Daniel Compton

FDA Salt Statement Leaves a “Mistaken Impression”

by Daniel Compton on April 28, 2010 · 2 comments

in Health and Illness, Nanny State, Personal Liberty, Precaution & Risk, Regulation, Zeitgeist

Some 80 years ago this month, Mahatma Gandhi led tens of thousands on a 240-mile march in protest against a British salt tax, inciting millions to engage in widespread acts of civil disobedience.  In a seemingly unintentional display of historic irony, the Food and Drug Administration made national headlines on April 20th for its efforts to forcibly restrict the amount of salt that can be added to processed foods.  The Washington Post was among the first to pick up the story, and was subsequently chastised for its efforts in a statement from the FDA, released later that day.  The FDA accused the Washington Post story of “[leaving] a mistaken impression” in the minds of readers.  But examination of the facts shows that The Washington Post got it right, and that it is the FDA statement itself which leaves the mistaken impression.

The event that triggered media interest was the release of a report by the Institute of Medicine urging the FDA to revoke salt’s GRAS (Generally Recognized As Safe) classification, thereby granting regulators the legal framework needed to mandate acceptable levels of salt for processed foods.

The Washington Post responded to the release by reporting that the FDA’s plans to clamp down on salt were already underway and that the initiative would be launched later this year, citing FDA insiders who spoke only on the condition of anonymity.  Within hours, the FDA responded with a statement that the Washington Post article leads readers to believe that the FDA “has begun the process of regulating the amount of sodium in foods.”  The statement went on to assert that “[t]he FDA is not currently working on regulations… to regulate sodium content in foods at this time.”

While it is true that the FDA has made no official announcements regarding their stance on salt regulation, the claims that they have not begun the process and are not currently working on it are demonstrably false.

For 30 years, the FDA had largely ignored calls to reclassify salt, voiced by groups such as the Center for Science in the Public Interest.  That all changed in October of 2007 when, in an abrupt about-face, the FDA announced in the Federal Register that they would hold a public hearing to consider a change in the regulatory status of salt.  The hearing was conducted that November, and the public comment period was closed in August of 2008.  Just a few weeks later, the IOM kicked off a 21 month project titled “Strategies to Reduce Sodium Intake”—a project sponsored by the FDA.  This project would ultimately lead to the creation of the recent IOM report, also FDA sponsored.

Over the course of 2009, 14 meetings and phone conferences were held discussing the project.  All but the first two of these meetings were entirely closed to the public.

At the first meeting, a representative of the FDA itself made a presentation explicitly discussing the regulatory status of salt, as well as its history as a GRAS substance.  The second meeting included a presentation addressing the legality of a reclassification of salt—concluding that the FDA has “ample legal authority” to do so—and one discussing how low salt reduction levels could be set.

But what of the science underwriting this new FDA push?  Also included in the first meeting was a presentation by the Department of Health and Human Services stating that “100% of adults exceed the [adequate intake] of 1,500 mg sodium/day”.  Presented with such a statistic, certain questions spring to mind.  For instance, if 100% of adults eat more than 1,500mg of salt, what research could possibly have been conducted that would lead them to conclude that 1,500mg is adequate?  One might assume that such research was conducted on residents of other countries, but the reality is that the average American consumes about 9% less salt than the worldwide average.

The only places in the world where you might find a significant population who eat so little salt are in countries so poor that people don’t have reliable access to food at all. In such a place, one might indeed find low rates of hypertension-related illness, but only because those who live under such tragic circumstances don’t enjoy the luxury of living to the age where high blood pressure starts to become a concern.

Decades of research, encompassing multiple lines of evidence, have shown that our bodies naturally self-regulate salt intake.  Not unlike the feeling of thirst we experience when we need more water, our bodies send us queues—though more subtle than thirst—that lead us to unconsciously adjust our diets to meet our salt requirements.  One recent study by nutritionists at the University of California at Davis examined data collected from over 19,000 individuals across 33 countries to find that the normal range of salt consumption is 2,700-4,900mg per day.  The study went on to conclude that, because of our natural ability to regulate salt intake, it is “unlikely to be malleable by public policy initiatives, no matter how well intended.”

A study conducted 12 years earlier coincides with these findings, concluding that most people are simply unable to reduce their consumption below about 2,700mg per day, even when receiving regular dietary counseling and instruction.  A third study, conducted the same year, demonstrates that people will unconsciously increase or decrease their dietary salt intake to stay within the normal range, even when they don’t know how much salt is in their food.  Neuroscientists have even successfully identified the specific neurological mechanism by which this unconscious salt-regulation occurs.

Grossly out of step with the current scientific understanding, the FDA clearly has begun the process of regulating the amount of sodium in foods, and has been working on it for several years.  Between the hearing in 2007, their sponsorship of—and participation in—the 21 month project specifically aimed at reclassifying salt, and their sponsorship of the report itself, there is little more that the FDA could have done to expedite the process.

It is true that the FDA has not yet formally proposed a rule, but that is the obvious next step on the new path it’s been taking for the past few years.

It is an outrage that the FDA would deign to censure The Washington Post for publishing an article informing readers about the shape of things to come.  Far from leaving a “mistaken impression”, The Washington Post’s article hit the nail squarely on the head.  If a mistaken impression is to be had, then readers need look no further than the FDA’s own statement.  And why would the FDA go to such lengths to deny that which is both obvious and confirmed by insiders?  It’s a safe bet that they want the unveiling of their plans to be timed just right, as whatever they are about to drop on us is bound to be damned unpalatable.

New York Salt-Slashing Op-Ed in NY Post

by Daniel Compton on January 13, 2010 · 2 comments

in Health and Illness, Healthcare, Nanny State, Personal Liberty, Politics as Usual, Precaution & Risk, Regulation

Here is my op-ed published in the New York Post on January 13th.

As-salt on science

On Monday, city officials rolled out an initiative to curb the salt content in manufactured and packaged foods. But the idea behind it — that salt intake has reached extreme levels in America — is a myth, and this “solution” wouldn’t work, anyway.

City Health Commissioner Dr. Thomas Farley aims to lead a national campaign to reduce the amount of salt in manufactured foods by 25 percent over the next five years. Cutting salt intake is supposed to reduce hypertension-related health problems. But while doctors may advise particular patients to cut down on salt, the science tells us that this is not a public-health problem.

Nutritionists at the University of California/Davis just published the first and only study to address salt intake and public policy. They found that people are naturally inclined to regulate salt intake to physiologically determined levels by unconsciously selecting foods to meet their needs — and even the most extreme interventions don’t do much.

The UC Davis study (published in the October issue of The Clinical Journal of the American Society of Nephrology) looked at data from more than 19,000 individuals from 33 countries worldwide. It determined that daily sodium intake ranges only from 2,700 milligrams to 4,900 mg, with the worldwide average of 3,700 mg.

It also determined that the average American consumes about 3,400 mg a day — disproving the claim spread by advocates such as the Center for Science in the Public Interest that US salt consumption is out of control.

In other words, Farley’s trying to fight a problem that doesn’t exist. Worse, his new guidelines say that daily sodium intake for most people shouldn’t exceed 1,500 mg — which is a ridiculous 45 percent below the bottom of the normal consumption range the UC Davis study identified, and a full 60 percent lower than the worldwide average.

The researchers also cite decades of research describing the specific mechanism by which the central nervous system, acting together with several organ systems, controls our appetite for salt. One of the studies they cite involved hundreds of participants in what was to be a three-year sodium-intake intervention, with the goal of reducing daily intake to 1,850 mg.

But after six months, researchers noted that participants were simply unable to cut sodium intake below about 2,750 mg a day — close to the bottom of the range the UC Davis study identified.

Another study had used intensive dietary counseling to get participants to cut daily sodium intake to an average of 1,775 mg over four weeks. After that, the subjects, while still receiving counseling, were randomly split into two groups — one getting a sodium tablet, the other a placebo.

Those who got the placebo still raised their intake by nearly 1,000 mg, while those on the sodium tablet actually cut their dietary-sodium consumption to compensate.

These people didn’t know how much sodium they were getting — they unconsciously changed their diets to match what their bodies “knew” they needed.

The UC Davis study also cites surveys showing that sodium intake in the United Kingdom has “varied minimally” over the last 25 years, despite a major government campaign to reduce it.

Overall, the researchers found, salt intake “is unlikely to be malleable by public policy initiatives,” and attempts to change it would “expend valuable national and personal resources against unachievable goals.”

The New York guidelines are voluntary — for now. But the city’s ban on trans fats started that way, too. And the federal Food and Drug Administration has also been looking to get in on the action — it may classify it as a “food additive,” subject to regulation, sometime this year.

But this campaign isn’t about public health — it’s about grandstanding on a pseudo-issue ginned up by activists, when science clearly shows that there’s neither a crisis nor a way for the government to actually alter our salt intake.

All these initiatives do is win headlines for ambitious policymakers (New York’s last health commissioner parlayed his trans-fat activism into a promotion to FDA chief), while making food slightly more costly and leaving a bad taste in the mouths of consumers — literally.

Daniel Compton is a research associate at the Competitive Enterprise Institute and contributor to OpenMarket.org

Climategate Op-Ed in Detroit News

by Daniel Compton on December 23, 2009 · 1 comment

in Energy, Environment, Global Warming, International, Regulation, Zeitgeist

Here is my op-ed published in the Detroit News on December 23.

Climategate: What e-mail really means

Daniel Compton

By now, most people are aware of the scandal surrounding the leak of thousands of e-mails and other documents from the University of East Anglia’s Climate Research Unit (CRU). Among these is an e-mail exchange involving several of the world’s leading climate scientists, dated October of 2009, in which the admission is made that even their best models cannot account for the last decade of temperature data. “The fact is that we can’t account for the lack of warming at the moment and it is a travesty that we can’t,” said Kevin Trenberth, one of the world’s preeminent climate scientists and lead author of the 2001 and 2007 IPCC reports.

Significantly for public policy, the admission implies that efforts to reduce carbon dioxide emissions — including the EPA’s endangerment finding, all forms of cap-and-trade-style legislation, and any possible resolution to emerge from the recently convened Copenhagen conference –have no basis in science .

Trenberth’s statement is compelling on its own, but the subsequent discussion is even more illuminating. Later in the same e-mail thread, fellow climate scientist Tom Wigley replies that he does not agree with Trenberth’s assertion. Trenberth then responds to Wigley, clarifying and expounding upon his earlier claims:

“How come you do not agree with a statement that says we are no where close to knowing where energy is going or whether clouds are changing to make the planet brighter. We are not close to balancing the energy budget. The fact that we can not account for what is happening in the climate system makes any consideration of geoengineering quite hopeless as we will never be able to tell if it is successful or not! It is a travesty!”

This comment requires some scientific translation for its significance to be fully understood. The “energy budget” is the total energy gains and losses incurred by the Earth. The overwhelming majority of the energy entering the Earth comes from the Sun. Some of that energy is reflected back out into space by the atmosphere, clouds, and the Earth’s surface, while the remaining energy is absorbed, and is later reradiated as heat. The amount of energy the Earth gains is approximately equal to the amount it loses, which is why global temperatures remain relatively stable from day to day.

We have fairly good estimates of how much energy is entering the Earth, and we know from the laws of thermodynamics that energy cannot cease to exist, so “balancing the energy budget” simply entails accounting for where all that energy is going. “Global warming” refers to the condition in which the Earth as a system is taking on slightly more energy than it is losing for a sustained period, causing it to heat up over time. Therefore, it is highly significant when one of the world’s leading climate scientists asserts that we are “no where close to knowing where energy is going” and “not close to balancing the energy budget”.

In this context, “geoengineering” refers to any deliberate effort to affect net energy gains or losses to achieve a desired result, such as a cooler planet. The energy income of the planet is approximately static, and also well beyond our control, so affecting net energy flow necessarily involves changing systemic energy losses.

Greater atmospheric concentrations of greenhouse gases, like carbon dioxide (CO2), can reduce energy loss, so reducing CO2 emissions is one method of geoengineering. Indeed, Trenberth, in a letter published in the February 2009 issue of Physics Today defined “geoengineering” to include all efforts to “reduce emissions … or reduce the amount of carbon dioxide in the atmosphere.” Therefore, using his own definition of “geoengineering,” Trenberth’s remark could be interpreted thus:

The fact that we can not account for what is happening in the climate system makes any consideration to reduce emissions … or reduce the amount of carbon dioxide in the atmosphere quite hopeless as we will never be able to tell if it is successful or not!

All policy actions that would be required under the EPA endangerment finding, cap-and-trade legislation, and any global climate treaty amount to attempts to reduce carbon dioxide emissions. Thus, by his own admission, Kevin Trenberth appears convinced that all these efforts are quite hopeless indeed.

Daniel Compton is a research associate at the Competitive Enterprise Institute and contributor to OpenMarket.org

FDIC Prepares for “an even-larger number of bank failures” in 2010

by Daniel Compton on December 17, 2009 · 1 comment

in Bailout Watch, Deregulate to Stimulate, Economy, Employment, Politics as Usual, Stimulus to Nowhere, Zeitgeist

In a display of supreme confidence in the strength of the American economy, the Federal Deposit Insurance Corporation announced a 2010 budget increase of close to 54% earlier this week.  The FDIC’s annual operating budget grew from $2.6 billion in 2009 to $4 billion for 2010.  The largest portion of the increase is devoted to funding takeovers of failed banks.  The 2009 budget allotted $1.3 billion for this purpose, while the new budget devotes $2.5 billion—nearly twice the amount.  Also in the budget is an increased allocation for staffing.  The FDIC intends to bring on over 1,600 new employees, most of whom are to be hired on a temporary basis, increasing their total staff by about 24% to 8,653.

And what is the impetus for this greatly increased budget?  The press release accompanying the new budget makes it clear that the increase is intended to “ensure that [they] are prepared to handle an even-larger number of bank failures” in 2010.  A total of 133 banks have failed so far in 2009, up from just 28 the previous year.

Clearly, the FDIC must not have gotten word that the recovery has begun.

Recession Over? Don’t Hold Your Breath

by Daniel Compton on November 2, 2009 · 2 comments

in Economy, Employment, Odds & Ends, Stimulus to Nowhere, Trade, Zeitgeist

The recent announcement that the GDP grew in the third quarter at an annualized rate of 3.5 percent was referred to by Treasury Secretary Tim Geithner as proof that the economy is finally improving.  But a quick glance at history demonstrates that this is not the case.

Between 1934 and 1937—during the heart of the Great Depression—GDP grew at by an average of 9.5 percent annually.  In 1934, GDP grew by nearly 11 percent, but it would be six more years until the depression finally ended.  Clearly, GDP growth alone cannot be taken as an indicator that the economy is on the upswing.

It is also disheartening that the two major contributors to GDP growth in the third quarter were housing construction and auto sales, both of which were propped up by government subsidies.  Auto sales were boosted by the Cash for Clunkers program, and housing construction was driven by the $8,000 first time home buyer tax credit.

Combine this with other spurious accounting maneuvers used to calculate third quarter GDP, and it begins to appear that GDP might actually have decreased during this period.

In addition to phony GDP growth, there are other signs that the recession is not yet over.  Employment during the third quarter fell by over 750,000, and it is expected to fall further still.  Employment has been called a lagging indicator of economic health, but when economic health is measured in terms of the financial well-being of the population, employment is not a lagging indicator, it is the indicator.

The recent bankruptcy of CIT Group is another sign that our economic woes are far from over.  A recipient of $2.3 billion in TARP funds—deemed likely unrecoverable—CIT Group Inc. filed for Chapter 11 today, seeking protection from $10 billion in debt.  CIT finances close to one million businesses, and conducts business with over 80 percent of all Fortune 1000 companies, so there is enormous potential for negative secondary effects stemming from the bankruptcy.

The CIT Group bankruptcy comes on the heels of nine more bank failures on Friday, which brings this year’s total to 115.  These bank failures came at a cost of $2.5 billion to the FDIC deposit insurance fund.

There is a clear political incentive for Geithner and others to make efforts to convince us that this economic slump is over.  It is unfortunate that these efforts include no actual facts.

Regulation Not Worth Its Salt

by Daniel Compton on October 16, 2009 · 3 comments

in Environment, Health and Illness, Nanny State, Personal Liberty, Regulation, Zeitgeist

Recently, the US Food and Drug Administration, working with the Institute of Medicine, has been considering a change in the regulatory status of salt.  The FDA cannot currently restrict the amount of salt that can be added to processed foods, and the proposed change would allow them to do so.

Advocates of the proposed regulation, like former FDA commissioner David Kessler and the Center for Science in the Public Interest, argue that reducing the sodium in foods would improve people’s health and cut public health spending.  Opponents argue that the evidence supporting health benefits of sodium reduction is by no means conclusive, and that attempts to reduce sodium intake could actually be harmful.

But a recent study by University of California, Davis nutritionists concludes that it may not even be possible to reduce salt intake through regulation.  The study shows that people are naturally inclined to regulate salt intake to physiologically determined levels by unconsciously selecting foods to meet their needs.

According to the study, measurements collected from over 19,000 individuals from 33 countries worldwide indicate that daily sodium intake is confined to the relatively narrow range of 2,700 to 4,900 mg, with the worldwide average of 3,700 mg.  This challenges the widely held belief that daily sodium consumption in the United States, which averages about 3,400 mg, has reached extreme levels.

The study also cites decades of research describing the specific mechanism by which the central nervous system, acting together with several organ systems, controls our appetite for salt.

In one cited study, a group of nearly 600 participants took part in what was to be a 3 year sodium intake intervention, with the goal of reducing daily intake to 1,850 mg.  After the first 6 months, researchers noted that participants were unable to reduce sodium intake below about 2,750 mg per day—close to the bottom of the range the UC Davis study identified.

Another study had similar findings.  In this study, subjects, through intensive dietary counseling, reduced their daily sodium intake to an average of 1,775 mg over 4 weeks.  The subjects were then randomized to receive either a 2,300 mg sodium tablet or a placebo, while still receiving counseling.

When taking the placebo, average sodium intake stabilized around 2,750 mg—again very close to the bottom of the identified range.  This means that subjects naturally increased their sodium intake when blinded to their treatment.  When this group was switched over to receive the 2,300 mg sodium supplement, daily intake rose to only 4,050 mg, far less than the predicted 5,050 mg.  This suggests that subjects naturally reduced their dietary sodium intake without consciously intending to do so.

The UC Davis study goes on to cite a number of surveys indicating that sodium intake in the United Kingdom has “varied minimally” over the past 25 years, despite a costly Food Standards Agency  campaign to reduce sodium intake in the UK.
The Institute of Medicine says that daily sodium intake should not exceed 2,300 mg, and new guidelines to be released in 2010 may set the recommended maximum even lower. Any regulatory action taken by the FDA would presumably aim to reduce intake at least to this 2,300 mg level, even though it is 17 percent lower than the bottom of the range the UC Davis study identified, and a full 38 percent lower than the worldwide average.

Given the findings of this study, it seems likely that regulation restricting sodium in foods would be ineffective because people would unconsciously adjust their diets to compensate.  As the study puts it, “[sodium intake] is unlikely to be malleable by public policy initiatives”, and attempts to change consumption would “expend valuable national and personal resources against unachievable goals.”