Bibliographies: 'United States. Department of Agriculture. Office of the Inspector General' – Grafiati (2024)

Abstract:

The Food Safety Modernization Act mandates building a national Integrated Food Safety System, which represents a seamless partnership among federal, state, local, territorial, and tribal agencies. During multistate foodborne illness outbreak investigations, local and state partners, the Centers for Disease Control and Prevention, the United States Food and Drug Administration (FDA), or the United States Department of Agriculture Food Safety Inspection Service, depending on the regulated food product, become engaged and assist in coordinating the efforts between partners involved and determine the allocation of resources. The FDA Center for Food Safety and Applied Nutrition (CFSAN) Office of the Coordinated Outbreak Response and Evaluation (CORE) Network coordinates foodborne illness outbreak surveillance, response, and post-response activities related to incidents involving multiple illnesses linked to FDA-regulated human food, dietary supplements, and cosmetic products. FDA has implemented the National Incident Management System (NIMS) Incident Command System (ICS) principles across the agency to coordinate federal response efforts, and CORE has adapted NIMS ICS principles for the emergency management of multistate foodborne illness outbreaks. CORE’s implementation of ICS principles has provided several benefits to the operational cycle of foodborne illness outbreak investigations, including establishing a consistent, standardized, and transparent step-by-step approach to outbreak investigations. ICS principles have been instrumental in the development of a national platform for rapid and systematic laboratory, traceback, and epidemiologic information sharing, data analysis, and decision-making. This allows for partners across jurisdictions to reach a consensus regarding outbreak goals and objectives, deploy resources, and take regulatory and public health actions.

Abstract:

The prevalence, costs, and disability associated with chronic pain continue to escalate. So too, the numerous modalities of treatments applied in managing these patients continue to increase as well. In the period from 2000 to 2011 interventional techniques increased 228%. In addition, analysis of utilization trends and expenditures for spinal interventional techniques alone from 2000 to 2008 illustrated an increase in Medicare fee-for-service expenditures of 240% in terms of dollars spent in the United States. The Office of Inspector General (OIG) of the Department of Health and Human Services showed an increase in facet joint and transforaminal epidural injections, with a significant proportion of these services did not meet the medical necessity criteria. The increasing utilization of interventional techniques is also associated with significant variations among specialty groups and regional variations among states. Overall procedures have increased by 173%, with rate of 130% per 100,000 Medicare beneficiaries for epidural injections; 383%, with a rate of 308% for facet joint interventions; and overall 410%, or a rate of 331% for sacroiliac joint interventions. Certain high volume interventions such as lumbar transforaminal epidural injections and lumbar facet joint neurolysis have actually increased a staggering 806% and 662%. Coverage policies across ambulatory settings and by multiple payers are highly variable. Apart from variability in the development of coverage policies, payments also substantially vary by site of service. In general, amongst the various ambulatory settings the highest payments are made to hospital outpatient departments (HOPDs) the lowest to in-office procedures, and payment to ambulatory surgery centers (ASCs) falling somewhere in the middle. This manuscript describes the many differences that exist between the various settings, and includes suggestions for accountable interventional pain management with coverage for techniques with evidence, addressing excessive use of specific techniques, and equalizing payments across multiple ambulatory settings. Key words: Accountable interventional pain management, Medicare, Medicare Evidence Development & Coverage Advisory Committee, epidural injections, facet joint interventions, sacroiliac joint injections, payment policies

Abstract:

Background: Recent reports of the United States Government Accountability Office (GAO), the Medicare Payment Advisory Commission (MedPAC), and the Office of Inspector General (OIG) expressed significant concern with overall fiscal sustainability of Medicare and exponential increase in costs for interventional pain management techniques. Interventional pain management (IPM) is an evolving specialty amenable to multiple influences. Evaluation and isolation of appropriate factors for increasing growth patterns have not been performed. Study Design: Analysis of the growth of interventional techniques in managing chronic pain in Medicare beneficiaries from 1997 to 2006. Objective: To evaluate the use of all interventional techniques. Methods: The standard 5% national sample of the CMS carrier claim record data for 1997, 2002, and 2006 was utilized. This data set provides information on Medicare enrollees in the feefor-service Medicare program. Current procedural technology (CPT) codes for 1997, 2002, and 2006 were used to identify the number of procedures performed each year, and trends in expenditures. Results: Interventional techniques increased significantly in Medicare beneficiaries from 1997 to 2006. Overall, there was an increase of 137% in patients utilizing IPM services with an increase of 197% in IPM services, per 100,000 Medicare beneficiaries. The majority of the increases were attributed to exponential growth in the performance of facet joint interventions. There was a 13.9-fold difference in the increase between the state with the lowest rate and the state with the highest rate in utilization patterns of interventional techniques (California 37% vs. Connecticut 514%), with an 11.6-fold difference between Florida and California (431% vs. 37% increase). In 2006, Florida showed a 12.7-fold difference compared to Hawaii with the lowest utilization rate. Hospital outpatient department (HOPD) expenses constituted the highest increase with fewer patients treated either in an ambulatory surgery center (ASC) or in-office setting. Overall HOPD payments constituted 5% of total 2006 Medicare payments, in contrast to 57% of total IPM payments, an 11.4-fold difference. Limitations: The limitations of this study include a lack of inclusion of Medicare participants in Medicare Advantage plans and potential documentation, coding, and billing errors. Conclusion: This study shows an overall increase of IPM services of 197% compared to an increase of 137% in patients utilizing IPM services from 1997 to 2006. Key words: Interventional techniques, interventional pain management, facet joint injections, epidural steroid injections, sacroiliac joint injections, chronic pain, chronic spinal pain, ambulatory surgery center (ASC), hospital outpatient department (HOPD)

Abstract:

ABSTRACT In May 2002, an oil spill exercise was led by Unocal Corporation - a major US based independent energy company, the U. S. Coast Guard, The Mexican Navy and members of several U.S. and Mexican government agencies. The objective of the exercise was to test the recently signed joint contingency plan between Mexico and the United States regarding pollution of the environment by discharges of hydrocarbons or other hazardous materials (MEXUS) and one of the associated geographic annexes; the MEXUS-Gulf. Participants and exercise design team members included representatives from U.S. Coast Guard, U.S. Minerals Management Service, the Texas General Land Office, Texas Natural Resource Conservation Commission, U.S. Department of the Interior, U.S. Department of Agriculture, Unocal Corporation, ERST/O'Brien's Inc., 1st Naval Zone of Mexico, Secretaria de Medio Ambiente y Recursos Naturales (SEMARNAT), Procuraduria Federal de Proteccion al Ambiente (PROFEPA) and Petroleos Mexicanos (PEMEX). This paper will describe the many lessons learned as the exercise was planned, conducted and evaluated. The exercise resulted in an exemplary show of cooperation between industry, U.S. and Mexican government officials in the desire to learn and understand the issues associated with hydrocarbon spills that cross or have the potential to cross the U.S./Mexico borders. Communications, language barriers, acceptable practices and standards for oil spill cleanup were all challenges faced by the teams in this unique exercise. Gaining a better understanding of these challenges and many other issues was invaluable and it was the consensus of all involved that this type of cooperative effort is the key to a successful cross-border response. Joint planning and training should continue in order to assure an effective implementation of the MEXUS plan should a real event ever occur.

Abstract:

Health care reform is one of the hottest topics in America. One need look no further than this year’s election cycle to see that health care reform was one of the main platforms for nearly every candidate for the 2020 election. Why is this the case? Healthcare costs amount to 17.9% of the overall Gross Domestic Product (“GDP”). This figure is shockingly high, especially when compared to health care costs of similarly situated countries. As it currently stands, the United States ranks at the top of per capita health care spending. Therefore, it should sadden the soul of our nation that our health care outcomes are among the lowest in the world. In addition to this cost inefficiency and ineffective care, millions of Americans are without affordable health insurance options. Emergency rooms have become the only option for medical treatment, which has exacerbated the rising costs of health care. Every person, whether directly or indirectly, is affected by health care costs. Solving this problem will take a multifaceted approach, and there are countless opinions on the best strategy to correct the direction of American health care. One approach that has gained popularity with health-industry stakeholders and regulators alike is value-based payment reform. Value-based payment models encourage integration and coordination of care across all levels of participation in the care team. Instead of a traditional fee-for-service payment model, the value-based payment models incentivize collaboration by the sharing of savings or increased profits with the healthcare team. The healthcare team realizes incentive-based payments only if there is accompanying proof that the patient care is improving while saving the federal program money. While there have been a handful of limited opportunities for this type of collaboration among providers, this program has not been widely adopted due to regulatory barriers that have impeded this type of reform. Health care fraud and abuse laws are one of the main barriers that limit the business arrangements and financial relationships that exist between hospitals, physicians, and other health care service providers, thus limiting new payment options to support a value-based payment model. The Anti-Kickback Statute (“AKS”), the Physician Self-Referral Law, and the False Claims Act (“FCA”) are three of the main health care fraud and abuse laws that are used to deter fraudsters from abusing Medicare and Medicaid programs. The AKS statute prohibits the payment or receipt of remuneration in exchange for health care referrals. The Physician Self-Referral Law, also known as the “Stark law” (“Stark”), prohibits a physician from referring patients for a designated health service to an entity that has a financial relationship with the physician or one of the physician’s immediate family members. The FCA is used to bring a claim against a person who submits a false or fraudulent bill to the government for reimbursem*nt. These three laws work in tandem to prevent fraud and abuse of the Medicare and Medicaid programs. Alleged violations of the AKS and the Stark law are often litigated through the use of the FCA, which allows for qui tam actions. While these laws serve an essential role in protect- ing patients from unnecessary medical treatment, overutilization of services, unfair competition, and general abuse of the federal programs, these laws are also blocking innovation in health care required to address the need for alternative models for health care delivery and payment. Additionally, compliance with these health care fraud and abuse laws is often difficult, even for the well-meaning who in good faith attempt to understand the requirements under the law. Numerous regulations and interpretive laws have been created in an effort to clarify how to implement and interpret these fraud and abuse laws. Guidance from both the Centers for Medicare and Medicaid Services (“CMS”) and the Office of Inspector General (“OIG”) has been very limited due to the relatively small number of advisory opinions issued over the years. Moreover, there is evidence that the guidance has been misused by the Department of Justice (“DOJ”). There is scant case law on many of the possible health care arrangements because stakeholders either shy away from entering into these arrangements for fear of violating a vague and ambiguous rule, or they settle with the DOJ to avoid litigation for fear of ruinous financial consequences of fighting the government. The law must be reformed to provide clarity and opportunity for innovation. As health care has dramatically evolved over the last three decades, so must the laws that were meant to prevent abuse in the health care system. Laws that were once relevant based on the traditional payment models are now largely irrelevant and an impediment to necessary change that will improve health care costs and outcomes. Due to the incredibly complex and numerous business relationships that exist in any given health care system, initiating change will be difficult. However, one approach that will alleviate the stress on hospitals and providers is to reform the Stark law to create an exception for value-based payment models, as well as to provide clarity for language currently included in the Stark law. I contend that these regulatory changes would enable hospitals and providers to create new arrangements that would focus on patient care, unobstructed by the myriad regulations that have prevented this type of collaboration. In Part II of this Article, I will examine the United States’ health care crisis and how it led to increased enforcement of the fraud and abuse laws that help deter the abuse in the system. Part III will center on the analysis of the fraud and abuse laws mentioned above and on how these laws work together to help prevent fraud in health care. In Part IV of this Article, I will discuss several necessary changes to the Stark law to help correct the direction of our health care spending and outcomes. I propose that a value-based exception be added to the current exceptions, as well as discuss the need for clarity of several critical terms to understand how to comply with the Stark exceptions. Additionally, I propose that the rules regarding advisory opinions should be amended to provide more guidance to the health care industry on these complicated issues. These changes, I contend, will relieve the barriers that are blocking the health care industry from making transformative changes and meeting the goal of higher quality care and increased efficiency.

Abstract:

Abstract Animals have been closely observed by humans for at least 17 000 years to gain critical knowledge for human and later animal survival. Routine scientific observations of animals as human surrogates began in the late 19th century driven by increases in new compounds resulting from synthetic chemistry and requiring characterization for potential therapeutic utility and safety. Statistics collected by the United States Department of Agriculture’s Animal and Plant Health Inspection Service and United Kingdom Home Office show that animal usage in biomedical research and teaching activities peaked after the mid-20th century and thereafter fell precipitously until the early 21st century, when annual increases (in the UK) were again observed, this time driven by expansion of genetically modified animal technologies. The statistics also show a dramatic transfer of research burden in the 20th and 21st centuries away from traditional larger and more publicly sensitive species (dogs, cats, non-human primates, etc) towards smaller, less publicly sensitive mice, rats, and fish. These data show that new technology can produce multi-faceted outcomes to reduce and/or to increase annual animal usage and to redistribute species burden in biomedical research. From these data, it is estimated that annual total vertebrate animal usage in biomedical research and teaching in the United States was 15 to 25 million per year during 2001–2018. Finally, whereas identification and incorporation of non-animal alternatives are products of, but not an integral component of, the animal research cycle, they replace further use of animals for specific research and product development purposes and create their own scientific research cycles, but are not necessarily a substitute for animals or humans for discovery, acquisition, and application of new (eg, previously unknown and/or unsuspected) knowledge critical to further advance human and veterinary medicine and global species survival.

Abstract:

ObjectiveImplement a mobile technology platform to capture and transmitsyndromic cattle data collected at Texas market sales.IntroductionAn active syndromic surveillance system was designed to collectcattle health information from a sample of Texas cattle market sales.Texas Animal Health Commission livestock inspectors record the totalnumber of animals observed along with the total number displayingclinical signs of interest grouped into body system categories(e.g. respiratory, neurologic, etc.). Inspection reports are submitted tothe United States Department of Agriculture Veterinary Services (VS)Risk Identification Team for monitoring.MethodsThe pilot project started in 2012 with paper-based data collectionforms to both 1) gain trust from the inspector supervisors and 2)evaluate the value of the system with minimal early investment.The data collected at each sale on paper-based forms were later enteredinto spreadsheets at the office. These sale inspection reports were thensubmitted to the inspector’s supervisor for review prior to forwardingby email to VS. VS staff aggregated data from each spreadsheet in toa centralized database and conducted weekly monitoring.Recently, a new reporting system was developed at VS to enablecollection and transmission of the data on mobile devices runningan Android operating system capable of transmitting data to VS viaa Wi-Fi connection. The new system was deployed March 2016following in-person training, release of a user guide document, and amonth of user testing.ResultsBetween March 2014 and June 2016 a total of 1,330 sale inspectionreports from 16 markets were submitted by spreadsheet an average11 days following the sale (range: 1 day through 141 days followingthe sale). These reports were tracked for data quality issues thatrequired manual intervention. It was discovered that 64 (4.8%) ofthe reports required correction. The most common types of dataquality issues were market sale date not provided, market alias ID notprovided, report submitted more than once, and report not submittedas an Excel file but as an image, such as a pdf file.Between March and June 2016 a total of 160 sale inspection reportsfrom 16 markets were submitted using mobile devices an average7 days following the sale (range: same day through 47 days followingthe sale). All data submitted could be directly imported into thecentralized database and processed as needed for monitoring withoutany data correction required.Some challenges encountered with deploying the mobile technologysystem included addressing the VS Information Technology securityrequirements for establishing user accounts and implementing directdata upload into VS systems. Additionally, Wi-Fi connectivity can bedifficult in some remote areas.Some advantages to using the mobile technology included havingthe option to download and run the application on most mobile devicesrunning the Android operating system. There was an improvementin data reporting timeliness of 4 days on average, and the rangesubstantially narrowed. There was also time savings for inspectorswho no longer needed to transfer hard copy data to a spreadsheet,and for VS personnel who no longer needed to aggregate data fromindividual spreadsheets. Improvements in data quality included theability to directly report that sales were canceled or not attended;the ability to provide comments at various levels of detail related to thesale, the pen of animals observed, or specific signs observed; and therequirement to supply essential data elements such as sale date andmarket ID.ConclusionsThe conversion from a paper and spreadsheet-based sale inspectionreport to a mobile technology platform resulted in significant timesavings and data quality improvements that appeared to justify thesystem development and deployment costs and challenges. Thesebenefits support potential expansion of the system.

Abstract:

A same-but-different dichotomy has recently been encapsulated within the US Food and Drug Administration’s ill-defined concept of “substantial equivalence” (USFDA, FDA). By invoking this concept the genetically modified organism (GMO) industry has escaped the rigors of safety testing that might otherwise apply. The curious concept of “substantial equivalence” grants a presumption of safety to GMO food. This presumption has yet to be earned, and has been used to constrain labelling of both GMO and non-GMO food. It is an idea that well serves corporatism. It enables the claim of difference to secure patent protection, while upholding the contrary claim of sameness to avoid labelling and safety scrutiny. It offers the best of both worlds for corporate food entrepreneurs, and delivers the worst of both worlds to consumers. The term “substantial equivalence” has established its currency within the GMO discourse. As the opportunities for patenting food technologies expand, the GMO recruitment of this concept will likely be a dress rehearsal for the developing debates on the labelling and testing of other techno-foods – including nano-foods and clone-foods. “Substantial Equivalence” “Are the Seven Commandments the same as they used to be, Benjamin?” asks Clover in George Orwell’s “Animal Farm”. By way of response, Benjamin “read out to her what was written on the wall. There was nothing there now except a single Commandment. It ran: ALL ANIMALS ARE EQUAL BUT SOME ANIMALS ARE MORE EQUAL THAN OTHERS”. After this reductionist revelation, further novel and curious events at Manor Farm, “did not seem strange” (Orwell, ch. X). Equality is a concept at the very core of mathematics, but beyond the domain of logic, equality becomes a hotly contested notion – and the domain of food is no exception. A novel food has a regulatory advantage if it can claim to be the same as an established food – a food that has proven its worth over centuries, perhaps even millennia – and thus does not trigger new, perhaps costly and onerous, testing, compliance, and even new and burdensome regulations. On the other hand, such a novel food has an intellectual property (IP) advantage only in terms of its difference. And thus there is an entrenched dissonance for newly technologised foods, between claiming sameness, and claiming difference. The same/different dilemma is erased, so some would have it, by appeal to the curious new dualist doctrine of “substantial equivalence” whereby sameness and difference are claimed simultaneously, thereby creating a win/win for corporatism, and a loss/loss for consumerism. This ground has been pioneered, and to some extent conquered, by the GMO industry. The conquest has ramifications for other cryptic food technologies, that is technologies that are invisible to the consumer and that are not evident to the consumer other than via labelling. Cryptic technologies pertaining to food include GMOs, pesticides, hormone treatments, irradiation and, most recently, manufactured nano-particles introduced into the food production and delivery stream. Genetic modification of plants was reported as early as 1984 by Horsch et al. The case of Diamond v. Chakrabarty resulted in a US Supreme Court decision that upheld the prior decision of the US Court of Customs and Patent Appeal that “the fact that micro-organisms are alive is without legal significance for purposes of the patent law”, and ruled that the “respondent’s micro-organism plainly qualifies as patentable subject matter”. This was a majority decision of nine judges, with four judges dissenting (Burger). It was this Chakrabarty judgement that has seriously opened the Pandora’s box of GMOs because patenting rights makes GMOs an attractive corporate proposition by offering potentially unique monopoly rights over food. The rear guard action against GMOs has most often focussed on health repercussions (Smith, Genetic), food security issues, and also the potential for corporate malfeasance to hide behind a cloak of secrecy citing commercial confidentiality (Smith, Seeds). Others have tilted at the foundational plank on which the economics of the GMO industry sits: “I suggest that the main concern is that we do not want a single molecule of anything we eat to contribute to, or be patented and owned by, a reckless, ruthless chemical organisation” (Grist 22). The GMO industry exhibits bipolar behaviour, invoking the concept of “substantial difference” to claim patent rights by way of “novelty”, and then claiming “substantial equivalence” when dealing with other regulatory authorities including food, drug and pesticide agencies; a case of “having their cake and eating it too” (Engdahl 8). This is a clever slight-of-rhetoric, laying claim to the best of both worlds for corporations, and the worst of both worlds for consumers. Corporations achieve patent protection and no concomitant specific regulatory oversight; while consumers pay the cost of patent monopolization, and are not necessarily apprised, by way of labelling or otherwise, that they are purchasing and eating GMOs, and thereby financing the GMO industry. The lemma of “substantial equivalence” does not bear close scrutiny. It is a fuzzy concept that lacks a tight testable definition. It is exactly this fuzziness that allows lots of wriggle room to keep GMOs out of rigorous testing regimes. Millstone et al. argue that “substantial equivalence is a pseudo-scientific concept because it is a commercial and political judgement masquerading as if it is scientific. It is moreover, inherently anti-scientific because it was created primarily to provide an excuse for not requiring biochemical or toxicological tests. It therefore serves to discourage and inhibit informative scientific research” (526). “Substantial equivalence” grants GMOs the benefit of the doubt regarding safety, and thereby leaves unexamined the ramifications for human consumer health, for farm labourer and food-processor health, for the welfare of farm animals fed a diet of GMO grain, and for the well-being of the ecosystem, both in general and in its particularities. “Substantial equivalence” was introduced into the food discourse by an Organisation for Economic Co-operation and Development (OECD) report: “safety evaluation of foods derived by modern biotechnology: concepts and principles”. It is from this document that the ongoing mantra of assumed safety of GMOs derives: “modern biotechnology … does not inherently lead to foods that are less safe … . Therefore evaluation of foods and food components obtained from organisms developed by the application of the newer techniques does not necessitate a fundamental change in established principles, nor does it require a different standard of safety” (OECD, “Safety” 10). This was at the time, and remains, an act of faith, a pro-corporatist and a post-cautionary approach. The OECD motto reveals where their priorities lean: “for a better world economy” (OECD, “Better”). The term “substantial equivalence” was preceded by the 1992 USFDA concept of “substantial similarity” (Levidow, Murphy and Carr) and was adopted from a prior usage by the US Food and Drug Agency (USFDA) where it was used pertaining to medical devices (Miller). Even GMO proponents accept that “Substantial equivalence is not intended to be a scientific formulation; it is a conceptual tool for food producers and government regulators” (Miller 1043). And there’s the rub – there is no scientific definition of “substantial equivalence”, no scientific test of proof of concept, and nor is there likely to be, since this is a ‘spinmeister’ term. And yet this is the cornerstone on which rests the presumption of safety of GMOs. Absence of evidence is taken to be evidence of absence. History suggests that this is a fraught presumption. By way of contrast, the patenting of GMOs depends on the antithesis of assumed ‘sameness’. Patenting rests on proven, scrutinised, challengeable and robust tests of difference and novelty. Lightfoot et al. report that transgenic plants exhibit “unexpected changes [that] challenge the usual assumptions of GMO equivalence and suggest genomic, proteomic and metanomic characterization of transgenics is advisable” (1). GMO Milk and Contested Labelling Pesticide company Monsanto markets the genetically engineered hormone rBST (recombinant Bovine Somatotropin; also known as: rbST; rBGH, recombinant Bovine Growth Hormone; and the brand name Prosilac) to dairy farmers who inject it into their cows to increase milk production. This product is not approved for use in many jurisdictions, including Europe, Australia, New Zealand, Canada and Japan. Even Monsanto accepts that rBST leads to mastitis (inflammation and pus in the udder) and other “cow health problems”, however, it maintains that “these problems did not occur at rates that would prohibit the use of Prosilac” (Monsanto). A European Union study identified an extensive list of health concerns of rBST use (European Commission). The US Dairy Export Council however entertain no doubt. In their background document they ask “is milk from cows treated with rBST safe?” and answer “Absolutely” (USDEC). Meanwhile, Monsanto’s website raises and answers the question: “Is the milk from cows treated with rbST any different from milk from untreated cows? No” (Monsanto). Injecting cows with genetically modified hormones to boost their milk production remains a contested practice, banned in many countries. It is the claimed equivalence that has kept consumers of US dairy products in the dark, shielded rBST dairy farmers from having to declare that their milk production is GMO-enhanced, and has inhibited non-GMO producers from declaring their milk as non-GMO, non rBST, or not hormone enhanced. This is a battle that has simmered, and sometimes raged, for a decade in the US. Finally there is a modest victory for consumers: the Pennsylvania Department of Agriculture (PDA) requires all labels used on milk products to be approved in advance by the department. The standard issued in October 2007 (PDA, “Standards”) signalled to producers that any milk labels claiming rBST-free status would be rejected. This advice was rescinded in January 2008 with new, specific, department-approved textual constructions allowed, and ensuring that any “no rBST” style claim was paired with a PDA-prescribed disclaimer (PDA, “Revised Standards”). However, parsimonious labelling is prohibited: No labeling may contain references such as ‘No Hormones’, ‘Hormone Free’, ‘Free of Hormones’, ‘No BST’, ‘Free of BST’, ‘BST Free’,’No added BST’, or any statement which indicates, implies or could be construed to mean that no natural bovine somatotropin (BST) or synthetic bovine somatotropin (rBST) are contained in or added to the product. (PDA, “Revised Standards” 3) Difference claims are prohibited: In no instance shall any label state or imply that milk from cows not treated with recombinant bovine somatotropin (rBST, rbST, RBST or rbst) differs in composition from milk or products made with milk from treated cows, or that rBST is not contained in or added to the product. If a product is represented as, or intended to be represented to consumers as, containing or produced from milk from cows not treated with rBST any labeling information must convey only a difference in farming practices or dairy herd management methods. (PDA, “Revised Standards” 3) The PDA-approved labelling text for non-GMO dairy farmers is specified as follows: ‘From cows not treated with rBST. No significant difference has been shown between milk derived from rBST-treated and non-rBST-treated cows’ or a substantial equivalent. Hereinafter, the first sentence shall be referred to as the ‘Claim’, and the second sentence shall be referred to as the ‘Disclaimer’. (PDA, “Revised Standards” 4) It is onto the non-GMO dairy farmer alone, that the costs of compliance fall. These costs include label preparation and approval, proving non-usage of GMOs, and of creating and maintaining an audit trail. In nearby Ohio a similar consumer versus corporatist pantomime is playing out. This time with the Ohio Department of Agriculture (ODA) calling the shots, and again serving the GMO industry. The ODA prescribed text allowed to non-GMO dairy farmers is “from cows not supplemented with rbST” and this is to be conjoined with the mandatory disclaimer “no significant difference has been shown between milk derived from rbST-supplemented and non-rbST supplemented cows” (Curet). These are “emergency rules”: they apply for 90 days, and are proposed as permanent. Once again, the onus is on the non-GMO dairy farmers to document and prove their claims. GMO dairy farmers face no such governmental requirements, including no disclosure requirement, and thus an asymmetric regulatory impost is placed on the non-GMO farmer which opens up new opportunities for administrative demands and technocratic harassment. Levidow et al. argue, somewhat Eurocentrically, that from its 1990s adoption “as the basis for a harmonized science-based approach to risk assessment” (26) the concept of “substantial equivalence” has “been recast in at least three ways” (58). It is true that the GMO debate has evolved differently in the US and Europe, and with other jurisdictions usually adopting intermediate positions, yet the concept persists. Levidow et al. nominate their three recastings as: firstly an “implicit redefinition” by the appending of “extra phrases in official documents”; secondly, “it has been reinterpreted, as risk assessment processes have … required more evidence of safety than before, especially in Europe”; and thirdly, “it has been demoted in the European Union regulatory procedures so that it can no longer be used to justify the claim that a risk assessment is unnecessary” (58). Romeis et al. have proposed a decision tree approach to GMO risks based on cascading tiers of risk assessment. However what remains is that the defects of the concept of “substantial equivalence” persist. Schauzu identified that: such decisions are a matter of “opinion”; that there is “no clear definition of the term ‘substantial’”; that because genetic modification “is aimed at introducing new traits into organisms, the result will always be a different combination of genes and proteins”; and that “there is no general checklist that could be followed by those who are responsible for allowing a product to be placed on the market” (2). Benchmark for Further Food Novelties? The discourse, contestation, and debate about “substantial equivalence” have largely focussed on the introduction of GMOs into food production processes. GM can best be regarded as the test case, and proof of concept, for establishing “substantial equivalence” as a benchmark for evaluating new and forthcoming food technologies. This is of concern, because the concept of “substantial equivalence” is scientific hokum, and yet its persistence, even entrenchment, within regulatory agencies may be a harbinger of forthcoming same-but-different debates for nanotechnology and other future bioengineering. The appeal of “substantial equivalence” has been a brake on the creation of GMO-specific regulations and on rigorous GMO testing. The food nanotechnology industry can be expected to look to the precedent of the GMO debate to head off specific nano-regulations and nano-testing. As cloning becomes economically viable, then this may be another wave of food innovation that muddies the regulatory waters with the confused – and ultimately self-contradictory – concept of “substantial equivalence”. Nanotechnology engineers particles in the size range 1 to 100 nanometres – a nanometre is one billionth of a metre. This is interesting for manufacturers because at this size chemicals behave differently, or as the Australian Office of Nanotechnology expresses it, “new functionalities are obtained” (AON). Globally, government expenditure on nanotechnology research reached US$4.6 billion in 2006 (Roco 3.12). While there are now many patents (ETC Group; Roco), regulation specific to nanoparticles is lacking (Bowman and Hodge; Miller and Senjen). The USFDA advises that nano-manufacturers “must show a reasonable assurance of safety … or substantial equivalence” (FDA). A recent inventory of nano-products already on the market identified 580 products. Of these 11.4% were categorised as “Food and Beverage” (WWICS). This is at a time when public confidence in regulatory bodies is declining (HRA). In an Australian consumer survey on nanotechnology, 65% of respondents indicated they were concerned about “unknown and long term side effects”, and 71% agreed that it is important “to know if products are made with nanotechnology” (MARS 22). Cloned animals are currently more expensive to produce than traditional animal progeny. In the course of 678 pages, the USFDA Animal Cloning: A Draft Risk Assessment has not a single mention of “substantial equivalence”. However the Federation of Animal Science Societies (FASS) in its single page “Statement in Support of USFDA’s Risk Assessment Conclusion That Food from Cloned Animals Is Safe for Human Consumption” states that “FASS endorses the use of this comparative evaluation process as the foundation of establishing substantial equivalence of any food being evaluated. It must be emphasized that it is the food product itself that should be the focus of the evaluation rather than the technology used to generate cloned animals” (FASS 1). Contrary to the FASS derogation of the importance of process in food production, for consumers both the process and provenance of production is an important and integral aspect of a food product’s value and identity. Some consumers will legitimately insist that their Kalamata olives are from Greece, or their balsamic vinegar is from Modena. It was the British public’s growing awareness that their sugar was being produced by slave labour that enabled the boycotting of the product, and ultimately the outlawing of slavery (Hochschild). When consumers boycott Nestle, because of past or present marketing practices, or boycott produce of USA because of, for example, US foreign policy or animal welfare concerns, they are distinguishing the food based on the narrative of the food, the production process and/or production context which are a part of the identity of the food. Consumers attribute value to food based on production process and provenance information (Paull). Products produced by slave labour, by child labour, by political prisoners, by means of torture, theft, immoral, unethical or unsustainable practices are different from their alternatives. The process of production is a part of the identity of a product and consumers are increasingly interested in food narrative. It requires vigilance to ensure that these narratives are delivered with the product to the consumer, and are neither lost nor suppressed. Throughout the GM debate, the organic sector has successfully skirted the “substantial equivalence” debate by excluding GMOs from the certified organic food production process. This GMO-exclusion from the organic food stream is the one reprieve available to consumers worldwide who are keen to avoid GMOs in their diet. The organic industry carries the expectation of providing food produced without artificial pesticides and fertilizers, and by extension, without GMOs. Most recently, the Soil Association, the leading organic certifier in the UK, claims to be the first organisation in the world to exclude manufactured nonoparticles from their products (Soil Association). There has been the call that engineered nanoparticles be excluded from organic standards worldwide, given that there is no mandatory safety testing and no compulsory labelling in place (Paull and Lyons). The twisted rhetoric of oxymorons does not make the ideal foundation for policy. Setting food policy on the shifting sands of “substantial equivalence” seems foolhardy when we consider the potentially profound ramifications of globally mass marketing a dysfunctional food. If there is a 2×2 matrix of terms – “substantial equivalence”, substantial difference, insubstantial equivalence, insubstantial difference – while only one corner of this matrix is engaged for food policy, and while the elements remain matters of opinion rather than being testable by science, or by some other regime, then the public is the dupe, and potentially the victim. “Substantial equivalence” has served the GMO corporates well and the public poorly, and this asymmetry is slated to escalate if nano-food and clone-food are also folded into the “substantial equivalence” paradigm. Only in Orwellian Newspeak is war peace, or is same different. It is time to jettison the pseudo-scientific doctrine of “substantial equivalence”, as a convenient oxymoron, and embrace full disclosure of provenance, process and difference, so that consumers are not collateral in a continuing asymmetric knowledge war. References Australian Office of Nanotechnology (AON). Department of Industry, Tourism and Resources (DITR) 6 Aug. 2007. 24 Apr. 2008 < http://www.innovation.gov.au/Section/Innovation/Pages/ AustralianOfficeofNanotechnology.aspx >.Bowman, Diana, and Graeme Hodge. “A Small Matter of Regulation: An International Review of Nanotechnology Regulation.” Columbia Science and Technology Law Review 8 (2007): 1-32.Burger, Warren. “Sidney A. Diamond, Commissioner of Patents and Trademarks v. Ananda M. Chakrabarty, et al.” Supreme Court of the United States, decided 16 June 1980. 24 Apr. 2008 < http://caselaw.lp.findlaw.com/cgi-bin/getcase.pl?court=US&vol=447&invol=303 >.Curet, Monique. “New Rules Allow Dairy-Product Labels to Include Hormone Info.” The Columbus Dispatch 7 Feb. 2008. 24 Apr. 2008 < http://www.dispatch.com/live/content/business/stories/2008/02/07/dairy.html >.Engdahl, F. William. Seeds of Destruction. Montréal: Global Research, 2007.ETC Group. Down on the Farm: The Impact of Nano-Scale Technologies on Food and Agriculture. Ottawa: Action Group on Erosion, Technology and Conservation, November, 2004. European Commission. Report on Public Health Aspects of the Use of Bovine Somatotropin. Brussels: European Commission, 15-16 March 1999.Federation of Animal Science Societies (FASS). Statement in Support of FDA’s Risk Assessment Conclusion That Cloned Animals Are Safe for Human Consumption. 2007. 24 Apr. 2008 < http://www.fass.org/page.asp?pageID=191 >.Grist, Stuart. “True Threats to Reason.” New Scientist 197.2643 (16 Feb. 2008): 22-23.Hochschild, Adam. Bury the Chains: The British Struggle to Abolish Slavery. London: Pan Books, 2006.Horsch, Robert, Robert Fraley, Stephen Rogers, Patricia Sanders, Alan Lloyd, and Nancy Hoffman. “Inheritance of Functional Foreign Genes in Plants.” Science 223 (1984): 496-498.HRA. Awareness of and Attitudes toward Nanotechnology and Federal Regulatory Agencies: A Report of Findings. Washington: Peter D. Hart Research Associates, 25 Sep. 2007.Levidow, Les, Joseph Murphy, and Susan Carr. “Recasting ‘Substantial Equivalence’: Transatlantic Governance of GM Food.” Science, Technology, and Human Values 32.1 (Jan. 2007): 26-64.Lightfoot, David, Rajsree Mungur, Rafiqa Ameziane, Anthony Glass, and Karen Berhard. “Transgenic Manipulation of C and N Metabolism: Stretching the GMO Equivalence.” American Society of Plant Biologists Conference: Plant Biology, 2000.MARS. “Final Report: Australian Community Attitudes Held about Nanotechnology – Trends 2005-2007.” Report prepared for Department of Industry, Tourism and Resources (DITR). Miranda, NSW: Market Attitude Research Services, 12 June 2007.Miller, Georgia, and Rye Senjen. “Out of the Laboratory and on to Our Plates: Nanotechnology in Food and Agriculture.” Friends of the Earth, 2008. 24 Apr. 2008 < http://nano.foe.org.au/node/220 >.Miller, Henry. “Substantial Equivalence: Its Uses and Abuses.” Nature Biotechnology 17 (7 Nov. 1999): 1042-1043.Millstone, Erik, Eric Brunner, and Sue Mayer. “Beyond ‘Substantial Equivalence’.” Nature 401 (7 Oct. 1999): 525-526.Monsanto. “Posilac, Bovine Somatotropin by Monsanto: Questions and Answers about bST from the United States Food and Drug Administration.” 2007. 24 Apr. 2008 < http://www.monsantodairy.com/faqs/fda_safety.html >.Organisation for Economic Co-operation and Development (OECD). “For a Better World Economy.” Paris: OECD, 2008. 24 Apr. 2008 < http://www.oecd.org/ >.———. “Safety Evaluation of Foods Derived by Modern Biotechnology: Concepts and Principles.” Paris: OECD, 1993.Orwell, George. Animal Farm. Adelaide: ebooks@Adelaide, 2004 (1945). 30 Apr. 2008 < http://ebooks.adelaide.edu.au/o/orwell/george >.Paull, John. “Provenance, Purity and Price Premiums: Consumer Valuations of Organic and Place-of-Origin Food Labelling.” Research Masters thesis, University of Tasmania, Hobart, 2006. 24 Apr. 2008 < http://eprints.utas.edu.au/690/ >.Paull, John, and Kristen Lyons. “Nanotechnology: The Next Challenge for Organics.” Journal of Organic Systems (in press).Pennsylvania Department of Agriculture (PDA). “Revised Standards and Procedure for Approval of Proposed Labeling of Fluid Milk.” Milk Labeling Standards (2.0.1.17.08). Bureau of Food Safety and Laboratory Services, Pennsylvania Department of Agriculture, 17 Jan. 2008. ———. “Standards and Procedure for Approval of Proposed Labeling of Fluid Milk, Milk Products and Manufactured Dairy Products.” Milk Labeling Standards (2.0.1.17.08). Bureau of Food Safety and Laboratory Services, Pennsylvania Department of Agriculture, 22 Oct. 2007.Roco, Mihail. “National Nanotechnology Initiative – Past, Present, Future.” In William Goddard, Donald Brenner, Sergy Lyshevski and Gerald Iafrate, eds. Handbook of Nanoscience, Engineering and Technology. 2nd ed. Boca Raton, FL: CRC Press, 2007.Romeis, Jorg, Detlef Bartsch, Franz Bigler, Marco Candolfi, Marco Gielkins, et al. “Assessment of Risk of Insect-Resistant Transgenic Crops to Nontarget Arthropods.” Nature Biotechnology 26.2 (Feb. 2008): 203-208.Schauzu, Marianna. “The Concept of Substantial Equivalence in Safety Assessment of Food Derived from Genetically Modified Organisms.” AgBiotechNet 2 (Apr. 2000): 1-4.Soil Association. “Soil Association First Organisation in the World to Ban Nanoparticles – Potentially Toxic Beauty Products That Get Right under Your Skin.” London: Soil Association, 17 Jan. 2008. 24 Apr. 2008 < http://www.soilassociation.org/web/sa/saweb.nsf/848d689047 cb466780256a6b00298980/42308d944a3088a6802573d100351790!OpenDocument >.Smith, Jeffrey. Genetic Roulette: The Documented Health Risks of Genetically Engineered Foods. Fairfield, Iowa: Yes! Books, 2007.———. Seeds of Deception. Melbourne: Scribe, 2004.U.S. Dairy Export Council (USDEC). Bovine Somatotropin (BST) Backgrounder. Arlington, VA: U.S. Dairy Export Council, 2006.U.S. Food and Drug Administration (USFDA). Animal Cloning: A Draft Risk Assessment. Rockville, MD: Center for Veterinary Medicine, U.S. Food and Drug Administration, 28 Dec. 2006.———. FDA and Nanotechnology Products. U.S. Department of Health and Human Services, U.S. Food and Drug Administration, 2008. 24 Apr. 2008 < http://www.fda.gov/nanotechnology/faqs.html >.Woodrow Wilson International Center for Scholars (WWICS). “A Nanotechnology Consumer Products Inventory.” Data set as at Sep. 2007. Woodrow Wilson International Center for Scholars, Project on Emerging Technologies, Sep. 2007. 24 Apr. 2008 < http://www.nanotechproject.org/inventories/consumer >.

Abstract:

During World War II, the Soviet Union’s food supply was in a state of crisis. Hitler’s army had occupied the agricultural heartlands of Ukraine and Southern Russia in 1941 and, as a result, agricultural production for the entire nation had plummeted. Soldiers in Red Army, who easily ate the best rations in the country, subsisted on a daily allowance of just under a kilogram of bread, supplemented with meat, tea, sugar and butter when and if these items were available. The hunger of the Red Army and its effect on the morale and strength of Europe’s eastern warfront were causes for concern for the Soviet government and its European and American allies. The one country with a food surplus decided to do something to help, and in 1942 the United States agreed to send thousands of pounds of meat, cheese and butter overseas to help feed the Red Army. After receiving several shipments of the all-American spiced canned meat SPAM, the Red Army’s quartermaster put in a request for a more familiar canned pork product, Russian tushonka. Pound for pound, America sent more pigs overseas than soldiers during World War II, in part because pork was in oversupply in the America of the early 1940s. Shipping meat to hungry soldiers and civilians in war torn countries was a practical way to build business for the U.S. meat industry, which had been in decline throughout the 1930s. As per a Soviet-supplied recipe, the first cans of Lend-Lease tushonka were made in the heart of the American Midwest, at meatpacking plants in Iowa and Ohio (Stettinus 6-7). Government contracts in the meat packing industry helped fuel economic recovery, and meatpackers were in a position to take special request orders like the one for tushonka that came through the lines. Unlike SPAM, which was something of a novelty item during the war, tushonka was a food with a past. The original recipe was based on a recipe for preserved meat that had been a traditional product of the Ural Mountains, preserved in jars with salt and fat rather than by pressure and heat. Thus tushonka was requested—and was mass-produced—not simply as a convenience but also as a traditional and familiar food—a taste of home cooking that soldiers could carry with them into the field. Nikita Khrushchev later claimed that the arrival of tushonka was instrumental in helping the Red Army push back against the Nazi invasion (178). Unlike SPAM and other wartime rations, tushonka did not fade away after the war. Instead, it was distributed to the Soviet civilian population, appearing in charity donations and on the shelves of state shops. Often it was the only meat product available on a regular basis. Salty, fatty, and slightly grey-toned, tushonka was an unlikely hero of the postwar-era, but during this period tushonka rose from obscurity to become an emblem of socialist modernity. Because it was shelf stable and could be made from a variety of different cuts of meat, it proved an ideal product for the socialist production lines where supplies and the pace of production were infinitely variable. Unusual in a socialist system of supply, this product shaped production and distribution lines, and even influenced the layout of meatpacking factories and the genetic stocks of the animals that were to be eaten. Tushonka’s initial ubiquity in the postwar Soviet Union had little to do with the USSR’s own hog industry. Pig populations as well as their processing facilities had been decimated in the war, and pigs that did survive the Axis invasion had been evacuated East with human populations. Instead, the early presence of tushonka in the pig-scarce postwar Soviet Union had everything to do with Harry Truman’s unexpected September 1945 decision to end all “economically useful” Lend-Lease shipments to the Soviet Union (Martel). By the end of September, canned meat was practically the only product still being shipped as part of Lend-Lease (NARA RG 59). Although the United Nations was supposed to distribute these supplies to needy civilians free of cost, travelers to the Soviet Union in 1946 spotted cans of American tushonka for sale in state shops (Skeoch 231). After American tushonka “donations” disappeared from store shelves, the Soviet Union’s meat syndicates decided to continue producing the product. Between its first appearance during the war in 1943, and the 1957 announcement by Nikita Khrushchev that Soviet policy would restructure all state animal farms to support the mass production of one or several processed meat products, tushonka helped to drive the evolution of the Soviet Union’s meat packing industry. Its popularity with both planners and the public gave it the power to reach into food commodity chains. It is this backward reach and the longer-term impacts of these policies that make tushonka an unusual byproduct of the Cold War era. State planners loved tushonka: it was cheap to make, the logistics of preparing it were not complicated, it was easy to transport, and most importantly, it served as tangible evidence that the state was accomplishing a long-standing goal to get more meat to its citizenry and improving the diet of the average Soviet worker. Tushonka became a highly visible product in the Soviet Union’s much vaunted push to establish a modern food regime intended to rival that of the United States. Because it was shelf-stable, wartime tushonka had served as a practical food for soldiers, but after the war tushonka became an ideal food for workers who had neither the time nor the space to prepare a home-cooked meal with fresh meat. The Soviet state started to produce its own tushonka because it was such an excellent fit for the needs and abilities of the Soviet state—consumer demand was rarely considered by planners in this era. Not only did tushonka fit the look and taste of a modern processed meat product (that is, it was standard in texture and flavor from can to can, and was an obviously industrially processed product), it was also an excellent way to make the most of the predominant kind of meat the Soviet Union had the in the 1950s: small scraps low-grade pork and beef, trimmings leftover from butchering practices that focused on harvesting as much animal fat, rather than muscle, from the carcass in question. Just like tushonka, pork sausages and frozen pelmeny, a meat-filled pasta dumpling, also became winning postwar foods thanks to a happy synergy of increased animal production, better butchering and new food processing machines. As postwar pigs recovered their populations, the Soviet processed meat industry followed suit. One official source listed twenty-six different kinds of meat products being issued in 1964, although not all of these were pork (Danilov). An instructional manual distributed by the meat and milk syndicate demonstrated how meat shops should wrap and display sausages, and listed 24 different kinds of sausages that all needed a special style of tying up. Because of packaging shortages, the string that bound the sausage was wrapped in a different way for every type of sausage, and shop assistants were expected to be able to identify sausages based on the pattern of their binding. Pelmeny were produced at every meat factory that processed pork. These were “made from start to finish in a special, automated machine, human hands do not touch them. Which makes them a higher quality and better (prevoskhodnogo) product” (Book of Healthy and Delicious Food). These were foods that became possible to produce economically because of a co-occurring increase in pigs, the new standardized practice of equipping meatpacking plants with large-capacity grinders, and freezers or coolers and the enforcement of a system of grading meat. As the state began to rebuild Soviet agriculture from its near-collapse during the war, the Soviet Union looked to the United States for inspiration. Surprisingly, Soviet planners found some of the United States’ more outdated techniques to be quite valuable for new Soviet hog operations. The most striking of these was the adoption of competing phenotypes in the Soviet hog industry. Most major swine varieties had been developed and described in the 19th century in Germany and Great Britain. Breeds had a tendency to split into two phenotypically distinct groups, and in early 20th Century American pig farms, there was strong disagreement as to which style of pig was better suited to industrial conditions of production. Some pigs were “hot-blooded” (in other words, fast maturing and prolific reproducers) while others were a slower “big type” pig (a self-explanatory descriptor). Breeds rarely excelled at both traits and it was a matter of opinion whether speed or size was the most desirable trait to augment. The over-emphasis of either set of qualities damaged survival rates. At their largest, big type pigs resembled small hippopotamuses, and sows were so corpulent they unwittingly crushed their tiny piglets. But the sleeker hot-blooded pigs had a similarly lethal relationship with their young. Sows often produced litters of upwards of a dozen piglets and the stress of tending such a large brood led overwhelmed sows to devour their own offspring (Long). American pig breeders had been forced to navigate between these two undesirable extremes, but by the 1930s, big type pigs were fading in popularity mainly because butter and newly developed plant oils were replacing lard as the cooking fat of preference in American kitchens. The remarkable propensity of the big type to pack on pounds of extra fat was more of a liability than a benefit in this period, as the price that lard and salt pork plummeted in this decade. By the time U.S. meat packers were shipping cans of tushonka to their Soviet allies across the seas, US hog operations had already developed a strong preference for hot-blooded breeds and research had shifted to building and maintaining lean muscle on these swiftly maturing animals. When Soviet industrial planners hoping to learn how to make more tushonka entered the scene however, their interpretation of american efficiency was hardly predictable: scientifically nourished big type pigs may have been advantageous to the United States at midcentury, but the Soviet Union’s farms and hungry citizens had a very different list of needs and wants. At midcentury, Soviet pigs were still handicapped by old-fashioned variables such as cold weather, long winters, poor farm organisation and impoverished feed regimens. The look of the average Soviet hog operation was hardly industrial. In 1955 the typical Soviet pig was petite, shaggy, and slow to reproduce. In the absence of robust dairy or vegetable oil industries, Soviet pigs had always been valued for their fat rather than their meat, and tushonka had been a byproduct of an industry focused mainly on supplying the country with fat and lard. Until the mid 1950s, the most valuable pig on many Soviet state and collective farms was the nondescript but very rotund “lard and bacon” pig, an inefficient eater that could take upwards of two years to reach full maturity. In searching for a way to serve up more tushonka, Soviet planners became aware that their entire industry needed to be revamped. When the Soviet Union looked to the United States, planners were inspired by the earlier competition between hot-blooded and big type pigs, which Soviet planners thought, ambitiously, they could combine into one splendid pig. The Soviet Union imported new pigs from Poland, Lithuania, East Germany and Denmark, trying valiantly to create hybrid pigs that would exhibit both hot blood and big type. Soviet planners were especially interested in inspiring the Poland-China, an especially rotund specimen, to speed up its life cycle during them mid 1950s. Hybrdizing and cross breeding a Soviet super-pig, no matter how closely laid out on paper, was probably always a socialist pipe dream. However, when the Soviets decided to try to outbreed American hog breeders, they created an infrastructure for pigs and pig breeding that had a dramatic positive impact of hog populations across the country, and the 1950s were marked by a large increase in the number of pigs in the Soviet union, as well as dramatic increases in the numbers of purebred and scientific hybrids the country developed, all in the name of tushonka. It was not just the genetic stock that received a makeover in the postwar drive to can more tushonka; a revolution in the barnyard also took place and in less than 10 years, pigs were living in new housing stock and eating new feed sources. The most obvious postwar change was in farm layout and the use of building space. In the early 1950s, many collective farms had been consolidated. In 1940 there were a quarter of a million kolkhozii, by 1951 fewer than half that many remained (NARA RG166). Farm consolidation movements most often combined two, three or four collective farms into one economic unit, thus scaling up the average size and productivity of each collective farm and simplifying their administration. While there were originally ambitious plans to re-center farms around new “agro-city” bases with new, modern farm buildings, these projects were ultimately abandoned. Instead, existing buildings were repurposed and the several clusters of farm buildings that had once been the heart of separate villages acquired different uses. For animals this meant new barns and new daily routines. Barns were redesigned and compartmentalized around ideas of gender and age segregation—weaned baby pigs in one area, farrowing sows in another—as well as maximising growth and health. Pigs spent less outside time and more time at the trough. Pigs that were wanted for different purposes (breeding, meat and lard) were kept in different areas, isolated from each other to minimize the spread of disease as well as improve the efficiency of production. Much like postwar housing for humans, the new and improved pig barn was a crowded and often chaotic place where the electricity, heat and water functioned only sporadically. New barns were supposed to be mechanised. In some places, mechanisation had helped speed things along, but as one American official viewing a new mechanised pig farm in 1955 noted, “it did not appear to be a highly efficient organisation. The mechanised or automated operations, such as the preparation of hog feed, were eclipsed by the amount of hand labor which both preceded and followed the mechanised portion” (NARA RG166 1961). The American official estimated that by mechanizing, Soviet farms had actually increased the amount of human labor needed for farming operations. The other major environmental change took place away from the barnyard, in new crops the Soviet Union began to grow for fodder. The heart and soul of this project was establishing field corn as a major new fodder crop. Originally intended as a feed for cows that would replace hay, corn quickly became the feed of choice for raising pigs. After a visit by a United States delegation to Iowa and other U.S. farms over the summer of 1955, corn became the centerpiece of Khrushchev’s efforts to raise meat and milk productivity. These efforts were what earned Khrushchev his nickname of kukuruznik, or “corn fanatic.” Since so little of the Soviet Union looks or feels much like the plains and hills of Iowa, adopting corn might seem quixotic, but raising corn was a potentially practical move for a cold country. Unlike the other major fodder crops of turnips and potatoes, corn could be harvested early, while still green but already possessing a high level of protein. Corn provided a “gap month” of green feed during July and August, when grazing animals had eaten the first spring green growth but these same plants had not recovered their biomass. What corn remained in the fields in late summer was harvested and made into silage, and corn made the best silage that had been historically available in the Soviet Union. The high protein content of even silage made from green mass and unripe corn ears prevented them from losing weight in the winter. Thus the desire to put more meat on Soviet tables—a desire first prompted by American food donations of surplus pork from Iowa farmers adapting to agro-industrial reordering in their own country—pushed back into the commodity supply network of the Soviet Union. World War II rations that were well adapted to the uncertainty and poor infrastructure not just of war but also of peacetime were a source of inspiration for Soviet planners striving to improve the diets of citizens. To do this, they purchased and bred more and better animals, inventing breeds and paying attention, for the first time, to the efficiency and speed with which these animals were ready to become meat. Reinventing Soviet pigs pushed even back farther, and inspired agricultural economists and state planners to embrace new farm organizational structures. Pigs meant for the tushonka can spent more time inside eating, and led their lives in a rigid compartmentalization that mimicked emerging trends in human urban society. Beyond the barnyard, a new concern with feed-to weight conversions led agriculturalists to seek new crops; crops like corn that were costly to grow but were a perfect food for a pig destined for a tushonka tin. Thus in Soviet industrialization, pigs evolved. No longer simply recyclers of human waste, socialist pigs were consumers in their own right, their newly crafted genetic compositions demanded ever more technical feed sources in order to maximize their own productivity. Food is transformative, and in this case study the prosaic substance of canned meat proved to be unusually transformative for the history of the Soviet Union. In its early history it kept soldiers alive long enough to win an important war, later the requirements for its manufacture re-prioritized muscle tissue over fat tissue in the disassembly of carcasses. This transformative influence reached backwards into the supply lines and farms of the Soviet Union, revolutionizing the scale and goals of farming and meat packing for the Soviet food industry, as well as the relationship between the pig and the consumer. References Bentley, Amy. Eating for Victory: Food Rationing and the Politics of Domesticity. Where: University of Illinois Press, 1998. The Book of Healthy and Delicious Food, Kniga O Vkusnoi I Zdorovoi Pishche. Moscow: AMN Izd., 1952. 161. Danilov, M. M. Tovaravedenie Prodovol’stvennykh Tovarov: Miaso I Miasnye Tovarye. Moscow: Iz. Ekonomika, 1964. Khrushchev, Nikita. Khrushchev Remembers. New York: Little, Brown & Company, 1970. 178. Long, James. The Book of the Pig. London: Upcott Gill, 1886. 102. Lush, Jay & A.L. Anderson, “A Genetic History of Poland-China Swine: I—Early Breed History: The ‘Hot Blood’ versus the ‘Big Type’” Journal of Heredity 30.4 (1939): 149-56. Martel, Leon. Lend-Lease, Loans, and the Coming of the Cold War: A Study of the Implementation of Foreign Policy. Boulder: Westview Press, 1979. 35. National Archive and Records Administration (NARA). RG 59, General Records of the Department of State. Office of Soviet Union affairs, Box 6. “Records relating to Lend Lease with the USSR 1941-1952”. National Archive and Records Administration (NARA). RG166, Records of the Foreign Agricultural Service. Narrative reports 1940-1954. USSR Cotton-USSR Foreign trade. Box 64, Folder “farm management”. Report written by David V Kelly, 6 Apr. 1951. National Archive and Records Administration (NARA). RG 166, Records of the Foreign Agricultural Service. Narrative Reports 1955-1961. Folder: “Agriculture” “Visits to Soviet agricultural installations,” 15 Nov. 1961. Skeoch, L.A. Food Prices and Ration Scale in the Ukraine, 1946 The Review of Economics and Statistics 35.3 (Aug. 1953), 229-35. State Archive of the Russian Federation (GARF). Fond R-7021. The Report of Extraordinary Special State Commission on Wartime Losses Resulting from the German-Fascist Occupation cites the following losses in the German takeover. 1948. Stettinus, Edward R. Jr. Lend-Lease: Weapon for Victory. Penguin Books, 1944.

Abstract:

In Ireland today, we eat more pigmeat per capita, approximately 32.4 kilograms, than any other meat, yet you very seldom if ever see a pig (C.S.O.). Fat and flavour are two words that are synonymous with pig meat, yet scientists have spent the last thirty years cross breeding to produce leaner, low-fat pigs. Today’s pig professionals prefer to use the term “pig finishing” as opposed to the more traditional “pig fattening” (Tuite). The pig evokes many themes in relation to cuisine. Charles Lamb (1775-1834), in his essay Dissertation upon Roast Pig, cites Confucius in attributing the accidental discovery of the art of roasting to the humble pig. The pig has been singled out by many cultures as a food to be avoided or even abhorred, and Harris (1997) illustrates the environmental effect this avoidance can have by contrasting the landscape of Christian Albania with that of Muslim Albania.This paper will focus on the pig in Irish cuisine and culture from ancient times to the present day. The inspiration for this paper comes from a folklore tale about how Saint Martin created the pig from a piece of fat. The story is one of a number recorded by Seán Ó Conaill, the famous Kerry storyteller and goes as follows:From St Martin’s fat they were made. He was travelling around, and one night he came to a house and yard. At that time there were only cattle; there were no pigs or piglets. He asked the man of the house if there was anything to eat the chaff and the grain. The man replied there were only the cattle. St Martin said it was a great pity to have that much chaff going to waste. At night when they were going to bed, he handed a piece of fat to the servant-girl and told her to put it under a tub, and not to look at it at all until he would give her the word next day. The girl did so, but she kept a bit of the fat and put it under a keeler to find out what it would be.When St Martin rose next day he asked her to go and lift up the tub. She lifted it up, and there under it were a sow and twelve piglets. It was a great wonder to them, as they had never before seen pig or piglet.The girl then went to the keeler and lifted it, and it was full of mice and rats! As soon as the keeler was lifted, they went running about the house searching for any hole that they could go into. When St Martin saw them, he pulled off one of his mittens and threw it at them and made a cat with that throw. And that is why the cat ever since goes after mice and rats (Ó Conaill).The place of the pig has long been established in Irish literature, and longer still in Irish topography. The word torc, a boar, like the word muc, a pig, is a common element of placenames, from Kanturk (boar’s head) in West Cork to Ros Muc (headland of pigs) in West Galway. The Irish pig had its place in literature well established long before George Orwell’s English pig, Major, headed the dictatorship in Animal Farm. It was a wild boar that killed the hero Diarmaid in the Fenian tale The Pursuit of Diarmaid and Gráinne, on top of Ben Bulben in County Sligo (Mac Con Iomaire). In Ancient and Medieval Ireland, wild boars were hunted with great fervour, and the prime cuts were reserved for the warrior classes, and certain other individuals. At a feast, a leg of pork was traditionally reserved for a king, a haunch for a queen, and a boar’s head for a charioteer. The champion warrior was given the best portion of meat (Curath Mhir or Champions’ Share), and fights often took place to decide who should receive it. Gantz (1981) describes how in the ninth century tale The story of Mac Dathó’s Pig, Cet mac Matach, got supremacy over the men of Ireland: “Moreover he flaunted his valour on high above the valour of the host, and took a knife in his hand and sat down beside the pig. “Let someone be found now among the men of Ireland”, said he, “to endure battle with me, or leave the pig for me to divide!”It did not take long before the wild pigs were domesticated. Whereas cattle might be kept for milk and sheep for wool, the only reason for pig rearing was as a source of food. Until the late medieval period, the “domesticated” pigs were fattened on woodland mast, the fruit of the beech, oak, chestnut and whitethorn, giving their flesh a delicious flavour. So important was this resource that it is acknowledged by an entry in the Annals of Clonmacnoise for the year 1038: “There was such an abundance of ackornes this yeare that it fattened the pigges [runts] of pigges” (Sexton 45). In another mythological tale, two pig keepers, one called ‘friuch’ after the boars bristle (pig keeper to the king of Munster) and the other called ‘rucht’ after its grunt (pig keeper to the king of Connacht), were such good friends that the one from the north would bring his pigs south when there was a mast of oak and beech nuts in Munster. If the mast fell in Connacht, the pig-keeper from the south would travel northward. Competitive jealousy sparked by troublemakers led to the pig keepers casting spells on each other’s herds to the effect that no matter what mast they ate they would not grow fat. Both pig keepers were practised in the pagan arts and could form themselves into any shape, and having been dismissed by their kings for the leanness of their pig herds due to the spells, they eventually formed themselves into the two famous bulls that feature in the Irish Epic The Táin (Kinsella).In the witty and satirical twelfth century text, The Vision of Mac Conglinne (Aisling Mhic Conglinne), many references are made to the various types of pig meat. Bacon, hams, sausages and puddings are often mentioned, and the gate to the fortress in the visionary land of plenty is described thus: “there was a gate of tallow to it, whereon was a bolt of sausage” (Jackson).Although pigs were always popular in Ireland, the emergence of the potato resulted in an increase in both human and pig populations. The Irish were the first Europeans to seriously consider the potato as a staple food. By 1663 it was widely accepted in Ireland as an important food plant and by 1770 it was known as the Irish Potato (Mac Con Iomaire and Gallagher). The potato transformed Ireland from an under populated island of one million in the 1590s to 8.2 million in 1840, making it the most densely populated country in Europe. Two centuries of genetic evolution resulted in potato yields growing from two tons per acre in 1670 to ten tons per acre in 1800. A constant supply of potato, which was not seen as a commercial crop, ensured that even the smallest holding could keep a few pigs on a potato-rich diet. Pat Tuite, an expert on pigs with Teagasc, the Irish Agricultural and Food Development Authority, reminded me that the potatoes were cooked for the pigs and that they also enjoyed whey, the by product of both butter and cheese making (Tuite). The agronomist, Arthur Young, while travelling through Ireland, commented in 1770 that in the town of Mitchelstown in County Cork “there seemed to be more pigs than human beings”. So plentiful were pigs at this time that on the eve of the Great Famine in 1841 the pig population was calculated to be 1,412,813 (Sexton 46). Some of the pigs were kept for home consumption but the rest were a valuable source of income and were shown great respect as the gentleman who paid the rent. Until the early twentieth century most Irish rural households kept some pigs.Pork was popular and was the main meat eaten at all feasts in the main houses; indeed a feast was considered incomplete without a whole roasted pig. In the poorer holdings, fresh pork was highly prized, as it was only available when a pig of their own was killed. Most of the pig was salted, placed in the brine barrel for a period or placed up the chimney for smoking.Certain superstitions were observed concerning the time of killing. Pigs were traditionally killed only in months that contained the letter “r”, since the heat of the summer months caused the meat to turn foul. In some counties it was believed that pigs should be killed under the full moon (Mahon 58). The main breed of pig from the medieval period was the Razor Back or Greyhound Pig, which was very efficient in converting organic waste into meat (Fitzgerald). The killing of the pig was an important ritual and a social occasion in rural Ireland, for it meant full and plenty for all. Neighbours, who came to help, brought a handful of salt for the curing, and when the work was done each would get a share of the puddings and the fresh pork. There were a number of days where it was traditional to kill a pig, the Michaelmas feast (29 September), Saint Martins Day (11 November) and St Patrick’s Day (17 March). Olive Sharkey gives a vivid description of the killing of the barrow pig in rural Ireland during the 1930s. A barrow pig is a male pig castrated before puberty:The local slaughterer (búistéir) a man experienced in the rustic art of pig killing, was approached to do the job, though some farmers killed their own pigs. When the búistéirarrived the whole family gathered round to watch the killing. His first job was to plunge the knife in the pig’s heart via the throat, using a special knife. The screeching during this performance was something awful, but the animal died instantly once the heart had been reached, usually to a round of applause from the onlookers. The animal was then draped across a pig-gib, a sort of bench, and had the fine hairs on its body scraped off. To make this a simple job the animal was immersed in hot water a number of times until the bristles were softened and easy to remove. If a few bristles were accidentally missed the bacon was known as ‘hairy bacon’!During the killing of the pig it was imperative to draw a good flow of blood to ensure good quality meat. This blood was collected in a bucket for the making of puddings. The carcass would then be hung from a hook in the shed with a basin under its head to catch the drip, and a potato was often placed in the pig’s mouth to aid the dripping process. After a few days the carcass would be dissected. Sharkey recalls that her father maintained that each pound weight in the pig’s head corresponded to a stone weight in the body. The body was washed and then each piece that was to be preserved was carefully salted and placed neatly in a barrel and hermetically sealed. It was customary in parts of the midlands to add brown sugar to the barrel at this stage, while in other areas juniper berries were placed in the fire when hanging the hams and flitches (sides of bacon), wrapped in brown paper, in the chimney for smoking (Sharkey 166). While the killing was predominantly men’s work, it was the women who took most responsibility for the curing and smoking. Puddings have always been popular in Irish cuisine. The pig’s intestines were washed well and soaked in a stream, and a mixture of onions, lard, spices, oatmeal and flour were mixed with the blood and the mixture was stuffed into the casing and boiled for about an hour, cooled and the puddings were divided amongst the neighbours.The pig was so palatable that the famous gastronomic writer Grimod de la Reyniere once claimed that the only piece you couldn’t eat was the “oink”. Sharkey remembers her father remarking that had they been able to catch the squeak they would have made tin whistles out of it! No part went to waste; the blood and offal were used, the trotters were known as crubeens (from crúb, hoof), and were boiled and eaten with cabbage. In Galway the knee joint was popular and known as the glúiníns (from glún, knee). The head was roasted whole or often boiled and pressed and prepared as Brawn. The chitterlings (small intestines) were meticulously prepared by continuous washing in cool water and the picking out of undigested food and faeces. Chitterlings were once a popular bar food in Dublin. Pig hair was used for paintbrushes and the bladder was occasionally inflated, using a goose quill, to be used as a football by the children. Meindertsma (2007) provides a pictorial review of the vast array of products derived from a single pig. These range from ammunition and porcelain to chewing gum.From around the mid-eighteenth century, commercial salting of pork and bacon grew rapidly in Ireland. 1820 saw Henry Denny begin operation in Waterford where he both developed and patented several production techniques for bacon. Bacon curing became a very important industry in Munster culminating in the setting up of four large factories. Irish bacon was the brand leader and the Irish companies exported their expertise. Denny set up a plant in Denmark in 1894 and introduced the Irish techniques to the Danish industry, while O’Mara’s set up bacon curing facilities in Russia in 1891 (Cowan and Sexton). Ireland developed an extensive export trade in bacon to England, and hams were delivered to markets in Paris, India, North and South America. The “sandwich method” of curing, or “dry cure”, was used up until 1862 when the method of injecting strong brine into the meat by means of a pickling pump was adopted by Irish bacon-curers. 1887 saw the formation of the Bacon Curers’ Pig Improvement Association and they managed to introduce a new breed, the Large White Ulster into most regions by the turn of the century. This breed was suitable for the production of “Wiltshire” bacon. Cork, Waterford Dublin and Belfast were important centres for bacon but it was Limerick that dominated the industry and a Department of Agriculture document from 1902 suggests that the famous “Limerick cure” may have originated by chance:1880 […] Limerick producers were short of money […] they produced what was considered meat in a half-cured condition. The unintentional cure proved extremely popular and others followed suit. By the turn of the century the mild cure procedure was brought to such perfection that meat could [… be] sent to tropical climates for consumption within a reasonable time (Cowan and Sexton).Failure to modernise led to the decline of bacon production in Limerick in the 1960s and all four factories closed down. The Irish pig market was protected prior to joining the European Union. There were no imports, and exports were subsidised by the Pigs and Bacon Commission. The Department of Agriculture started pig testing in the early 1960s and imported breeds from the United Kingdom and Scandinavia. The two main breeds were Large White and Landrace. Most farms kept pigs before joining the EU but after 1972, farmers were encouraged to rationalise and specialise. Grants were made available for facilities that would keep 3,000 pigs and these grants kick started the development of large units.Pig keeping and production were not only rural occupations; Irish towns and cities also had their fair share. Pigs could easily be kept on swill from hotels, restaurants, not to mention the by-product and leftovers of the brewing and baking industries. Ed Hick, a fourth generation pork butcher from south County Dublin, recalls buying pigs from a local coal man and bus driver and other locals for whom it was a tradition to keep pigs on the side. They would keep some six or eight pigs at a time and feed them on swill collected locally. Legislation concerning the feeding of swill introduced in 1985 (S.I.153) and an amendment in 1987 (S.I.133) required all swill to be heat-treated and resulted in most small operators going out of business. Other EU directives led to the shutting down of thousands of slaughterhouses across Europe. Small producers like Hick who slaughtered at most 25 pigs a week in their family slaughterhouse, states that it was not any one rule but a series of them that forced them to close. It was not uncommon for three inspectors, a veterinarian, a meat inspector and a hygiene inspector, to supervise himself and his brother at work. Ed Hick describes the situation thus; “if we had taken them on in a game of football, we would have lost! We were seen as a huge waste of veterinary time and manpower”.Sausages and rashers have long been popular in Dublin and are the main ingredients in the city’s most famous dish “Dublin Coddle.” Coddle is similar to an Irish stew except that it uses pork rashers and sausage instead of lamb. It was, traditionally, a Saturday night dish when the men came home from the public houses. Terry fa*gan has a book on Dublin Folklore called Monto: Murder, Madams and Black Coddle. The black coddle resulted from soot falling down the chimney into the cauldron. James Joyce describes Denny’s sausages with relish in Ulysses, and like many other Irish emigrants, he would welcome visitors from home only if they brought Irish sausages and Irish whiskey with them. Even today, every family has its favourite brand of sausages: Byrne’s, Olhausens, Granby’s, Hafner’s, Denny’s Gold Medal, Kearns and Superquinn are among the most popular. Ironically the same James Joyce, who put Dublin pork kidneys on the world table in Ulysses, was later to call his native Ireland “the old sow that eats her own farrow” (184-5).The last thirty years have seen a concerted effort to breed pigs that have less fat content and leaner meat. There are no pure breeds of Landrace or Large White in production today for they have been crossbred for litter size, fat content and leanness (Tuite). Many experts feel that they have become too lean, to the detriment of flavour and that the meat can tend to split when cooked. Pig production is now a complicated science and tighter margins have led to only large-scale operations being financially viable (Whittemore). The average size of herd has grown from 29 animals in 1973, to 846 animals in 1997, and the highest numbers are found in counties Cork and Cavan (Lafferty et al.). The main players in today’s pig production/processing are the large Irish Agribusiness Multinationals Glanbia, Kerry Foods and Dairygold. Tuite (2002) expressed worries among the industry that there may be no pig production in Ireland in twenty years time, with production moving to Eastern Europe where feed and labour are cheaper. When it comes to traceability, in the light of the Foot and Mouth, BSE and Dioxin scares, many feel that things were much better in the old days, when butchers like Ed Hick slaughtered animals that were reared locally and then sold them back to local consumers. Hick has recently killed pigs for friends who have begun keeping them for home consumption. This slaughtering remains legal as long as the meat is not offered for sale.Although bacon and cabbage, and the full Irish breakfast with rashers, sausages and puddings, are considered to be some of Ireland’s most well known traditional dishes, there has been a growth in modern interpretations of traditional pork and bacon dishes in the repertoires of the seemingly ever growing number of talented Irish chefs. Michael Clifford popularised Clonakilty Black Pudding as a starter in his Cork restaurant Clifford’s in the late 1980s, and its use has become widespread since, as a starter or main course often partnered with either caramelised apples or red onion marmalade. Crubeens (pigs trotters) have been modernised “a la Pierre Kaufman” by a number of Irish chefs, who bone them out and stuff them with sweetbreads. Kevin Thornton, the first Irish chef to be awarded two Michelin stars, has roasted suckling pig as one of his signature dishes. Richard Corrigan is keeping the Irish flag flying in London in his Michelin starred Soho restaurant, Lindsay House, where traditional pork and bacon dishes from his childhood are creatively re-interpreted with simplicity and taste.Pork, ham and bacon are, without doubt, the most traditional of all Irish foods, featuring in the diet since prehistoric times. Although these meats remain the most consumed per capita in post “Celtic Tiger” Ireland, there are a number of threats facing the country’s pig industry. Large-scale indoor production necessitates the use of antibiotics. European legislation and economic factors have contributed in the demise of the traditional art of pork butchery. Scientific advancements have resulted in leaner low-fat pigs, many argue, to the detriment of flavour. Alas, all is not lost. There is a growth in consumer demand for quality local food, and some producers like J. Hick & Sons, and Prue & David Rudd and Family are leading the way. The Rudds process and distribute branded antibiotic-free pig related products with the mission of “re-inventing the tastes of bygone days with the quality of modern day standards”. Few could argue with the late Irish writer John B. Keane (72): “When this kind of bacon is boiling with its old colleague, white cabbage, there is a gurgle from the pot that would tear the heart out of any hungry man”.ReferencesCowan, Cathal and Regina Sexton. Ireland's Traditional Foods: An Exploration of Irish Local & Typical Foods & Drinks. Dublin: Teagasc, 1997.C.S.O. Central Statistics Office. Figures on per capita meat consumption for 2009, 2010. Ireland. http://www.cso.ie.Fitzgerald, Oisin. "The Irish 'Greyhound' Pig: an extinct indigenous breed of Pig." History Ireland13.4 (2005): 20-23.Gantz, Jeffrey Early Irish Myths and Sagas. New York: Penguin, 1981.Harris, Marvin. "The Abominable Pig." Food and Culture: A Reader. Eds. Carole Counihan and Penny Van Esterik. New York: Routledge, 1997. 67-79.Hick, Edward. Personal Communication with master butcher Ed Hick. 15 Apr. 2002.Hick, Edward. Personal Communication concerning pig killing. 5 Sep. 2010.Jackson, K. H. Ed. Aislinge Meic Con Glinne, Dublin: Institute of Advanced Studies, 1990.Joyce, James. The Portrait of the Artist as a Young Man, London: Granada, 1977.Keane, John B. Strong Tea. Cork: Mercier Press, 1963.Kinsella, Thomas. The Táin. Oxford: Oxford University Press, 1970.Lafferty, S., Commins, P. and Walsh, J. A. Irish Agriculture in Transition: A Census Atlas of Agriculture in the Republic of Ireland. Dublin: Teagasc, 1999.Mac Con Iomaire, Liam. Ireland of the Proverb. Dublin: Town House, 1988.Mac Con Iomaire, Máirtín and Pádraic Óg Gallagher. "The Potato in Irish Cuisine and Culture."Journal of Culinary Science and Technology 7.2-3 (2009): 1-16.Mahon, Bríd. Land of Milk and Honey: The Story of Traditional Irish Food and Drink. Cork:Mercier, 1998.Meindertsma, Christien. PIG 05049 2007. 10 Aug. 2010 http://www.christienmeindertsma.com.Ó Conaill, Seán. Seán Ó Conaill's Book. Bailie Átha Cliath: Bhéaloideas Éireann, 1981.Sexton, Regina. A Little History of Irish Food. Dublin: Gill and Macmillan, 1998.Sharkey, Olive. Old Days Old Ways: An Illustrated Folk History of Ireland. Dublin: The O'Brien Press, 1985.S.I. 153, 1985 (Irish Legislation) http://www.irishstatutebook.ie/1985/en/si/0153.htmlS.I. 133, 1987 (Irish Legislation) http://www.irishstatuebook.ie/1987/en/si/0133.htmlTuite, Pat. Personal Communication with Pat Tuite, Chief Pig Advisor, Teagasc. 3 May 2002.Whittemore, Colin T. and Ilias Kyriazakis. Whitmore's Science and Practice of Pig Production 3rdEdition. Oxford: Wiley-Blackwell, 2006.

Abstract:

Thesis (M.P.A. )--Kutztown University of Pennsylvania, 2004
Source: Masters Abstracts International, Volume: 45-06, page: 2955. Typescript. Abstract precedes thesis as 4 preliminary leaves (ii- v). Includes bibliographical references ( leaves 108-111).