Last week, when you went to sleep, you were certain that you had no illegal substance in your home. But now you may be harboring nutrition enemy number one. That seemingly innocuous container of frosting or that roasted veggie frozen pizza may now contain a food ingredient that has been declared no longer safe—trans fat.
The Food and Drug Administration (FDA) has posted in the Federal Register a call for comments on its decision to rescind the Generally Recognized as Safe (GRAS) status for partially hydrogenated oil (PHO) due to its content of trans fat. Since PHO or trans fat will be considered a food additive, food companies would have to stop using it in any amount in food unless that company applies to the FDA for approval prior to going to market. And what are the chances the FDA would allow that? This announcement is a wake-up call to the food industry that consumers don’t trust how food is made and the opportunity to educate, inform and connect with them is now.
The FDA decision comes after years of smaller steps to educate and inform consumers about the ills of trans fat in the food supply. The FDA started the educational efforts with labeling requirements to add trans fat to the nutrition facts panel. Over the years, the Institute of Medicine, the American Heart Association and the Dietary Guidelines Advisory Committee have all warned that trans fat may increase LDL or “bad” cholesterol levels, decrease HDL or “good” cholesterol levels and subsequently increase the risk of coronary heart disease.
It may be possible to debate some of the science such as the number of observational studies that the FDA chose to use to argue its case even though health claims cannot be supported by that data. Or we may want to argue that trans fat comprises only 1 to 2 percent of the calories in the American diet so such action by the FDA is unwarranted. Resisting the urge to argue these points, we can be certain that there are three main reasons this decision from the FDA is problematic.
Number one, erosion of consumer confidence in the food industry
Let’s face it, consumer confidence in the food supply is at an all-time low. Activists have already been fanning the flames around obesity, GMOs, processed foods and carbon footprints, but headlines on the trans fat ruling were adding fuel to the fire by roundly citing the 20,000 heart attacks and 7,000 deaths that can be attributed to trans fats each year. No matter that the statistic was presented without attribution to any scientific study or organization. Consumers can only be left to wonder, “You mean trans fat wasn’t safe and you put it in my food!” The FDA’s action will only turn the volume up. Science evolves, but that is a nuance lost on consumers, media and, frankly, many health professionals. So far, the industry’s stance has been defensive, pointing to previous efforts to remove trans fats from their products and their promise to work with the FDA. Health professionals, meanwhile, have joined the media in citing the harms of trans fat but have scrambled to figure out where it is and how it will impact the food supply. The industry must engage consumers in an open dialogue about how food is made and how innovations are developed and evolve over time. Today’s FDA action is a clarion call to the food industry to educate consumers, media and health professionals about how it makes the foods we love. This means not talking to them like a marketing target but bringing them in closer to see and hear how it’s done to showcase the value of the industry to consumers and their health. We must remove the veil of mystery to help consumers embrace what the industry is accomplishing.
Number two, what might this mean for other ingredients under scrutiny
This move by the FDA could potentially set precedence and open the floodgate for similar arguments from the Center for Science in the Public Interest or the Pew Trust aimed at other food ingredients thought harmful. Sodium, sugar and caffeine are already in the cross hairs. If PHO (trans fat) loses its GRAS status based on the risk it poses to health, then what is to prevent the same argument for sodium, sugar, caffeine or the ingredient du jour? To be fair, there is a difference between an ingredient that when consumed excessively poses a risk versus something that is unsafe. Sodium, sugar and caffeine do not pose harm when consumed in reasonable amounts, but some groups are already floating the GRAS issue for those ingredients. The industry needs to be aware of this energy and begin laying the foundation to correct such efforts.
Number three, more reformulation at the cost of innovation
When health authorities started to warn against trans fat and the FDA required labeling, the food industry invested significant time and energy in reformulating food and redesigning oil to reduce trans fat. The effort was so great that other innovations that could have improved nutritional attributes or safety of food had to take a second seat. To the credit of the industry, trans fat has been significantly reduced in the food supply. For the industry to go back and remove what’s left will distract again from other food innovations setting the food industry back. One opportunity, however, is for the industry to comment to the FDA on the time it would take to strip all trans fat out and perhaps account for this innovation lag.
The Federal Register notice provides a 60-day comment period. While some believe that could be extended there is no time to waste. This situation is a teachable moment for everyone within the industry and without. Nutrition and food science is a growing and changing creature and no doubt what’s in today maybe out tomorrow. However, the food industry, scientists and regulators must sit down together to understand how best to ensure the healthfulness and safety of the food supply. If the industry does not take the initiative, broad brush policy decisions like this one will become more common and costly.
Mary Christ-Erwin, Stephen McCauley and Ilene Smith contributed to this article.