Talking Agriculture to Democrats

By Marshall L. Matz, as published in Agri-Pulse

Look at a map of the 2012 election results by county and you quickly see the urban-rural divide in America. The vast swath of the heartland, much of the West and most of the South are red, while the urban areas, the East and West Coasts are blue.

The rural population is shrinking. Ironically, one reason for the urban migration is agriculture’s efficiency. It takes fewer and fewer farmers and ranchers to feed the nation. That means less people with a connection to, and knowledge of, agriculture. It also means fewer Members of Congress who represent agriculture districts.

Secretary Tom Vilsack put it bluntly at a December 19th Forum on Agricultural Innovation hosted by the U.S. Chamber of Commerce: “Rural America can no longer elect the President.” Similarly, The Economist asks, “Is Rural America still politically relevant?”

Democrats must learn how to connect with rural Americans but the converse is also true. Farmers, farm organizations and production agriculture must learn how to talk to Democrats.

I would suggest a three-part strategy:

·        Expand the message;

·        Broaden the target audience; and

·        Debunk the myths about production agriculture.


President Obama’s number one domestic priority is jobs and the economy, including the rural economy. He told the American Farm Bureau that “We need an economy built to last; an economy built on things we make and produce.” Most importantly, the President then included agriculture in that category.

We frequently cite net farm income and export numbers but let’s take it a step further and connect the dots. While only a few hundred thousand farmers can feed the country, it is net farm income that drives the rural economy. It is important to rural banks, implement dealers and the coffee shops on Main Street.

Secretary Vilsack is on a mission to demonstrate the importance of agriculture and rural development pointing out that agriculture supports 1 in 12 jobs. Senate Agriculture Committee Chair Debbie Stabenow notes that “One out of every four jobs in Michigan depends on agriculture.” Senator Stabenow and Ranking Member Collin Peterson know that developing and expanding rural economies is critical to a successful national economy but most urban Democrats do not understand this relationship.

The President has made energy policy, including biofuels a very high priority. Biofuels are very important to the rural economy and to the President’s goal of energy independence. Here, again, we need to connect the dots and link it to production agriculture.

Global food security is important to the President, urban Members of Congress and editorial writers. The Administration, from President Obama to the State Department, the White House National Security Council, USAID and USDA, has put global food security front and center. In addressing the Symposium on Global Food Security on May 18th, the President said, “As the wealthiest nation on Earth, I believe the United States has a moral obligation to lead the fight against hunger and malnutrition and partner with others…Food security is a moral imperative but it is also an economic imperative…We have a self interest in this.”

The Camp David Declaration, written by the National Security Staff and adopted by the Group of Eight (G8), followed suit: “Today we commit…to take to scale new technologies and other innovations that can increase sustainable agriculture production.” In order to effectively scale up new technologies there has to be greater cooperation between the G8 countries and China on synchronizing the regulatory systems.

Africa contains a majority of the world’s under-utilized agriculture land.  Helping Africans bring the green revolution to Africa is important to the economic growth of Africa but it is also the key to global food security. The Department of Agriculture has entered into an agreement with the Alliance for a Green Revolution in Africa (AGRA) to transfer technology and training. In short, global food security brings another political constituency to the table for production agriculture.

Secretary of State Hillary Clinton recently gave a speech on “Transformational Trends.” The Secretary said, “The United States is moving economics to the center of foreign policy.” She noted, “We rightly call America the indispensable nation when it comes to climate change, poverty, hunger and disease.” Agriculture has a role to play on all of these issues, including preventing disease.

The Target Audience

After expanding the message, we should strive to carry the message to a wider audience.

Berkeley author Michael Pollan may support higher food prices as a way of fighting obesity but keeping down the cost of food is important to the Congressional Black Caucus (CBC) and anti-hunger advocates.

Rep. Marcia Fudge will Chair the CBC in the 113th Congress.

The Food Research Action Center (FRAC) and Feeding America are leading advocates for the Supplemental Nutrition Assistance Program (SNAP), formerly the food stamp program. The SNAP program currently costs $80 billion. If the price of food increases from 10 percent of Americans’ disposable income to 15 percent, the cost of SNAP will exceed $100 billion and low income people will face a terrible challenge. Higher food prices could lead to more demands for cutting benefits, which would hurt food sales. The CBC, FRAC, other anti-hunger groups, as well as the National Consumers League, should be briefed and brought into the discussion on the relationship between production agriculture and the price of food.

On June 1, 2013, some forty organizations wrote to the President commending the Administration’s National Bioeconomy Blueprint. The list of organizations included many scientific organizations. The Vatican’s scientific advisors have also expressed their support for science as a moral duty. In a statement condemning opposition to genetically modified (GM) crops in rich countries, a group of scientists, including leading members of the Pontifical Academy of Sciences, demanded a relaxation of “excessive, unscientific regulations” for approving GM crops, saying that these prevent the development of crops for the “public good.”

There should be a sustained effort to reach out to leading scientists who can provide third party validation for what the agriculture sector is saying on technology.

Alleviating poverty in rural America is also a priority for the Administration.  Expanding production agriculture, especially on Indian Reservations where unemployment is as high as 70-80 percent, is an effective way to attack rural poverty.  The National Congress of American Indians and the Great Plains Tribal Chairman’s Association are interested in an Indian Agriculture Act. These organizations would make excellent allies when approaching the Administration and Democrats in Congress.

I think you get the idea: we must connect production agriculture to larger issues and educate more stakeholders. Lastly, we must address the concerns and myths about production agriculture.


When it comes to commercial food production, more than any other issue, consumers are concerned that production agriculture might be hurting the environment and contributing to climate change.  You can’t be silent on this issue and expect it to go away. The science is on our side but we need to address this issue directly. Americans do not understand that modern agriculture is sustainable and that farmers rely on healthy soil and clean water.

Earlier this year, the United Nations released the Secretary-General’s report on global sustainability entitled Resilient Planet, Resilient People.  It says: “New ‘green’ biotechnology can play a valuable role in enabling farmers to adapt to climate change, improve resistance to pests, restore soil fertility and contribute to the diversification of the rural economy.”

A UN report may not score many points with the American public but it is a very good source of information to rely upon at the Office of Energy and Climate Change Policy at the White House and with Congressional Democrats.

Another popular myth is that production agriculture is at war with organic agriculture. There is a demand for organic foods and locally produced foods (not the same thing) which is respected by production agriculture. While pointing out the importance of the organic industry, however, it is fair to note that is only 5 percent of the U.S. food supply. It is production agriculture, using modern technology and biotechnology that accounts for 95 percent the f the food supply and energy crops too. In the wake of the close vote on Prop 37 and the FDA decision on salmon, we must debunk the myths associated with production agriculture and make it more transparent.

It is production agriculture that drives down the cost of food, stimulates rural development, produces our renewable energy and holds the promise of global food security. That is an effective, pragmatic, message to bring to Democrats and all American consumers.

A Reality Check for Organic Food Dreamers

Modern farming methods offer the best hope to feed the world’s billions

By John R. Block

I grew up on a farm in Knox County, Ill., and I still farm the family land. We grow corn, soybeans and wheat, and we raise hogs. A generation ago, we lost yield every year to corn borers, root worms and other pests. Today, with advanced technology and genetic engineering, our family farm is better protected and so are its products. We use fewer chemicals and produce better-quality crops.

Yet instead of celebrating that progress—especially with the recent debate around the labeling of “genetically modified” foods—some Americans are asking, in effect, why can’t we just go back to the way we farmed in the 19th century?” Well, there’s a reason for that. Several, actually:

• Food safety. The American food supply has never been as safe as it is today. During the industrial revolution, as manufacturers started to process and package food, poor hygiene and dirty manufacturing conditions (not to mention questionable ingredients) resulted in unhealthy products. Since then, America’s farmers and ranchers have led the way in building a sophisticated food-safety infrastructure to improve the health of their animals and deliver fresh, clean produce.

Without modern sanitation and industry testing, we would see a lot more illness. As for genetically modified foods, despite all the hysteria, there has never been a single case where a GM food caused an illness or contributed to a contaminated product.

• Food choices. In this economy, as families grapple with utility bills, high college tuition costs and meager 401(k) savings, the ability to select from a variety of affordable, healthy choices in the grocery store aisle can offer some relief. Not long ago, what we ate was entirely dependent on the farmer’s skill, the weather and other unpredictable variables. Preindustrial yields were low and stagnant before the introduction of machines, fertilizers, plant and animal breeding, pesticides and genetic engineering.

Americans are no longer limited to a small variety of local and seasonal food (unless that’s what they choose). Modern agriculture is simply more productive, providing more variety at better prices.

• Stewardship. While early farmers didn’t really think in terms of environmental stewardship, since the 1960s farmers have taken it seriously. New technologies allow American farmers to do more to protect the land’s natural resources. Water-conservation technologies have been especially invaluable during this year’s severe drought, thanks in large part to lessons learned during the Dust Bowl of the 1930s.

Today’s farmers also use new practices to improve the sustainability of the land and limit the use of herbicides, pesticides and fertilizers. For example, a soil-testing process called “grid sampling,” introduced just 20 years ago, significantly reduces the amount of chemicals used on farms. And the goal of much of the research into genetically engineered crops is higher yield with less water and chemical use.

Alternative energy is also a growing trend, with some farmers reusing manure from livestock and turning it into biodiesel that can power farm equipment. Others are installing solar panels and wind turbines to produce power for their farm or community.

• Sustainability. The large-scale, sophisticated farming of today is simply better equipped to produce the abundance of food needed to sustain the world’s growing population. When I was a child, we had two horses pulling a two-row corn planter. Today, our tractor pulls a 32-row planter. America’s farmers grow five times as much corn as they did in the 1930s—on 20% less land. The yield per acre has increased sixfold in the past 70 years, to 154 bushels today from just 24 in 1931.

Still, America’s farmers and ranchers will need to produce about 75% more food per acre by 2020 in order to help feed the more than eight billion people the United Nations expects by 2030. To meet that goal, farmers and ranchers will use the latest and most effective technologies to produce more with less. I support organic and conventional farming. But organic farming cannot produce the amount of food that is demanded in today’s world.

Indulging in a romanticized image of the farming industry stands in the way of progress. Do we want a smart, sophisticated approach to food supply that we can depend on for safety, healthy choices, environmental stewardship and long-term sustainability? Or do we want to return to food shortages, higher prices and the days of two horses pulling a corn planter?

Mr. Block, secretary of the Department of Agriculture from 1981 to 1985, is a senior policy adviser at OFW Law in Washington, D.C.

Please note that a version of this article appeared December 24, 2012, on page A11 in the U.S. edition of The Wall Street Journal.  Click here to see that version.

What Should an Establishment Consider in Controlling Pathogenic STECs?

By Dennis R. Johnson and Barbara J. Masters, D.V.M.

As the U.S. Department of Agriculture’s Food Safety Inspection Service (FSIS) begins to conduct Food Safety Assessments (FSA) at beef slaughter establishments to verify controls for Pathogenic Shiga Toxin-Producing E. coli (STEC), establishments should ensure that they have systems in place that are effective for pathogenic STEC.  Preventing contamination, effective use of interventions, and verification of the overall system will be the keys to a successful FSA.  In that regard, establishments should ensure the following issues are addressed prior to an FSA.

Is the establishment taking measures to ensure process control throughout the entire slaughter process?

Establishments should take necessary precautions throughout the slaughter process to ensure the carcass does not become contaminated with enteric organisms.  Sanitary dressing is the key to preventing carcass contamination.

Is the establishment taking measures to correct incidental contamination after it occurs?

Multi-hurdle interventions have been validated to be effective on enteric organisms that might contaminate a carcass.  There are many effective interventions including hot water, steam and organic acids.  Scientific research has demonstrated that these interventions work effectively for both E. coli O157 as well as the non-O157s.

Is the establishment applying the intervention at the appropriate parameters, such as time, temperature, pressure, and other parameters that are necessary for the intervention to be effective?

To be effective, an intervention must be operated as designed.  The establishment should ensure it has identified the key parameters, such as the temperature of the intervention on product or concentration of the solution.  Not operating as intended will not provide a food safety benefit.

Is the establishment using a tool to ensure the slaughter process is effective?

If an establishment is preventing contamination, and using interventions effectively, the incidence of microbial contamination should be very low.  However, the establishment should have a means to verify this.  Over time, establishments have demonstrated that robust testing for E. coli O157:H7 serves as a tool to verify effectiveness of the slaughter process.  In addition, establishments should conduct validation and periodic verification testing for non-O157 to ensure the system is controlling all relevant STEC.

Are you ready for an FSIS audit?

GIPSA Investigation of Lamb Industry Could Be Tip of Iceberg

By Brett T. Schwemer

In October, at the request of a trade association representing sheep producers, eight Senators sent a letter to the Secretary of Agriculture requesting that the USDA’s Grain Inspection Packers and Stockyards Administration (GIPSA) investigate a recent dramatic price drop in the lamb market to determine if lamb packers and processors are manipulating the market in violation of the Packers and Stockyards Act (P&S Act).  Among other things, the letter expressed specific concern regarding packers owning an excessive number of feeder lambs for slaughter.

It is important to note that the Senators’ letter does not cite any specific evidence that lamb packers have altered their procurement practices with the intent to manipulate the markets or that any procurement practices utilized by packers were the direct cause of the recent price decline in lambs.  Indeed, several economists and industry experts, including one official from USDA’s Agricultural Marketing Service, have pointed to a variety of economic and environmental factors for causing the recent drop in lamb prices.  These factors include a significant decline in consumer demand for lamb and this summer’s drought in the Midwest, which caused more producers to send lambs to feedlots and be fed to market weights before they were needed.  The Senators’ letter gives fleeting mention to only some these factors.

This is not the first time producers selling in a cash market have alleged that packers are manipulating the markets in violation of the P&S Act.  Indeed, in recent years several class action lawsuits have been filed by producers against livestock packers alleging that their use of vertical integration models or captive supply agreements have the effect of manipulating the markets by withdrawing supply from the cash markets and depressing cash prices for livestock.  However, courts have uniformly upheld these practices, finding that there are legitimate, competitive business justifications for packer’s use of vertical integration models or captive supply agreements.  These justifications include the ability to ensure a reliable and stable supply of livestock for processing plants and the ability to reduce transaction costs in procuring livestock. See e.g.Pickett v. Tyson Fresh Meats, Inc., 420 F.3d 1272 (11th Cir. 2005); Griffen v. Smithfield Foods, 183 F.Supp.2d 824 (E.D. Virginia 2002).

Undeterred by these defeats in the courts, many producer groups have lobbied Congress and USDA for new laws to restrict packers from vertically integrating or using captive supply agreements to procure livestock.  Although these efforts have failed to date, it is believed that the recent request for GIPSA to investigate the lamb industry is just another means to keep the pressure on Congress and USDA to do something.  While many in the livestock industry are confident that GIPSA’ investigation will reveal no wrongdoing by lamb packers or processors, this does not mean that the livestock industry or even the poultry industry should feel confident that issues such as packer concentration, vertical integration and the use of captive supply agreements will die with GIPSA’s investigation.  Livestock producer groups, such as R-calf, have already written letters in support of the GIPSA’s investigation of the lamb industry, arguing that the Department’s investigation should provide “insights into the antitrust and unlawful anticompetitive practices” occurring in other livestock markets.  GIPSA’s investigation of the lamb market could easily evolve into a wider investigation involving the rest of the livestock industry, as well as the poultry industry.  The battle will likely continue.

FTC Releases Final COPPA Rule

By Tish Eggleston Pahl

Today, the FTC adopted final amendments to the Children’s Online Privacy Protection Act (COPPA) Rule to increase privacy protections and give greater parental control over the personal information that websites and online services may collect from children under 13.  A summary of the rule’s changes is here.

The amended rules should be of interest to any companies that have websites directed at children under 13 and/or that are collecting personal information online from children under 13.  The rule is effective on July 1, 2013.

New Bill would Authorize Voluntary “Carcinogen-Free” Labeling of Food and Consumer Goods

By Mark L. Itzkoff

A new bill introduced into the U.S. House of Representatives last month could eventually result in new labeling for food and other consumer products.  H.R. 6601, The Carcinogen-Free Label Act of 2012 (CFLA) introduced last month by Rep. Theodore Deutch (D-FL) and Rep. Sue Myrick (R-NC), would require the U.S. Food and Drug Administration, Department of Agriculture, Environmental Protection Agency and Consumer Product Safety Commission to establish programs to permit labeling of products regulated by each agency as “Carcinogen-Free.”  The CFLA programs would be voluntary and would be funded through fees charged to companies applying to use the “Carcinogen-Free” label.

Under the proposed legislation, companies who apply for the label will be required to submit an application that includes a list of all the substances contained within the product along with a sample of the product for testing by the appropriate agency.  Information contained in the applications is deemed to be a trade secret and is not disclosable under the Freedom of Information Act.

Products would be eligible for approval if the agency determines that the list provided is accurate, the product does not contain any carcinogens and that the product does not contain any substances that “display carcinogenicity upon degradation, upon interactions with other substances contained within the product or exposed to the product, during storage or transportation, or during intended use of the product, …”  The bill defines a carcinogen as either: (1) a substance listed in the National Toxicology Program Report on Carcinogens that is known to be a human carcinogen or reasonably anticipated to be a human carcinogen (i.e., any substance listed in the NTP report) or (2) a substance described in EPA’s Integrated Risk Information System (IRIS) as carcinogenic to humans or likely to be carcinogenic to humans.  Companies that use the “carcinogen-free” label without an approved application or that market products with substances not listed in their application are subject to fines up to $100,000.

In the case of food, CFLA does not differentiate between substances added to foods during processing and substances that are naturally present.  Thus, potatoes and other starchy foods might not be eligible for the “carcinogen-free” label if they contain substances that form acrylamide when the food is fried, roasted or baked.

The proposed bill is in some ways a mirror image of the California Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65).  CFLA as currently proposed would permit suppliers to voluntarily submit applications and label their products as “Carcinogen-Free,” whereas Prop 65 requires suppliers to warn before “exposing” consumers to products containing carcinogens.  Thus while CFLA and Prop 65 have similar goals, their respective approaches to achieving those goals are very different.

It should be noted that under the present proposal, CFLA would not include an exemption for products that contain only insignificant concentrations of the listed carcinogens.  By comparison, Prop 65 allows California to establish “safe harbor” exposure limits for listed carcinogens.  Products that contain listed carcinogens but whose use would result in exposure at or below the safe harbor limit are exempt from the Prop 65 warning requirements.

It is unlikely that the CFLA bill will be acted on in the few days remaining in the current Congress.  The Ag/FDA Blog will monitor the situation and post further should the bill be re-introduced in the 113th Congress.

Humane Society’s Middlegame: HSUS Files Complaint With USDA Inspector General Over Pork Board’s Use of Checkoff Dollars

By Stewart D. Fried and John G. Dillard

It’s safe to say there is no love lost between the Humane Society of the United States (HSUS) and the National Pork Producers Council (NPPC).  HSUS is the so-called animal rights organization devoted to ending modern animal agriculture. The NPPC is the voice of America’s hog farmers on policy and advocacy issues.  Needless to say, they don’t see eye-to-eye on many things and HSUS has repeatedly attempted to stifle NPPC’s free speech rights through complaints with courts and regulatory agencies.

HSUS’s latest salvo is its November 28, 2012, complaint to USDA’s Inspector General (IG), Phyllis Fong (IG Complaint).  HSUS alleges that the National Pork Board (Pork Board) has violated the Pork Act by contributing funds from the Pork Checkoff Program to NPPC for membership in NPPC’s Pork Alliance program.  The Pork Checkoff Program is funded by pork producers who pay a small amount into marketing fund each time an animal is sold.  The Pork Board, which administers the Pork Checkoff Program, is required to expend checkoff funds on “promotion, research, and consumer information plans and projects.” 7 U.S.C. § 4809, 7 C.F.R. § 1230.74(a).  The Pork Act also prohibits the Pork Board from using checkoff funds to influence legislation or government policy or actions.  HSUS contends that by associating with NPPC as a partner in NPPC’s Pork Alliance, the Pork Board is violating the prohibition on funding policy advocacy efforts.  HSUS has requested that the IG investigate and enjoin the Pork Board from remaining as a partner in the Pork Alliance.  In response, NPPC asserts that HSUS’s claim is a “bullying tactic” and is “another desperate attempt by the radical activist group to severely curtail animal agriculture and take away consumer food choices.”
HSUS’s IG Complaint is the latest in a series of bi-monthly attacks on America’s hog producers following NPPC’s opposition to proposed laying hen housing legislation.  In April 2012, HSUS filed a complaint with the Federal Trade Commission (FTC) which asserted that NPPC was “engaging in deceptive advertising related to animal well-being.”  During July 2012, HSUS filed notices of intent to sue with several large hog producers over allegations that they were violating the Emergency Planning and Community Right to Know Act (EPCRA) by failing to report releases of ammonia and hydrogen sulfide into the atmosphere. More recently, HSUS sued USDA during September 2012 over the Pork Board’s purchase of the well-known trademark “The Other White Meat” from NPPC.   While the FTC and USDA complaints remain pending, HSUS did not file suit against any of the six producers who received EPCRA notices of intent to sue.  While it is unclear what the IG will do, it seems fairly certain that this is not the last gambit from HSUS with no endgame in sight.

The Ag/FDABlog will be monitoring further developments related to the IG Complaint.  Until then, the Vegas line on a Wayne Pacelle (CEO of HSUS)/Neil Dierks (CEO of NPPC) beer summit stands at 100,000:1.

A copy of HSUS’ complaint to the USDA Inspector General can be found here.

PCAST Report

By Marshall Matz

Today, the President’s Council of Advisors on Science and Technology (PCAST) released its Report to the President on Agricultural Preparedness and the Agriculture Research Enterprise.  The report outlines the importance of agricultural research as well as the top seven scientific challenges facing agriculture: The need to manage new pests, pathogens, and invasive plants; increase the efficiency of water use; reduce the environmental footprint of agriculture; adapt to a changing climate; and accommodate demands for bioenergy—all while continuing to produce safe and nutritious food at home and for those in need abroad.  According to PCAST, the U.S. economy has gained at least $10 in benefits for every $1 invested in agricultural research.

Click here to read the PCAST report.

The First Americans Are Last

By Marshall L. Matz, as published in Agri-Pulse

The first Americans are still last in America, especially in the Northern Great Plains, where the disparity is the greatest. The unemployment rate on Indian reservations in the Dakotas, Montana and Wyoming exceed seventy and eighty percent.  Unemployment on the Rosebud Sioux Reservation in South Dakota is at 85 percent, around ten times the national average. The unemployment rate for the white population in this area of the country is below the national average, fueled by an increase in  crop prices and energy production.

These extreme unemployment rates leads to a shorter life expectancy, higher suicide rates, alcoholism, violence against women, education gaps and a host of other negative social indicators.

The Indian reservation system in America is complex — legally, socially and economically — but there is no excuse for allowing the economic disparity between whites and Indians that exists in this country. It remains a national stain on our conscience.

You can read the complete article here.

New CDC Study of Calories from Alcohol Supports Alcohol Beverage Label Reform

By Gary Zizka

Alcohol accounts for a large portion of the daily calories consumed by many American adults, a new Centers for Disease Control and Prevention (CDC) study concludes. The study found 19 percent of men and 6 percent of women take in more than 300 calories daily from alcoholic drinks.

“I think people may be aware that there are calories in alcoholic beverages,” said Dr. Nielsen, “but I don’t know if people actually look at a beer and realize that it’s the same amount of calories as a soda. Or that a five-ounce glass of wine is almost as much as a soda.”

A 12-ounce can of beer is 150 calories, about the same as a 12-ounce can of regular soda. A standard serving of spirits, which has the same alcohol content as the 12-ounce beer, is about 90 calories.

The new study may be a source of energy for a long-stalled effort to modernize alcohol beverage labels. In 2003, the National Consumers League joined with the Center for Science in the Public Interest, Consumer Federation of America and 75 other public health and consumer organizations to submit a formal petition (at p. 22279) to the federal agency that regulates alcohol labels, now the Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau, or the TTB.  The petition called for an “Alcohol Facts” label on alcoholic beverages that would provide information on calorie and alcohol content, comparable to the “Nutrition Facts” label on foods and the “Supplement Facts” label on dietary supplements.

Subsequently the agency issued an “advanced notice of proposed rulemaking” in April 2005 and received more than 18,000 comments, of which 96 percent supported giving consumers access to standardized and complete labeling information on beer, wine and distilled spirits labels.

The TTB’s most recent action occurred in 2007 when the agency proposed a mandatory “Serving Facts” panel on beer, wine and distilled spirits but notably ignored the most important information consumers need when consuming an alcoholic beverage – the amount of alcohol in a serving and the number of servings per container. This resulted in another barrage of letters from consumers and public health leaders, all calling for more complete information on the label. Since the close of the public comment period in February 2008, the TTB has not found the energy or political will to move forward with issuing final regulations.

According to the US Dietary Guidelines, people who drink alcohol should do so in moderation, defined as not more than one drink per day for women, and two drinks per day for men. Absent a final alcohol labeling rule from TTB, consumers have no meaningful way to understand how their drinking compares with those guidelines.