To Be “Milk” or Not to Be? That is the Question!

17_Labeling_FDA_Public_Comments_BW_S

UPDATE: Comment Period Extended Until October 11!

August 27th is Deadline for Comments to FDA on Milk Standards of Identity

Background Information for the purpose of preparing public comments to the FDA concerning Standards of Identity for Milk

 

On March 29, 2018, FDA introduced the  “FDA Nutrition Innovation Strategy,” a comprehensive effort to review labeling of foods and an impact on human health, particularly in relation to preventable and chronic diseases.

“An almond doesn’t lactate, I will confess.”  And with those words, FDA Commissioner Scott Gottlieb, in a July 17 report by Politico,  amped up the debate about the relabeling of plant beverages which label themselves as ‘milk,’ which many believe are misleading and deceptive.

Although firm enforcement of FDA standards of identity should have been implemented several decades ago when “Plant Beverages” or “Nut Milks” first began to creep onto ‘dairy’ shelves, they were not.  No one knows the reasons why, but here we are, now with a debate and labeling examination which will cost taxpayers – and companies – millions of dollars.  Here’s some background:

A History:

First, it’s helpful to actually read and know about the standards as they exist:

000000_FDA_Standards_Identity_S

Standards of Identity for ‘Real Milk” were established in 1938 in the Federal, Food, Drug, and Cosmetic Act.

Part of the controversy results from the “real” vs. “processed” (aka ‘fake/faux ) nutritional properties of real milk.  The Wisconsin Agriculturist, in a July 23rd, 2018 article written by Fran O’Leary,  describes it this way:

Real milk provides eight times more naturally occurring protein in every glass, is wholesome and simple, and is a minimally processed beverage. Real milk also has no added sugar. The sugar in real milk is lactose, which is a naturally occurring sugar. Many types of nondairy milk, such as almond milk, contain sugar. Tell that to your friends and family members who believe otherwise.”

The Wisconsin Agriculturist concludes that article by quoting an emphatic statement from the American Dairy Coalition, which reminds real dairy advocates:

“It is crucial the dairy industry speaks up on the issue,” the American Dairy Coalition said in a statement. “We can no longer stand by” and allow plant-based beverages to be labeled as milk.

On July 26, 2018, the FDA released an official statement concerning its reasoning and approach to re-working milk / dairy labeling standards.

This statement occurred in conjunction with a July 26, 2018 Public Meeting to Discuss FDA’s Nutrition Innovation Strategy.   Several industry stakeholders went on the record with comments at that meeting, and those comments can be accessed via links here. 

Public comments on the FDA Nutrition Innovation Strategy will be taken until August 27, 2018.  (Update / 3rd week of August:  comments now taken until Oct. 11.)  Comments can be posted at this docket folder. (Electronic – OR – written/mail delivery submission is acceptable!).   It is particularly important for dairy FARMERS – those whose livelihood depends most directly on the sales of milk from their farms – to comment either individually, and via any producer organizations of which they are members!!

A Kathleen Doheny Article from WebMd:
“[Gottleib] . . . said the agency has ”probably not” been enforcing the standard of identity — and as a result, this nonenforcement has become the standard.”
– Agency will be ‘modernizing’ the standards of identity
– Comments expected be taken for a year
– Intentions to enforce standard of identity

The article also notes that plant / nut beverage sales increased 61% from 2012-2017, while Real Milk sales decreased 15%.

This proliferation of plant-based beverages has led to sales of those products which are expected to reach over $16 Billion (in US Dollars, but referring to the total world market value)  by the end of 2018.  That competition is in two forms: 1) dollars which have been removed from dairy communities & economies across the United States, and 2) Hundreds of Millions of gallons of real milk from real cows which no longer has a home, and has led to a long cycle of depressed prices which is steadily killing rural economies.

Much of that market displacement – and resultant stress on rural economies –  is believed to be because plant “milk” is a term which cannibalizes and preys on the goodness of natural milk, and the proven knowledge milk is natural protein source, readily absorbed by the human body.  

Spirited Plant-Based Advocacy Organizations and Individuals will challenge Real Dairy / Real Cow-Goat-Sheep-Mammal Advocates:

It should go without saying, but never doubt that those organizations and businesses who continue to build their financial empires while opposing the enforcement of standards of identity of “Real Milk”  will be relentless and tireless in their fight to bend the narrative in their favor.

A collaborative editorial in a Boulder, Colorado, web-based publication, advocates for the blurred lines and gray areas which are the basis for the advocacy of truth-in-labeling for those who believe traditional standards of identity exist for a reason.  Their citations to many will be questionable, and in some cases, outdated in their accuracy, particularly in the Greenhouse Gas Emission discussion.   At least one commenter suggests alternative beverages be called ‘milk substitutes.’

The Good Food Institute, whose website has the tagline “Creating a healthy, humane, and sustainable food supply,’ has already submitted this letter on July 23rd, before the July 26th hearing.

Food Navigator, in an article written by Elaine Watson, relays views of a firm which recently raised $24 Million to commercialize ‘animal-free proteins.”  According to the article, the company ‘takes food grade yeast, and adds DNA sequences . . . which instruct the yeast to produce the proteins found in milk.”

[Note: Admittedly, this technology is morbidly fascinating, but also gives real meaning to the terms “Sci-Fi Food” and “Frankenfood.”  We really, really need to ask ourselves:  just because we can – should we?”] 

 

Dairy Farming: continued decline, will it stabilize, or more consolidation?

It is no secret that the dairy farming industry is in a sea change of transition from smaller (400-head or smaller) herds to large herds of 1000 cows or more. And with that change, rural ag economies, the agribusinesses and services which serve those dairy farms are at risk themselves.

From New York, to Virginia, to Georgia, to Wisconsin, and to other regions, reports of dairy farms exiting from the industry are almost of epidemic proportions.  If these were job losses from a ‘factory in a big building’ closing, the public outcry would be deafening. However, because dairy is so scattered across the landscape and not contained in a single building like an industrial building, the loss of these economies is often a silent erosion that gets little public notice.

One example of some of the abuse that has occurred:

From The Cheese Reporter: Sunflower Butter!  A bid request from the USDA itself

But let’s give credit to #TraderJoes, who actually has an acceptable label on their plant beverages!  Kudos to them, and I’ll be back in their stores because they get it right! This is an example to others that it can be done!

900_Trader_Joes_Beverages_Labels_Right_F

Additional Links to Consider (and look for others to be added before Aug. 27th!):

From Feedstuffs:  Gottleib:  “FDA . . . is invariably likely to get sued”

For now, please begin to do your homework, and draft your comments.   It could be as simple as “Real Milk comes from Cows, Goats, Sheep and other mammals.  Make this simple, and have “MILK” be labeled that way!”

From the American Dairy Coalition – Background & bullet points:

You can save time, and comment via electronic means directly to FDA via the portal.  As you do this, please remember your comments may be able to be viewed by the public.

And here’s a link to the portal to comment by October 11 deadline – Comment here.

  • As of 5:00 pm on Monday, August 20, 496 comments were received.
  • As of 11:59 pm on Sunday, August 26, 2,303 comments had been posted.

Please make sure that by late evening, on Monday, August 27, and now on October 11, your voice will be among them too.

#MilkTruthMatters  #IdentityMatters  #RulesMatter

17_Labeling_FDA_Public_Comments_BW_S

TN June Dairy Month: Kickoff Luncheon & Then 4-H at work!

30_June_Kickoff_Raise_Glass_F

It’s ‘Raise A Glass’ Time in Tennessee!!

For several decades, the Tennessee June Dairy Month Kickoff has been the launch for events across the state highlighting Tennessee’s collective dairy industry.  The 2018 event was held at Battle Mountain Farm, the event venue of Hatcher Family Dairy Farm, College Grove, TN on May 30.  The rural setting, with Holsteins and Jerseys grazing in a nearby pasture, emphasized that tasty and nutritious dairy products truly do begin on a farm.

This event honors several aspects of Tennessee 4-H involvement in dairy related activities.  4-H County Chairmen, who conduct dairy promotion and awareness events across the state are recognized.  The Tennessee 4-H Dairy Quiz Bowl Finals are held. And always, an inspirational speaker brings life’s insights to 4-H’ers as they return home to begin June Dairy Month events.  Their activities allow them to compete for awards in several categories, which are presented at the next years events.

This year’s event was organized by Denise Jones, of The Dairy Alliance, who put the engaging tables and decor together and set a great dairy mood as folks entered the beautiful event venue.  She was assisted by Joan Benton and Cindy Cooper of The Dairy Alliance.

Following are some photo highlights of the event.

30_June_Kickoff_Intro_F

Emma Mull, McMinn County, Grace Rich, Clay County, and Elizabeth Bright of Loudon County, are three of several County Dairy Month Chairs who have a full slate of activities planned.

You can follow Grace on Instagram as ‘udderlylegendairy,  Emma will be social on Facebook as McMinn County June Dairy Month, and Elizabeth Bright’s creative videos and spots are on Facebook at June Dairy Month – Loudon County.  Look for other social promotions and public activities from chairmen in your area of TN!

30_June_Kickoff_4H_Mull_Rich_F

Part of the setting front and center of the banquet hall, framing the dynamic Denise Jones, the event organizer, of The Dairy Alliance!  Did you know MILK is Tennessee’s Official Beverage?  It was given that designation in 2009 by the Tennessee Legislature.

30_June_Kickoff_Denise_Jones_Dairy_F

Three 4-H’ers, who will become future consumers, related how their participation both in Dairy Production Projects and Nutrition, Health, and Fitness projects, have made them appreciate dairy’s unparalleled nutritional benefits, along with the hard work of Tennessee farmers who produce that milk. Abigail Ferguson, Ashley Bell, and Kathryn Fellhoelter all gave great presentations.

30_June_Kickoff_4H_Speakers_F

Marshall County is the winner of the Dairy Quiz Bowl Competition, and will be headed to the National Contest later this year.

30_June_KickOff_Quiz_Bowl_Milksheds_F

Some more of our Tennessee County 4-H Chairmen!  Do you know who the 4-H Dairy Chairman is in your county?

30_June_Kickoff_4H_Chairs_1

30_June_Kickoff_4H_Chairs_2_F

Jeff Aiken, President of TN Farm Bureau, and a former dairy farmer himself, represented the organization as an event sponsor, and brought words of encouragement to those attending.  He was accompanied by many Farm Bureau staff members from across the state, as they came to support the TN June Kickoff event.

30_June_Kickoff_Farm_Bureau_Sponsors_F

Do You Know “What’s Your Why?”

30_June_Kickoff_Wilson_Keynote

George Wilson, who retired from the Tennessee Titans after an NFL career with several teams, challenged the audience with the question “What’s Your Why?”  A two-time Walter Payton Man of the Year in the NFL, he inspired with point after point:

  1. Be the first to show up, and the last to leave. Be grueling, tough, and unrelenting in the pursuit of your dream!
  2. Be mindful of what you do and the choices you make, and of those whom you allow to make decisions for you.  [He began at an SEC school, Arkansas, on an academic scholarship, walked-on and made the football team, and then was able to receive a football scholarship because someone got arrested and lost the scholarship they had.  And that set the stage for his 11-year NFL career.]
  3. Sometimes in life, “Opportunity is Disguised as Hard Work!  [It took 15-16 years of hard work and sweat on the football field to finally get a starting position on an NFL team and an interception against the cowboys on national TV.]
  4. “I give of myself because others gave of themself to me.  THAT’S MY WHY! He prayed, “Lord, if you you allow my dream, I will give back.  And then noted, “that is a debt I’ll never repay!”
  5. Why does he care about Fuel Up to Play 60?  Because his thoughts were captured by this statement: “We could be raising the first generation of kids who won’t outlive their parents.  FUTP 60 puts power and decision-making in the hands of students who participate in the program.”

 

Celeste Blackburn, President of TN American Dairy Association, served as MC for the event, and gave Mr. Wilson an appreciation gift featuring some of Tennessee’s farmstead dairy products.

30_June_Kickoff_Speaker_Basket_Wilson_F

At the event close, Jimmy Hopper, Assistant Commissioner of the TN Department of Agriculture overseeing TDA’s Consumer and Industry Services Division, was honored with the TN Outstanding Dairy Promoter Award. One of Hopper’s responsibilities was overseeing the Dairy Quality Division, charged with quality and safety on dairy farms and in milking barns, in processing plants, and addressing retail dairy sales outlets.  Jimmy went above and beyond a ‘job description’ to serve Tennessee’s dairy industry.  And he did it with class and respect for all he worked with. During his tenure, Tennessee’s first robotic milking barn was installed.

The Tennessee Cooperator has a great summary of Hopper’s career.

Always a man of humility, Hopper encouraged young folks present to find a dairy farmer and work with them for a while.  He noted there was no better role model for developing a work ethic that would serve one well throughout a career.

30_June_Kickoff_Hopper_Award_Blog_F

McMinn & Loudon 4-H’ers Helped with a Milk Drive on World Milk Day!

Wasting no time getting started with June Dairy Month promotions, and in a way that serves others, the McMinn Co. 4-H Chairman, Emma Mull, and Loudon County’s Elizabeth Bright spent World Milk Day (June 1) helping Second Harvest in East TN at the Randy Davis Memorial Milk Drive. 

The event they participated in was held at Lenoir City, in Loudon County, Tennessee’s #1 Dairy County.   On that one night, in a 4-hour period, 1457 gallons of milk were purchased and loaded on a Second Harvest refrigerated truck, destined for distribution to neighbors in need in their 18-county East TN service area.

These annual events, held onsite with the cooperation of Ingles Groceries in East TN, encourage purchases of milk at the groceries for the purpose of distributing milk to hungry neighbors.  With their hands-on approach, the onsite drives encourage human-to-human connections in the spirit of giving back, and ignite a life-long spirit of being a benefactor to the community.

Customers coming in to the grocery stores can contribute in two ways:  they can make monetary contributions, which the Milk Drive Team uses to purchase milk from the store, or  they can purchase the milk themselves and bring to the waiting Second Harvest Refrigerated Truck.

30_June_Kickoff_Milk_Drive_Blog_F

Tennessee Agriculture has had a very difficult spring in 2018, dealing with price and market challenges in all sectors of agriculture, Dairy included.

With future consumers enthusiastic and connecting with farmers and industry leaders present, the 2018 TN June Dairy Month Kickoff served as a happy occasion to remind us all in the TN Dairy Industry to reflect:

So, “What’s Your Why?”

30_June_Kickoff_Wilson_Keynote