AN EDITORIAL
Proposed Single Federal Agency To Oversee All Food Safety. FDA and FSIS to Merge. Honey Definition and Oversight to be Included.
Back in January we reported in the BUZZ that the ERS has sent a Report to the Commissioner of the Food and Drug Administration as Required by the 2014 Farm Bill on “How an Appropriate Federal Standard of Identity for Honey Would be in the Interest of Consumers, the Honey Industry, and U.S. Agriculture”.
The report was generated by tallying comments posted to the ERS web site commenting on the Standards FDA had come up with in response to requests by the beekeeping industry since 2006. FDA wanted to know how those standards might affect consumers and the honey industry.
In Summary, AMS found that 1) the preponderance of comments across multiple regions and organizations support the establishment of a standard; and 2) there are divergent opinions on the content and wording of such a standard, and its relationship to existing international standards.
Who is this preponderance of commenters? 85 comments posted. 76 supported the proposed regulations. You can read the entire proposed regulations here which are included within the joint comments made by the ABF, AHPA, National Honey and Packers and Dealers, Sioux Honey, and the Western States Packers and Dealers groups. Combined, these groups represent more than 90% of the US Honey Industry. Read their comments…they make good points about a lot of what needs to be said about this subject. And, since they have a loud voice, maybe you should know what they are saying. I’ll get back to this in a minute.
Other groups and people make comments too. Here are a few…. The Texas Beekeepers Association had more than anybody, Food and Water Watch, an environmental advocacy group submitted a petition to establish regulations (specifics not listed) signed by every one of their 20,000 members. Monsanto voiced a positive opinion, Vaughn Bryant, the pollen expert from Texas A&M who writes here on occasion had a long and detailed comment on the pollen aspect of what was being said, and Amina Harris, the Director of the Honey and Pollination Center in Davis, CA suggested the Codex Standards be adopted.
There were others of course, mostly all supporting the adoption of some kind of standard, but offering little in the way of guidelines. That, I suspect, is what most of us would do. But not all of us.
This is the Standard people commented on.
Standard for Honey
1. Scope. This standard applies to all honey produced by honey bees and covers all styles of honey presentations which are processed and ultimately intended for direct consumption and to all honeys packed, processed or intended for sale in bulk containers as honey.
2. Description. 2.1.Definition: Honey is the natural sweet substance produced by honey bees from the nectar of plants or from secretions of living parts of plants or excretions of plant sucking insects on the living parts of plants, which the bees collect, transform by combining with specific substances of their own, deposit, dehydrate, store and leave in the honey comb to ripen and mature. 2.1.1. Blossom Honey or Nectar Honey is the honey which comes from the nectars of plants. 2.1.2. Honeydew honey is the honey which comes mainly from excretions of plant sucking insects (Hemiptera) on the living parts of plants or secretions of living parts of plants.
2.2. Description: Honey consists essentially of different sugars, predominantly fructose and glucose as well as other substances naturally derived from the collection of nectar by honey bees for conversion into honey. The color of honey varies from nearly colorless to dark brown: the consistency can be fluid, viscous or partly to entirely crystallized. The flavor and aroma vary, but are derived from the plant origin.
3. Essential Composition and Quality Factors. 3.1. Honey sold as such shall not have added to it any food ingredient, including food additives.
3.1.1. Styles of Honey: 3.1.1.1. Filtered – Filtered honey is honey of any type defined in the United States Standards for Grades of Extracted Honey that has been filtered to the extent that all or most of the fine particles, pollen grains, air bubbles, or other defects normally found in suspension have been removed. 3.1.1.2. Strained – Strained honey is honey of any type defined in the United States Standards for Grades of extracted Honey that has been strained to the extent that most of the particles, including comb, propolis, or other defects normally found in honey have been removed. Grains of pollen, small air bubbles, and very fine particles would not normally be removed. 3.1.1.3. Unfiltered/Unstrained – Unfiltered/Unstrained honey is honey that has not been filtered or strained as described by United States Standards for Grades of Extracted Honey and may include extracted or non-extracted honey and whereas most whereas most of the fine particles, pollen grains, air bubbles, comb, propolis and other defects normally found in suspension may be present.
3.2.Honey shall not be filtered to less than 1.0 microns. 3.3. Chemical or biochemical treatments shall not be used in the packaging or processing of honey. 3.4. Moisture content: Honey Shall not have a moisture content exceeding 23%. 3.5. Sugars Content. 3.5.1. Fructose and Glucose Content (Sum of Both). 3.5.1.1. Honey not listed below – not less than 60g/100g. 3.5.1.2. Honeydew honey, blends of honeydew honey with blossom honey – not less than 45g/100g. 3.5.2. Sucrose Content. 3.5.2.1. Honey not listed below – not more than 10g/100g. 3.5.2.2. Lavender (Lavandula spp), Borage (Borago officinalis) – not more than 15g/100g 3.6.Water Insoluble Solids Content 3.6.1. Honeys – not more than 0.5/ 100g.
You can probably imagine why some groups would have difficulty adopting this standard. Moreover, when considering there are already nine state standards, none alike, the babble from the regulatory front would be deafening. Utah for instance has a definition that isn’t legal in the other 8 states with regulations…make that work in a grocery store.
In the US today, food safety oversight is divided among fifteen federal agencies. The USDA’s Food Safety and Inspection Service, or FSIS and the FDA, a part of the Department of Health and Human Services are the most important. FSIS inspects meat, poultry and eggs and FDA everything else.
So ERS (a part of USDA) sends FDA (Health and Human Services) a document that has comments from, (considering the one sent from the ABF, AHPA et al), more than 90% of the honey industry, plus many others, that want some kind of oversight regulation on honey, which is under the watchful eye of FDA. Why isn’t FDA doing something? Well, consider…
Every year contaminated food makes 48 million people sick. Of these 128,000 of them are hospitalized, and 3,000 die. Salmonella alone infects more than a million Americans each year, sending 19,000 to the hospital, and kills more than any other food borne pathogen.
Currently, when the CDC identifies the cause of a food borne illness reported to them by doctors the responsibility to curb the problem points to which ever agency the offending food falls under…meat for FSIS, everything else for FDA. FSIS has a huge army of inspectors, checking meat production everywhere meat is processed. FDA has almost nobody checking and years may go between inspections at food processing plants. However, safety audits do occur at these plants conducted by private inspection services hired by retailers who what to know they are getting safe food. The cantaloupe/listeria outbreak in 2011 fell under the oversight of FDA, but had been inspected by a private agency hired by retailers. Only when the CDC was able to identify the source of the contaminated fruit was something able to be done. Listeria is relatively rare, infecting about 1600 people in the US every year, killing 1 in 5 of them. Thirty three died from the 147 victims of the infected cantaloupe. There are no in-plant contamination limits on infected food, with the exception of E. coli in chicken because it is considered an adulterant, not a dangerous bacteria. Officials must use indirect methods to shut down a facility, like posting news of the violation on websites, or announcing it on TV and Radio. This is generally effective, but not always, and not very fast. When it works what you hear is the announcement of a voluntary recall by producers of the offending product..
Well, all that is supposed to change. The 2010 Farm Bill, now supported by the President’s new budget, proposed consolidating the USDA FSIS and HHS FDA into a new department within HHS. This new agency would work closely with state and local health departments, now mostly handled by CDC.
The 2010 Food Safety Bill gives authority to the current FDA (whose Head is stepping down within the month) to inspect processing plants, order recalls, impose strict standards on imported foods and make, and enforce stricter standards on farms and manufacturing facilities. In effect, give some power to the food safety police and save lives. Imported honey will fall under their gaze, and their gaze will be meaningful. But your honey house and packing facility may l too, and all three may be able to be shut down by the Feds if the bill passes.
This budget proposal for even greater government oversight, it is assumed, will meet with significant resistance from the food industry, farmers and manufacturers, especially now in a Republican dominated congress
But the above definition of honey has measurable attributes that could change the labeling of the end product. By the above definition, it’s filtered honey if it doesn’t have pollen, and strained or unstrained if it does. Sugar and moisture content are both measurable by this definition, and that nothing should be added is mentioned. It is obvious these new rules were made to oversee honey’s problems with adulteration and tainting and country of origin label laws.
We can’t go on with 50 definitions of honey and appear anywhere near professional. And there needs to be some tools to use to stop illegal product from being sold. This new agency will fix the problems with the definition of honey, but may be able to open the door to your honey house. Will the beekeeping industry support this new agency?
Kim Flottum, Editor
