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Bumbling Bureaucrats and the Malthusian March

August 21, 2022

This post was originally published in this Beef Initiative newsletter.

America is blessed with abundant natural resources, arable crop land, in particular. So one might expect the average American to be healthy, vital, and happy – given the theoretical variety of quality agricultural products available to consumers. In reality, roughly 42% of Americans are obese, per data gathered during 2017-2018 by the CDC.

Over the years, there have been attempts to highlight the reasons for this health epidemic; some attribute this trend to the supposition that Americans lead more sedentary lifestyles than, say, Europeans. But a study published in August 2020 suggests that Europeans are, on average, trending toward a more sedentary lifestyle themselves.

Anecdotally, many Europeans note that there’s a “strange” taste to American food – and they can’t place what it is.

What if there were factions within the food supply chain failing to ensure the safety of products that end up in American homes? What if those in charge of setting clear guidelines for food processors were incompetent, at best, or accepting lobbying dollars in return for feined ignorance?

The goal of this piece is to review sparcely mentioned, but important facets of the American food system. In particular, we’ll cover a food safety classification called “generally recognized as safe” (GRAS), as well as how “GMO” labeling is being ditched in favor of a more… palatable label. Finally, we’ll examine the Malthusian marketing campaign meant to dissuade consumption of nutrient-dense animal products and redirect that consumption back to the industrial sludge which lines the pockets of food manufacturers.

Generally Recognized as Safe?

One does not need to be a linguist in order to recognize the dubiousness of such a classification. “Generally” recognized as safe, according to whom? Well, as with most instances of food safety in the United States, oversight for this classification rests on the shoulders of the FDA. The official GRAS rule was published in August 2016 and was meant to clarify the criteria used by the FDA in regulating the use of substances in food for humans (and animals) that are not subject to the premarket approval requirements of the Food, Drug and Cosmetic Act (FD&C Act).

Notably, this rule amended the process by which manufacturers cleared their GRAS substances with the FDA – as it stands now, the oversight of GRAS substances is contingent on manufacturers voluntarily notifying the FDA. That seems like a conflict of interest, but I’m not a lawyer.

Critics of the rule pressed that issue via a class action lawsuit; they contended that this conflict of interest would likely lead to manufacturers covertly determining what substances may be added to food. The FDA technically does have the right to disagree with a GRAS determination and unfortunately for critics of the GRAS rule, a federal judge in New York held that the FDA did not unlawfully subdelegate its authority via their 2016 rule:

Other than prudential concerns and citations to inapposite case law, plaintiffs provide no legal support for their argument that the GRAS rule violates the Constitution by adopting a voluntary notification system and allowing post-violation, instead of pre-violation enforcement, – Judge Vernon S. Broderick

The inapposite case law citation the judge is referring to is the Food Additives Amendment of 1958. This statute required an approval process for food additives but carved out an exception for substances that experts generally recognized to be safe. What’s more, congress did not specifically address whether GRAS notifications to the FDA were mandatory. This is essentially the reason the judge ruled in favor of the FDA, he noted that the plaintiffs needed to take their frustrations up with congress and that the FDA had limited resources to allocate to food safety.

Judge Broderick noted that GRAS submissions had substantially increased since the 1958 amendment, which makes sense given the technological progress made in the last 60 years.

Looking at the FDA’s official database, there are 1056 substances to date that have been voluntarily submitted as GRAS. In 76% of those cases, the FDA has no questions, 16% of cases have ceased their evaluation at the request of the notifier, 6% are pending, and only in 2% of cases did the FDA push back.

The FDA is tacitly exploiting a loophole in a congressional amendment from 1958: they are not unlawfully subdelegating their responsibility to protect the unsuspecting American consumer, but they are subdelegating nonetheless.

Until that loophole is closed, Americans will de-facto need to trust that agribusiness’ “food scientists” aren’t covertly adding unsafe substances to food products for the benefit of their bottom lines.

Redefining GMOs

I would venture a guess that most people know what GMOs are, and also know that they should remove GMO foods from their consumption model. For those less familiar, GMOs, broadly speaking, refer to transgenic crops that have been engineered with combinations of plant, animal, bacteria, and virus genes that cannot occur in nature or in traditional breeding. Interestingly, most GMO crops grown globally have been engineered to include Agrobacterium tumefaciens – a soil bacterium that makes the crops more herbicide-tolerant.

Crops engineered in this way are massively profitable to mega-corporations that manufacture the herbicides. Unfortunately for the average American, avoiding genetically modified “foods” got more difficult this past year.

The so-called public servants at the USDA quietly passed the National Bioengineered Food Disclosure Standard in December 2018, which became mandatory on January 1st, 2022. On its face, this standard appears imply a mandatory labeling of GMO-containing products at a national level. Reading through the legislation, however, surfaces spurious details that are sure to further confuse consumers.

The legislation mandates the use of “bioengineered” instead of the more familiar “GMO.” According to 2018 data collected by the Non-GMO Project, terms like “bioengineered food” or “BE food” are orders of magnitude less familiar than GMO. The obfuscation continues: the law exempts GMO foods that have been processed and refined (which most GMO foods are). Therefore, a product could have several highly refined GMO ingredients and still not be labeled under this standard. For example, a can of soup with “water, broth, meat” listed as the primary ingredients along with GMO corn would be exempt from BE labeling laws.

There are no technical requirements to ensure that GMO testing is done in a legitimate manner. Crops grown specifically as livestock feed are also exempt from BE labeling laws – but don’t you worry about the biomagnification of toxic additives as you consume contaminated livestock. And to top it off, there are no penalties at all for failing to comply.

These bureaucrats are not here to help us. They don’t care that the industrial food complex is knowingly damaging the collective health of our nation. The reach of megacorporations extends far past the aisles of supermarkets: their tentacles have long-since infiltrated powerful lobbying groups who - for better or worse - ultimately dictate what legislation gets passed.

The Harvest of Deception has not yet reached its zenith, and as we will see in the following section, a nefarious marketing campaign is well underway.

March of the Malthusians

While our “civil servants” over at the FDA and USDA are hard at work chipping away at what’s left of the public’s food intelligence, an even more sinister trend is starting to come to fruition. Slim has said multiple times that 2022 is the year in which the world will begin to experience what he’s called the Global Industrial Food Shift.

Dominos have already begun to fall elsewhere in the world: nationwide protests in the Netherlands over “environmental” legislation have opened the door for a potential expropriation of farmland – land which has been responsibly stewarded by small, family farms for generations.

The Dutch legislation introduced on June 10th seeks to reduce nitrogen emissions by 50% nationwide by 2030. Many in the ruling party see this transition as “inevitable,” and believe that while farmers may be forced to completely shut down their operations, the price is worth their desired outcome. Never mind the fact that the Dutch are the world’s second-largest agricultural product exporter (behind only the US), or the fact that exports in 2021 totaled a record 104.7 billion euros. No, surely these policies won’t have any similar effects as those passed by Sri Lankan legislators in 2021.

Our neighbors to the north, who have suffered through one of the most draconian responses to the supposed pandemic, are in for more pain it seems. Comrade Trudeau’s government is marching in lock-step with their WEF-affiliated, Dutch counterparts: the Canadian government is proposing legislation aimed at cutting emissions from fertilizer by 30% by 2030. Time will tell how these policies affect Canada’s food security.

The war on animal protein is a non-linear, multi-medium campaign – and it has only just begun. Malthusian interests are coalescing around the world, marketing efforts are already underway to normalize the consumption of fake meats (e.g. Beyond Meat) and to vilify livestock cultivation and consumption. As noted above, this is non-linear warfare – nefarious actors prey on the ignorance of climate hysterics, play on recent fears of disease, and point to fallacies of the opportunity cost of agricultural land use.

Perhaps the most repulsive aspect of the Malthusian march are those sock-puppet “journalists” normalizing cannibalism and media figures touting insect protein as a sustainable alternative to livestock. What these muppets are not telling you is that regardless of what’s said on the nutrition labels, grass-fed meat is substantially more nutrient-dense than plant-based or insect-based protein.

Independent researcher John Paul outlines another reason why we should be skeptical of the push to shift protein production to insects. In the article, John Paul threads together a series of studies, one of which found that 81% of bugs in a sampled farming operation were infected with parasites, 30% of which are known to be harmful to humans. This is not a new revelation.

Considering the lengths to which the industrial food complex will go to obfuscate the substances, additives, and ingredients included in their products, do you really think they’ll have you or your family’s interests in mind as they seek to transition to alternative protein sources?


If you were unaware of the level of incompetence at which our so-called civil servants are currently operating (as I was before writing this), I hope that highlighting the GRAS fiasco and the GMO-to-Bioengineered transition has given you an indication. Those in charge of food safety are self-interested, and their judgment has long been clouded by cash injections courtesy of lobbying groups and corporate interests.

As the system currently exists, there is no money to be made in protecting the American consumer; high-priced lawyers enable food processors to seamlessly exploit loopholes in half-baked legislation, multinational holding companies spin up shell corporations out of thin air – and hell, “organic” and “grass-fed” certifications are pay-for-play operations.

We are living through an active Malthusian marketing campaign intended to vilify the consumption of pure animal protein, executed via non-linear psychological warfare. The intention of such a campaign, it seems, is to further separate the animal (and the soil) from our consumption models. If the globalists get their way, we’ll all be eating our neatly portioned, packaged lab-grown “meat” from our quaint little pods, and if we’re lucky, some cricket pudding for dessert.

Ominous and precarious times, to be sure, but the silver lining is that you are perfectly positioned to reduce your reliance on these rent-seekers. The time has come for us all to get our boots on the ground and create our own market access. Within the Beef Initiative, we often advise people to “shake your rancher’s hand” as the first step toward sovereign market access. This opens up the opportunity to learn from that particular rancher why they do what they do, and what makes their operation special.

When we, as consumers, approach these conversations from a position of seeking education, a foundation of trust and good faith is built. Such a foundation is a well-spring that delivers actionable knowledge passed down for generations, capable of sustaining life-long friendships and facilitating value for value exchanges.

As it relates to bitcoin, I’ve found that slow-playing that aspect of the conversation yields the best results. Lead by asking to be educated, and rest assured that the conversation will touch on low-time preference, land stewardship, personal responsibility, or the principles of sound money. We ought not think of ourselves as unpaid bitcoin shills; bitcoin is a tremendous tool, and in a certain sense, it speaks for itself.

Ultimately, it is up to us as consumers to change our demand. We must not accept highly processed industrial sludge, we must demand better for ourselves, our families, and our communities. Create your (and your family’s) market access through good-faith interactions with responsible food producers. Approach them from a place of humility and passion and you will be successful.

This is our counter-punch to the powers-that-wish-to-be – support your local rancher, farmer, and producer: this is how we win.