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Trans Fat Ban page 2
Why Not Turn Away Less Nutritious Food Donations
The Food Bank and the network of programs we serve are not in a position to refuse donations of food. Because of the manner in which donated food is offered in mixed loads (as described in the previous section) it would in fact be irresponsible of the network to turn away food. Firstly, due to insufficient government funding for emergency food, there is not enough food in the emergency food system to meet the existing need, and given the intensification of poverty in the city during the past few years we can only expect this need to grow. Also, as the vast majority of the most nutritious, fresh food in the system comes through the food donation channel, turning away mixed loads of donated food to rid the emergency food system of less nutritious food would also reduce access to fresh, healthy food for the poorest New Yorkers.
It should also be understood that the emergency food programs do not have the capacity to monitor labels in the manner that would be required, due to the heavy reliance on volunteers and the chronic lack of operational funding available for emergency food organizations (as described in the background section). Indeed, given its constraints, it is a miracle that this under-supported system manages to serve 1.2 million of the neediest New Yorkers every year.
Why Trans Fat Should Be Eliminated at the Source
As previously mentioned, a full analysis of the trans fat content of government-funded emergency food is not yet available. A recent onsite analysis of the Food Bank's warehouse revealed very little inventory that contains trans fat, most of which was food supplied by donations. However, until such time as the issue is addressed at the source and a trans fat ban is implemented at the manufacturing and processing end of the food supply chain, it is not possible to assert that trans fat will not be present in future shipments of government or donated food. Rather, given the extent to which the emergency food system is dependent on food that comes from outside New York City and State, coupled with the increasing dependency on donated food, it is very likely that a small percentage of food containing trans fat will continue to find its way into the city's emergency food system. Should future allocations of government food contain food with trans fat, it would be wholly irresponsible and impractical to expect that soup kitchens in New York City would not be permitted to utilize this inventory. As mentioned earlier, the vast majority of the government food is supplied by the federal government, and thus will not necessarily be in compliance with a local ban. In addition, if local or other government agencies opt to purchase alternative food items to ensure compliance with the proposed trans fat ban, a cost analysis should be conducted to ensure that no loss of food is incurred. Increased food costs, without a matching increase in government funding, would result in even less government-funded food entering the emergency food system — at a time when soup kitchens and other emergency food programs do not have sufficient supplies to help the vulnerable New Yorkers standing in line for food — and would further increase reliability on donated food — which typically includes a higher percentage of inventory containing trans fat.
It would be beneficial to further consider that the typical donated food items that contain trans fat do not constitute the main meals served in soup kitchens. As one would expect trans fat is usually found in donated items such as crackers, cookies and pies — which could be described as the typical luxury foods that no one of us actually needs to eat. However, it may even be counterproductive to cite soup kitchens for the provision of this food and it runs the risk of sending the wrong message. After all, who doesn't like to indulge in the occasional edible luxury? In fact, in the context of a soup kitchen, providing a plate of cookies as an extra food item can even help to lend an atmosphere of normalcy, creating an environment that is warm, friendly and inviting. We look forward to a day when the manufacturers of all such luxury food items take the care or are required by law to eliminate all ingredients that constitute serious health risks, such as corn syrup and trans fat, but in the meantime it would be regrettable if policies aimed at improving the health of all residents were to inadvertently result in further restricting food access for the poorest among us. We should aim to restrict food processing, not poor people. What we need are sensible policies that aim to increase choice and access to the most nutritious food available, and strong campaigns to ensure that the healthiest type of food is being manufactured for all of us.
Proposed Ban May Increase Amount of Trans Fat Food in Emergency Food System
While the recent changes in the federal labeling law and the proposed trans fat ban are intended to improve the quality of all food, for all populations, over time, it should be noted that these measures run the risk of actually increasing the supply of food containing trans fat into the emergency food program system. As mentioned in the background section, a certain amount of food dumping inspires some food donations. In addition to good quality food items, typical donations also include food that is not selling well. The proposed trans fat ban will serve to heighten public consciousness about the dangers of trans fat in food, and although a seemingly positive outcome, it will result in more consumer avoidance of food items containing trans fat in establishments outside of restaurants, such as grocery stores, thereby impacting market trends. The emergency food providers share in the collective hope that heightened consumer awareness will encourage manufacturers to voluntarily refrain from using trans fat in food processing, but as the proposed ban is limited to New York City, it is likely that some manufacturers will continue to use trans fat, and a long period of dumping food that no one else wants into the emergency food system will result. Sadly, it will be the poorest and neediest of New Yorkers who will get the short end of the trans fat stick, simply because they do not have enough money in their pockets to afford to walk into a grocery store and purchase their own food, after they incur the crippling costs of other basic necessities. Further, in keeping with usual trends, food dumping of this nature would be most likely to occur at the end of the grace period for other food service establishments, making it twice as difficult for soup kitchens to comply with the proposed ban.
Needed Measures to Address Why Low-income New Yorkers Eat Less Nutritiously
The greatest danger posed by the proposed trans fat ban, from the emergency food perspective, is that it distracts from the larger health issue that our programs struggle to combat every day — hunger. Of the one in four New Yorkers at risk of hunger, approximately half must rely on emergency food, and the majority lack access to affordable, nutritious food in their local communities. Increasing food choice and accessibility is key to improving the health and well-being of food insecure New Yorkers.
In the near term it is imperative that sufficient supplies of nutritious food be available to all families and individuals turning to soup kitchens, food pantries and other emergency food programs. To this end, new government funding to increase the supply of fresh food in emergency food programs would be a very welcome measure.
The experience of the emergency food program network is that people choose the healthiest options, such as fresh produce, whenever this food is available. But with food prices higher in New York City than anywhere else in the country, fresh food can be prohibitively expensive for families struggling to make ends meet. In addition, access to supermarkets and other retail establishments that offer fresh, nutritious food is very limited in low-income communities, forcing the poorest New Yorkers to travel longer distances to purchase healthy food, travel that may be physically or cost-prohibitive for the most vulnerable populations at risk of hunger, including the elderly and the disabled. As a result, at-risk families are often forced to resort to cheaper, less nutritious foods that are often high in fat, salt, sugar and preservatives. This lack of wholesome, nutritious food can lead to obesity and other health problems, such as diabetes and heart disease. A long-term solution that would significantly improve the health of poor New Yorkers is a solid investment in making fresh food available in low-income communities, including increasing the number of green markets and ensuring that markets can accept food stamps, WIC and other food vouchers, developing initiatives to increase the number of supermarkets in poor neighborhoods and making funding available to small local food stores to develop their capacity to sell fresh fruit and vegetables and other healthy foods.
As part of its mission to supply the food that is distributed by its network of emergency and community food programs to New Yorkers in need, the Food Bank supports and promotes the development of improved nutrition for New Yorkers at risk of hunger. Indeed, we view the very issue of hunger to be one of the gravest health concerns faced by New York City residents and would very much welcome the opportunity to spend more time in dialogue about long-term solutions to the problem. In the meantime, I wish to encourage reconsideration of the plan to implement the proposed trans fat ban at soup kitchens, bearing in mind the following concerns:
- Although the Food Bank supplies most of the food to the emergency food system in New York City, it only controls the purchasing for 8.5 percent of the total food distributed. The majority of food in the New York City emergency food system comes from outside of the city and state. While the City's EFAP will likely be in compliance with the ban, it only accounts for less than one-fifth of the total food distributed by the Food Bank. The USDA emergency food program (TEFAP) accounts for most of the government funded food in the system and will not be governed by the proposed ban. Similarly, reliance on donated food, which currently accounts for one-third of total distribution, is increasing and is the likeliest source of food containing trans fat.
- The Food Bank cannot turn away any food donations, as donations are typically provided in mixed allocations, and donated food is both the source of the most nutritious and the least nutritious food entering the emergency food system. Turning away donated food would result in less access to healthy, fresh food for low-income New Yorkers.
- Although soup kitchens provide prepared meals to members of the general public, they are not business ventures. Rather, due to limited operational budgets, they are heavily reliant on volunteers and do not have the capacity and/or control to monitor labels or change their operations in the manner and time period the trans fat ban proposal requires.
- Through network education and training as well as the development of strong relationships with donors the Food Bank has significantly increased the availability of nutritious, fresh food for New Yorkers at risk of hunger. Implementation of the trans fat ban as described by the proposal could result in an increase of food containing trans fat entering the emergency food system, particularly toward the end of the grace period, thereby serving as a set-back to the nutritional education and improvement work currently being conducted within the emergency food program network in the city.
- Further, it is of some concern that the trans fat ban is too small a measure to adequately address the health needs of New Yorkers at risk of hunger and may in fact detract from the numerous, pressing health-related matters that should be addressed, not the very least of which are an insufficient supply of emergency food to meet existing demand and lack of access to healthy, nutritious food in low-income communities. We encourage a broader focus that would address the need to develop government funding to increase the supply of fresh food in the emergency food system and increase the number of green markets and retail establishments providing healthy food choices in low-income neighborhoods.
In closing I again thank you for the opportunity to share this testimony today, and I invite more detailed discussion of the concerns and recommendations therein, and particularly encourage consideration of a mechanism that would allow for the extra hardship incurred by soup kitchens.
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 Hunger Safety Net 2004: Measuring Gaps in Food Assistance in New York City. (2004). Food Bank For New York City/Food Policy Institute, Rutgers University.