The RD as Food Labeling Advisor for Food Companies About

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The RD as Food Labeling Advisor for Food Companies About

Transcript Of The RD as Food Labeling Advisor for Food Companies About

The RD as Food Labeling Advisor for Food Companies
Lauren Swann, MS, RD, LDN

About Me
I’ve been writing, evaluating, analyzing and advising on food labeling for decades and I still enjoy knowing all about this part of technical food marketing communications that helps consumers figure out the facts about their food.
I’ve written articles about food labeling for leading industry publications, developed continuing education short courses for food manufacturers, trade and professional associations, guest lectured at major universities, presented at annual conferences and developed a series of industry-publicized webinars on specific food labeling subtopics related to product development and marketing matters - trends, positioning strategy, public health concerns and anticipated regulatory changes and legal outcomes.
I got my experience in U.S Food & Drug Administration (FDA) and Dept. of Agriculture (USDA) labeling regulations first from staff positions with major manufacturers but also through consulting work. My marketing communications background enables integrating how the food label and it's required elements, optional features and associated promotion influence product and menu development and play a role in successful and effective food marketing.
After earning a Bachelor’s in Medical Dietetics and becoming an RD in 1981, I spent a year in hospital work, then got a grad degree in Nutrition Communications which led to a Consumer Communications position with Kraft Foods in their Consumer Affairs department, from there I applied for an internal promotion in the Regulatory Affairs department and began working as a Labeling Compliance Specialist – 5 years on staff including Supervisor Regulatory Compliance and Project Manager before going out on my own. Eight years of self-employment led to a position establishing the Regulatory Affairs department for a Campbell’s Soup spin-off company, Vlasic Foods – a year after they became Pinnacle Foods I returned to consulting and advisory work.

Learning Objectives

1 Identify core
competencies that relate to applied food labeling regulations.

2 Recognize how a
dietetics educational foundation can lead
to food labeling regulations
compliance work.

3 Explain the
role RDs can play in food labeling advice.


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Why This Presentation?
• Frequent inquiries on the Academy of Nutrition and Dietetics (AND) Dietetic Practice Group (DPG) Electronic Mailing Lists (EMLs) about work in food labeling, often from nutrient analyses requests, yet there is so much more to food labeling regulations compliance
• RDNs exploring food/nutrition labeling can arise in a variety of ways – such as inquiries from the bakery or café down the street, interest in a full-time job opening or adding a consulting specialty
• Opportunities are likely to grow with menu labeling compliance and packaged foods nutrition facts label revisions
• I’m not the first
• My path, others’ paths
• Our educational requirements can be a good foundation
• Scope of Practice v Core Competencies

Dietetics Scope of Practice
“Scope of practice in nutrition and dietetics encompasses the range of roles, activities and regulations within which nutrition and dietetics practitioners perform. For credentialed practitioners, scope of practice is typically established within the practice act and interpreted and controlled by the agency or board that regulates the practice of the profession in a given state.”1
“A credentialed practitioner’s individual scope of practice in nutrition and dietetics has flexible boundaries to capture the breadth of the practitioner’s professional practice, which is informed by the RDN’s or NDTR’s education, training, credentialing, experience, and demonstrated competence.”2
Food and nutrition labeling regulations compliance work is within a dietetics scope of practice.

1Scope of Practice. Academy of Nutrition & Dietetics website. Accessed April 23, 2020.

2Hui K, Khan M, McCauley S. Why Do Practitioners Need to Read the

Revised 2017 Scope/Standards 2018;118(5):964





Die#t. TDVirtualSymposium


Dietetics Scope of Practice
Academy of Nutrition and Dietetics: Revised 2017 Scope of Practice for the Registered Dietitian Nutritionist3:
Nutrition Informatics • Use technology for recipe and menu management, perform or oversee nutrition
analysis of product ingredients to comply with state and federal regulations for food labeling and restaurant menu nutrient analysis.
US Public Health Service • Manage staff and interns; oversee foodservice operations; provide inpatient and
outpatient clinical nutrition services; plan, design, and implement research; ensure food and dietary supplement label compliance; inspect food for food safety; and educate the public on nutrition, food labeling, and biologics.

3Andersen, D, et al. Academy of Nutrition and

Dietetics: Revised 2017 Scope of Practice for the

Registered Dietitian Nutritionist. J. Acad. Nutr. Diet.

2018; 118, (1):141-165.



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Applied Food Labeling Regulations: A Core Competency for RDNs
The American Dietetic Association Foundation Knowledge and Skills and Competency Requirements for Entry-Level Dietitians:4
• Content area: Food
• Basic knowledge about: food technology, biotechnology, culinary techniques
• Working knowledge of: food and nutrition laws, regulations, and policies
• Demonstrated ability to: calculate and interpret nutrient composition of foods, translate nutrition needs into menus for individuals and groups, write specifications for food, apply food science knowledge to functions of ingredients in food
4The American Dietetic Association Foundation Knowledge and Skills and Competency Requirements for Entry-Level Dietitians. In: Institute of Medicine (US) Committee on Nutrition Services for Medicare Beneficiaries. The Role of Nutrition in Maintaining Health in the Nation's Elderly
#TDVirtualSymposium Evaluating Coverage of Nutrition Services for the Medicare Population.
Washington (DC): National Academies Press (US); 2000: Appendix E.

Applied Food Labeling Regulations: A Core Competency for RDNs
Food & Culinary Professionals DPG
• Core competencies for registered dietitian nutritionists active or interested in food and culinary career options within the profession.5
• Food laws and standards – federal nutrition label requirements

5Food & Culinary Professionals DPG Core Food & Culinary

Competencies. Food & Culinary Professionals website

accessed April 23, 2020




Are There Core Competencies for Food Labeling specialists?
Northeastern University, Graduate Program in Regulatory Affairs

Working in Regulatory Affairs: Careers And Trends6

• “Regulatory professionals come from a variety of backgrounds; there is no one degree or career trajectory. Successful regulatory affairs professionals typically have cross-functional training in areas such as science, pharmacy, engineering, marketing, and business.”

• “Over 88% of current regulatory professionals began working in a different industry before transitioning into regulatory affairs, according to the 2016 RAPS report. Most of these individuals worked first in related industries, such as research and development, manufacturing, clinical research.”

• “A majority of regulatory workers earn undergraduate degrees in the disciplines of life science, clinical science, public health, or engineering, but others begin in unrelated areas, such as business, economics, or liberal arts.”

6Working In Regulatory Affairs: Careers And Trends.

Northeastern University Graduate Programs website.

affairs-careers-and-trends/ November 3, 2018. Accessed April

23, 2020.



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Are There Core Competencies for Food Labeling specialists?
Food Labeling Regulations Compliance tends to fall under: • “Regulatory Affairs” or “Regulatory Compliance” • Many in food companies majored in food science or food chemistry – but other basic science
also • The RDs who trained me had pursued graduate level work and post-grad experience in food
science • Another example: RD from Gerber’s • “Become a Labeling Food Technologist: Education and Career Roadmap” ogist_Education_and_Career_Roadmap.html Food Labeling Specialist: Job Description & Career Definition
Food Labeling Overview
Labeling Elements
Food Labeling Overview: Federal Government Authorities
Food & Drug Administration (FDA) • All non-meat/poultry (unless a small percentage of it is contained) • Includes game/wild meats • Dietary supplements:
• criteria for product category with specific regulations, some the same as for food labels and some very different
• Supplement Facts • No pre-approval process for finished food or dietary supplement product
labels #TDVirtualSymposium

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Food Labeling Overview: Federal Government Authorities
“Food & Drug Administration (FDA) has jurisdiction over 80 percent of the food supply, including seafood, dairy, and produce. The US Dept of Agriculture (USDA) regulates meat, poultry, and processed egg products, while FDA regulates all other food products.”7

7Institute of Medicine and National Research Council. Enhancing Food Safety: The Role of the Food and Drug Administration. Washington, DC: The National Academies Press. 2010. Appendix D The U.S. Food and Drug Administration’s Food Defense Program.



Food Labeling Overview: Federal Government Authorities
USDA - Food Safety & Inspection Service (FSIS) • Meat & Poultry (excludes game and exotic meats unless under fee for
inspection) • Processed egg products, catfish • Initial pre-approval required for product to ship from an inspected
establishment • Generic labeling approval now for broader range of products without FSIS submission for approval • Electronic submissions for approval
Food Labeling Overview: Federal Government Authorities
USDA Agricultural Marketing Service (AMS): • For ALL (meat and non-meat) products • Bioengineered (GMO) labeling – required
disclosure Optional designations subject to regulations if used: • Organic – National Organic Standards Board • Grading & Quality Standards • Child Nutrition Labeling – School Meal
program (USDA-Food & Nutrition Service FNS)

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Food Labeling Overview: State Authority
• States usually adapt Federal Guidelines • California – Prop 65 • Recombinant bovine growth hormone (rBGH) and recombinant
bovine somatotropin (rBST) claim labeling • Perishable – “use-by” or “sell-by” labeling
• FDA – shell eggs and proposed guidelines • USDA-FSIS – product specific rules • Container Deposit Labeling
Food Labeling Overview: Federal Government Authorities
Liquor governed under: • Alcohol & Tobacco Tax & Trade Bureau (TTB), Dept of
Treasury But some Alcohol/Liquor is under FDA jurisdiction: • Certain beers meet "malt beverage" definition • Wine beverages and cider with less than 7% alcohol • Unfermented Beverages – use of the word “champagne" • Dealcoholized wine and malt beverages – labeling
Food Labeling Overview: Amenability
Considered an extension of labeling: • Product websites • Product literature – consumer & • Trade sell sheets • Point-of-Purchase/Point-of-Sale Advertising is under the Federal Trade Commission (FTC)

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Anatomy of a Food Label
• Some labeling is required, other labeling is optional but still subject to regulations and laws if used
• Even on an FDA amenable product, some elements are under a different federal authority e.g. • Required origin declaration on imported items: • Customs & Border Protection for packaged foods • USDA-AMS for raw agricultural commodities • Recently required GMO disclosure is under USDAAMS
Anatomy of a Food Label
Food Labeling vs Nutrition Labeling: • Nutrition Labeling: nutrients, nutrition-related claims • Food Labeling: ingredient composition, quality claims
(“Natural”, etc.) Menu Labeling: • FDA only over nutrition • Restaurants also get into quality, ingredient, origin,
preparation/production claims Food Labeling is more than just nutrition!
Anatomy of a Food Label
• Minimum mandatory requirements • Statement of Identity: common/usual
name • Ingredient List (includes allergen disclosure) • Net Contents • Company Name/Address: “signature line” • USDA: Inspection Legend Seal • Nutrition Facts: unless exempt for product
volume and company size • Product Specific Requirements, for example:
• Percentage of juice • Warning statements • Raw meat handling statement

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Anatomy of a Food Label
All elements subject to graphic type size and placement requirements:

USDA-FSIS Descriptive Product Name for Raw Meat and Poultry with Added Solutions
• Immediately adjacent with no text or graphics in between • Percent of added solution and ingredients in one easy-to-read
typeface/style • Single-color contrast, upper/lower case, min. 1/3 size of largest
letter • "Contain/ing” ok but not “enhanced” if not subject to standards • Effective date 1/1/16, size requirement by 1/1/18 “Requiring common, usual, understandable names for products with added solutions to clearly easily distinguish them from products without. More descriptive product names enable consumers to purchase knowingly to suit their tastes - very helpful for trying to lower sodium intake or for other dietary concerns.”

Optional Claims

Involve a Specific Defined Nutrient • Nutrient Content • Structure Function (can involve a
botanical or herbal component) • Health or Disease-Prevention

Ingredient Quality or (no-nutrient) Compositional Claims • Natural, Organic, No-GMO
• Gluten-Free, [Allergen]-Free, LactoseFree
• Fresh
• No Preservatives
• No Caffeine • No Artificial Flavors, Colors, Ingredients
• Fruit/Vegetable equivalence/amount per serving
• Breed (Angus), Hormones, Antibiotics, Free-Range

Whole Grains amount per serving of product 3rd Party Seals, Symbols



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Menu Labeling: FDA as the Authority for Nutrition ONLY
• Chain restaurants and similar retail food establishments with 20 or more locations must disclose the number of calories contained in standard items on menus and menu boards
• Self-service foods and display foods must show calories in close proximity and clearly associated with the standard menu item
• Must also provide, upon request, certain written nutrition information; nutrients are not the exact same set as currently required on the Nutrition Facts label for packaged food products

What Are You Responsible For?
• Nutrition Facts: calculations or coordinating laboratory? Values or panel format?
• Ingredient List? • Allergen statement? • Whole label: expected to do a complete review? • Dietary supplements: substantiating structure-function claims
or just checking compliance for wording/terms?

Specific Labeling Examples

Labeling General Overall Labeling Product Name Ingred List Signature Statement (company name/address) Net Wt Nutrition Origin Claims - Ingredient/Quality Claims - Nutrient-based health


Language of Labeling


Name Game

Name Game

Allergen-Ingred of Avoid



Nutrition Labeling part 1



Whole Truths

Nutrition Labeling part 2

Nutrition Carbs Fat Protein Sodium-Salt Sugar Vitamins Minerals

Sweeter Labels (Sugar) Transitioning (Trans Fat) Push for Protein Tasty Labels (Sodium and Flavor) Sweeter Labels (Sugar) Super-Power Foods Fortification

Category Specific Grocery Supermarket Children's Food

Labeling for Retailer Labeling for Kids Food market

Product Specific

Dietary Supplements

Supplement Labeling



ium Seafood Labeling Beverage & Caffe











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RD/RDN Background
Coursework and Training and Labeling Regulations Compliance Advisory
Dietetics Core Competencies and Food Labeling Regulations Work • Human Nutrition • Dietary Analyses • Nutrient Composition of Food • Chemistry, Biology • Food Science
Dietetics Scope of Practice
Dietitians have always worked in food labeling regulations: • FDA and USDA staff • Food manufacturers • Industry trade associations • Commodity boards Conducted and managed clinical trials to support: • Substantiation of structure-function claims • Proposed or petitioned disease-prevention (“health”) claims

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