FDA warns about false claims made regarding turkey.

24 November 2009-U.S.

FDA Watch: Warning Letter Issued to Food Producers

In surprise move today, the The US Food and Drug Administration has written warning letters to United States turkey producers, the growers and processors of the popular Thanksgiving element, explaining that they have reviewed the general labeling of the industries’ frozen, uncooked turkey products and found that most labels contain "serious violations" of federal regulations.

The details of the FDA findings are in a letter dated earlier this week, from the Midwest director for the FDA to turkey producers who are purveyors of the central dish of America’s one true National holiday.

According to the FDA, turkey producers are breaking federal regulations on three counts: they are growing, processing turkey as an "unapproved new drug" and misbranding the product by making "unauthorized health claims" and “failing to inform the public” about health risks and dangers of consuming the product.”

The FDA letter to the food companies states:

"FDA's review found serious violations of the Federal Food, Drug, and Cosmetic Act (the Act) and the applicable regulations in Title 21, Code of Federal Regulations (21 CFR)."

The FDA said that the frozen and unfrozen turkey product labels promotes it like a drug intended for use in the "prevention, mitigation, and treatment of disease". The letter drew particular attention to phrases that say the product claims pertaining to cholesterol, and the other “healthy white meat.” Claims pertaining to the ability to lower cholesterol by "4 per cent in 6 weeks", that it can also reduce bad cholesterol by 4 per cent, and that it is "clinical proven" to lower cholesterol. The FDA went on to address that such claims are spurious at best when considered that turkey is rarely made without seasoning and never served as a stand alone dish.

The letter does not address the veracity of the claims, instead it addresses the point that by making such claims then the product is really a drug and should go through the proper channels for obtaining drug approval.

For example, as the letter explains, the claims indicate that producers have claimed that turkey is: "Intended for use in lowering cholesterol, and therefore in preventing, mitigating, and treating the disease hypercholesterolemia." And by claiming that the product lowers total and bad cholesterol, then it is also claiming to treat heart disease, for which total and bad (LDL) cholesterol are known risk factors. This is what puts the product in the "new drug" category, and the letter quotes several sections of "the Act" to support their case. The FDA said another reason that turkey is considered to be a "new drug" was because under another section of "the Act", it is "not generally recognized as safe and effective for use in preventing or treating hypercholesterolemia or coronary heart disease".

The letter’s second claim was the equivalent of a bombshell when the FDA took an aggressive tact on the known levels of tryptophan contained within the natural chemistry of turkey, both uncooked and frozen. Tryptophan is an essential amino acid, meaning that the body can't manufacture it. The body has to get tryptophan and other essential amino acids from food. Tryptophan helps the body produce the B-vitamin niacin, which, in turn, helps the body produce serotonin, a remarkable chemical that acts as a calming agent in the brainand plays a key role in sleep.

The FDA acknowledged that they had no evidence that turkey producers were artificially enhancing higher levels of tryptophan during the typical 20 week growing season, but the FDA made no bones about their view that turkey producers were not discouraging turkeys from engaging in eating habits and activities that may enhance the ability of young turkeys to produce dangerous levels of tryptophan, which in turn would be passed on to ultimate consumers of turkey.

The FDA said that the dangers of high levels of tryptophan are well-known, particularly around the Thanksgiving holiday season when excessive amounts of turkey are consumed by vast portions of the American public. Turkey producers “turn a negligent eye” from the glut of turkey consumption, according to one unnamed source close to the FDA. “Turkey producers are no different than pushers on the street” (sic) referring the lack of conscience in distributing a “laced” product. Further parallels were made to a turkey being the equivalent of “a massive syringe, willingly being placed in the mouths of ravenous Americans by their own hand…” Ironically, sociologists point out that postprandial Thanksgiving day sedation (and its dangers) likely has more to do with what else is consumed along with the turkey, in particular massive doses of carbohydrates in deceptive forms and excessive alcohol consumption. This observation correlates with the FDA’s third claim.

On the issue of misbranding, the FDA said that turkey producers bear "unauthorized health claims in its labeling" and cites text on the various producers' websites, which under the Act is considered to be part of the product labeling, as being faulty in this respect. The labeling should include disclaimers and warnings akin to "WARNING: eating large quantities of this product can produce drowsiness, feelings of lethargy, excessive bloating and gas." While the FDA has not elaborated, FDA precedence would likely also lead to similar warnings of “WARNING: do not operate or use heavy machinery or operate a vehicle after consuming this product” or “ WARNING: consumption of this product mixed with alcohol and carbohydrates could result in adverse health and social consequences.”

The letter also refers to another labeling omission about the excessive trimmings and ancillary dishes typically served with turkey. Dressing with high levels of gluten and salt, yams with sugary marshmallows and brown sugar, green beans with mushroom base and salty dried onion toppings, cranberries laced with high concentrations of pectin, sugar and red dye #40, potatoes with copious amounts of starch and preservatives (although garlic and chives do have certain health benefits) and the kiss of death, turkey gravy which has highly concentrated levels of tryptophan itself, cleverly disguised in turkey drippings and fat. Space does not allow for a detailed description of potential life-ending versions of desserts that quickly follow the ritual gluttony or the fluids used to “chase down” the collective meal or the desire to forget the conversation with the participants that you are dining with.

The FDA said the lack of adequate warnings about consumption, use, side effects and use of the product while being consumed with ancillary products fails to meet the authorized format because, for example, like the other claim, it does not mention the obvious warnings, nor does it address the overall context of the healthy (or lack thereof) diet.

In what could otherwise be categorized as an unprecedented coda, the agency also took issue with the added phrase "Have a Happy” before the seasonal references to Thanksgiving on most packaging without actually citing a violation or potential violation as a basis. As the FDA letter explains:

"The claim authorized through the notification procedure of “Have a Happy” does not emphasize the relationship between perceived happiness that one may have prior to consuming the food and stark contrast to how one feels within a half hour after consuming it, not to mention how they feel about it a week later when consuming leftovers." Thinly veiled references to "mislabeling" appear to be the motivation as the "claim" of "happy" is an intended outcome as opposed to a seasonal greeting. Third party sources have commented that anything relative to “Have a Happy…” and the FDA in the same sentence clearly has no idea of what they are talking about.

Turkey Producer spokesperson, Jonathon J. Johnson, Jr. provided some confusing commentary at a press conference this morning stating that “as far as we know, the turkeys are in good health and generally happy until two weeks before Thanksgiving.” “We cannot comment on the use of drugs by any of our turkeys.” “We have nothing further to add... (unintelligible) ...we’re happy...(unintelligible)… bender; I have to go now.”
PETA spokesperson, Drew Laney released a statement applauding the FDA for its criticism of the turkey producers, but attempted to draw blood on the FDA by demanding that they immediately enact a “Cease & Desist” on the entire industry to avoid further loss of life, health risks and obvious dangers. Laney's release elaborated that this would have a benefit to humans as well.

Turkey producers have 15 days to reply with an explanation of how they intend to "correct the violations" and to ensure that "similar violations do not occur". While the FDA has written off this years’ Thanksgiving holiday as having too much momentum to provide a meaningful impact on changing labeling practices, the FDA is aiming to bring sweeping changes to the turkey industry prior to the upcoming Christmas/New Year’s holiday consumption season.

                    - submitted anonymously (Think I could get a job writing for the Onion?)

Get low to the ground – and start listening!

I believe eating ‘low to the ground’* is something our bodies naturally want – and, perhaps, even need. Given our busy lifestyles, it’s nearly impossible to hear (or even listen to) a body all cranked up on drive-thru food and over processed foods that need to be loaded with colorings, added flavors, preservatives and fillers just to make them palatable. I know, through personal experience, that the longer I went without eating manufactured foods, the more I began to hear my body. Sounds a bit extreme - but it actually happens. I didn’t set out expecting or looking for this either. I did it as a health plan – as a way to eat more naturally. However, as a by-product of doing so, my body started talking to me. Kind of like a car telling you to change its oil, get new brake pads or get more gas. (I love the expression “I run like a well oiled machine”. I think that’s true.)

I listen to my body on other subjects all the time: When I’m tired, I rest. When my knee hurts, I walk instead of run. When I’m stressed, I try to exercise. Why wouldn’t eating, one of the most basic things we do for our bodies, be exactly the same? One way our bodies talk is through the language of cravings. I crave certain foods when I am tired or stressed – or energetic. If we teach our bodies - by giving them nutritious food for a while – and then listen – they will start to tell us what we need. A body hyped up on fast food and preservatives will probably crave more of the same – it just doesn’t know any better. But given 3-4 weeks ‘low to the ground’, the body will start to crave nutritious foods.

I know, with schedules and families to feed, it’s hard to stick to such a pure regimen, but just starting to think in these terms can make a huge difference. You can be as extreme as you like: how far you go is up to you. Simply being conscious of what you put in your mouth is a healthy start…
…it’s all just food for thought!

*Think of ‘low to the ground’ as foods locally grown, minimally processed and probably eaten by your ancestors.

Ann Sullivan is a self-proclaimed “Food Anthropologist” and an avid health and fitness activist. After 20 years as a wife and stay-at-home-mom, preparing meals to satisfy the masses instead of her inner voice, she has started listening – and is discovering an entirely new level of nutritional health and personal satisfaction.