Brady Ratcliffe, Elizabeth Fladling, Kyle Marshall

Executive Summary A lot of debate surrounds the issue of food safety and contamination within the United States. This controversy struggles between the health and safety of our consumers and an efficient means of food distribution among a capitalistic government. With the emphasis in today's society being geared toward business profits from an organization standpoint and lessening the amount coming out of citizens own pockets from an individual standpoint, it makes it a difficult task to provide food without the use of additives and without it being processed. After our research however, it became clear to us that something needs to be done about our flawed food market. Our proposal involves a gradual shift in government subsidies towards healthier, more localized farms as opposed to the previous massive commercial farms that are heavily subsidies. We believe that the agra-industry should be more state regulated while continuing to have the HHS and the FDA as overseers by implementing laws that restrict faulty practices and unsanitary conditions. At the same time, it is necessary to allow different areas across the nation the means to maximize their own resources in order for us to receive the healthiest food products possible as opposed to only several commercialized farms distributing their food across the country to feed everyone. In order for everyone to have a realistic opportunity at having such food available for them, more incentives and price regulations need to be applied with buying locally grown produce and livestock.

Our course of action includes getting a more accurate and easily accessible range of information to the general public regarding the nutritional facts of food products sold

in the U.S. An increase in authority given to the FDA would make this goal considerably more feasible. In turn, our plan would gain more public support for the change that needs to take place. The change itself involves a concrete, progressive step-process in which a shift in government subsidies takes place. This shift would ultimately become directed completely towards healthy production practices as oppose to large-scale commercially grown products. These healthier methods will become more appealing to farmers and meat packing industries and the gradual process in which our plan will be carried out will give producers a sufficient amount of time to adjust.

Introduction Kathleen Sebelius, as the Secretary of Health and Human Services, you oversee government agencies such as the FDA. Because of the high authority associated with your position, we feel that your assistance is the most direct way of fixing the current problem of our food industry. Problems caused by this area are affecting the health of our nation and therefore are of critical concern. We believe that the food industry as a whole needs to make a shift from mass production and giant factories to more locally operated small farms. Our current system of large businesses running food is a hazard to public health. The risk of food contamination among less commercialized operations is considerably lower. As the Secretary of Health and Human Services you are directly responsible for the well-being of the people. You have the power to move us away from the unsafe and unhealthy practices of this flawed industry. The types of changes we are asking for is a shift in subsidies. These would be gradual changes over time so companies in order for producers to ease into the changes. There will be resistance from large corporations who are making

large profits to turn to healthier production methods because many times they mean higher costs of production. However, we would like there to be more subsidies directed towards safe and healthy production strategies as well as tax breaks in order for these operations to become more appealing. This creates an incentive for mass corporations to change for the better. Price caps on this food in grocery stores may also be necessary throughout this shift in government subsidies in order to make it available to all people at all income levels. What we are suggesting is an industry reform that will take time but in the end will benefit everyone. First, we want to get the word out about the flaws of big business, its corruption and unsanitary environments, through publications, internet, social medias, educational classes, commercials, and other public broadcasts along with restrictions on false advertising in the form of packaging and commercials. Next, the FDA should have more control over regulations and enforcement. Our proposal will happen in segments; in the beginning new requirements will be implemented in order to receive incentives for good farming practices. These would include heavy subsidies for farms that follow the rules. These regulations include avoiding the use of unnecessary chemicals and pesticides used on crops. We are calling for more regulations on living conditions of live-stock and mandatory health standards on all food products. After the shift in government spending from factory farms to more locally owned, better ran farms, then new rules will become absolute to deter companies from reverting back to their old ways. Once these rules are set in stone they will be punishable by law and only overlooked in dire situations. Our plan incorporates major changes in a balanced way.

Rational Farming in the United States has continued to progressively move more and more toward mass production and away from conventional small farms. These types of practices have had negative health consequences on consumers. There isnt much regulation in the industry either. Food production is run by a small number of huge farms that dominate the system. Though there are agencies set up to check on these companies and their practices, there is little done to make sure everything is safe and even less done when it comes to punishment of breaking these rules. Though new laws continue to be proposed and put into effect there is a still a lot that needs to be done. After World War II, as people became more urbanized, the demand for food from grocery stores and restaurants increased. Fast food chains began to become more popular and farmers had to come up with ways to get a lot of food to consumers for cheap. According to a PBS article about the movie King Corn, corn production increased after World War II, leading farmers to start using corn to feed their live-stock. This has negative effects on animals; E.R. Orskov writes in The Journal of Animal Science that grain supplemented diets lead to weight gain, less nutrients absorption in the rumen, and rumen complication in these organisms. Scientific America said that in a study 93% of the tissue that comprised hamburger meat was derived from corn. This could be due to the all the subsidies for corn production. Environmental working group has data from corn subsidies from 1995-2010 showing they totaled $77.1 billion allowing farmers to grow and sell corn for very low prices. However, this tends to negatively affect both

animals and consumers. Unlike corn that isnt naturally broken down by cattle and causes farmers to give them many antibiotics. By pumping cows full of antibiotics this is creating more drug resistant strands of these certain bacteria that is passed down to humans through ingestion of contaminated meat. In 1976, chickens that were given a human antibiotic, tetracycline, were becoming resistant. The animals went from no resistant strains to 31.3% of them having one within 5 months (EHP Brogan & Partners). Antibiotics are also used as growth promoters which adds to the problem, an estimated 11.2 million kg a year are used for this purpose (EHP Brogan & Partners). An article by the Environmental Health Prospective (EPH) says that when low levels of antibiotics are used bacteria isnt fully eliminated and is able to survive and mutate into resistant strains and then passed on to the next generation. An article by Epidemiologic Reviews in the Oxford Journal talks about E. coli O157:H7 has a growing problem in the United States saying it was found in 63% of feedlots around the nation (Epidemiologic Review). Diseases like these are made worse through poor living conditions of live-stock in the Concentrated Animal Feeding Operations or CAFOs where these animals are kept. An article by the Environmental Health Prospective explains how CAFOs are causing increases in zoonotic diseases, or diseases that can be passed from animals to humans. The article talks about avian influenza causing deaths in both poultry and poultry workers due to the unsanitary conditions where the animals were kept. Though there are many studies on these facts, corn continues to grow in its use as feed to the animals we consume. The article by Environmental Health Prospective goes on to say how corn-fed cattle are also low in monounsaturated or good fats like omega-3 and high in saturated or bad

fats (EPH). This leads to another growing problem that seems to be highly correlated to modern day food practices is obesity. Since the 1970s there has been a steady rise in both childhood and adult obesity in the U.S. shown by a study from the Centers for Disease control. This overlaps the increasing popularity of fast food chains, Eric Schlosser writes in his book Fast Food Nation, In 1970, Americans spent about $6 billion on fast food; in 2001 they spent $110 billion, ( Fast Food Nation). The CDC tells how obesity can cause a variety of health problems such as diabetes, hypertension, stroke, cancers, liver and gallbladder disease, dyslipidemia, heart disease and more. These consequences of poorly run farming practices are hazardous to the health and well-being of humans. More needs to be done in the way of government regulation. Currently, branches of the United States Department of Agriculture (USDA) oversees food productions to make sure its safe. These agencies consist of the Food and Drug Administration (FDA) which oversees the United States food supply, according to their website, and the Food Safety Inspection Service (FSIS) which ensures the quality of meat, poultry, and eggs. Both branches deal with recalls of products and inspections of producers. However, in terms of punishment for companies that dont follow a good procedure, the FDA manual put that responsibility lies in the hands of the federal government and actually has little control over it.

Issues The Status Quo

for

Consideration

The structure of the current Food Industry has been in place for a very long time. With an industry so large and so powerful, it is going to be very hard to get it to

change easily. The inner workings of the food industry are comparable to an engine, very complicated and intricate. Remove one part, and replace it with another that is not quite the same shape, and the whole system shuts down. In order to prevent this from happening to the food industry, the little reforms and bills need to be carefully shaped so that when they are put into place, they will work perfectly even though they are not exactly the same. There are some benefits to leaving the status quo of the current system alone. First of all, it would be very expensive to reform a nationwide industry. Considering how the majority of the American populace has such a large aversion to paying taxes, the money for this would be coming directly out of the federal governments pockets, unless major support from interest groups is gained, which is also very difficult to assemble. So yes, not doing anything would definitely save a lot of money. Secondly, you have to think about how our system of capitalism works. Industry does not like to be told what to do, so at the smallest hint of danger, companies will purposefully shut down to punish the government for trying to make things better. This creates a plethora of other problems for the economy in the shape of lost jobs due to companies cutting back on production, a huge rise in food prices that could be potentially be worse than the food crisis of 2008 and other issues that would ultimately be detrimental to our economy's fragile state. Despite all of the reasons to not try and fix the food industry, there are plenty of reasons to enact new policy. If it is done in the correct manner, none of the aforementioned downfalls could even happen. Everyone would be happy and, most importantly, healthy.

One major production law in place currently that governs good food production practices is called the Good Manufacturing Practices (GMPs). It is published in Title 21 of the Code of Federal Regulations, Part 110. GMPs describe the methods, equipment and facilities used for food production, as well as the minimum sanitary and processing standards. Then, there is the Food, Drugs and Cosmetics Act. This is another big law that lays down pretty much everything that the FDA can and cannot do, and goes into great detail about every conceivable aspect of the production and distribution of foods, drugs and cosmetics. Also, there is a section about what authority the FDA actually has over these laws, and what the punishments are for companies falling below the standards. (FDAC Act, U.S. House of Representatives 2005) So, why then, if there are so many laws, regulations and standards that are required to be met by the food industry, are there so many problems with our production industry? The answer to that question is fairly simple. These laws, regulations and standards are all minimum requirements. So say that the minimum sanitary score for a company that has to be met on inspection day is a 70%; this company only has to score a 70% to get the okay to keep up production. Whats worse is that there is nothing stopping this hypothetical company from letting everything go for a while to the point that their true score could possibly be as low as 30%-40%, and then frantically cleaning up before inspection time. A very good and REAL example of this is a certain Red Lobster in Chillicothe, Ohio. With one of us being a food service employee, we have had a first hand account of how restaurants handle inspections. According to Brady Ratcliffe, the store that he works at is one of the best examples of this. He said that once and a while,

other managers would call his store manager and hint that maybe this week was Quality Inspection time. What did that mean? Everyone in the store, even the managers, would stay well after closing time to deep clean the restaurant to get make sure everything was in order. Granted, this example is of an outstanding situation, one where the store itself is under great management and is very clean. But, what is stopping other production facilities, restaurants or anywhere else that handles food products from doing this same thing, just on a much dirtier, less healthy way? One way to counter act this would be to raise the minimum standards say five points every few years. That way, over time, the production of food will slowly become more efficient and safe. How do you stop the problem of frantic inspection cleaning though? One way to effectively counter something like this is to have more inspections per quarter. Instead of having one inspection per quarter, add one big inspection, and maybe two or three unannounced surprise inspections. This would ensure that these companies arent falling behind on their duties to provide safe, wholesome food. If they are falling behind, proper sanctions could be enacted, be it a warning, a recall or a fine. Also, a gradual increase on the inspection pass score could be raised slightly every year, so eventually the score will be higher in the long run, making companies stay on their game. Unfortunately, the FDA currently does not have much power over enacting their punishments to violators, which is troubling. Well cover this a little later.

Quick, Major Reform Trying to change everything at once will end in utter failure. It would be comparable to the SB5 law that was passed in Ohio, but on a national scale. There were

sections of that bill that, yes, needed to be enacted, but they were all huge changes that effected everyone on a personal level. Broken up into bite size pieces, we believe SB5 would have been passed no problem, and the effects on the general populace would have been exponentially lesser. The same goes for some of the major changes we are proposing to you. Broken down into manageable pieces and possibly with some floating caps like the EPA has on CO2 output, these changes could be enacted with barely anyone noticing. The goal is to not make people angry, but to get business to be business and go for the options that generate the best income flow. So instead of a rapid change of the food industry, which many currently are asking for, we want to solve the issues on a realistic and fair timetable that will ultimately benefit the United States and its citizens in the long run. A fantastic way of doing this following our slower plan is by using unrealistic proposals in order to obtain something that would normally seem ridiculous. This is called the Shock Theory. Simply, it is a way of presenting an outstanding idea, and then presenting a smaller less unrealistic idea (after the first one is shot down) to get your way. Most people in congress will vote down the original since it would be so unrealistic. After the original bill gets broken down into smaller pieces, present these pieces gradually over several years; it will have a greater chance of being passed into law now that these pieces look far more reasonable compared to the behemoth you presented originally. That is how we get these bills enacted to laws. Politicians can begin with a shocking policy that consumers would never agree to, and then, after it is denied, spend the next few years passing small portions of the bill until essentially the original idea is made law.

Lack

of

Information

available

to

make

healthy

choices

Another critical concern that would be unwise not to take into account is the amount of, or lack there of, easily accessible information available to the average citizen regarding the quality of their food. This may not seem on the surface as urgent an issue as a few other points mentioned thus far, however, the uninformed consumer in reality, is one of the key mechanisms for these large mega corporations to succeed in carrying out their unhealthy practices. Whether it be because of various advertisement techniques or simple education on how to read nutritional facts to determine the quality of food, Americans Fast are clearly practicing unhealthy Food behaviors on a large scale. Industry

Without nutrition facts being readily available in fast food menus and carry-out bags, our citizens struggle to realize just how detrimental these abusive ingredients are to their bodies. The fast food industry has been responsible for the sky rocketing rates of obesity and diabetes in the past 30 years. Recent studies show that about one-third of U.S. adults (33.8%) are obese. Approximately 17% (or 12.5 million) of children and adolescents are obese (Center for Disease Control and Prevention, 2010). This trend is still currently on the rise while Americans continue to be completely oblivious to what they are putting in their bodies. A prominent reason for such occurrences is this lack of easily accessible nutrition facts with accurate proportions displayed. It is no secret that restaurants such as McDonalds or Wendys make it difficult for the consumer to attain these essential nutrition proportions. One would most likely have to ask a manager or some kind of executive to attain such information in the restaurant itself. Although many fast food

restaurants have began to post their nutrition facts on their websites, a study conducted by JAMA (Journal of American Medical Association) concludes that from the 269 food items tested, 50 (19%) contained measured energy contents of at least 100 kcal/portion more than the stated energy contents (JAMA, 2011). So now there is a problem of not only attaining the information, but also making sure the information is accurate. Implementing requirements for conducting nutrition tests while also making sure this information is available on menus and carry-out bags is absolutely necessary. Grocery Stores Even in grocery stores where such information can be found directly on the label, there is a certain amount of complexity that confuses the average consumer. Dr. Russell L. Rothman of Vanderbilt University ran a study attempting to determine how well American consumers can effectively read nutrition labels. It turned out that about two thirds of his sample group could not accurately recall the important facts noted on the label. It turned out that this result occured because as many as 90 million Americans have inadequate literacy and numeracy skills(Eric Nagourney, 2006). However, labels also proved challenging to strong readers. Dr. Rothmans conclusion stated that some were confused by the footnote of recommended daily nutrient intake, believing that it referred to what was in the product they were looking at (Nagourney). Ultimately, the issue seems to lie in the hands of the producers misleading format of their labels. Advertising Techniques A preconceived notion of food security seems to loom over our nation. This may be a result of advertising techniques and even false advertisement at times used by food companies. A study undergone by the Journal of Community Health gives a clear

realization that fast food ads target consumers at a young age and even target low income areas. The study involved the recognition of brand logos including fast food companies and other healthier food brands. It was shown that children were significantly more likely to recognize fast food restaurant logos than other food logos (Brand Name Logo Recognition of Fast Food and Healthy Food Among Children, 2008). Moreover, the study concludes that parents psychosocial and socio-demographic characteristics were associated with the type of food logo recognized by the children (Brand Name Logo Recognition of Fast Food and Healthy Food Among Children, 2008). This study runs parallel with the wide belief that fast food corporations take advantage of young consumers and of low income areas. These businesses thrive off of highly populated areas in which food desserts develop. These areas make it extremely difficult for residents to attain healthy food day in and day out. After further research, we found that Professor Roland Marchand has pinpointed a noticeable change in advertisements as these corporations began to exploit the status quo. He describes this shift in his recent book regarding American advertising explaining that this change included the development of modern advertising as it evolved from simple descriptions of the cost and function of an advertised product to the more complex modern strategies that may provide the consumer with very little information about the product and instead merely connect the product with a highly idealized life style (Schmidt and Burns, 1988). The new methods being used now clearly impact the opinions of Americans. False Advertisement Misinformation represented in advertisements is also a great concern. As I am sure you are aware, this has been a pressing issue in recent years. With the assumption

American citizens seem to have that anything printed or sold is truthful, it makes it easy for books, talk shows, magazine and newspaper articles, advertisements, and mail order companies to often distort nutrition information (Janice R. Hermann). This faulty information leads to hindered credibility of the entire industry regarding various product claims. As of now, which progressively seems to be changing, the FDA can (only) prohibit the introduction of any food, drug, device, or cosmetic that not labeled correctly. As a result, claims often appear in books, television, brochures, and promotional materials (Janice R. Hermann). Their argument is that their freedom of speech in such mediums are guaranteed in the constitution. However, this clearly is not representing the justice proposed in our constitution.

Lack

of

Authority

given

to

the

FDA

This issue seems to present itself time and time again. Although many believe that more regulatory authority needs to be given to the FDA, is it also a matter of available resources they lack to undergo accurate health evaluations. The FDAs authority is deemed not sufficiently nuanced to give the agency the flexibility required to implement a life-cycle approach to benefitrisk profiling by The Institute of Medicines book Challenges for the FDA. This hindrance in available resources necessary and lack of authority granted allows for major corporations to, in a sense, walk all over them. Clearly an issue regarding their financial aid is of utmost significance. To carry out effective and accurate tests or evaluations, they can only go as far as their budget allows them. To give a better perspective on how important this agency is to U.S. consumers, the FDA is responsible for regulating products that represent roughly 25 percent of all consumer

spending in the United States (Challenges for the FDA). The immense responsibility and considerable amount of operations they conduct seems to contrast with their executive authority in respect to our government as a whole. The FDAs ability to request recalls on defective, unhealthy, or unsanitary products can only go so far. When push comes to shove, it is the Federal Court Systems responsibility to take action and prosecute organizations that violate the regulations laid out by FDA standards. Depending on the company these standards may include an absence of disease causing bacteria or viruses within their ingredients, clean water being used, favorable conditions for livestock, accurate records regarding inputs to their food products, accurate records regarding food quality tests, etc. Providing the FDA with the appropriate tools necessary to evaluate the nutritious quality of our food and the ability to prosecute a fraudulent organization is absolutely necessary to ensure safe practices in the food industry.

Our Plan In order to get the peoples support, we must begin by increasing awareness of all that is going on in the food industry that they have been blind to. When American citizens get a view of the big picture, they will naturally gravitate towards change and reform. We can educate citizens on a number of issues throughout the food industry. We want people to know about the living conditions for livestock, any additives in the food they are consuming, and a certification from the FDA that their farm is clean and safe. We also want continued listing of nutrition facts on all foods as to inform consumers of the health threats. To accomplish this, we intend on using social media. We can do this through news stations, commercials, popular websites like YouTube, and mandatory

classes for youth, anything to broadcast the wrong doing in the system. Also, we argue that stricter labeling policies be enforced so that everything in a grocery store lists where a product came from and includes information about the producer. With knowledge, people become united and motivated to better themselves and the world we live in. Once the general public has been informed of the dangers it faces we can move to the more difficult parts of the plan. Beginning with our second step in which we intend on creating a slow process of shifting government subsidies away from commercial and corporate food suppliers and toward local farmers in an effort to support healthier food. The current political strategy of subsidization in the food industry is simply illogical. Foods that have proven there is a strong possibility of negative effects on human health are supported through the current system. In contrast, according to Daily Finance, vegetables and fruits are not subsidized in any way; despite the governments nutrition leaders desperately begging the public to eat more of these foods for the past several decades. Ultimately, the only way to fix this is to reverse the course. In our plan, we do not cut off all money given to unhealthy food providers immediately; that would be careless. We do, however, help incentivize commercial farms by subsidizing those local farms that are producing the safest and healthiest foods. We will do this by giving some power to the states to complete this task. Now, there will be certain farming practices that will help a farm receive the greatest level of subsidies. The top subsidies will eventually be given to those farms that produce organic food and use environmentally friendly organic fertilizer. Other farms will be subsidized in larger amounts for using grass fed livestock and antibiotics that are specifically created for animals. There will be many positives implications from these subsidies. Due to the state

sponsored subsidy on local food production, food that typically costs more than a commercially grown product will be able to lower their price to a more reasonably marketable level with the help of government resources. This will create a more equal playing field that will allow consumers the choice between healthy, organic foods and those foods that are fatty and sometimes grown in dangerous conditions. There should be a program that encourages a sound diet for Americans by making healthy food more affordable and more available for all citizens (NY Times). By following these types of healthy and safe farming practices, the American populace can choose between healthy foods that will not be expensive due to subsidizing. The third part of our plan ask the government to set mandatory health standards on all products made in commercial and local farms. These standards will be far stricter than those that currently exist in the food industry and will once again encourage healthy food preparation. As previously mentioned, we will give more power to the FDA and other governing bodies that can most properly help clean the food industry. Those who do not comply will lose all of their government subsidization until they have reformed their practices accordingly and could potentially be punished by law. There are a number of standards we plan to set. First, there will be absolutely no genetically modified organisms or pesticide usage unless they are proven, by scientific analysis, to be completely safe in the environment. The FDA will create a very elaborate list of GMOs that are considered safe and there will be no moving away from this list. Also, FDA officials will be required to test both the water and soil quality at all farms. If a farm does not pass the required sanitation level, they will be immediately taken out of business until the issue is solved. Finally, multiple inspections will be conducted a year to inspect the

living conditions of livestock. The World Society for the Protection of Animals further explain the conditions that must be avoided by stating; factory farmed animals are crammed together in conditions that prohibit natural behavior they cannot eat, exercise or form relationships as they are meant to. In some cases, they live without daylight. These issues will be fixed. Fortunately, this part of the plan will have minimum negative implications and can work effectively due to the rising number of local farmers who will be supplying food in the United States. Farms that choose to practice faulty food handling will either lose all of its subsidies and face bankruptcy or will be turned over to legal officials and be punished by law. In conclusion, we hope you see the great importance of the plan we have set before you. Inevitably we envision our plan working similar to that of the recent carbon dioxide emission limitations put in place by the EPA. This particular strategy asks countries to cut down on their CO2 emissions over an elongated period of time so as to not drastically change the current system. We believe it is smart to model our plan in a similar way because the American populace will only accept something that they can slowly become familiar with. Very few monumental policy changes have led to positive feedback for the political bodies that enact them, so we avoid this problem with the gradual shift. Also, by slowly transferring resources away from the unhealthy commercial farms, we give them a sufficient amount of time to comply with new standards before they are noticeably hurt. It is entirely possible to avoid most negative situations through the idea that we set before you. With the increased subsidies for local farmers and greater standards on producing healthy food, the United States can finally set themselves apart as

a nation focused on the health of its constituents. So, in closing, we insist that you allow us to inform the public and then subsidize farms that produce the healthiest foods and take resources away from farms that do not follow our standards.