Michael T. Roberts

When we get into really complicated products, that becomes a complicated question.

Standards of identity are really important because that's the benchmark by which we decide whether a food is authentic or not.

They became very popular when we had the very first Food Act, the 1906 Pure Food and Drug Act, and then they became even more popular with the 1938 Federal Food and Drug and Cosmetic Act.

All of these acts were passed in response to food safety problems, or more broadly, food adulteration problems, which included both fraud and safety.

So you had standards of identity being populated by the FDA right and left on food.

In fact, peanut butter killed the making of standards.

How so?

Al Gore, Vice President, Bill Clinton, was given the assignment to modernize government, to clean up bureaucracies, cut waste.

And he encountered this long saga of the making of a peanut butter standard, which led for over a decade, years and years of arguing about what is peanut butter.

You had congressional hearings on this.

The FDA was tied up in the knots over science.

The question was, how many peanuts should it be in peanut butter?

And that was a really important economic question that had a lot of cost implications.

It dragged on for years and years, and tons of money was spent.

And Al Gore just wrote a scathing report about these peanut butter standards that were wasting time and money.

It really caught a lot of attention, and the FDA literally at that point stopped making standards because it just wasn't worth the effort.

Let's say, for example, you want to take to the FDA honey that you don't consider to be real honey, and the FDA has to decide that based on what?

Well, you don't have a standard of identity, so who's to say what honey is?

When I talked earlier about these different indirect ways of manipulating honey, do those take it out of the definition of honey?

Well, it's a great question, and this is something I love to pony up in my classes.