The document discusses the revolving door between government regulatory agencies and food industry lobbyists and how this creates conflicts of interest. It provides examples of former food industry lobbyists obtaining waivers to work for the USDA under the Trump administration where they can influence policies around agriculture subsidies and food assistance programs. The revolving door allows political appointees and regulators to be influenced by their former employers in the food industry when shaping public health policies and dietary guidelines.

1. Nutrition, Diet, and Dietary
Guidelines
Why is it so hard to
know what to eat?

2. Dietary Guidelines, Food
Regulations, and Food
Regulators

3. The “revolving door” refers to rules and political
structures that permit the movement of “former
federal employees into jobs as lobbyists, consultants
and strategists just as the door pulls former hired
guns into government careers.” In other words, the
revolving door allows individuals to move easily
between paid work in the corporate sector and work
in government agencies and elected office.
The revolving door allows political appointees at
agencies like the USDA and FDA to shape
government policies on behalf of their former (and
possibly future) employers. This creates a conflict of
interest, whereby the concerns or aims of two groups
represented by an appointee (e.g. farmers and
consumers, or food industries and workers) are
potentially incompatible.
Source: https://www.opensecrets.org/revolving/
The Revolving Door

4. In 2018, TYT News reported of the Trump administration,
“…former food industry lobbyists are helping shape policy by
advising top officials at the U.S. Department of Agriculture.
[Ethics] waivers, issued by White House counsel Donald
McGahn, allow three recent lobbyists for trade groups
including the National Grocers Association, the National Corn
Growers Association, and the American Farm Bureau to advise
the agency [USDA] on the very matters that they recently
lobbied—matters that impact the profits of the companies that
these associations represent….The ex-lobbyists are working on
welfare programs administered by the USDA, provisions in the
2018 Farm Bill, and seasonal agricultural worker policy. The
results could exclude people from food stamps, weaken
conservation programs, and remove protections for
farmworkers….The waivers represent a significant number of
industry lobbyists within the USDA, appointed by President
Donald Trump and Agriculture Secretary Sonny Perdue, who
present direct conflicts of interest. Because of these conflicts,
McGahn produced the ethics waivers, allowing the recent
lobbyists to do work that, ordinarily, would be considered
unethical.”
The Revolving Door in Motion
Source: https://legacy.tyt.com/2018/03/22/revolving-door-food-
industry-lobbyists-swarm-usda-to-shape-welfare-visa-policies/

5. Representatives of food companies and their trade associations
make the following claims:
• The keys to healthful diets are balance, variety, and moderation.
• All foods can be part of healthful diets.
• There is no such thing as a good or bad food.
• Dietary advice changes so often that we need not follow it.
• Research on diet and health is so uncertain that it is meaningless.
• Only a small percentage of the population would benefit from following population-based
dietary advice.
• Diets are a matter of personal responsibility and freedom of choice.
• Advocacy for more healthful food choices is irrational.
• Government intervention in dietary choice is unnecessary, undesirable, and incompatible
with democratic institutions.
Nestle, “The Politics of Food Choice” (2002), pg. 358.

6. USDA Dietary Guidelines
Federal dietary guidelines are issued every five years by the U.S. Department of Agriculture
(USDA). Notably, the same federal agency tasked with increasing American consumption
of agricultural products is also responsible for telling Americans what they should eat. This
creates a conflict of interest. As Nestle points out, it is therefore impossible for the USDA
to simply tell Americans to “eat less,” advice that most nutritionists agree is a useful starting
point. Instead, USDA recommendations are undeniably influenced by the lobbying power of
the meat and dairy industries, sugar lobbies, and other organized industry groups.
As you look at the history of USDA dietary guidelines, consider:
• What foods and “food groups” are featured in each set of guidelines?
• How does each set of guidelines compare to the ones before it?
• How does the visual design (often the shape) of the guidelines highlight its message?
• What messages come across most clearly, and which are less easily understood or less
easy to follow?
Think in terms of general patterns rather than details.

7. (1943-56)

8. Basic Four (1965)

9. 1980 1985

10. 1990 1995

11. 1992

12. 2005

14. Let’s Move! (2010-2017)
“To meet our goal, we must accelerate implementation of successful strategies
that will prevent and combat obesity. Such strategies include updating child
nutrition policies in a way that addresses the best available scientific
information, ensuring access to healthy, affordable food in schools and
communities, as well as increasing physical activity, and empowering parents
and caregivers with the information and tools they need to make good choices
for themselves and their families. They will help our children develop lifelong
healthy habits, ensuring they reach their greatest potential toward building a
healthier and more prosperous America.”
—President Barack Obama,
upon establishing a Task Force on
Childhood Obesity in 2010.

15. “You as a parent and a consumer should be able to walk
into your local grocery store, pick up an item off the
shelf, and be able to tell whether it’s good for your
family. So this is a big deal, and it’s going to make a
big difference for families all across this country.”
—First Lady Michelle Obama

16. 2011

17. Balance Calories
• Enjoy your food, but eat less.
• Avoid oversized portions.
Foods to Increase
• Make half your plate fruits and
vegetables.
• Switch to fat-free or low-fat (1
percent) milk.
• Make at least half of your grains
whole grains.
Foods to Reduce
• Compare sodium (salt) in foods like
soup, bread, and frozen meals.
Choose foods with lower numbers.
• Drink water instead of sugary drinks.
Federal Dietary Guidelines (2011)

18. The Food and Drug Administration
(FDA) unveiled an updated nutrition
label (on right) in May 2016.
How does the new label compare to
the old one (on left)? What
information does it highlight, and
how?

21. Who is in charge?
The Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA) share some
overlapping areas of responsibility for and jurisdiction over the U.S. food supply.

22. Given the difficulty of navigating
dietary guidelines and the conflicting
advice of food industries, government
agencies, public health officials, and
nutritionists, journalist Michael Pollan
offers a few simple rules to guide
consumers in choosing what to eat.
He outlines these in the film
In Defense of Food (2015).

23. So, what is food?

24. Don’t eat anything your great grandmother wouldn’t recognize
as food. (Don’t eat anything incapable of rotting.)
Unlike whole foods, “edible food-like substances”:
• Contain chemical additives and corn/soy derivatives.
• Deceive the body and “confound the senses we rely on to assess
new foods” (pg. 12).
• Push our evolutionary buttons, exploiting an inborn human
preference for sweetness, fat, and salt  more energy dense than
traditional whole foods.
• Contain less water, fiber, and micronutrients, and much more sugar
and fat: “More fattening, less nutritious!”
From Michael Pollan, “Eat Food: Food Defined,” in Holly Bauer (ed.) Food Matters (Bedford, 2016).

26. Avoid food products containing ingredients that are
a) unfamiliar,
b) unpronounceable,
c) more than five in number, or
d) high-fructose corn syrup (HFCS).
• Reliable markers of foods that have been highly processed and are
now “edible, food-like substances.”
• Indicate foods that are likely not what they say they are but are labeled
thus by the FDA. E.g. Industrially produced shelf-stable “bread”
contains more than just water, flour, yeast, and salt.
• Engineered foods need to add things (e.g. texturizers, sweeteners,
stabilizers) to compensate for lost flavor.

28. Avoid food products that make health claims.
• These foods must be prepackaged.
• Producers must have significant resources to secure FDA-approval of
these claims  big companies only.
• E.g. American Heart Association charges a fee for its “heart-healthy seal of
approval.”
• Dangers of incomplete and erroneous science.
• E.g. Case of trans fat, developed as a supposedly “healthier” alternative to
saturated fats but later proven to cause heart disease.
• Companies can promote claims any way they want.
• E.g. HFCS “probably does contribute to your health—as long as it replaces a
comparable amount of, say, poison in your diet and doesn’t increase the total
number of calories you eat in a day” (Pollan, pg. 16).

30. In addition to “Authorized Health Claims,” the FDA approves three
levels of “qualified” health claims that allow a product to be marketed
as health-promoting without sufficient evidence to support the claim.
Examples:
1. “Although there is scientific evidence supporting the claim, the evidence
is not conclusive.”
2. “Some scientific evidence suggests [this] …However, the FDA has
determined that this evidence is limited and not conclusive.”
3. “Very limited and preliminary scientific research suggests…. The FDA
concludes that there is little scientific evidence supporting this claim.”
Source: https://www.fdareader.com/blog/tag/qualified+health+claim

31. The makers of Mazola Corn Oil filed a petition in 2006 to make a
“Reduced Risk of Heart Disease” claim. The petition asked for
permission to make this claim:
Scientific evidence establishes that including corn oil-containing foods in
your diet may reduce your risk of heart disease. To achieve such benefits,
include slightly less than 1 tablespoon (12 grams) of corn oil per day in
your diet while not increasing calories, saturated fat or cholesterol. One
serving of this product contains [x] grams of corn oil. Although there is
scientific evidence supporting the claim, the evidence is not conclusive.

32. Instead, the FDA approved this claim:
Very limited and preliminary scientific evidence suggests
that eating about 1 tablespoon (16 grams) of corn oil daily
may reduce the risk of heart disease due to the unsaturated
fat content in corn oil. The FDA concludes that there is
little scientific evidence supporting this claim. To achieve
this possible benefit, corn oil is to replace a similar amount
of saturated fat and not increase the total number of
calories you eat in a day. One serving of this product
contains [x] grams of corn oil.

33. Shop the peripheries of the supermarket and stay out of the middle.
Processed foods dominate the center aisles.
Fruits, vegetables, meat, and dairy products are
typically on the perimeter of supermarkets.

34. Get out of the supermarket whenever possible.
(“Shake the hand that feeds you.”)
• Farmers’ markets sell “fresh whole foods picked at the peak of their taste
and nutritional quality” (pg. 16).
• Avoid the realm of the Western diet—supermarkets, convenience stores, and
fast food outlets—to improve your health and the health of the food chain.
• Seasonal foods diversify your eating habits.  Cook with raw/whole
ingredients.
• Such foods are often organic, even if not officially certified as organic
because small farms need to be highly diversified to survive and therefore
have less need for pesticides. (They are also less likely to be able to pay for
the certification process.)