed nutrition label format.
SNE has long supported mandatory nutrition labeling of all foods of significant nutritional value and prominently declaring the content of all food components of dietary importance. While this goal may be difficult to reach in a limited number of cases, e.g., small packages or in food service, efforts must be made to prOvide consumers with reliable nutrition information in an easily understood manner to em-
power them to make individual food choices. An appropriate label format must attract consumers while providing easily read and understood nutrition information.
Harmonization of USDA and FDA Fonnats
SNE is very concerned with certain statements in this proposed regulation that suggest USDA may be planning to propose a different format for food labeling than FDA [57 FR 32056]. SNE strongly opposes use of different label formats by the two agencies because consumers would be extremely confused and educational efforts would be greatly handicapped. Regardless of whether FDA or USDA regulates a food product, all processed foods should have the same nutrition information presented in the same format, and use the same serving sizes and descriptors. Differences in label format will decrease the comprehensibility of the label by consumers (Adler, 1991).
foods, arguing that judgments should be made on the outcome, not the process, of the biotechnology-derived foods. If modified foods contained an allergen, lost some of their original nutrients, or contained some toxin, FDA's proposal would require the same type of pre-market approval as the agency now uses in clearing new food additives. In the next few years, FDA estimates that food biotechnology will create nearly 800 different developments ranging from biopesticides to pest/disease resistant plants, and from vegetables with higher nutrient content to plants that can be produced more effiCiently with less cost and spoilage. Our food supply is quickly changing and consumers need help in comprehending these changes. Some consumer groups are asking for product labeling and for regulation of modified foods as additives subject to premarket approval. The European Community is preparing a directive on "novel foods," implementing new requirements that have trade implications. With such potential changes in America's food supply, this complex public policy issue needs the careful study and attention of nutrition educators.
Nancy Chapman, Director SNE Office of Public Policy 1723 U Street, NW Washington, DC 20009
SNE strongly objects to the format (Appendix F) suggested by USDA. This format does not meet the requirements of the Nutrition Labeling and Education Act (NLEA). The NLEA amendments require that the information on the nutrition label be conveyed in a manner that enables consumers to understand its relative significance in the context of a total diet. USDA's proposed format is inadequate in meeting this goal. Most of the Dietary Guidelines are about foods. Consumers will have difficulty making a direct connection between the Dietary Guidelines and the other label information. Previous research on the Dietary Guidelines verifies this conclusion from the consumer perspective (Achterberg et al., 1989; Achterberg and Bradley, 1991; Trenkner and Achterberg, 1991).
Inclusion of the DRV on the Label
SNE agrees with FDA and strongly supports the inclusion of the Daily Reference Value (DRV) on the label [57 FR 32070]. This satisfies the requirements of the 1990 National Labeling Education Act (NLEA). The NLEA amendments require that the information on the nutrition label be conveyed in a manner that enables consumers to understand its relative Significance in the context of the total diet. SNE pre-