Dissertation Project | “Bread and Butter Policy: America’s Food Identity Standards, 1938- 2018”

“An almond doesn’t lactate, I will confess” - Food and Drug Administration Commissioner Scott Gottlieb, July 2018

At a policy summit in the summer of 2018, FDA Commissioner Gottlieb voiced his support for a narrow definition of milk that only permits secretions from the mammary glands of animals to be called “milk”. His comments came in response to the growing popularity of alternative “milks” like almond milk, and recent calls from dairy farmers for stricter regulation of what can be called milk. While food industry lobbies have been the loudest voices in this debate, the naming of milk is governed by a little known provision initially created as a part of the Food Drug and Cosmetic Act of 1938 to protect consumers: food identity standards. Presently, there are about 300 food identity standards in effect that dictate the ingredients and naming of many common foods like bread, peanut-butter, and cheese. Over the course of the 20th century, the framing of standards was shaped by bureaucrats, politicians, business-people, and activists, sometimes generating thousands of pages of testimony for a single standard. These provisions hold a massive influence on America’s food supply, yet currently there are no comprehensive studies on the history of these standards. This dissertation traces the history of the FDA’s food identity standards to understand how these regulations were written, and who they were meant to protect. My research suggests that the history of food identity standards is not simply the history of a little-known provision, but a reflection of the scientific, medical, cultural, and economic transformations of the twentieth century. This project uses the standards as an archive to contribute to contemporary conversations like concerns about the health implications of processed foods, the capture of regulatory agencies, and public health issues like the obesity epidemic.