    [House Hearing, 115 Congress]
    [From the U.S. Government Publishing Office]

                   PROS AND CONS OF RESTRICTING SNAP PURCHASES

    =======================================================================

                                    HEARING

                                   BEFORE THE

                            COMMITTEE ON AGRICULTURE
                            HOUSE OF REPRESENTATIVES

                         ONE HUNDRED FIFTEENTH CONGRESS

                                 FIRST SESSION

                                   ----------

                               FEBRUARY 16, 2017

                                   ----------

                                Serial No. 115-2

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              Printed for the use of the Committee on Agriculture
                             agriculture.house.gov

                  PROS AND CONS OF RESTRICTING SNAP PURCHASES

    =======================================================================

                                    HEARING

                                   BEFORE THE

                            COMMITTEE ON AGRICULTURE
                            HOUSE OF REPRESENTATIVES

                         ONE HUNDRED FIFTEENTH CONGRESS

                                 FIRST SESSION

                                   __________

                               FEBRUARY 16, 2017

                                   __________

                                Serial No. 115-2

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Printed for the use of the Committee on Agriculture
                             agriculture.house.gov

                                    ______

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                            COMMITTEE ON AGRICULTURE

                      K. MICHAEL CONAWAY, Texas, Chairman

    GLENN THOMPSON, Pennsylvania         COLLIN C. PETERSON, Minnesota,
        Vice Chairman                    Ranking Minority Member
    BOB GOODLATTE, Virginia,             DAVID SCOTT, Georgia
    FRANK D. LUCAS, Oklahoma             JIM COSTA, California
    STEVE KING, Iowa                     TIMOTHY J. WALZ, Minnesota
    MIKE ROGERS, Alabama                 MARCIA L. FUDGE, Ohio
    BOB GIBBS, Ohio                      JAMES P. McGOVERN, Massachusetts
    AUSTIN SCOTT, Georgia                FILEMON VELA, Texas, Vice Ranking
    ERIC A. ``RICK'' CRAWFORD, Arkansas  Minority Member
    SCOTT DesJARLAIS, Tennessee          MICHELLE LUJAN GRISHAM, New Mexico
    VICKY HARTZLER, Missouri             ANN M. KUSTER, New Hampshire
    JEFF DENHAM, California              RICHARD M. NOLAN, Minnesota
    DOUG LaMALFA, California             CHERI BUSTOS, Illinois
    RODNEY DAVIS, Illinois               SEAN PATRICK MALONEY, New York
    TED S. YOHO, Florida                 STACEY E. PLASKETT, Virgin Islands
    RICK W. ALLEN, Georgia               ALMA S. ADAMS, North Carolina
    MIKE BOST, Illinois                  DWIGHT EVANS, Pennsylvania
    DAVID ROUZER, North Carolina         AL LAWSON, Jr., Florida
    RALPH LEE ABRAHAM, Louisiana         TOM O'HALLERAN, Arizona
    TRENT KELLY, Mississippi             JIMMY PANETTA, California
    JAMES COMER, Kentucky                DARREN SOTO, Florida
    ROGER W. MARSHALL, Kansas            LISA BLUNT ROCHESTER, Delaware
    DON BACON, Nebraska
    JOHN J. FASO, New York
    NEAL P. DUNN, Florida
    JODEY C. ARRINGTON, Texas

                                     ______

                       Matthew S. Schertz, Staff Director

                     Anne Simmons, Minority Staff Director

                                      (ii)

                                 C O N T E N T S

                                  ----------
                                                                       Page
    Conaway, Hon. K. Michael, a Representative in Congress from
      Texas, opening statement.......................................     1
        Prepared statement...........................................     2
        Submitted report.............................................   153
    Peterson, Hon. Collin C., a Representative in Congress from
      Minnesota, opening statement...................................     3

                                   Witnesses

    Rachidi, Ph.D., Angela K., Research Fellow in Poverty Studies,
      American Enterprise Institute, Washington, D.C.................     4
        Prepared statement...........................................     5
    Schanzenbach, Ph.D., Diane Whitmore, Director and Senior Fellow,
      Economic Studies, Brookings Institution; Professor of Social
      Policy and of Economics, The Hamilton Project, Northwestern
      University, Washington, D.C....................................    11
        Prepared statement...........................................    12
        Submitted question...........................................   395
    Sarasin, Leslie G., President and Chief Executive Officer, Food
      Marketing Institute, Arlington, VA.............................    17
        Prepared statement...........................................    19
    Weidman, John, Deputy Executive Director, The Food Trust,
      Philadelphia, PA...............................................    29
        Prepared statement...........................................    31
    Wansink, Ph.D., Brian, John S. Dyson Professor of Marketing and
      Director, Cornell University Food and Brand Lab, Ithaca, NY....    33
        Prepared statement...........................................    34

                               Submitted Material

    Feeding Texas, submitted policy brief............................   282
    Secretaries' Innovation Group, submitted statement...............   283
    Allison, Ph.D., David B., Distinguished Quetelet Endowed
      Professor; Associate Dean for Research & Science; Director,
      Office of Energetics; Director, Nutrition & Obesity Research
      Center, Department of Nutrition Sciences, School of Health
      Professions, University of Alabama at Birmingham, submitted
      letter.........................................................   284

                  PROS AND CONS OF RESTRICTING SNAP PURCHASES

                                  ----------

                          THURSDAY, FEBRUARY 16, 2017

                              House of Representatives,
                                      Committee on Agriculture,
                                                       Washington, D.C.
        The Committee met, pursuant to other business, at 10:24
    a.m., in Room 1300 of the Longworth House Office Building, Hon.
    K. Michael Conaway [Chairman of the Committee] presiding.
        Members present: Representatives Conaway, Thompson,
    Goodlatte, King, Rogers, Gibbs, Austin Scott of Georgia,
    Crawford, Hartzler, Denham, LaMalfa, Davis, Yoho, Allen, Bost,
    Rouzer, Kelly, Comer, Marshall, Bacon, Faso, Dunn, Arrington,
    Peterson, David Scott of Georgia, Costa, Walz, Fudge, McGovern,
    Lujan Grisham, Kuster, Nolan, Bustos, Maloney, Plaskett, Adams,
    Evans, Lawson, O'Halleran, Panetta, Soto, and Blunt Rochester.
        Staff present: Bart Fischer, Caleb Crosswhite, Callie
    McAdams, Haley Graves, Jackie Barber, Jadi Chapman, Jennifer
    Tiller, Mary Rose Conroy, Stephanie Addison, Keith Jones,
    Kellie Adesina, Lisa Shelton, Troy Phillips, John Konya, Nicole
    Scott, and Carly Reedholm.

    OPENING STATEMENT OF HON. K. MICHAEL CONAWAY, A REPRESENTATIVE
                         IN CONGRESS FROM TEXAS

        The Chairman. This hearing of the Committee on Agriculture
    entitled, Pros and Cons of Restricting SNAP Purchases, will
    come to order. Thank you.
        I want to welcome our witnesses to today's hearing, and
    thank them for taking the time to share their views on a very
    timely and somewhat sensitive topic, the idea of restricting
    SNAP purchases. This hearing is a continuation of the
    conversation had at a Member roundtable last October. There are
    good arguments to be made on both sides of this issue, and this
    discussion will be yet another addition to the Committee's
    commitment to strengthening the Supplemental Nutrition
    Assistance Program.
        On November 18 of last year, USDA released a report
    entitled, Foods Typically Purchased by Supplemental Nutrition
    Assistance Program Households. This study analyzed food
    purchase data collected at the point of sale to assess
    differences in the purchasing patterns of SNAP and non-SNAP
    households. Ultimately, the report found that about 40 of
    every dollar of every purchase dollar was spent on basic items
    like meat, fruits, vegetables, milk, eggs, and bread. Another
    20 was spent on sweetened drinks, desserts, salty snacks,
    candy, and sugar. The remaining 40 was spent on a variety of
    items such as cereal, prepared foods, other dairy products,
    rice, beans, and other cooking ingredients. To be clear, when
    comparing spending on broad food categories, the data show that
    both SNAP and non-SNAP households make similar food choices.
    However, the report also confirms that there are differences in
    spending in individual food categories. One can also reasonably
    infer from the report that billions in taxpayer dollars are
    being spent on items like sweetened beverages and prepared
    desserts.
        This report, while not the sole basis of this hearing, begs
    the question of whether certain food or beverage items should
    be restricted as eligible food items in SNAP. While it is
    important to have this discussion, we can all agree that no one
    in America ought to go hungry, and SNAP is essential to
    providing nutrition to the most vulnerable citizens during
    tough times.
        Our goal is to provide much-needed nutrition and to
    encourage Americans to eat healthier. To that end, this
    Committee has historically advocated for nutrition education
    and healthy eating incentive programs. Today, we will consider
    whether additional restrictions should be added to that mix.
        Thank you again to the witnesses for being here today. We
    look forward to your testimony.
        [The prepared statement of Mr. Conaway follows:]

      Prepared Statement of Hon. K. Michael Conaway, a Representative in
                              Congress from Texas
        I want to welcome our witnesses to today's hearing and thank them
    for taking the time to share their views on a very timely and somewhat
    sensitive topic--the idea of restricting SNAP purchases. This hearing
    is a continuation of the conversation had in a Member roundtable last
    October. There are good arguments to be made on both sides of this
    issue, and this discussion will be yet another addition to the
    Committee's commitment to strengthening the Supplemental Nutrition
    Assistance Program.
        On November 18th of last year, USDA released a report entitled,
    Foods Typically Purchased by Supplemental Nutrition Assistance Program
    Households. This study analyzed food purchase data collected at the
    point of sale to assess differences in the purchasing patterns of SNAP
    and non-SNAP households.
        Ultimately, the report found that about 40 of every food purchase
    dollar was spent on basic items like meat, fruits, vegetables, milk,
    eggs, and bread.
        Another 20 was spent on sweetened drinks, desserts, salty snacks,
    candy, and sugar. The remaining 40 was spent on a variety of items
    such as cereal, prepared foods, other dairy products, rice, beans, and
    other cooking ingredients.
        To be clear, when comparing spending on broad food categories, the
    data show that both SNAP and non-SNAP households made similar food
    choices. However, the report also confirms that there are differences
    in spending on individual food categories. One can also reasonably
    infer from the report that billions in taxpayer dollars are being spent
    on items like sweetened beverages and prepared desserts.
        The report, while not the sole basis of this hearing, begs the
    question of whether certain food or beverage items should be restricted
    as eligible food items in SNAP. While it's important to have this
    discussion, we can all agree that no one in America ought to go hungry,
    and SNAP is essential in providing nutrition to the most vulnerable
    citizens during tough times.
        Our goal is to provide much needed nutrition and to encourage
    Americans to eat healthier. To that end, this Committee has
    historically advocated for nutrition education and healthy eating
    incentive programs. Today, we will consider whether additional
    restrictions should be added to that mix. Thank you again to the
    witnesses for being here today. We look forward to your testimony.
        With that, I now turn to the Ranking Member for any comments he
    would like to make.

        The Chairman. I now turn to the Ranking Member for any
    comments that he would like to make.

       STATEMENT OF HON. COLLIN C. PETERSON, A REPRESENTATIVE IN
                  CONGRESS FROM THE STATE OF MINNESOTA

        Mr. Peterson. Thank you, Mr. Chairman.
        We have had 16 SNAP hearings, we are now taking a look at
    how SNAP recipients are purchasing food, what kind of food they
    are purchasing with their SNAP dollars.
        Before we get too far, though, I think it is important to
    again note that the overwhelming theme of the testimony we have
    heard in the last Congress is that while there are some areas
    for improvement, SNAP works. We heard testimony opposing
    efforts to block grant SNAP and on the importance of keeping
    SNAP within the farm bill.
        Those of us who have been around a while know that this is
    a complicated program, and I would urge Members to keep that in
    mind as we work on the farm bill this next year. I don't think
    there is one single issue that is the problem, and I don't
    think there is one single solution that will magically somehow
    improve SNAP efficiency.
        Looking specifically at SNAP food choice, it would seem
    pretty straightforward that we not allow SNAP dollars to be
    spent on junk food. But the problem is, how do you define that?
    This is something that I took a look at when I was Chairman.
        In Minnesota, they tried this. Somehow or another they
    requested a waiver from FNS to disallow candy, I don't know how
    they did this, but when they were defining candy, if the candy
    didn't contain wheat it was banned, but if it did contain
    wheat, it wasn't. So a Kit-Kat bar was okay under what they
    were doing, and a Hershey bar was not. So I don't know. When
    you go down this route, you are opening a real can of worms,
    and from what I can tell talking to my folks back home, that
    grocery stores have really no interest in being the food
    police. USDA has been resistant to this effort as well. And
    from what I know, when you look at how, and the kind of food,
    SNAP recipients buy, it is really not different from the food
    of people that are not on SNAP. The underlying issue is all of
    us in the United States do a bad job of deciding what to eat,
    and we can all use some guidance probably. But I am not sure
    the government is the way to provide that.
        So I am hopeful that we can be open-minded. The discussion
    on these issues can continue and our efforts can continue, so
    that we learn more about how SNAP actually works, and I look
    forward to hearing today's witnesses and yield back.
        The Chairman. I thank the gentleman. The chair would remind
    or request that other Members submit their opening statements
    for the record so witnesses may begin their testimony to ensure
    that there is ample time for questioning.
        I want to thank our panel for being here. It is, by all
    arguments, some of the best informed folks, and it is a
    balanced panel. We have folks on both sides of the issue, and
    we have folks who have to administer the program, whatever it
    is we come up with. So we have a terrific panel and I am
    excited to hear from them after reading their testimony last
    night.
        Today, we have with us Dr. Angela Rachidi. She is a
    Research Fellow, Poverty Studies at American Enterprise
    Institute here in Washington, D.C. We have Diane Whitmore
    Schanzenbach, Director of The Hamilton Project, Senior Fellow,
    Economic Studies, the Brookings Institute here in D.C. We have
    Leslie Sarasin, CEO of the Food Marketing Institute in
    Arlington, Virginia. We have Mr. John Weidman, who is the
    Deputy Executive Director, The Food Trust, Philadelphia,
    Pennsylvania. And we have Brian Wansink, the Director of
    Cornell University Food and Brand Lab at Ithaca, New York. And
    given everyone's last names, I came sort of close to getting
    some of those right. So Dr. Rachidi, if you will, please, 5
    minutes.

            STATEMENT OF ANGELA K. RACHIDI, Ph.D., RESEARCH
             FELLOW IN POVERTY STUDIES, AMERICAN ENTERPRISE
                      INSTITUTE, WASHINGTON, D.C.

        Dr. Rachidi. Thank you. Chairman Conaway, Ranking Member
    Peterson, and other Members of the Committee, thank you for the
    opportunity to testify this morning on restrictions on
    purchases in the Supplemental Nutrition Assistance Program, or
    SNAP. My name is Angela Rachidi, and I am a Research Fellow in
    Poverty Studies at the American Enterprise Institute, or AEI.
    Prior to joining AEI, I was the Deputy Commissioner for Policy
    and Evaluation at the New York City Department of Human
    Resources, or HRA. HRA administers SNAP, and during my time
    there, we provided benefits to almost two million New Yorkers
    each month.
        Most relevant for my testimony today is my experience
    drafting a proposal for a demonstration project in New York
    City to restrict the use of SNAP benefits to purchase sweetened
    beverages. Regrettably, it was denied by the U.S. Department of
    Agriculture in 2011.
        I will make four main points today. First, obesity and the
    related health problems remain one of the most challenging
    public health issues of our time, with sweetened beverages
    identified as one of the main contributors. Second, the
    integrity of SNAP as a publicly funded program rests on how
    well its implementation matches the stated goals of the
    program. Third, this problem is not unique to low-income
    households, but SNAP offers one opportunity for government to
    play a positive role. And fourth, a demonstration project to
    test a restriction on sweetened beverages in SNAP is consistent
    with bipartisan efforts to support evidence-based policy
    making.
        For my oral testimony, I won't go through all of the
    research on obesity, the related health problems, and its
    connection to sweetened beverages. But I do want to say,
    however, that obesity is a major public health crisis that
    affects all Americans, no matter their income status, and for
    this reason, it requires a multi-faceted public health
    approach.
        High sweetened beverage consumption is not unique to SNAP
    households, but supporting such purchases, especially at the
    levels suggested in the data, directly contradicts the stated
    goals of the program. The Food Stamp Act of 1977 states that
    the goal is to provide for improved levels of nutrition among
    low-income households through a cooperative Federal-state
    program of food assistance. This purpose holds today.
        For a program with a stated goal of improving nutrition,
    accepting such a large percentage of spending on beverages with
    no nutritional value seems counterintuitive and likely
    undermines public support for the program. Estimates suggest
    SNAP households spend almost ten percent of their food budgets
    on these products. Allowing the purchase of sweetened beverages
    also directly competes with nutritional education programming,
    and it competes against costs associated with obesity, which
    sweetened beverages are a large contributor to; estimates
    suggest that obesity costs $147 billion per year.
        Placing restrictions on SNAP should be part of a broader
    approach to address this problem. Some believe that educating
    SNAP recipients on healthy eating is a better approach. I would
    argue that it should not be one or the other, and the USDA's
    own research supports this. The USDA's Healthy Incentives
    Program, which gave financial incentives to SNAP households to
    purchase fruits and vegetables had no effect on sweetened
    beverage consumption, even though these households did eat more
    fruits and vegetables. The Summer EBT for Children Program
    found that a WIC-based model which provided restrictions was
    more effective than a SNAP-based model, which did not allow
    restrictions. And another study not conducted through the USDA
    found that restrictions plus incentives was most effective in
    reducing sweetened beverage intake.
        As part of a broader approach toward evidence-based policy
    making, a demonstration project is needed. I believe that with
    cooperation from the USDA and funding from Congress, a
    demonstration project is feasible. A random assignment
    experiment similar to the Healthy Incentives Pilot could be
    conducted. With the technology that exists today, this would
    not be overly burdensome on retailers. In fact, when we
    developed the proposal in New York City, we spoke to retailers
    and they told us that it would not be that difficult to
    implement such a restriction, since they program their EBT
    systems anyway.
        In conclusion, with a new Congress and Administration, I am
    hopeful that a demonstration project in a few states will be
    allowed in order to test whether a restriction could be
    effective. At a time when leaders of both parties are promoting
    evidence-based policy making, testing such an idea and
    rigorously evaluating the results should receive broad support.
        Thank you, and I can respond to any questions that you may
    have.
        [The prepared statement of Dr. Rachidi follows:]

      Prepared Statement of Angela K. Rachidi, Ph.D., Research Fellow in
        Poverty Studies, American Enterprise Institute, Washington, D.C.
    The Supplemental Nutrition Assistance Program (SNAP): Time to Test a
            Sweetened Beverage Restriction
        Chairman Conaway, Ranking Member Peterson, and other Members of the
    Committee, thank you for the opportunity to testify this morning on
    restrictions on purchases in the Supplemental Nutrition Assistance
    Program or SNAP.
        My name is Angela Rachidi, and I am a Research Fellow in Poverty
    Studies at the American Enterprise Institute (AEI). Prior to joining
    AEI, I spent almost a decade at the New York City Human Resources
    Administration (HRA) as the Deputy Commissioner for Policy and
    Evaluation. HRA is New York City's main social service agency and
    administers SNAP. During my time at HRA, the city provided SNAP
    benefits to almost two million New Yorkers each month.
        In my role, I studied all aspects of the program. Most relevant for
    today is my experience--under the direction of then-Mayor Michael
    Bloomberg, Commissioners for Health Thomas Friedan and Thomas Farley,
    and HRA Commissioner Robert Doar--drafting a proposal for a
    demonstration project in New York City to restrict the use of SNAP
    benefits to purchase sweetened beverages. We proposed a restriction as
    a way to support the overarching goal of the program, which is to
    improve nutrition. Regrettably, it was denied by the U.S. Department of
    Agriculture (USDA) in 2011.
        In the years since I left HRA, the public health problems caused by
    sweetened beverages have not solved themselves. I am here today to urge
    the Committee to support demonstration projects that test whether a
    sweetened beverage restriction in SNAP can improve the health and well-
    being of SNAP recipients.
        I will make four main points to support this recommendation:

      1.  Obesity and related health problems remain one of the most
                challenging public health issues of our time, affecting
                millions of poor and non-poor Americans, with sweetened
                beverages identified as one the main contributors.

      2.  The integrity of SNAP as a publicly-funded program rests on how
                well its implementation matches the stated goals of the
                program. Congress has stated that the purpose of SNAP is to
                support nutrition among low-income households, which is
                directly contradicted by allowing sweetened beverages to be
                purchased.

      3.  This public health problem is complex and requires a
                comprehensive approach that includes multiple strategies,
                including changes to SNAP.

      4.  A demonstration project to test a sweetened beverage restriction
                in SNAP is consistent with bipartisan efforts to support
                evidence-based policymaking. Through rigorous evaluation, a
                demonstration project could assess whether government
                efforts can achieve potential gains, such as better health,
                without adversely affecting other measures of well-being.

        Before I get to these main points, I want to state clearly that
    SNAP is one of the more effective Federal safety net programs in the
    U.S. A large body of research shows that it reduces poverty, improves
    food security among low-income households, and has positive effects on
    infant health and long-term benefits for children who receive it.\1\ In
    the average month in 2016, 44.2 million Americans received SNAP for a
    total cost of $70.9 billion.\2\ Among American households, 12.7 percent
    were food-insecure in 2015 and 5.0 percent had very low food
    insecurity; percentages which likely would be much higher without
    SNAP.\3\ In 2015, SNAP lifted almost 4.6 million people out of poverty,
    according to the Supplemental Poverty Measure.\4\
    ---------------------------------------------------------------------------
        \1\ See Judith Bartfield, et al., eds, SNAP Matters: How Food
    Stamps Affect Health and Well-Being (Stanford, CA: Stanford University
    Press, 2015); Douglas Almond, Hilary W. Hoynes, and Diane Whitmore
    Schanzenbach, ``Inside the War on Poverty: The Impact of Food Stamps on
    Birth Outcomes,'' Review of Economics and Statistics 93, no. 2 (May
    2011): 387-403; and Hilary Hoynes, Diane Whitmore Schanzenbach, and
    Douglas Almond, ``Long-Run Impacts of Childhood Access to the Safety
    Net,'' American Economic Review 106, no. 4 (April 2016): 903-34.
        \2\ U.S. Department of Agriculture, Food and Nutrition Service
    ``Supplemental Nutrition Assistance Program Participation and Costs,''
    February 3, 2017, https://www.fns.usda.gov/sites/default/files/pd/
    SNAPsummary.pdf.
        \3\ Alisha Coleman-Jensen, et al., ``Household Food Security in the
    United States in 2015,'' U.S. Department of Agriculture, Economic
    Research Services, September 2016, https://www.ers.usda.gov/webdocs/
    publications/err215/err-215.pdf?v=42636.
        \4\ Trudi Renwick and Liana Fox, ``The Supplemental Poverty
    Measure: 2015,'' U.S. Census Bureau, September 2016, http://
    www.census.gov/content/dam/Census/library/publications/2016/demo/p60-
    258.pdf.
    ---------------------------------------------------------------------------
        Beyond these national statistics, I saw first-hand the positive
    impacts that SNAP had on individuals and families in New York City. It
    serves a wide variety of households, including the elderly, the
    disabled, and working families. However, as with any government
    program, it can always be improved. And as a nutrition assistance
    program, SNAP could do more to support healthy eating among recipient
    households, especially children.
    Obesity, Health Problems, and the Connection to Sweetened Beverages
        The National Institutes of Health has termed obesity ``a
    devastating public-health crisis for the United States,'' \5\ and for
    good reason. Among all Americans, 37.9 percent of adults (age 20 or
    older) were obese in 2013-2014 and over 70 percent were overweight or
    obese.\6\ Among children, 20.6 percent of 12-19 year olds and 17.4
    percent of 6-11 year olds were obese in those same years.\7\ According
    to the Centers for Disease Control and Prevention (CDC), people who are
    obese are a greater risk for a variety of health issues, including type
    2 diabetes, heart disease, stroke, some cancers, low quality of life,
    and certain mental illnesses.\8\
    ---------------------------------------------------------------------------
        \5\ National Institutes of Health, ``About We Can! Background,''
    February 13, 2013, https://www.nhlbi.nih.gov/health/educational/wecan/
    about-wecan/background.htm.
        \6\ Centers for Disease Control and Prevention, National Center for
    Health Statistics, ``Obesity and Overweight,'' June 13, 2016, https://
    www.cdc.gov/nchs/fastats/obesity-overweight.htm.
        \7\ Ibid.
        \8\ Centers for Disease Control and Prevention, ``The Health
    Effects of Overweight and Obesity,'' June 5, 2015, https://www.cdc.gov/
    healthyweight/effects/.
    ---------------------------------------------------------------------------
        Excessive sugar consumption is considered one of the primary causes
    of obesity, with sugar-sweetened beverages specifically linked to
    excessive weight gain and obesity, and the related health problems that
    result.\9\ Because of these known associations and because sweetened
    beverages have no nutritional value, the White House Task Force on
    Childhood Obesity issued a report in 2010 that included recommendations
    calling for the nation's food assistance programs to be part of the
    solution by encouraging access to nutritious foods and offering
    incentives and eliminating disincentives to healthy eating habits.\10\
    In addition, according to the 2015-2020 Dietary Guidelines for
    Americans:
    ---------------------------------------------------------------------------
        \9\ Brian K. Kit, et al., ``Trends in Sugar-Sweetened Beverage
    Consumption Among Youth and Adults in the United States: 1999-2010,''
    American Journal of Clinical Nutrition 98, no. 1 (May 2013): 180-88.
        \10\ White House Task Force on Childhood Obesity, ``Solving the
    Problem of Childhood Obesity Within a Generation,'' May 2010, https://
    letsmove.obamawhitehouse.archives.gov/sites/letsmove.gov/files/
    TaskForce_on_Childhood_Obesity_May2010_FullReport.pdf.

              The two main sources of added sugars in U.S. diets are sugar-
            sweetened beverages and snacks and sweets. Many foods high in
            calories from added sugars provide few or no essential
            nutrients or dietary fiber and, therefore, may contribute to
            excess calorie intake without contributing to diet quality;
            intake of these foods should be limited to help achieve healthy
            eating patterns within calorie limits. There is room for
            Americans to include limited amounts of added sugars in their
            eating patterns, including to improve the palatability of some
            nutrient-dense foods, such as fruits and vegetables that are
            naturally tart (e.g., cranberries and rhubarb). Healthy eating
            patterns can accommodate other nutrient-dense foods with small
            amounts of added sugars, such as whole-grain breakfast cereals
            or fat-free yogurt, as long as calories from added sugars do
            not exceed ten percent per day, total carbohydrate intake
            remains within the AMDR [Acceptable Macronutrient Distribution
            Range], and total calorie intake remains within limits.\11\
    ---------------------------------------------------------------------------
        \11\ U.S. Department of Agriculture, Dietary Guidelines for
    Americans 2015-2010, December 2015, 31, https://health.gov/
    dietaryguidelines/2015/resources/2015-2020_Dietary_
    Guidelines.pdf.

        The USDA's Dietary Guidelines go on to note that the ``the major
    source of added sugars in typical U.S. diets is beverages, which
    include soft drinks, fruit drinks, sweetened coffee and tea, energy
    drinks, alcoholic beverages, and flavored waters.'' \12\ In fact,
    almost \1/2\ of added sugars consumed by the U.S. population come from
    sweetened beverages.\13\
    ---------------------------------------------------------------------------
        \12\ Ibid.
        \13\ Ibid.
    ---------------------------------------------------------------------------
        This is why it is so alarming that such a notable percentage of
    food/beverage purchases in American households are for sweetened
    beverages, according to a recent USDA study.\14\ Among SNAP households,
    9.25 percent of food purchases were for sweetened beverages and 7.10
    percent of non-SNAP households were for the same. SNAP households spent
    more on sweetened beverages than fruits and milk combined. According to
    the National Health and Nutrition Examination Survey (NHANES), low-
    income children are more likely to consume sweetened beverages and
    intake more calories from sweetened beverages than higher-income
    children.\15\ Children participating in SNAP in particular were more
    likely than nonparticipants to consume sweetened beverages,\16\ and 63
    percent of adults receiving SNAP consumed a sweetened beverage on the
    day of the NHANES.\17\ Also according to the NHANES, more than \1/2\ of
    adult SNAP recipients drank regular soda and 24 percent drank another
    sweetened beverage on the day of the survey.\18\ Sweetened beverage
    consumption is high among all American households, with low-income
    households and SNAP recipients no exception.
    ---------------------------------------------------------------------------
        \14\ U.S. Department of Agriculture, Food and Nutrition Service,
    ``Foods Typically Purchased by Supplemental Nutrition Assistance
    Program (SNAP) Households,'' November 2016, https://www.fns.usda.gov/
    sites/default/files/ops/SNAPFoodsTypicallyPurchased.pdf.
        \15\ Euna Han and Lisa M. Powell, ``Consumption Patterns of Sugar-
    Sweetened Beverages in the United States,'' Journal of the Academy of
    Nutrition and Dietetics 113, no. 1 (January 2013): 43-53.
        \16\ Cindy Leung, et al., ``Associations of Food Stamp
    Participation with Diet Quality and Obesity in Children,'' Pediatrics
    131, no. 3 (March 2013): 463-72.
        \17\ Sara N. Bleich, Seanna Vine, and Julia A. Wolfson, ``American
    Adults Eligible for SNAP Consume More Sugary Beverages Than Ineligible
    Adults,'' Preventative Medicine 57, no. 6 (December 2013), https://
    www.ncbi.nlm.nih.gov/pmc/articles/PMC3842507/.
        \18\ U.S. Department of Agriculture, Food and Nutrition Service,
    ``Diet Quality Among SNAP Recipients by SNAP Participation Status: Data
    from the National Health and Nutrition Examination Survey, 2007-2010,''
    May 2015, https://www.fns.usda.gov/sites/default/files/ops/NHANES-
    SNAP07-10.pdf.
    ---------------------------------------------------------------------------
    Program Integrity
        High sweetened beverage consumption is not unique to SNAP
    households. But supporting such purchases, especially at levels
    suggested in the data, directly contradicts the stated goals of the
    program. The Food Stamp Act of 1977, which outlines the purpose of the
    program, states that the goal is ``to provide for improved levels of
    nutrition among low-income households through a cooperative Federal-
    state program of food assistance.'' \19\
    ---------------------------------------------------------------------------
        \19\ Food Stamp Program Act of 1977, https://www.fns.usda.gov/
    sites/default/files/PL_106-580.pdf.
    ---------------------------------------------------------------------------
        Public health experts have clearly determined that sweetened
    beverages have no nutritional value and are a major contributor to
    obesity and related health problems. Few can argue the reverse. Yet,
    almost ten percent of food and beverage spending among SNAP households
    is on these products.
        To be fair, it is unclear whether SNAP households would make these
    purchases with their own money if they were restricted from SNAP or
    even in the absence of SNAP. However, for a program with a stated goal
    of improving nutrition, accepting such a large percentage of spending
    on beverages with no nutritional value seems counterintuitive and
    likely undermines public support for the program.
        Beyond these concerns, allowing the purchase of sweetened beverages
    directly competes with the USDA's nutrition education programming at
    the Federal and state level. Approximately $350 million is spent per
    year on SNAP Nutrition Education activities, with more spent by the
    states.\20\ The Farm Bill of 2008 authorized an additional $20 million
    to test demonstration projects designed to increase healthy eating.
    Federal dollars dedicated to improving nutrition are in direct
    competition with benefit dollars being spent to purchase sweetened
    beverages.
    ---------------------------------------------------------------------------
        \20\ U.S. Department of Agriculture, Economic Research Service,
    ``Nutrition Education,'' October 12, 2016, https://www.ers.usda.gov/
    topics/food-nutrition-assistance/supplemental-nutrition-assistance-
    program-snap/nutrition-education/.
    ---------------------------------------------------------------------------
        Separately from SNAP, not confronting the problems created by
    obesity has substantial impacts on Federal medical expenditures.
    Medical costs associated with obesity (which largely fall on Medicare
    and Medicaid) are estimated to be at least $147 billion per year.\21\
    Not only is SNAP contributing to sweetened beverage consumption, but it
    may be adding to other Federal expenditures related to medical costs
    associated with obesity.
    ---------------------------------------------------------------------------
        \21\ See Eric A. Finkelstein, et al., ``Annual Medical Spending
    Attributable to Obesity: Payer and Service-Specific Estimates,'' Health
    Affairs 28, no. 5 (2009): w822-31, http://content.healthaffairs.org/
    content/28/5/w822.full.pdf.
    ---------------------------------------------------------------------------
    Problem Is Complex and Requires a Comprehensive Approach
        As I already mentioned, the public health challenges posed by
    sweetened beverages are not unique to low-income households. But
    restrictions could be part of a broader approach to address the
    problem. Already, the USDA pilot tested a Healthy Incentive program,
    which gave financial incentives to SNAP households to purchase fruits
    and vegetables. The results of the evaluation found that the financial
    incentives increased consumption of certain fruits and vegetables by a
    small, but statistically significant amount.\22\ It also found that
    retailers had little trouble implementing the pilot. But the incentives
    had no effect on added sugars, which included no change to sweetened
    beverage consumption.
    ---------------------------------------------------------------------------
        \22\ See U.S. Department of Agriculture, Food and Nutrition
    Service, Healthy Incentives Pilot Final Evaluation Report, September
    2014, https://www.fns.usda.gov/snap/healthy-incentives-pilot-final-
    evaluation-report.
    ---------------------------------------------------------------------------
        In another study, researchers randomly assigned low-income
    households not receiving SNAP into four different groups to test
    incentives, restrictions, and both. They found that the incentive plus
    restriction group (the restriction was on sweetened beverages and other
    sweets) had positive effects on fruit consumption and reduced sweetened
    beverage and other sweets intake.\23\ The incentive-alone and
    restriction-alone group showed no difference compared with the control
    group. Although this was not conducted with SNAP households (given that
    the USDA has not allowed testing restrictions), it suggests that
    restrictions could be used to reduce sweetened beverage consumption.
    ---------------------------------------------------------------------------
        \23\ Lisa Harnack, et al., ``Effects of Subsidies and Prohibitions
    on Nutrition in a Food Benefit Program: A Randomized Clinical Trial,''
    JAMA Internal Medicine 176, no. 11 (November 2016): 1610-19.
    ---------------------------------------------------------------------------
        Similarly, although not the main purpose, a study of the Summer
    Electronic Benefit Transfer for Children Program published in 2016
    found that only a Women, Infant, and Children (WIC)-based model, which
    restricted what could be purchased with benefits, including sweetened
    beverages, led to a reduction in sweetened beverage consumption among
    families who participated.\24\ The SNAP-based model, which had no
    restrictions, did not reduce sweetened beverage consumption.
    ---------------------------------------------------------------------------
        \24\ U.S. Department of Agriculture, Food and Nutrition Service,
    ``Summer Electronic Benefit Transfer for Children (SEBTC)
    Demonstration: Summary Report,'' May 2016, https://www.fns.usda.gov/
    sites/default/files/ops/sebtcfinalreport.pdf.
    ---------------------------------------------------------------------------
        Another recent study surveyed SNAP and non-SNAP participants on
    their perceptions of the program and areas for improvement around
    nutrition. Just over \1/2\ of SNAP participants supported removing
    sweetened beverages from products allowed under SNAP, and almost 80
    percent of non-SNAP participants supported the same.\25\ In 2011, we
    surveyed New York City SNAP participants on their consumption patterns
    and attitudes around restrictions. We found that almost 70 percent of
    surveyed SNAP participants supported restricting sweetened beverages
    from SNAP (49 percent) or didn't care one way or the other (16
    percent).
    ---------------------------------------------------------------------------
        \25\ Cindy W. Leung, et al., ``Improving the Nutritional Impact of
    SNAP: Perspectives from the Participants,'' American Journal of
    Preventive Medicine 52, no. 2 (February 2017): 252.
    ---------------------------------------------------------------------------
        This research suggests that a restriction may be beneficial, but
    likely as part of other efforts to achieve the same. It also suggests
    that combining a restriction with incentives, broader nutrition
    education programs, and public messaging may reduce sweetened beverage
    consumption among those exposed.
    SNAP Demonstration Project to Test Restrictions
        For these reasons, and as part of a broader approach toward
    evidence-based policymaking, a demonstration project to test a
    sweetened beverage restriction in SNAP is needed. It could involve a
    few states or localities to assess whether the potential gains, such as
    better health, can be achieved without adverse effects on other
    measures of well-being. In a bipartisan effort in 2010, under the
    direction of Governor David Patterson and Mayor Michael Bloomberg, and
    in partnership with the New York City Department of Health, we
    submitted a proposal to the USDA to administer a demonstration project
    in New York City that would restrict sweetened beverages from SNAP.
        Our main objective was to test whether a restriction would lead to
    changes in consumption of sweetened beverages and other food groups
    among SNAP recipients, as well as whether a restriction could be
    implemented. We designed a rigorous evaluation to compare like counties
    within New York City (one would experience the restriction while the
    other would not), as well as to assess whether retailers could
    appropriately implement the restriction and whether participants could
    follow the changes. We proposed using survey data and retailer data to
    assess changes in consumption patterns over time, as well as
    qualitative work to assess the retailer and participant experience.
    Regrettably, our proposal, which was to be funded completely by the
    city and the state, was denied by the USDA in 2011.
        Since our proposal in 2010, we now know more about the Healthy
    Incentive[s] Pilot and the Summer EBT pilot. Both studies suggest that
    more can be done to improve nutrition and reduce sweetened beverage
    consumption among SNAP households. The logical next step is to conduct
    a study of SNAP restrictions. Given what was learned from those
    studies, a demonstration project is not only possible, but has been
    made more feasible. With cooperation from the USDA and funding from
    Congress, a demonstration project involving a few states could greatly
    expand our knowledge of what works in combating sweetened beverage
    consumption and the obesity crisis.
        To give you a sense of how this might work, the Healthy
    Incentive[s] Pilot operated in 2010-2012 reprogrammed EBT data systems
    at the retailer source to identify and calculate incentives as part of
    the program. A similar approach could be taken, but with restrictions.
    Participants assigned to the restriction group would receive special
    EBT cards and retailer EBT systems would be programmed to not allow
    sweetened beverage purchases among those SNAP households. With the
    technology systems in place today, implementing this type of
    demonstration project would not be overly burdensome on retailers. In
    fact, as part of the Healthy Incentive[s] Pilot, few retailers
    identified problems, and few said the pilot affected store operations.
    This type of design is not only possible, but it would provide a strong
    treatment and control study that would tell us whether any changes in
    sweetened beverage consumption were due the restrictions or not.
        When we developed the New York City proposal, retailers were
    consulted about the ease or difficulty of implementing such a
    restriction. Retailers with EBT systems indicated that it could be done
    fairly easily since restrictions are already in place for other
    purchases, such as alcohol or nonfood items. One concern was retailers
    who do not use EBT systems, instead using manual systems. But these
    retailers make up a small share of overall SNAP sales and, as part of a
    demonstration project, could be counseled to ensure that they
    understand who is restricted from purchasing sweetened beverages and
    who is not. As part of the data collection effort, the evaluators would
    know whether households assigned to the restriction group were allowed
    to purchase sweetened beverages or not.
        With a new Congress and Administration, I am hopeful that a
    demonstration project in a few states be allowed in order to test
    whether a restriction could be effective. Given the problems of obesity
    and the toll it takes on our poor communities, this is an issue that
    receives bipartisan support. For example, the bipartisan National
    Commission on Hunger recommended in its 2015 report that Congress pass
    legislation to restrict sweetened beverages from SNAP. As a first step,
    Congress could authorize funding for demonstration projects.
    Conclusion
        Some may ask why restrict sweetened beverages and no other foods
    with added sugar. Even though precedent exists in other government
    programs to determine what is nutritious and what is not, there are two
    reasons for starting with sweetened beverages. First, the research is
    clear that sweetened beverages are a much larger contributor to added
    sugars in the diets of Americans today (almost 50 percent of added
    sugars comes from these products) than other products. Second, the
    amount of spending on sweetened beverages far surpasses what is spent
    on other candies and sweets. And added sugars are often combined with
    other nutritious foods, such as whole grain cereals, yogurts, or nuts.
    The case against sweetened beverages in a nutrition assistance program
    seems clear.
        Some also argue that restrictions would be overly burdensome on
    retailers. While I respect the views of industry professionals,
    retailers already place restrictions on what can be purchased with SNAP
    benefits through their EBT systems, and the definition of sweetened
    beverage could be defined in a way that is very straightforward.
        In terms of how a restriction might affect low-income households, I
    am sympathetic to not wanting the government to stigmatize or unfairly
    targeted poor households. But SNAP is a government-funded program with
    a clearly stated goal: to improve the nutrition of low-income
    households. Not only is allowing sweetened beverages inconsistent with
    that goal, it actually may work against it by contributing to poor
    health. I also question how detrimental a restriction could be, given
    that certain restrictions already apply, other food assistance programs
    implement restrictions, and the majority of SNAP households either
    support the restriction or do not care when asked on surveys. It is
    also possible that SNAP benefits are fungible, and many SNAP households
    use their own money for food purchases, suggesting that a restriction
    may not have much effect on consumption. However, it is unclear how
    SNAP households would respond to a restriction until it is tested and
    rigorously evaluated.
        In conclusion, a restriction on sweetened beverages should be
    tested as part of a demonstration project for the purpose of improving
    public health. At a time when leaders of both parties are promoting
    evidence-based policymaking, testing such an idea and rigorously
    evaluating the results should receive broad support. I urge Congress to
    support pilot projects and urge the USDA to approve any requests from
    states.
        Thank you, and I can respond to any questions that you may have.

        The Chairman. Thank you, Dr. Rachidi.
        Dr. Schanzenbach?

            STATEMENT OF DIANE WHITMORE SCHANZENBACH, Ph.D.,
      DIRECTOR AND SENIOR FELLOW, ECONOMIC STUDIES, THE HAMILTON
                    PROJECT, BROOKINGS INSTITUTION;
       PROFESSOR OF SOCIAL POLICY AND OF ECONOMICS, NORTHWESTERN
                      UNIVERSITY, WASHINGTON, D.C.

        Dr. Schanzenbach. Thank you. Chairman Conaway, Ranking
    Member Peterson, and Members of the Committee, thanks for the
    opportunity to appear before you today. My name is Diane
    Schanzenbach. I am the Director of The Hamilton Project, which
    is an economic policy initiative at Brookings Institution. I am
    also a Professor of Social Policy of Economics at Northwestern
    University in Illinois.
        SNAP is a highly efficient and effective program. It lifted
    nearly five million children out of poverty in 2014. SNAP is
    targeted efficiently to families who need benefits the most. It
    reduces the likelihood that families have trouble affording
    food, and serves as an automatic fiscal stabilizer in times of
    economic downturn. It also has extremely low rates of both
    error and fraud.
        A key reason for SNAP's success is that it relies on the
    private-sector to provide efficient access to food from grocery
    stores and other retail outlets. The reliance on the program on
    the free market system has been a feature of SNAP since the
    beginning. With a few restrictions, recipients have been able
    to optimize which items to purchase, and from which retail
    stores, subject to prevailing prices, and also to their own
    taste preferences and nutritional needs.
        SNAP also has long-term benefits to children. My own recent
    research study, which is the only long-term causal study on
    SNAP access, found that those who had access to SNAP benefits
    during childhood were more likely to graduate from high school,
    they grew up to be healthier, and for women in particular, they
    grew up to be more economically self sufficient as adults, all
    due to childhood access to SNAP benefits, because this is an
    investment in children.
        There has been much media discussion of the November 2016
    USDA report on the typical food purchase patterns by SNAP
    participants and non-participants. The top line finding of that
    report is that SNAP and non-SNAP families have extremely
    similar spending patterns. The study did not address the more
    fundamental question, namely, how does SNAP change the types of
    groceries that participants buy? By increasing a family's
    resources available to purchase groceries, SNAP is expected to
    increase not only the quantity, but also the quality of foods
    purchased. SNAP families are able to buy more nutritious foods
    that they otherwise could not afford.
        Additional restrictions on SNAP purchases will undermine
    the effectiveness and the efficiency of the program. In
    particular, SNAP restrictions will be difficult to structure
    and practice. In the case of a proposed ban on the purchase of
    soft drinks or sweetened beverages, it will be unlikely to
    change consumption patterns.
        So recall that SNAP benefits are modest. They are
    approximately $4.50 per person per day, and as a result, almost
    everyone who participates in the program has to supplement
    their SNAP purchases with groceries purchased out of their own
    cash income. So what will happen if a soft drink purchase is
    banned using SNAP benefits? Well, we would expect there to be
    no consumption change. A family could continue to purchase the
    same basket of goods. They will just have to make certain at
    the checkout line to pay for the soft drinks out of their cash
    instead of their SNAP benefits. In other words, a ban will
    likely increase the administrative cost of the program, both to
    the USDA and to retailers, and increase the stigma faced by
    recipients when they use SNAP, but not have the benefit of
    actually inducing any behavioral changes. It will be all costs
    and no benefits.
        I think there are better policy options that are more
    likely to improve the diets of SNAP recipients. Market-based
    policies that reduce the relative price of healthy foods can
    increase that consumption. For example, as you know, the
    Healthy Incentives Pilot in Massachusetts increased consumption
    of targeted healthy foods by 25 percent. Exploring ways to
    replicate or scale this type of program nationally would
    provide an effective and a market-based path forward toward
    achieving the goal of increasing healthy food consumption of
    SNAP recipients.
        Strengthening SNAP is a smart public investment that will
    improve both public health and economic growth, but banning
    certain foods will raise the administrative burdens and costs
    of the program, making it less efficient, but is unlikely to
    change consumption.
        By contrast, policy changes that strengthen the purchasing
    power of SNAP benefits and allow markets to function without
    undue interference are more likely to improve dietary choices
    of recipients and reduce food insecurity.
        Thank you, and I am looking forward to questions.
        [The prepared statement of Dr. Schanzenbach follows:]

    Prepared Statement of Diane Whitmore Schanzenbach, Ph.D., Director and
        Senior Fellow, Economic Studies, The Hamilton Project, Brookings
    Institution; Professor of Social Policy and of Economics, Northwestern
                          University, Washington, D.C.
        Chairman Conaway, Ranking Member Peterson, and Members of the
    Committee:
        Thank you for the opportunity to appear before you today at this
    hearing on the Pros and Cons of Restricting Purchases in the
    Supplemental Nutrition Assistance Program (SNAP).
        My name is Diane Schanzenbach, I am Director of the Hamilton
    Project, an economic policy initiative at the Brookings Institution,
    where I am also a Senior Fellow in Economic Studies.
        I am also a Professor of Social Policy and Economics at
    Northwestern University. For the past 2 decades, I have conducted and
    published numerous peer-reviewed research studies and book chapters on
    the U.S. safety net, including SNAP and the Food Stamp Program. I also
    study childhood obesity, food consumption, and food insecurity. I
    recently served as a member of the Institute of Medicine's Committee on
    Examination of the Adequacy of Food Resources and SNAP Allotments.
        My testimony today draws primarily from research that I have
    conducted or reviewed that considers the role of SNAP and other
    influences on food consumption and food insecurity.
        SNAP is a highly efficient and effective program. It lifted nearly
    five million people out of poverty in 2014 (the most recent data
    available).\1\ SNAP is targeted efficiently to families who need
    benefits the most, reduces the likelihood that families have trouble
    affording food, and serves as an automatic fiscal stabilizer in times
    of economic downturns.2-3 It has extremely low rates of both
    error and fraud.4-5 SNAP also has long-term benefits to
    children. My own recent research study found that those who had access
    to SNAP benefits during childhood were more likely to graduate from
    high school, grew up to be healthier, and women in particular were more
    likely to become economically self-sufficient due to childhood access
    to SNAP benefits, as shown in Figure 1.
    ---------------------------------------------------------------------------
        \1\  Sherman, Arloc. 2015, September 16. ``Safety Net Programs Lift
    Millions From Poverty, New Census Data Show.'' Center on Budget and
    Policy Priorities, Washington, D.C. Available at: http://www.cbpp.org/
    blog/safety-net-programs-lift-millions-from-poverty-new-census-data-
    show.
        \2\ Institute for Research on Poverty. 2015, November. ``SNAP, Food
    Security, and Health.'' Policy Brief No. 8, Institute for Research on
    Poverty, University of Wisconsin-Madison, Madison, WI. Available at:
    http://www.irp.wisc.edu/publications/policybriefs/pdfs/PB8-SNAPFoodSecu
    rityHealth.pdf.
        \3\ Schanzenbach, Diane Whitmore, Lauren Bauer, and Greg Nantz.
    2016, April 21. ``Twelve Facts about Food Insecurity and SNAP.''
    Economic Facts, The Hamilton Project, Washington, D.C. Available at:
    http://www.hamiltonproject.org/papers/twelve_facts_about_food_
    insecurity_and_snap.
        \4\ Rosenbaum, Dottie. 2014, July 2. ``SNAP Error Rates at All-Time
    Lows.'' Report, Center on Budget and Policy Priorities, Washington,
    D.C. http://www.cbpp.org/research/snap-error-rates-at-all-time-lows.
        \5\ U.S. Department of Agriculture (USDA). 2013, August 15. ``USDA
    Releases New Report on Trafficking and Announces Additional Measures to
    Improve Integrity in the Supplemental Nutrition Assistance Program.''
    Food and Nutrition Service, U.S. Department of Agriculture, Washington,
    D.C. Available at: https://www.fns.usda.gov/pressrelease/2013/fns-
    001213.
    ---------------------------------------------------------------------------
    Figure 1. Impact of Access to Food Stamps During Early Life on Adult
            Health and Economic Outcomes
              Access to food stamps in early life improves health outcomes
            in men and women and economic self-sufficiency in women in
            later life.

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Sources: Hoyes, Schanzenbach, and Almond 2016.
              Note: Hollowed bars are not statistically significant.

        Generally, economists advise policymakers not to interfere in the
    private market unless there is a compelling reason to do so--such as a
    market failure or another inefficiency that would be improved through
    government intervention. In the case of SNAP, the fundamental problem
    the program is meant to address is not a market failure, but is instead
    a lack of resources available to purchase food. Government assistance
    is needed because some families, generally temporarily, do not have
    adequate resources to purchase enough food to sustain an active,
    healthy lifestyle. When they receive SNAP, participating families have
    more resources they can use to purchase groceries. Once the fundamental
    problem of resource adequacy is addressed, recipients can interact with
    the private market to obtain the food they need.
        A key reason for SNAP's success is that it relies on the private-
    sector to provide efficient access to food, through grocery stores and
    other retail outlets. The reliance of the program on the free market
    system has been a feature of SNAP since the beginning. With few
    restrictions, recipients have been able to optimize which items to
    purchase and from what retail stores, subject to prevailing prices and
    their own tastes, preferences, and nutritional needs.
        In my opinion, additional restrictions on SNAP purchases will
    undermine the effectiveness and the efficiency of the program. In
    particular, based on my research on SNAP and food consumption I believe
    that SNAP restrictions: will be difficult to structure in practice,
    will be inefficiently targeted, and in many cases--such as a proposed
    ban of the purchase of soft drinks or sweetened beverages--will be
    unlikely to change consumption patterns. There are better policy
    options for promoting healthy eating patterns, both for SNAP recipients
    and for all Americans.
    SNAP Restrictions will be Difficult to Structure in Practice
        There are a few broad types of restrictions that have gained policy
    traction. One set involves narrowly targeting the commodities that can
    be purchased with SNAP, another involves restricting the purchase of
    unhealthy foods broadly, or sodas or sugar sweetened beverages in
    particular, and another proposes banning purchases of certain luxury
    foods. Each of these will be difficult to implement in practice because
    of the complexities involved in determining which items would fall
    under the ban. In addition, the restrictions would increase the
    administrative burden on private businesses, and particularly on small
    establishments.
        The complexities arise in part because of the sheer number of
    products that would need to be classified. Consumers have vast
    differences in their tastes and preferences, and the market responds by
    providing variety. There are more than 650,000 food and beverage
    products on the market today, and 20,000 more are introduced
    annually.\6\ The complexity is multiplied because there is no clear
    standard for defining foods as ``healthy'' or ``unhealthy,'' or as
    luxury goods. Creating such standards would be difficult at best, and
    would entail substantial administrative costs to categorize and track
    the nutritional profile of each good to produce a SNAP-eligible foods
    list. The list would have to be maintained continuously and
    communicated to retailers and consumers in real time. My prediction is
    that the additional bureaucracy needed to support such an undertaking
    is not likely to save taxpayer money.
    ---------------------------------------------------------------------------
        \6\  USDA. 2016, October 12. ``New Products.'' Economic Research
    Service, U.S. Department of Agriculture, Washington, D.C. Available at:
    https://www.ers.usda.gov/topics/food-markets-prices/processing-
    marketing/new-products/.
    ---------------------------------------------------------------------------
        Furthermore, items should not be classified in a manner that
    suggests a particular food is always ``good'' or ``bad.'' The Academy
    of Nutrition and Dietetics, the largest organization of food and
    nutrition professionals, has adopted a position statement that the
    ``total diet'' or overall pattern of food eaten should be the most
    important focus of healthy eating.\7\ All foods can fit into a healthy
    diet if consumed in moderation and with appropriate portion size, and
    as a result no particular food should be always banned.
    ---------------------------------------------------------------------------
        \7\ Freeland-Graves, Jeanne H., and Susan Nitzke. 2013. ``Position
    of the Academy of Nutrition and Dietetics: Total Diet Approach to
    Healthy Eating.'' Journal of the Academy of Nutrition and Dietetics 113
    (2): 307-17. Available at: http://www.andjrnl.org/article/S2212-
    2672(12)01993-4/abstract.
    ---------------------------------------------------------------------------
    SNAP Improves Diets
        By focusing on the descriptive question of what SNAP participants
    buy, the USDA study did not address the more fundamental question--
    namely how does SNAP change the types of groceries that participants
    buy? Economists have strong predictions about the impact of SNAP: by
    increasing a family's resources available to purchase groceries, SNAP
    is expected to increase both the quantity and the quality of foods
    purchased, and it has. When SNAP increases low-income families' grocery
    purchasing power, they are able to buy more nutritious foods they
    otherwise could not afford. While this is a surprisingly hard question
    to study empirically, a recent study found that a $30 increase in
    monthly SNAP benefits would increase participants' consumption of
    nutritious foods such as vegetables and healthy proteins, while
    reducing food insecurity and consumption of fast food, as shown in
    Figure 2 below.\8\
    ---------------------------------------------------------------------------
        \8\ Anderson, Patricia M., and Kristin F. Butcher. 2016, June 14.
    ``The Relationships Among SNAP Benefits, Grocery Spending, Diet
    Quality, and the Adequacy of Low-Income Families' Resources.'' Report,
    Policy Futures, Center on Budget and Policy Priorities, Washington,
    D.C. Available at: http://www.cbpp.org/research/food-assistance/the-
    relationships-among-snap-benefits-grocery-spending-diet-quality-and-
    the.
    ---------------------------------------------------------------------------
    Figure 2. Estimated Impact of a $30 Increase in Monthly Per Capita SNAP
            Benefits

            [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Source: Anderson and Butcher 2016.
              Note: Percentages for the dark green bars represent change in
            consumption. Food insecurity is defined as having difficulty at
            some time during the year providing enough food for all
            household members due to lack of resources. The hollowed bars
            are not statistically significant.

        Similar impacts were found in a randomized controlled trial of a
    Summer EBT program that gave families $60 per month in benefits per
    eligible child during the summer months, to offset the loss of school
    meals. The study found that children assigned to receive additional
    benefits improved their diets, consuming more fruits, vegetables, whole
    grains, and dairy products, and fewer sugar-sweetened beverages.\9\
    ---------------------------------------------------------------------------
        \9\ Briefel, Ronette, Ann Collins and Anne Wolf. 2013, November 8.
    ``Impact of the Summer Electronic Benefits Transfer for Children
    (SEBTC) Demonstration on Children's Nutritional Status.'' Panel Paper,
    Mathematica Policy Research and Abt Associates, Washington, D.C.
    Available at: https://appam.confex.com/appam/2013/webprogram/
    Paper7254.html.
    ---------------------------------------------------------------------------
    SNAP and Non-SNAP Households Have Similar Consumption
        There has been much media discussion of the November 2016 USDA
    report on typical food purchase patterns by SNAP participants and non-
    participants.\10\ The top-line finding of that report is that SNAP and
    non-SNAP households have extremely similar food spending patterns. Out
    of every dollar spent by SNAP families:
    ---------------------------------------------------------------------------
        \10\ USDA. 2016, November 18. ``Foods Typically Purchased by
    Supplemental Nutrition Assistance Program (SNAP) Households.''
    Nutrition Assistance Program Report, Office of Policy Support, Food and
    Nutrition Service, U.S. Department of Agriculture, Washington, D.C.
    Available at: https://www.fns.usda.gov/snap/foods-typically-purchased-
    supplemental-nutrition-assistance-program-snap-households.

       Around 40 went to what the study classifies as ``basic
    ---------------------------------------------------------------------------
            items'' such as meat, fruits, vegetables, eggs, bread and milk.

       Around 20 went to salty snacks, sugar, candy and sweetened
            beverages, with 5 going to soft drinks.

       The remaining 40 spent on other goods, including prepared
            foods, cereal, rice, beans, and dairy products.

        The USDA findings are consistent with my own published research
    using the Consumer Expenditure Survey that also found similar spending
    patterns across food categories for SNAP and non-SNAP households.\11\
    ---------------------------------------------------------------------------
        \11\ Hoynes, Hilary W., Leslie McGranahan, and Diane W.
    Schanzenbach. 2014. ``SNAP and Food Consumption.'' Discussion Paper
    2014-03, Center for Poverty Research, University of Kentucky,
    Lexington, KY. Available at: http://uknowledge.uky.edu/cgi/
    viewcontent.cgi?article=
    1008&context=ukcpr_papers.
    ---------------------------------------------------------------------------
        Public-health advocates rightly point out that sugar-sweetened
    beverages are the largest source of excess calories in the average
    American diet, and they provide no nutritional benefit.12-13
    The obesity epidemic has hit Americans across all income levels, and
    public-health advocates are right to call attention to our excessive
    consumption of sugar-sweetened beverages as one probable cause.\14\ The
    USDA study indicates that this is an issue across the income
    distribution, and there is no need to single out SNAP recipients for
    their consumption of soft drinks. Among the spending observed in the
    USDA study, about 5 of each dollar went to the purchase of soft
    drinks. This rate is similar to non-SNAP households, which spend an
    average of four percent of their grocery dollars on soft drinks.
    ---------------------------------------------------------------------------
        \12\  Welsh, J.A., A.J. Sharma, L. Grellinger, and M.B. Vos. 2011.
    ``Consumption of Added Sugars is Decreasing in the United States.''
    American Journal of Clinical Nutrition 94 (3): 726-34. Available at:
    https://www.ncbi.nlm.nih.gov/pubmed/21753067.
        \13\ The Nutrition Source. ``Public Health Concerns: Sugary
    Drinks.'' School of Public Health, Harvard University, Cambridge, MA.
    Available at: https://www.hsph.harvard.edu/nutritionsource/healthy-
    drinks/beverages-public-health-concerns/.
        \14\ Center for Disease Control and Prevention. 2016, September 1.
    ``Adult Obesity Facts.'' Center for Disease Control and Prevention,
    U.S. Department of Health & Human Services, Atlanta, GA. Available at:
    https://www.cdc.gov/obesity/data/adult.html.
    ---------------------------------------------------------------------------
    A Soda Ban Will Not Reduce Soda Consumption
        Another option that has been proposed is to disallow only the
    purchase of soft drinks or sweetened beverages with SNAP benefits.
    These proposals exaggerate the potential impacts on consumption such
    bans would have, because the rationale for the bans is based on a false
    understanding of how SNAP benefits work. SNAP benefits are modest--
    approximately $4.50 per person per day--and as a result nearly all
    families supplement their SNAP purchases with groceries purchased from
    their cash income. This occurs by design, and is why the program is
    called the Supplemental Nutrition Assistance Program; it is intended in
    most cases to extend a family's food purchasing power, not to cover 100
    percent of food purchases. Estimates suggest that 70 to 80 percent of
    participants, perhaps even higher, supplement their SNAP spending with
    cash.
        What will happen if soft drink purchases are banned using SNAP
    benefits? Take a typical family that spends the average amount--$12 per
    month--on soft drinks, and supplements their SNAP spending with
    spending out of cash resources. Our best prediction is that there will
    be no consumption change as a result of the SNAP restriction; such a
    family can continue to purchase the same basket of goods, but they
    would have to make certain to pay for the soft drinks out of their own
    cash instead of their SNAP benefits. In other words, a ban will likely
    increase the administrative costs of the program to both the USDA and
    retailers, and increase the stigma faced by recipients when they use
    the benefits, but not have the benefit of inducing any behavioral
    changes.
    Recommendations
        There are better policy options that are more likely to improve the
    diets of SNAP recipients, particularly when you consider that, over the
    past decade, fresh fruits and vegetables have become relatively more
    expensive compared to foods that are considered less healthy, as shown
    in Figure 3 below. In response, market-based policies can increase the
    affordability of healthy foods and provide incentives for low-income
    families to purchase them.
        One approach that merits further consideration is the USDA's
    randomized controlled trial of the Healthy Incentives Pilot in
    Massachusetts. This pilot program gave SNAP recipients an immediate 30
    rebate for every dollar they spent on a narrowly defined group of
    fruits and vegetables.\15\ In response to this price rebate,
    consumption of the targeted healthy foods increased by 25 percent.\16\
    In recent years, many local areas and even a few states have taken a
    similar approach by awarding bonus dollars for benefits used at
    farmers' markets, allowing recipients to stretch their food budget
    farther when they buy fresh produce. To date, these programs have been
    successful. Exploring ways to replicate or scale these types of
    programs nationally would provide a more constructive and effective
    path forward toward achieving the goal of increasing healthy food
    consumption by SNAP recipients.
    ---------------------------------------------------------------------------
        \15\ USDA. 2015, September 2. ``Healthy Incentives Pilot.'' Report,
    Food and Nutrition Service, U.S. Department of Agriculture, Washington,
    D.C. Available at: https://www.fns.usda.gov/hip/healthy-incentives-
    pilot.
        \16\ Bartlett, Susan, Jacob Klerman, Parke Wilde, Lauren Olsho,
    Michelle Blocklin, Christopher Logan, and Ayesha Enver. 2013. ``Healthy
    Incentives Pilot (HIP) Program.'' Food and Nutrition Services, Office
    of Policy Support, U.S. Department of Agriculture, Washington, D.C.
    Available at: https://www.fns.usda.gov/sites/default/files/
    HIP_Interim.pdf.
    ---------------------------------------------------------------------------
    Figure 3. Price Levels by Food Category, 1980-2016

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Source: Bureau of Labor Statistics 2016.
              Note: Base year of the index (100) is the average for 1982-
            84.

        Strengthening SNAP and reducing food insecurity in the more than 22
    million U.S. households that receive nutritional assistance on a
    monthly basis is a smart public investment that will improve both
    public health and economic growth. Banning certain foods will raise the
    administrative burdens and cost of the program, but is unlikely to
    change consumption. By contrast, policy changes that strengthen the
    purchasing power of SNAP benefits and allow markets to function without
    undue interference are more likely to improve dietary choices of
    recipients and reduce food insecurity.
        Thank you, and I look forward to answering any questions you might
    have.

        The Chairman. Thank you.
        Ms. Sarasin, 5 minutes.

     STATEMENT OF LESLIE G. SARASIN, PRESIDENT AND CHIEF EXECUTIVE
                   OFFICER, FOOD MARKETING INSTITUTE,
                             ARLINGTON, VA

        Ms. Sarasin. Good morning. Thank you very much. I am Leslie
    Sarasin. I serve as President and CEO of FMI. Our members'
    grocery stores are located in every Congressional district in
    the country.
        Grocers play an important role in the efficient delivery of
    safe, affordable food for both the SNAP and the WIC Programs.
    We appreciate this Committee's work to better understand SNAP
    this morning.
        Becoming an authorized SNAP retailer is a complicated
    process. Retailers must submit specified paperwork and
    credentials, and adhere strictly to the SNAP operating rules
    and ongoing training for their associates. Violation of SNAP
    operating rules results in revocation of both the SNAP and the
    WIC licenses.
        SNAP authorized stores code all products within the
    electronic checkout system as either SNAP eligible or
    ineligible. When an eligible item is scanned, the system
    deducts the product's price from the customer's SNAP EBT card.
    When an ineligible item is scanned, the cashier is prompted to
    ask the customer for another form of payment. Approximately 50
    percent of SNAP transactions are multi-tendered, such that
    another form of payment is also used to pay for non-food items,
    ineligible items, or eligible food items that exceed the
    balance available on the SNAP EBT card. If a customer tries to
    purchase a tobacco or alcohol product with their SNAP EBT
    benefits, the electronic system will freeze until the product
    is actually removed. Within the electronic systems, WIC
    eligible items are charged against that benefit first, followed
    by those eligible for SNAP, and finally, the cashier must
    collect another form of payment: cash, check, debit, or credit
    for all remaining items.
        Grocery transactions for SNAP customers vary significantly
    throughout the month. Data indicate the first transaction of
    the month is usually the largest and may contain larger
    quantities of protein and perishables. By the last week of the
    month, customers typically purchase maximum calories at minimum
    cost.
        We appreciate the Committee's recognition of the role
    grocers play in the SNAP program. FMI has announced a new
    industry SNAP task force to identify areas where the program
    works well, and also to consider those that may require
    improvement. Some suggest that limiting what customers can buy
    with SNAP, making it more like WIC, may help achieve these
    goals. Doing so would place a tremendous burden, both on USDA
    and on food retailers, and likely would not achieve policy
    goals. Please consider two recent examples from the WIC
    Program.
        When USDA began the Fresh Fruits and Vegetables Cash Value
    Voucher Program, it subjectively decided all fresh fruits and
    vegetables were eligible, except white potatoes. As many of you
    will recall, this ban on white potatoes unleashed a great
    debate throughout Congress and the industry. In the end, after
    more than a year of debate and consideration of actual science,
    USDA reversed the ban to allow white potatoes to be purchased
    through WIC. This was one item out of the tens of thousands
    found in each of our members' stores that would have to be
    studied and debated before USDA can make a determination as to
    whether a product is in or out.
        Second, if our goal with SNAP is to provide short-term
    lifelines to needy Americans so they can get and keep a job to
    earn enough to support their families without government
    benefits, such limitations seem unlikely to help accomplish
    that goal at a reasonable cost. Doing so will require
    additional USDA staff to make these decisions for all products
    currently in market, as well as the estimated 20,000 new
    products introduced every year. USDA would also need to
    maintain a real time list downloadable to every electronic
    payment system in the country.
        I should note that in 2004, Congress directed USDA to
    create an electronically downloadable real time UPC database
    for all WIC eligible foods. Today, retailers are still waiting
    for this list. The fact that nearly 13 years later we are still
    waiting for the list shows the complexity of creating and
    keeping one updated in real time, even for a list of products
    as small as WIC's. A similar SNAP database would include more
    than 100 times the number of products, along with more than the
    20,000 that are introduced every year. Could it be done?
    Probably so, but we expect it would be both challenging and
    expensive.
        Finally, FMI members are incredible contributors to their
    communities. They are the largest contributors to our nation's
    food banks, create good paying jobs, and help build our future
    workforce. We look forward to working with the Committee on
    SNAP and other related issues, and I am also happy to answer
    any questions you may have.
        [The prepared statement of Ms. Sarasin follows:]

    Prepared Statement of Leslie G. Sarasin, President and Chief Executive
                Officer, Food Marketing Institute, Arlington, VA
        Chairman Conaway, Ranking Member Peterson, and Members of the
    Committee,

        My name is Leslie Sarasin, and I serve as President and Chief
    Executive Officer of Food Marketing Institute,\1\ a trade association
    that represents food retailers and wholesalers, as well as their
    suppliers of products and services. FMI members are located in every
    Congressional district across the country. FMI's maxim when referring
    to its member companies is ``Feeding Families and Enriching Lives,'' a
    responsibility we take very seriously.
    ---------------------------------------------------------------------------
        \1\ Food Marketing Institute proudly advocates on behalf of the
    food retail industry. FMI's U.S. members operate nearly 40,000 retail
    food stores and 25,000 pharmacies, representing a combined annual sales
    volume of almost $770 billion. Through programs in public affairs, food
    safety, research, education and industry relations, FMI offers
    resources and provides valuable benefits to more than 1,225 food retail
    and wholesale member companies in the United States and around the
    world. FMI membership covers the spectrum of diverse venues where food
    is sold, including single owner grocery stores, large multi-store
    supermarket chains and mixed retail stores. For more information, visit
    www.fmi.org and for information regarding the FMI foundation, visit
    www.fmifoundation.org.
    ---------------------------------------------------------------------------
    Food Retail Role
        In the context of ``feeding families,'' our industry is pleased to
    maintain an important role in facilitating the efficient delivery in
    our stores of safe, affordable food products for both the Supplemental
    Nutrition Assistance Program (SNAP) and the Special Supplemental
    Nutrition Program (WIC). I appreciate the work this Committee is
    undertaking to better understand the operations of SNAP and the
    differences between a short-term hunger program as contemplated in SNAP
    and a longer-term nutrition program as contemplated in WIC.
        As you know, the WIC program serves mothers and their children up
    to age 5. FMI members redeem very specific food prescriptions designed
    to ensure moms and their babies have access to the early nutrition they
    need for optimum physical and mental development. This important
    nutrition program is overseen by the House Education and the Workforce
    Committee and is currently up for reauthorization.
        SNAP, the program under the full purview of this Committee, is one
    in which FMI members serve as the delivery mechanism for benefits.
    SNAP, a program created to address hunger among Americans, is designed
    to supplement the food budgets for seniors and/or families experiencing
    financial difficulty, or on a longer-term basis, individuals who are
    disabled.
        As designed, SNAP allows customers to purchase approved food
    products from a SNAP-authorized retailer. Becoming an authorized SNAP/
    WIC retailer is not a simple process, and that process requires
    completion of specified paperwork and the providing of many
    credentials, including a business license, a photo ID for each owner of
    the business and proof of a social security number. This information
    may be requested at reauthorization or at any time throughout the
    process. Once approved, retaining SNAP/WIC authorization is not a
    foregone conclusion. The food retailer must agree to adhere strictly to
    the SNAP operating rules, violation of which results in having both the
    SNAP and WIC licenses revoked. Additionally, authorized retailers must
    agree to ongoing training programs for their associates to ensure they
    understand and adhere to all SNAP rules and regulations, as delineated
    in USDA's 25 page training guide.
        SNAP has been enhanced in recent years by moving from a paper-based
    program that issued ``food stamps'' to an electronic benefits transfer
    program known as ``EBT,'' through which benefits are downloaded
    electronically to a government-issued debit card which then may be
    utilized at store level by SNAP benefit recipients. This movement to
    EBT has increased the efficiency of the program and enhanced its
    accountability by reducing the opportunity for fraud and human error.
    The program also benefitted from the work of this Committee and then
    Nutrition Subcommittee Chairman Bob Goodlatte, whose efforts focused on
    ensuring interoperability and consistency of the program across state
    lines. The EBT Interoperability and Portability Act (P.L. 106-171),
    signed into law in 2000, ensures that EBT transactions operate
    consistently from state to state. This law has significantly reduced
    the incidence of error and has allowed shoppers living in border state
    areas to seek the best prices through which to stretch their SNAP
    benefits. It also has enabled those who must cross state lines for
    emergency reasons, such as to care for a sick relative or to escape the
    disastrous results of a natural event like Hurricane Sandy, to continue
    receiving benefits in a seamless manner.
        As the front line purveyors of SNAP, authorized retailers maintain
    a unique and special vantage point from which to see SNAP transactions.
    At the time of food purchase, SNAP recipients input their unique,
    secret PIN after swiping their card. As is the case with commercial
    debit cards, the PIN is an important added authentication to prevent a
    stolen card from being used by an unauthorized person.
        All products in SNAP-authorized stores are coded within the
    electronic checkout system as being either eligible or ineligible for
    purchase with SNAP benefits. This designation often can be seen on a
    paper receipt with the initials ``FS.'' When a SNAP customer places
    products on the checkout conveyor belt, the checkout system scans each
    item as either eligible or ineligible for SNAP. If an item is eligible,
    the system deducts the product's price from the customer's SNAP EBT
    card. If ineligible, it prompts the cashier to ask the customer for
    another form of payment. Examples of ineligible items include laundry
    detergent and diapers, since they are not food items, and a hot
    rotisserie chicken, since hot, ready-to-eat food items are not eligible
    for purchase with SNAP benefits.
        Data indicate that approximately 50% of supermarket customers using
    SNAP benefits when purchasing groceries also use other forms of
    payment, either to pay for non-food items, ineligible products or for
    eligible food items that exceed the remaining balance on the SNAP EBT
    card. It also is my understanding that if a customer attempts to
    purchase a tobacco product or alcoholic beverage, the electronic system
    will freeze and will not allow the transaction to continue until the
    tobacco or alcohol product is removed.
        Those not fully involved in the SNAP transactional process can find
    it baffling and can often be confused about products that are eligible
    and those that are ineligible and therefore paid for through other
    means, and even in some cases by products that are eligible but not
    paid for with SNAP benefits in a particular transaction. Under the
    electronic systems in place today, the items eligible for WIC are
    charged against that benefit first, followed by those eligible for SNAP
    benefits, and finally, the cashier must collect another form of
    payment--cash, check, debit or credit--for all remaining items not
    eligible under either of the programs and/or for items that exceed the
    dollar or prescription value of the benefits. As a result, while the
    items the electronic system charges to the SNAP benefit are eligible to
    be purchased with SNAP, they may not necessarily be designated by the
    customer to be the specific items purchased with SNAP benefits. This
    occurs, for example, when a SNAP customer places $100 worth of eligible
    items, such as bananas, eggs and bread, and has only $80 in benefits on
    the EBT card; the electronic system deducts $80 from the grand total of
    SNAP-eligible items, but does not necessarily attribute the $80 to a
    specific array of products on the checkout conveyor belt.
        It is worth noting that grocery transactions for SNAP customers
    vary significantly throughout the month. Data indicate the first
    transaction of the month is likely the largest and may contain larger
    quantities of protein, perishables, or even a splurge item. The
    purchases of second and third weeks of the month are often more
    balanced, and the purchases made in the last week of the month
    typically find customers purchasing maximum calories at minimum cost.
        This variation among purchases is particularly noteworthy in the
    seven states that continue to issue benefits to all recipients on only
    1 day of the month, rather than spreading issuance dates throughout the
    month. There are four states that distribute benefits on only 2 or 3
    days each month. Expanding the dates for issuing SNAP benefits allows
    supermarkets to better address supply chain issues on fresh and
    perishable items and allows labor needs to be spread throughout the
    month into full-time positions rather than having them concentrated in
    a segment of the month with multiple part-time positions to accommodate
    the volume of SNAP shoppers trying to redeem benefits on one day. A
    chart of state issuance time frames is attached to this testimony.
    Need for Sound Public Policy
        FMI member companies appreciate the Committee's recognition that
    food retailers are engaged and informed partners in the SNAP and WIC
    programs, as evidenced by the invitation for this testimony. As your
    partners in this endeavor, we hope you will consider several issues of
    concern to food retailers.
        Against the backdrop of food retailers' commitment to enrich the
    lives of individuals in the communities they serve, we suggest that as
    the Committee examines SNAP, it keep in mind the larger goals and
    purpose of this hunger program. A strategic policy-oriented discussion
    could help make an already good program even better. If, however, the
    consideration becomes bogged down in energy zapping tactical questions
    of specific product(s) to be considered for elimination from SNAP, this
    program enhancement will be made much more difficult, if not
    impossible. FMI respectfully submits that changes to the program should
    be part of a broad policy discussion with clearly articulated desired
    results and delineation of the most effective and efficient means to
    achieve those results.
        We at FMI would be pleased to participate in that ``results''
    discussion. To assist in that process, we have announced the
    development of an industry SNAP Task Force to identify areas of the
    program we find to be exceptional, to make sure those are not
    eliminated, and to consider those we believe may require improvement in
    order to achieve your policy goals.
        As I understand them, among the Committee goals are the following:

       To ensure no unfair penalty on individuals who find
            themselves on the edge of the benefits cliff and who are trying
            to move to a higher paying job;

       To ensure SNAP is the most efficient program possible,
            eliminating fraud and opportunities for fraud on both the
            delivery and recipient side;

       To make SNAP the least burdensome possible for individuals
            whose participation in the program may actually reduce
            government health care, social services, and education costs,
            such as seniors with a fixed income, disabled individuals and
            families supporting children under the age of 18; and

       To identify and prepare individuals who receive SNAP
            benefits for enhanced employment opportunities.

        It has been suggested that achievement of these goals might be
    facilitated by development of a prescription of limitations for SNAP
    purchases, perhaps similar to those that exist in the WIC program.
    While this may seem an attractive option, I respectfully suggest that
    prior to doing so we first identify the result being sought in
    undertaking such a change in the program.
        To demonstrate how a tactical reaction may actually prove to be
    inconsistent with a policy goal, it is worthwhile to consider an
    anecdote from the most recent reauthorization of the WIC nutrition
    program. At that time, similar debates occurred regarding products that
    should or should not be authorized under the WIC program. There were a
    number of factions, including farmers touting the unique benefits of
    the crops they were growing. Ultimately, WIC was updated to allow for
    the first time a fresh fruits and vegetables benefit and all fruits and
    vegetables were allowed under this program, with one exception. The
    exception made was for white potatoes, deemed at the time not to be
    nutritionally significant. Yet, just 1 year later, the Institute of
    Medicine issued a report indicating that Americans suffer from
    relatively high incidences of a deficiency in potassium, for which
    white potatoes serve as a good source under definitions established by
    the Food and Drug Administration. Moreover, we are now in the process
    in this country of redesigning the Nutrition Facts Panel that appears
    on food products to add potassium as a required element so that
    consumers can begin to address this deficiency. In the last Congress,
    in 2015 a change was made to allow white potatoes as a vegetable in the
    WIC program.
        From experience previously in my career while serving as the
    President and Chief Executive Officer of the American Frozen Food
    Institute, I can relay anecdotes regarding the treatment of frozen
    foods, specifically frozen fruits and vegetables, that are
    nutritionally equivalent and in some cases nutritionally superior, to
    their unfrozen counterparts in not being declared WIC eligible by some
    states to the utter detriment of both the programs and the frozen fruit
    and vegetable industries.
        Of course, the discussions today will hardly illuminate specific
    issues such as these, but it is critical as we consider changes to
    Federal hunger programs such as SNAP that we identify the policy goals
    to be achieved, rather than just focus on a potentially desirable sound
    bite. I would respectfully suggest that if our goal with SNAP is to
    provide needy Americans a short-term lifeline to allow them to get and
    keep a job so they earn enough to support their families without
    government benefits, the unilateral limitation of any specific product
    is unlikely to help accomplish that goal. It is worth noting that doing
    so will also increase the need for additional USDA staff to make and
    encode these determinations for an estimated 20,000 new products
    introduced into the marketplace annually and then download these
    electronically on a real-time basis to every electronic payments system
    in the country.
        SNAP was designed and currently serves as a hunger program. It is a
    supplementary program for the customers whose circumstances require
    them to rely upon it for a season of their life, and for these
    individuals it is a life-saver. Eighty-two percent of all SNAP benefits
    in FY 2015 went to households that included a child, an elderly person
    or a person with disabilities.
        There have been a number of limitations suggested for this program
    whether it be no meats, no desserts, no snacks, no soft drinks and even
    no white bread. Not only do such limitations appear incongruous to the
    policy positioning of a program designed to provide temporary
    assistance addressing hunger considerations, but they also would prove
    an administrative nightmare, increasing the cost of acceptance and
    slowing down checkout lines in an industry that historically has
    experienced only just more than a 1% profit margin and in which every
    second of delay affects profitability and ultimately the number of
    associates that can be hired and the prices in a store.
        Language was included in the WIC reauthorization legislation in
    2004 directing the Secretary to develop an electronically downloadable
    list of WIC-eligible products on a state by state basis. This has still
    not been completed because of its complexity. A similar type of
    electronic list for SNAP would easily involve 100 times more products
    making it a 100 times more complex. Could it be done? Probably so. But
    if it hasn't been done in the WIC program in spite of a 15 year old
    Congressional directive, it likely would not be easy or inexpensive.
    And at the end of the day, we must ask ourselves what the policy goal
    is that this level of expenditure of time and money would achieve.
        We are truly blessed in this country with the safest, most abundant
    and most affordable food supply in the world. We believe that with that
    blessing comes the responsibility to lift up those individuals in our
    communities who may need an extra hand, with the goal that they might
    provide an extra hand for someone else at another time in the future.
        FMI member companies are the largest contributors to our nation's
    food banks. In 2016, food retailers donated more than 1.3 billion of
    the four billion meals Feeding America provided to families in need.\2\
    We are also constantly developing new ways to enhance this donation
    level by decreasing food waste. In fact, we have spent much of the past
    year working with our supplier partners at the Grocery Manufacturers
    Association (GMA) on efforts to reduce customer confusion regarding
    product date labels, frequently misunderstood to be expiration dates.
    FMI and GMA have just announced an industry-driven voluntary program to
    reduce dozens of terms currently in use on date labels and move (to the
    extent possible) to two primary labels: ``BEST if used by'' to indicate
    quality and ``USE by'' for perishable products that may have potential
    degradation implications.
    ---------------------------------------------------------------------------
        \2\ Source: Feeding America, 2016 Annual Report, Available at
    http://www.feedingamerica.org/about-us/about-feeding-america/annual-
    report/2016-feeding-america-annual-report.pdf, pp.13.
    ---------------------------------------------------------------------------
        I am pleased to answer any questions you may have and to serve as a
    resource to this Committee as you work to make SNAP even more
    efficient. I also have to call out the exceptional FNS retailer
    management division at USDA headed by Andrea Gold. Through hurricanes,
    tornados and floods as well as new store openings or changes in
    ownership, we could not have had a better resource than Andrea and her
    team to help our members through their challenges.

              State-by-State Monthly SNAP Benefit Issuance Schedule
      (Current as of February 13, 2017; Food Marketing Institute Research)
    ------------------------------------------------------------------------
                 State                 Day(s) of SNAP Benefit Distribution
    ------------------------------------------------------------------------
    Alabama                         In August 2013, the state expanded their
                                     distribution dates, moving from the 4th
                                     to the 18th of the month to the 4th
                                     through the 23rd of the month. To
                                     assist in the transition, recipients
                                     received \1/2\ of their benefit on
                                     their original date and \1/2\ on their
                                     new date in the month.
    Alaska **                       The main SNAP issuance is all on the
                                     first day of the month. Smaller
                                     supplemental issuances for new
                                     applicants and late recertifications
                                     occur daily throughout the month.
    Arizona                         SNAP benefits are distributed over the
                                     first 13 days of the month by the first
                                     letter of the recipients' last name.
                                     For example: last names that begin with
                                     A or B are distributed on the first day
                                     of the month; 2nd day of the month: C
                                     and D; etc.
    Arkansas                        Arkansans receive their benefits on
                                     these 8 days: 4th, 5th, 8th, 9th, 10th,
                                     11th, 12th or 13th of each month, based
                                     on the last number of their [S]ocial
                                     [S]ecurity [N]umber.
    California                      California is different in that each
                                     county distributes SNAP to those who
                                     qualify. The payments go out to all
                                     those who qualify between the 1-10 of
                                     the month. Others (i.e., new
                                     applicants) get paid throughout the
                                     month depending on when they were
                                     accepted.
    Colorado                        Food Stamp benefits are distributed on
                                     the first 10 days of the month by the
                                     recipient's last digit of their
                                     [S]ocial [S]ecurity [N]umber.
    Connecticut                     SNAP benefits and cash are distributed
                                     on the first 3 days of the month, by
                                     the first letter of the recipient's
                                     last name. (A-F are available on the
                                     first; G-N on the second and O-Z are
                                     distributed on the third day of the
                                     month.)
    Delaware                        Benefits are made available over 23
                                     days, beginning with the 2nd day of
                                     every month, based on the first letter
                                     of the client's last name.
    District of Columbia            Benefits are made available from the 1st
                                     to the 10th of every month, based on
                                     the first letter of the client's last
                                     name.
    Florida                         All SNAP recipients moved from a 15 day
                                     distribution to a 28 day distribution
                                     in April 2016. In March 2016, to assist
                                     in the new transition, benefits were
                                     ``split.'' Recipients received the
                                     first half of their benefits on their
                                     ``old'' date and received the second
                                     half of their monthly benefits on what
                                     was their ``new'' date going forward.
                                     The ACCESS Florida system assigns
                                     benefit availability dates based on the
                                     case number recipients received when
                                     they became eligible for the SNAP
                                     program.
    Georgia                         In September 2012, SNAP benefits in
                                     Georgia expanded from the 5th to the
                                     14th, and then finally to the current
                                     5th to 23rd of each month, distributed
                                     every other day.
    Hawaii                          Benefits are made available on the 3rd
                                     and the 5th of every month, based on
                                     the first letter of the client's last
                                     name.
    Idaho                           Benefits were previously made available
                                     on the first day of every month. (Prior
                                     to August 2009, benefits were
                                     distributed on 5 consecutive days at
                                     the beginning of each month, but this
                                     was later moved to 1 day.) In 2014,
                                     H.B. 565 was enacted. The bill requires
                                     the state Department of Health and
                                     Welfare to issue SNAP benefits over the
                                     course of 10 consecutive days within a
                                     month. Bonus money received from USDA
                                     paid for the cost of the change.
                                    Currently, and since July 1, 2016,
                                     benefits are distributed over the first
                                     10 days of each month based on the last
                                     number of the birth year of the
                                     recipient; for example, a birthday of 8/
                                     25/64 would receive benefits on the 4th
                                     day of each month.
    Illinois                        SNAP benefits are made available on
                                     these 12 days of the month: 1st, 3rd,
                                     4th, 7th, 8th, 10th, 11th, 14th, 17th,
                                     19th, 21st, and 23rd of every month,
                                     based on a combination of the type of
                                     case and the case name.
    Indiana                         On January 1, 2014, the state
                                     implemented an expanded schedule for
                                     the distribution of benefits during the
                                     fifth through the twenty-third day of
                                     each month, to be issued every-other-
                                     day, based on the first letter of the
                                     recipient's last name. For example: A
                                     or B = benefits available on the 5th;
                                     first Letter of the Last Name is: C or
                                     D = benefits available on the 7th.
                                     Previously, benefits were made
                                     available on the first 10 calendar days
                                     each month. (TANF is issued on the
                                     first of the month.)
    Iowa                            Benefits are made available over the
                                     first 10 calendar days of every month,
                                     based on the first letter of the
                                     client's last name.
    Kansas                          Benefits are made available over the
                                     first 10 calendar days of every month,
                                     based on the first letter of the
                                     client's last name.
    Kentucky                        Benefits are made available over the
                                     first 19 calendar days of every month,
                                     based on the last digit of the client's
                                     case number. This was recently expanded
                                     from the previous 10 day distribution.
    Louisiana                       Benefits are made available between the
                                     1st and the 14th of every month, based
                                     on the last digit of the client's SSN.
                                     (Elderly and disabled benefits are made
                                     available between the 1st and the 4th
                                     of every month.)
    Maine                           Benefits are available the 10th to the
                                     14th of every month based on the last
                                     digit of the recipient's birthday.
    Maryland                        In January 2016, the distribution
                                     schedule was changed. Benefits are now
                                     distributed from the 4th to the 23rd of
                                     every month, based on the first three
                                     letters of the client's last name.
                                     Previously, benefits were distributed
                                     from the 6th through the 15th of the
                                     month. This was accomplished through a
                                     5 month phase-in.
    Massachusetts                   Distribution is based on the last digit
                                     of each recipient's [S]ocial [S]ecurity
                                     [N]umber and distributed over the first
                                     14 days of the month.
    Michigan                        In January 2011, SNAP moved from a 7 day
                                     distribution to the current
                                     distribution, which is from the 3rd to
                                     the 21st, distributed every-other-day,
                                     based on the last digit of the head of
                                     household's recipient identification
                                     number. For example, clients' numbers
                                     ending with 0 will receive food
                                     benefits on the 3rd of the month;
                                     numbers ending with 1, food benefits
                                     will be available on the 5th of the
                                     month.
    Minnesota                       Benefits are staggered over 10 calendar
                                     days, beginning on the 4th through the
                                     13th of every month, without regard to
                                     weekends or holidays, based on the last
                                     digit of the client's case number.
    Mississippi                     Effective February 2017, benefits are
                                     made available from the 4th to the 21st
                                     of every month, based on the last two
                                     digits of the client's case number.
                                     Benefits were previously distributed
                                     from the 5th to the 19th (15 days) of
                                     every month.
    Missouri                        Benefits are made available over the
                                     first 22 days of every month, based on
                                     the client's birth month and last name.
    Montana                         Benefits are distributed over 5 days by
                                     the last number of the recipient's case
                                     number, from the 2nd to the 6th of
                                     every month.
    Nebraska                        Nebraska distributes benefits during the
                                     first 5 calendar days of the month. The
                                     day of distribution is based on the
                                     last digit of the [S]ocial [S]ecurity
                                     [N]umber.
    Nevada **                       In Nevada, food stamp benefits are
                                     issued on the first day of each month.
    New Hampshire **                New Hampshire benefits are available on
                                     the 5th of every month.
    New Jersey                      The monthly SNAP allotment is available
                                     over the first 5 days of the month. The
                                     day is based on the number in the 7th
                                     position of their case number. Some of
                                     the cases still receive their benefits
                                     based on the assignment at the time the
                                     county was converted to EBT. In Warren
                                     County, all benefits are made available
                                     on the 1st of the month.
    New Mexico                      Benefits are made available over 20 days
                                     every month, based on the last two
                                     digits of the SSN.
    New York                        The process is twofold as follows: in
                                     New York City, recipients receive their
                                     SNAP benefits within the first 13
                                     business days of the month, according
                                     to the last digit of their case number,
                                     not including Sundays or holidays. The
                                     actual dates change from 1 month to the
                                     next, so NYC publishes a 6 month
                                     schedule showing the exact availability
                                     dates. For the remainder of New York
                                     State, recipients receive their
                                     benefits within the first 9 days of the
                                     month, also according to the last digit
                                     of their case number, including Sundays
                                     and holidays.
    North Carolina                  Effective July 2011, the state expanded
                                     its 10 day distribution schedule.
                                     Benefits are now distributed from the
                                     3rd to the 21st of every month, based
                                     on the last digit of the primary
                                     cardholder's Social Security Number.
    North Dakota **                 Benefits are made available on the first
                                     day of every month.
    Ohio                            In April 2014, Ohio expanded its SNAP
                                     distribution from the first 10 days of
                                     the month to the first 20 days of the
                                     month, staggered every 2 days. This
                                     only affected SNAP recipients who moved
                                     from one county to another; recipients
                                     who experienced a 1 day or more break
                                     in eligibility; and, all new
                                     recipients. Recipients who were on SNAP
                                     before April 2014 did not see a change.
    Oklahoma                        Benefits are made available from the 1st
                                     to the 10th of every month, based on
                                     the last digit of the client's SNAP
                                     case number.
    Oregon                          SNAP is distributed on the first 9 days
                                     of the month as such: [S]ocial
                                     [S]ecurity [N]umbers ending with ``0''
                                     or ``1'' distribute on the 1st day of
                                     the month, numbers ending with a ``2''
                                     are distributed on the 2nd day of the
                                     month and so on.
    Pennsylvania                    Benefits are made available over the
                                     first 10 business days of every month
                                     (excluding weekends and holidays) based
                                     on the last digit of the client's case
                                     number.
    Rhode Island **                 Benefits are made available on the first
                                     day of every month.
    South Carolina                  In 2012, South Carolina expanded from a
                                     9 day to a 19 day issuance. Current
                                     recipients stayed within the 9 day
                                     distribution, but all new recipients
                                     were given a date that expanded into
                                     the 19 days.
    South Dakota **                 Benefits are made available on the 10th
                                     day of every month.
    Tennessee                       In October 2012, Tennessee expanded
                                     distribution from 10 to 20 days.
    Texas                           Benefits are made available over the
                                     first 15 days of the month, based on
                                     the last digit of the client's SNAP
                                     case number.
    Utah                            Benefits are made available on the 5th,
                                     11th, or 15th of every month, based on
                                     the first letter of the client's last
                                     name: A-G available on the 5th; H-O
                                     available on the 11th; P-Z available on
                                     the 15th.
    Vermont **                      Vermont benefits are available on the
                                     first of every month.
    Virginia                        On September 1, 2012, benefit
                                     distribution was moved from 1 day a
                                     month to 5 days, and then eventually to
                                     the current 1st to the 9th day of every
                                     month, based on the last digits of the
                                     client's case number.
    Washington                      Benefits are staggered over the first 10
                                     days of the month based on the last
                                     digit of the households' assistance
                                     unit number. Weekends and holidays do
                                     not affect the schedule. However,
                                     beginning February 1, 2017, an
                                     expansion of distribution was fully
                                     implemented. Going forward, it will be
                                     the first 20 days of the month.
    West Virginia                   Benefits are made available over the
                                     first 9 days of every month, based on
                                     the first letter of the client's last
                                     name.
    Wisconsin                       Benefits are made available over the
                                     first 15 days of every month, based on
                                     the eighth digit of the client's SSN.
    Wyoming                         SNAP is distributed on the first 4 days
                                     of the month.
    ------------------------------------------------------------------------
    Notes:
    ** States with asterisks are those that only distribute benefits on 1
      day a month. There are seven that still do so. Warren County, New
      Jersey distributes only 1 day a month, although the rest of the state
      distributes over 5 days. Also, there are four states that distribute
      SNAP just 2 or 3 days a month.
    Additional Distribution Information:
    There is no limit on the number of days for stagger. The only condition
      in regulation is that no single household's issuance should exceed 40
      days between issuances.
    Currently, benefit recipients may only be issued their benefits one time
      a month, or within 40 days.

                   Supplemental Nutrition Assistance Program: One-Month Change in Total Participation
                                (Prepared by the Food Research and Action Center (FRAC))
                                              (Data as of January 6, 2017)
    ----------------------------------------------------------------------------------------------------------------
                                                                                            Percent Change September
                  State                     September 2016              October 2016          2016 vs. October 2016
    ----------------------------------------------------------------------------------------------------------------
                       Kentucky                     657,389                    671,628                        2.2
                       Arkansas                     399,538                    403,376                        1.0
                 South Carolina                     746,646                    752,030                        0.7
                          Texas                   3,864,686                  3,891,234                        0.7
                        Wyoming                      33,806                     33,977                        0.5
                         Kansas                     246,179                    247,281                        0.4
                         Nevada                     441,986                    443,138                        0.3
                        Montana                     119,863                    120,065                        0.2
                        Vermont                      78,034                     78,092                        0.1
                  Massachusetts                     771,436                    771,512                        0.0
                     Washington                     952,711                    951,845                       ^0.1
                       Colorado                     467,426                    466,789                       ^0.1
                          Idaho                     176,217                    175,976                       ^0.1
                   Pennsylvania                   1,858,232                  1,855,129                       ^0.2
                        Arizona                     964,979                    963,303                       ^0.2
                    Mississippi                     555,278                    554,225                       ^0.2
                         Hawaii                     173,669                    173,289                       ^0.2
                        Florida                   3,287,446                  3,279,009                       ^0.3
                  West Virginia                     351,391                    350,474                       ^0.3
                        Georgia                   1,688,832                  1,683,945                       ^0.3
                        Indiana                     710,738                    708,476                       ^0.3
                         Oregon                     712,084                    709,684                       ^0.3
                           Iowa                     378,478                    377,126                       ^0.4
                      Minnesota                     465,211                    463,461                       ^0.4
                       New York                   2,950,208                  2,938,258                       ^0.4
                     New Jersey                     857,779                    854,146                       ^0.4
                       Missouri                     770,944                    767,403                       ^0.5
                        Alabama                     830,742                    826,790                       ^0.5
                      Wisconsin                     712,582                    709,134                       ^0.5
                       Oklahoma                     621,462                    618,434                       ^0.5
                     California                   4,252,654                  4,230,399                       ^0.5
                   South Dakota                      95,655                     95,153                       ^0.5
                    Connecticut                     424,431                    422,181                       ^0.5
                       Maryland                     720,566                    716,620                       ^0.5
                       Delaware                     149,158                    148,340                       ^0.5
                  New Hampshire                      95,393                     94,823                       ^0.6
                          Maine                     183,299                    182,095                       ^0.7
                           Ohio                   1,564,498                  1,553,901                       ^0.7
                       Virginia                     811,949                    806,332                       ^0.7
                           Utah                     214,505                    212,903                       ^0.7
                       Michigan                   1,434,550                  1,423,008                       ^0.8
                   North Dakota                      54,622                     54,124                       ^0.9
                      Tennessee                   1,083,880                  1,071,344                       ^1.2
                       Illinois                   1,931,575                  1,907,969                       ^1.2
                 North Carolina                   1,470,079                  1,450,485                       ^1.3
                     New Mexico                     480,493                    473,398                       ^1.5
                   Rhode Island                     168,973                    166,365                       ^1.5
           District of Columbia                     132,308                    126,322                       ^4.5
                               Louisiana          1,042,876                    943,685                       ^9.5
                       Nebraska                     177,912                    153,419                      ^13.8
                         Alaska                      84,825                     71,768                      ^15.4
                                     -------------------------------------------------------------------------------
      Total.........................             43,493,149                 43,215,557                       ^0.6
    ----------------------------------------------------------------------------------------------------------------
    The following areas receive Nutrition Assistance Grants which provide benefits analogous to the Supplemental
      Nutrition Assistance Program: Puerto Rico, American Samoa, and the Northern Mariana[ Islands]. In addition,
      2015 and 2016 data are preliminary and are subject to significant revision.
    * State where October 2016 SNAP data include disaster assistance (D-SNAP).

                    Supplemental Nutrition Assistance Program: One-Year Change in Total Participation
                                (Prepared by the Food Research and Action Center (FRAC))
                                              (Data as of January 6, 2017)
    ----------------------------------------------------------------------------------------------------------------
                                                                                             Percent Change  October
                  State                      October 2015               October 2016         2015 vs.  October 2016
    ----------------------------------------------------------------------------------------------------------------
                               Louisiana            879,541                    943,685                        7.3
                        Montana                     113,462                    120,065                        5.8
                        Wyoming                      32,729                     33,977                        3.8
                          Texas                   3,777,317                  3,891,234                        3.0
                     New Mexico                     460,048                    473,398                        2.9
                         Alaska                      69,996                     71,768                        2.5
                   North Dakota                      53,271                     54,124                        1.6
                         Nevada                     439,498                    443,138                        0.8
                       Delaware                     147,127                    148,340                        0.8
                       Oklahoma                     613,397                    618,434                        0.8
                   Pennsylvania                   1,873,447                  1,855,129                       ^1.0
                   South Dakota                      96,692                     95,153                       ^1.6
                  Massachusetts                     786,492                    771,512                       ^1.9
                       New York                   2,996,649                  2,938,258                       ^1.9
                           Iowa                     384,685                    377,126                       ^2.0
                  West Virginia                     359,001                    350,474                       ^2.4
                        Arizona                     991,567                    963,303                       ^2.9
                       Colorado                     481,892                    466,789                       ^3.1
                    Connecticut                     439,210                    422,181                       ^3.9
                   Rhode Island                     173,148                    166,365                       ^3.9
                       Virginia                     844,204                    806,332                       ^4.5
                      Minnesota                     485,317                    463,461                       ^4.5
                           Utah                     222,981                    212,903                       ^4.5
                           Ohio                   1,629,349                  1,553,901                       ^4.6
                     California                   4,436,189                  4,230,399                       ^4.6
                         Hawaii                     182,226                    173,289                       ^4.9
                       Illinois                   2,007,492                  1,907,969                       ^5.0
                     New Jersey                     899,481                    854,146                       ^5.0
                        Georgia                   1,774,540                  1,683,945                       ^5.1
                        Vermont                      82,364                     78,092                       ^5.2
                 South Carolina                     793,218                    752,030                       ^5.2
                          Maine                     192,404                    182,095                       ^5.4
                       Kentucky                     713,911                    671,628                       ^5.9
                       Michigan                   1,513,129                  1,423,008                       ^6.0
                        Alabama                     881,402                    826,790                       ^6.2
                      Wisconsin                     756,434                    709,134                       ^6.3
                         Oregon                     759,386                    709,684                       ^6.5
                         Kansas                     265,478                    247,281                       ^6.9
                  New Hampshire                     101,894                     94,823                       ^6.9
                          Idaho                     189,385                    175,976                       ^7.1
                       Maryland                     779,303                    716,620                       ^8.0
                      Tennessee                   1,168,238                  1,071,344                       ^8.3
                     Washington                   1,043,008                    951,845                       ^8.7
                       Missouri                     843,876                    767,403                       ^9.1
           District of Columbia                     140,654                    126,322                      ^10.2
                        Indiana                     799,663                    708,476                      ^11.4
                        Florida                   3,708,499                  3,279,009                      ^11.6
                    Mississippi                     628,354                    554,225                      ^11.8
                       Arkansas                     457,380                    403,376                      ^11.8
                 North Carolina                   1,647,808                  1,450,485                      ^12.0
                       Nebraska                     176,363                    153,419                      ^13.0
                                     -------------------------------------------------------------------------------
      Total.........................             45,368,265                 43,215,557                       ^4.7
    ----------------------------------------------------------------------------------------------------------------
    The following areas receive Nutrition Assistance Grants which provide benefits analogous to the Supplemental
      Nutrition Assistance Program: Puerto Rico, American Samoa, and the Northern Mariana[ Islands]. In addition,
      2015 and 2016 data are preliminary and are subject to significant revision.
    * State where October 2016 SNAP data include disaster assistance (D-SNAP).

                      Supplemental Nutrition Assistance Program: Five-Year Change in Participation
                                (Prepared by the Food Research and Action Center (FRAC))
                                              (Data as of January 6, 2017)
    ----------------------------------------------------------------------------------------------------------------
                                                                                             Percent Change  October
                  State                      October 2011               October 2016         2011 vs.  October 2016
    ----------------------------------------------------------------------------------------------------------------
                         Nevada                     351,686                    443,138                       26.0
                     New Mexico                     432,289                    473,398                        9.5
                     California                   3,867,094                  4,230,399                        9.4
                    Connecticut                     396,517                    422,181                        6.5
                       Illinois                   1,831,037                  1,907,969                        4.2
                   Pennsylvania                   1,785,240                  1,855,129                        3.9
                               Louisiana            916,060                    943,685                        3.0
                       Delaware                     144,612                    148,340                        2.6
                         Hawaii                     169,405                    173,289                        2.3
                        Wyoming                      33,252                     33,977                        2.2
                        Florida                   3,225,957                  3,279,009                        1.6
                  West Virginia                     347,064                    350,474                        1.0
                       Maryland                     709,681                    716,620                        1.0
                       Oklahoma                     624,112                    618,434                       ^0.9
                   Rhode Island                     168,694                    166,365                       ^1.4
                        Montana                     121,992                    120,065                       ^1.6
                       Colorado                     480,566                    466,789                       ^2.9
                       New York                   3,060,107                  2,938,258                       ^4.0
                         Alaska                      74,792                     71,768                       ^4.0
                     New Jersey                     890,859                    854,146                       ^4.1
                           Iowa                     398,574                    377,126                       ^5.4
                          Texas                   4,174,348                  3,891,234                       ^6.8
                   South Dakota                     103,282                     95,153                       ^7.9
                  Massachusetts                     838,603                    771,512                       ^8.0
                   North Dakota                      59,383                     54,124                       ^8.9
                        Alabama                     910,034                    826,790                       ^9.1
           District of Columbia                     140,003                    126,322                       ^9.8
                        Georgia                   1,870,781                  1,683,945                      ^10.0
                       Virginia                     896,420                    806,332                      ^10.0
                         Oregon                     798,772                    709,684                      ^11.2
                           Ohio                   1,766,584                  1,553,901                      ^12.0
                       Nebraska                     174,941                    153,419                      ^12.3
                 North Carolina                   1,655,694                  1,450,485                      ^12.4
                      Minnesota                     531,728                    463,461                      ^12.8
                     Washington                   1,095,139                    951,845                      ^13.1
                 South Carolina                     867,258                    752,030                      ^13.3
                    Mississippi                     645,220                    554,225                      ^14.1
                      Wisconsin                     828,362                    709,134                      ^14.4
                        Arizona                   1,138,220                    963,303                      ^15.4
                      Tennessee                   1,280,908                  1,071,344                      ^16.4
                  New Hampshire                     114,744                     94,823                      ^17.4
                        Vermont                      94,604                     78,092                      ^17.5
                       Arkansas                     490,487                    403,376                      ^17.8
                         Kansas                     302,633                    247,281                      ^18.3
                       Missouri                     950,725                    767,403                      ^19.3
                       Kentucky                     842,885                    671,628                      ^20.3
                        Indiana                     901,967                    708,476                      ^21.5
                       Michigan                   1,884,542                  1,423,008                      ^24.5
                          Idaho                     233,194                    175,976                      ^24.5
                           Utah                     285,695                    212,903                      ^25.5
                          Maine                     251,189                    182,095                      ^27.5
                                     -------------------------------------------------------------------------------
      Total.........................             46,224,722                 43,215,557                       ^6.5
    ----------------------------------------------------------------------------------------------------------------
    The following areas receive Nutrition Assistance Grants which provide benefits analogous to the Supplemental
      Nutrition Assistance Program: Puerto Rico, American Samoa, and the Northern Mariana[ Islands]. In addition,
      2015 and 2016 data are preliminary and are subject to significant revision.
    * State where October 2016 SNAP data include disaster assistance (D-SNAP).

                                        Share of Population Participating in SNAP
                                (Prepared by the Food Research and Action Center (FRAC))
                                              (Data as of January 6, 2017)
    ----------------------------------------------------------------------------------------------------------------
                                         Population Estimate         SNAP Participants,
                  State                         (2015)                  October 2016           Share of Population
    ----------------------------------------------------------------------------------------------------------------
                     New Mexico                   2,085,109                    473,398                       22.7
                               Louisiana          4,670,724                    943,685                       20.2
                  West Virginia                   1,844,128                    350,474                       19.0
           District of Columbia                     672,228                    126,322                       18.8
                    Mississippi                   2,992,333                    554,225                       18.5
                         Oregon                   4,028,977                    709,684                       17.6
                        Alabama                   4,858,979                    826,790                       17.0
                        Georgia                  10,214,860                  1,683,945                       16.5
                      Tennessee                   6,600,299                  1,071,344                       16.2
                        Florida                  20,271,272                  3,279,009                       16.2
                       Oklahoma                   3,911,338                    618,434                       15.8
                   Rhode Island                   1,056,298                    166,365                       15.7
                       Delaware                     945,934                    148,340                       15.7
                 South Carolina                   4,896,146                    752,030                       15.4
                         Nevada                   2,890,845                    443,138                       15.3
                       Kentucky                   4,425,092                    671,628                       15.2
                       New York                  19,795,791                  2,938,258                       14.8
                       Illinois                  12,859,995                  1,907,969                       14.8
                   Pennsylvania                  12,802,503                  1,855,129                       14.5
                 North Carolina                  10,042,802                  1,450,485                       14.4
                       Michigan                   9,922,576                  1,423,008                       14.3
                          Texas                  27,469,114                  3,891,234                       14.2
                        Arizona                   6,828,065                    963,303                       14.1
                          Maine                   1,329,328                    182,095                       13.7
                       Arkansas                   2,978,204                    403,376                       13.5
                           Ohio                  11,613,423                  1,553,901                       13.4
                     Washington                   7,170,351                    951,845                       13.3
                       Missouri                   6,083,672                    767,403                       12.6
                        Vermont                     626,042                     78,092                       12.5
                      Wisconsin                   5,771,337                    709,134                       12.3
                         Hawaii                   1,431,603                    173,289                       12.1
                           Iowa                   3,123,899                    377,126                       12.1
                       Maryland                   6,006,401                    716,620                       11.9
                    Connecticut                   3,590,886                    422,181                       11.8
                        Montana                   1,032,949                    120,065                       11.6
                  Massachusetts                   6,794,422                    771,512                       11.4
                   South Dakota                     858,469                     95,153                       11.1
                     California                  39,144,818                  4,230,399                       10.8
                        Indiana                   6,619,680                    708,476                       10.7
                          Idaho                   1,654,930                    175,976                       10.6
                         Alaska                     738,432                     71,768                        9.7
                       Virginia                   8,382,993                    806,332                        9.6
                     New Jersey                   8,958,013                    854,146                        9.5
                       Colorado                   5,456,574                    466,789                        8.6
                         Kansas                   2,911,641                    247,281                        8.5
                      Minnesota                   5,489,594                    463,461                        8.4
                       Nebraska                   1,896,190                    153,419                        8.1
                   North Dakota                     756,927                     54,124                        7.2
                  New Hampshire                   1,330,608                     94,823                        7.1
                           Utah                   2,995,919                    212,903                        7.1
                        Wyoming                     586,107                     33,977                        5.8
                                     -------------------------------------------------------------------------------
      Total.........................            321,418,820                 43,215,557                       13.4
    ----------------------------------------------------------------------------------------------------------------
    The following areas receive Nutrition Assistance Grants which provide benefits analogous to the Supplemental
      Nutrition Assistance Program: Puerto Rico, American Samoa, and the Northern Mariana[ Islands]. In addition,
      2015 and 2016 data are preliminary and are subject to significant revision.
    * State where October 2016 SNAP data include disaster assistance (D-SNAP).

        The Chairman. Thank you.
        Mr. Weidman, 5 minutes.

    STATEMENT OF JOHN WEIDMAN, DEPUTY EXECUTIVE DIRECTOR, THE FOOD
                        TRUST, PHILADELPHIA, PA

        Mr. Weidman. Thank you, Chairman Conaway and Ranking Member
    Peterson, for inviting me to testify. My name is John Weidman.
    I am Deputy Executive Director for The Food Trust, a
    Pennsylvania-based nonprofit working nationally to improve
    access to healthy food.
        This year through a grant from the Robert Wood Johnson
    Foundation, we have launched the Center for Healthy Food
    Access, a national collaborative effort aimed at improving the
    health of children. I am here today to talk about strategies
    The Food Trust has been employing to improve health and
    encourage healthy eating among SNAP participants.
        We believe that to have the greatest impact, it takes a
    comprehensive approach that includes access, education, and
    incentives. In Pennsylvania, we have been improving access by
    opening farmers' markets, working with corner stores to stock
    healthier products, and incentivizing new supermarket
    development. Our team of nutrition educators is providing
    innovative and engaging programing through SNAP-Ed to teach
    children and adults how to eat healthy, cook, and shop on a
    budget. And we run a successful Food Bucks Program that
    provides $2 worth of free produce for every $5 spent with SNAP
    at farmers' markets and a local supermarket.
        Based on research, this comprehensive approach is working.
    A peer-reviewed study published in the journal Pediatrics found
    that our SNAP-Ed program reduced childhood overweight by 50
    percent. More recently, data collected on the BMI of
    Philadelphia children is showing that after decades of rising
    childhood obesity rates, we are finally seeing them drop. The
    strategies that are being implemented, access to healthy food,
    nutrition education, SNAP incentives, are happening all around
    the country and they are not only changing eating habits and
    preventing diet-related disease, but they are also creating
    jobs and spurring economic development.
        I want to share a brief story about Nicole Speller, a
    participant in one of our free 6 week SNAP-Ed cooking workshops
    that take place in over 500 community sites across southeastern
    Pennsylvania. Nicole had decided to make a change and improve
    her health. She also happened to be a fantastic cook, and each
    week she would share the recipe she was learning with her
    neighbors and her church. Upon completing the workshop series,
    Nicole started her own healthy cooking class at her church.
    This is just one example of how SNAP-Ed is helping to create a
    culture of health, and it is happening in innovative ways in
    every state in the nation.
        Of course, understanding how to eat healthy is only part of
    the problem. Accessing healthy food continues to be a challenge
    for millions of Americans. Over the last decade, we have seen
    incredible success through public-private partnerships to
    incentivize grocery stores to meet the need for better access.
    In Pennsylvania, through the leadership of now-Congressman
    Dwight Evans, we have the Pennsylvania Fresh Financing
    Initiative, which funded 88 grocery store projects in urban and
    rural areas, and created 5,000 jobs. Based on this successful
    model, there is now the Federal HFFI and programs in many other
    states.
        Most recently through Governor Kasich's Ohio Fresh Food
    Program, Vinton County, a rural county in southeast Ohio, is
    now slated for a new grocery store to open after the only store
    in the entire county had previously closed. This store will now
    serve seniors and working families who have been unable to
    satisfy the very basic human need of going to the store to buy
    food.
        The same grocers who we work with on HFFI programs also
    stress the need of the importance of nutrition education. It
    makes sense if grocers open a store and stock it with fresh
    produce, they need nutrition education to drive demand for
    healthy food. This is why both access and education go hand-in-
    hand, not only to drive better health outcomes, but also to
    ensure that stores are profitable and serve as economic
    anchors.
        Last, I want to discuss incentives that help make healthy
    choices more affordable. In Philadelphia, 73 percent of Philly
    Food Bucks users report eating more fruits and vegetables, and
    SNAP sales at our farmers' markets have increased 300 percent
    since we launched the program. In Michigan, the Double Up Food
    Bucks Program is available throughout the state at farmers'
    markets and supermarkets, and around the country, hospitals are
    now participating in Veggie  programs, allowing physicians
    to prescribe fruits and vegetables to low-income patients. The
    USDA FINI Program has supported the expansion of these SNAP
    incentive programs. Making healthier food more affordable makes
    it easier for low-income families to make healthier choices.
    Many parents might try putting a plate of fresh carrots in
    front of a toddler. If he doesn't like it, they can just fix
    him something else to eat. But imagine if you only have enough
    money to afford one plate of food. The decision to try new
    things becomes much more difficult.
        In closing, there is no silver bullet to prevent diet-
    related disease like obesity and diabetes, but the costs are
    real. A recent study calculated the cost of diet-related
    disease at $427 billion. A comprehensive approach that combines
    access, nutrition education, incentives, and includes public-
    private partnerships holds the most promise for stemming these
    rising healthcare costs. Congress has moved forward to address
    obesity and diabetes through innovative programs like SNAP-Ed,
    FINI, and HFFI. SNAP is the foundation of this comprehensive
    approach and keeps millions of families from going hungry, and
    it is a critical economic pillar in low-income urban and rural
    communities. Without SNAP, stores would close, jobs would be
    lost, families would go hungry, and it would increase the need
    for food stamps. Quite a vicious cycle, if there ever was one,
    but by expanding access to healthy food, nutrition education,
    and SNAP incentives in the next farm bill, we can improve
    health, increase revenues for American farmers, create jobs in
    urban and rural areas, and control rising healthcare costs.
        Thank you for asking me to testify.
        [The prepared statement of Mr. Weidman follows:]

    Prepared Statement of John Weidman, Deputy Executive Director, The Food
                            Trust, Philadelphia, PA
        Thank you, Chairman Conaway and Ranking Member Peterson, for
    inviting me to testify. My name is John Weidman, and I am the Deputy
    Executive Director of The Food Trust, a Pennsylvania based nonprofit
    that works nationally to improve access to affordable nutritious food.
    We were founded in 1992, and 2017 marks our 25th Anniversary. This
    year, through a grant from the Robert Wood Johnson Foundation we have
    launched the Center for Healthy Food Access: a national collaborative
    effort aimed at improving the health of children in America. I am here
    today to talk about the strategies that The Food Trust has been
    employing to improve health and encourage healthy eating among SNAP
    participants. We believe that to have the greatest impact it takes a
    comprehensive approach that includes improving access, providing
    nutrition education, and utilizing SNAP incentives. In Pennsylvania, we
    have been improving access by opening and maintaining farmers[']
    markets in low-income neighborhoods, working with small food stores to
    stock healthier products, and incentivizing new supermarket development
    through the Pennsylvania Fresh Food Financing Initiative, the national
    model for Healthy Food Financing programs. Our team of dieticians and
    nutrition educators is providing innovative and engaging programming
    through the SNAP-Ed program to teach children and adults how to eat
    healthy, how to cook, and how to shop on a budget. And we run a
    successful Food Bucks program that provides $2 worth of free fruits and
    vegetables for every $5 spent with SNAP at Philadelphia farmers[']
    markets and a local supermarket chain.
        Based on research that has been conducted in Philadelphia, this
    comprehensive approach is working. A peer-reviewed study published in
    the journal Pediatrics found that our SNAP-Ed funded school nutrition
    education program reduced childhood overweight by 50%.\1\ More
    recently, data collected on the Body Mass Index (BMI) of Philadelphia
    children is showing that after decades of rising childhood obesity
    rates, we are finally seeing them drop.\2\ The strategies that are
    being implemented in Pennsylvania--access to healthy food, nutrition
    education, and SNAP Incentives--are happening all around the country,
    and they are not only changing eating habits and preventing diet-
    related diseases like heart disease and diabetes, but they are also
    creating jobs and spurring economic development in struggling urban and
    rural communities.
    ---------------------------------------------------------------------------
        \1\ Foster, G.D., Sherman, S., Borradaile, K.E., Grundy, K.M.,
    Veur, S.S., Nachmani, J., Karpyn, A., Kumanyika, S., Shults, J. (2008).
    A Policy-Based School Intervention to Prevent Overweight and Obesity.
    Pediatrics, 121(4). doi:10.1542/peds.2007-1365.
        \2\ Robbins, J.M., Mallya G., Wagner A., Buehler J.W. Prevalence,
    Disparities, and Trends in Obesity and Severe Obesity Among Students in
    the School District of Philadelphia, Pennsylvania, 2006-2013. Prev.
    Chronic. Dis. 2015; 12; 150185. DOI; http://dx.doi.org/10.5888/
    pcd12.150185.
    ---------------------------------------------------------------------------
        I want to share a brief story about Nicole Speller, a participant
    in one of our free 6 week SNAP-Ed cooking workshops that take place in
    over 500 community sites: libraries, community centers, and churches
    across southeastern Pennsylvania. Nicole had decided to make a change
    and improve her health. She also happened to be a fantastic cook, and
    each week she would share the recipes and nutrition tips she was
    learning with her neighbors and her church group. Upon completing the
    workshop series, Nicole started her own healthy cooking class at her
    church. This is just one example of how SNAP-Ed is helping to create a
    culture of health, and it is happening in innovative ways in every
    state in the nation. In addition to our cooking workshops, we also use
    Share Our Strength's excellent Cooking Matters program to teach how to
    shop healthy in the supermarket and make healthy choices on a budget.
    We also work directly with thousands of school children each year to
    teach them about food, farming, and eating healthy.
        Of course, understanding how to eat healthier is only part of the
    problem for many SNAP participants. Accessing healthy food continues to
    be a challenge for millions of Americans. Over the last decade, we have
    seen incredible success through public-private partnerships to
    incentivize grocery stores, farmers['] markets, and other healthy food
    retail solutions to meet the need for better access. In Pennsylvania,
    thanks in large part to now-Congressman Dwight Evans, our Fresh Food
    Financing Initiative funded 88 grocery store projects in urban and
    rural areas and created 5,000 jobs. Based on this successful model, we
    now have the Federal Healthy Food Financing Initiative (HFFI) and
    programs in New York, Illinois, Mississippi, Colorado, and other
    states. Most recently, through Governor Kasich's Ohio Fresh Food
    Program, Vinton County--a rural county in southeast Ohio--is now slated
    for a new grocery store to open after the only store in the county had
    previously closed. This store will now serve seniors and working
    families who have been unable to satisfy the very basic human need of
    going to the store to buy food.
        While the HFFI model was developed working directly with grocers
    who want to improve access in under-served areas, they also stress the
    importance of nutrition education. It makes sense: if grocers open a
    store and stock it with fresh produce, they need nutrition education
    programs to drive demand for purchasing healthy food. For this reason,
    some grocers are now hiring registered dieticians to guide consumers in
    the store. Grocers understand the need to improve eating habits, but at
    the end of the day they cannot stock food that does not sell. This is
    why both access and education go hand-in-hand, not only to drive better
    health outcomes, but also to ensure that stores are profitable and
    serve as economic anchors for small towns and urban neighborhoods.
        In addition to the vital role the Federal Government plays,
    partnerships with the private sector are a critical component of the
    solution. Consumer demand for healthy products is growing, and many
    operators and manufacturers are shifting their product portfolios in a
    healthier direction. At the same time, retailers are developing
    innovative ways to sell these products. Grocers, bodega owners, and
    farmers have been indispensable partners in all of the efforts I have
    been discussing. We are partnering with food manufacturers such as
    Campbell Soup Company, which is spearheading a 10 year initiative in
    Camden, New Jersey, to improve health and reduce food insecurity. GSK
    (GlaxoSmithKline), another corporate partner, is funding a city-wide
    initiative called Get HYPE Philly! that is focused on youth leadership
    development, healthy eating and exercise, and education and job skills.
    We need more of these innovative partnerships in the years ahead.
        Last, I want to discuss incentives that encourage SNAP participants
    to try healthier foods and that make healthier choices more affordable.
    As I mentioned, The Food Trust launched our Philly Food Bucks program
    in 2011, and it has been a huge success. Seventy-three percent of
    Philly Food Bucks users report eating more fruits and vegetables, and
    SNAP sales at farmers['] markets have increased 300% since the start of
    the program. Based in Michigan, the Fair Food Network has greatly
    expanded their Double Up Food Bucks program in farmers' markets and
    grocery stores across the country. Wholesome Wave, based in
    Connecticut, is bringing SNAP incentives to health care, allowing
    physicians to ``prescribe'' fruits and vegetables to low-income
    patients for redemption at local farmers['] markets. In 2014, USDA
    launched FINI, the Food Insecurity Nutrition Incentive program, which
    has supported research, piloting, and expansion of SNAP incentive
    programs. Making healthier food more affordable makes it easier for
    low-income families to take risks when trying new foods. Many parents
    might try putting a plate of fresh carrots and peas in front of a
    toddler. If he sticks out his tongue and says yuck, they can just fix
    him something else to eat. (This is based on personal experience. I
    have a 3 year old). But imagine if you only have enough money to afford
    one plate of food--the decision to try new things becomes much more
    difficult.
        In closing, there is no silver bullet to prevent diet-related
    diseases like obesity and diabetes, but the costs are real. A recent
    study by the Milken Institute calculated the direct medical costs for
    diet-related disease in 2014 at $427.8 billion.\3\ Soda and sugary
    drinks are a big driver of the problem and Congress has moved forward
    to address obesity and diabetes through innovative programs like SNAP-
    Ed, FINI and HFFI. A comprehensive approach that combines access,
    nutrition education, and SNAP incentives holds the most promise for
    stemming these rising healthcare costs and building new, healthier
    habits. SNAP is the foundation of this comprehensive approach. It keeps
    millions of families from going hungry and is a critical economic
    pillar for lower income urban and rural communities. Without SNAP,
    stores would close, jobs would be lost, more families would drop into
    poverty, and more people would need food stamps. A vicious cycle, if
    there ever was one. By expanding access to healthy food, nutrition
    education, and incentives in the next farm bill we can improve health,
    increase revenues for American farmers, create jobs in urban and rural
    areas, and control rising healthcare costs.
    ---------------------------------------------------------------------------
        \3\ Waters, H., & DeVol, R. (2016). Weighing Down America: The
    Health and Economic Impact of Obesity. Retrieved from Milken Institute:
    http://assets1c.milkeninstitute.org/assets/Publication/ResearchReport/
    PDF/Weighing-Down-America-WEB.pdf.
    ---------------------------------------------------------------------------
        Thank you for the opportunity to testify, I look forward to your
    questions.

        The Chairman. Thank you very much.
        Dr. Wansink?

            STATEMENT OF BRIAN WANSINK, Ph.D., JOHN S. DYSON
              PROFESSOR OF MARKETING AND DIRECTOR, CORNELL
               UNIVERSITY FOOD AND BRAND LAB, ITHACA, NY

        Dr. Wansink. Thank you for giving me the opportunity to
    present my perspective on the pros and cons of restricting SNAP
    purchases. I will be addressing three questions today: first,
    what happens when food purchases are restricted; second, who
    has the most potential to shop healthier; and third, how can
    this be best encouraged? Thank you.
        First, as a behavioral scientist and Director of the
    Cornell Food and Brand Lab, I focus on changing behaviors in a
    practical way. But as former USDA Executive Director from the
    Center for Nutrition Policy and Promotion, the Dietary
    Guidelines, I focused on changing eating behaviors in a
    scalable way. What I want to emphasize is our best and worst
    eating habits start in the grocery store. If we can change what
    people bring home, we change what they eat.
        Now how do food restrictions influence people? Well, I have
    two exhibits. First, how does shopping behavior change after
    versus before people receive SNAP benefits? Well, there is a
    new 6 year study of SNAP recipients in Rhode Island that shows
    that spending on SNAP eligible products went up once they
    received the benefits, but the general purchase of SNAP
    ineligible benefits, the soft drinks and things like this, did
    not go down. What they do is they trace some of this to people
    buying more convenient products when they get SNAP benefits.
        Exhibit 2 looks at incentives. When we specifically
    financially incentivize shoppers to buy more fruits and
    vegetables, what happens? In one 6 month study of 208 families
    in Utica, New York, we gave shoppers ten percent more money
    back in a debit card when they bought healthy foods like fruits
    and vegetables. When low-income shoppers were given this, they
    spent $33 more per week with $12 of that being on healthier
    foods, but $21 being on less healthy foods such as snack foods.
    The money they saved on healthy foods, they also spent on less
    healthy foods.
        Now these are both preliminary reports. They do show that
    when people are incentivized to buy healthy foods, they do, but
    they also buy less healthy foods.
        What I want to look at is who has the biggest potential to
    eat better? Now we make a mistake when we only look at all SNAP
    recipients as a homogenous group of shoppers. Instead, people
    are in a pyramid like this. It goes in a hierarchy of healthy
    disposition. If you see something like this, there are people
    at the top who are very vigilant shoppers. These are people who
    know the number of calories in a Coke, the number of calories
    in Fritos. They care about what they eat. No change is going to
    influence what they buy. At the very bottom, you have health
    disinterested shoppers. Again, these are people who are either
    resigned or they are disinterested in shopping healthier, and
    again, no change is going to have much impact on what they buy.
    Who we can influence is this middle group, the health
    predisposed shoppers, because these are the people who want to
    eat better, but they just need the help and the nudge to do so.
        Now if we look at what is going to work best for these
    health predisposed shoppers, the question is how do we do this?
    Will the restriction work? And second, will something else work
    better?
        Now I said earlier it is not clear whether the hassles of
    related retailing shopper dignity would merit a change, but
    there might be a solution to this. So for instance, one option
    would be to give a SNAP recipient an option. They can use 100
    percent of their SNAP benefits to purchase whatever they
    wanted, or if they agreed themselves to restricting--let's just
    say to produce. Maybe they get a bonus. They get 125 percent
    more. Now we are not sure how this would work, and it does
    merit testing as mentioned earlier, but a second option is far
    easier to implement and can be scaled very quickly. It involves
    providing simple guidelines to retailers, maybe even a
    certification on how to make it easier for SNAP shoppers, all
    shoppers, to buy healthier foods by making it more convenient,
    attractive, and normal to do so.
        There is a precedent for this healthier by design shopping
    program that is beginning to work in food deserts. Last year,
    the National Association of Convenience Stores developed and
    launched a new tool kit of evidence-based tactics that could be
    used to increase the sales of healthier foods. It is one reason
    why when you buy gas, you often find a basket of bananas next
    to the cash register. That is because of this program. These
    are small, easy changes to make, and they are win-win benefits
    for both retailers, SNAP recipients, and us. But systematically
    giving other retailers the guidance on how to make these
    healthy nudges and credit them for doing so would benefit SNAP
    shoppers just as well as it is benefitting us.
        Another way this retail program is underway is the Nordic
    solution to sustainability and obesity, it is related to the
    EAT Foundation and GreeNudge. And over there, supermarkets are
    being guided to make small changes in signage, service, and
    structure, and it has increased fruits and vegetables
    consumption for that.
        Now in summary, and this is a third alternative, but I will
    give three things. SNAP recipients get benefits and restricted
    benefits, but they do not necessarily buy only healthier foods.
    They buy everything else. Second, there are three segments of
    shoppers; and third, there are different ways to best encourage
    this health predisposed segment.
        Thanks for this opportunity to talk with you.
        [The prepared statement of Dr. Wansink follows:]

    Prepared Statement of Brian Wansink, Ph.D., John S. Dyson Professor of
    Marketing and Director, Cornell University Food and Brand Lab, Ithaca,
                                       NY
        Good morning, Chairman Conway, Ranking Member Peterson, Members of
    the Committee: Thank you for giving me the opportunity to present my
    perspective on the pros and cons of restricting SNAP purchases. I will
    be addressing three questions today: (1) What happens when food
    purchases are restricted? (2) Who has the most potential to shop
    healthier, and (3) How can this be best encouraged?
    When Happens When Food Purchases are Restricted?
        As a behavioral scientist and Director of the Cornell Food and
    Brand Lab, I focus on changing eating behaviors in a practical way. As
    the former USDA Executive Director for the Center for Nutrition Policy
    and Promotion--the Dietary Guidelines--I focused on changing eating
    behaviors in a scalable way.
        When Food Stamps were first introduced, their purpose was to fill
    bellies with calories. Seventy years later we have another important
    opportunity. Fill bellies with the right calories. With increasing
    health care costs threatening the future of the American economy, one
    place we can begin turning this around--starting tonight--is with what
    we eat in our homes. Of all the health concerns that face Americans,
    diet-related disease and obesity are the ones that we can tackle most
    immediately.
        What is critical to remember, however, is this: Our best and worse
    eating habits start in the grocery store. If we can change what people
    bring home from the grocery store or market, we can change how they
    eat.
        Do people shop differently when they're given extra money--such as
    a rebate or SNAP benefits? Two preliminary studies give us some insight
    here.
        Exhibit No. 1. How does shopping behavior change after versus
    before people receive SNAP benefits? A new 6 year study of SNAP
    recipients in Rhode Island showed that the spending on SNAP eligible
    products went up once they received benefits, but the general purchase
    of SNAP ineligible benefits did not go down (Hastings and Shaprio
    2017). Further unpublished analyses (learned through conversation) also
    suggest that purchase of convenient-to-eat foods goes up once a person
    receives SNAP benefits. They trade their SNAP benefits for convenience.
        Exhibit No. 2 looks at incentives. What if we specifically
    financially incentivize shoppers to buy more fruits and vegetables? In
    one 6 month study of 208 families in Utica, NY, we gave shoppers a 10%
    bonus--10% more money back on their debit card--when they bought
    healthy foods such as fruits and vegetables. When low-income shoppers
    (poverty ratio less than 1.3) were given this extra money as a subsidy,
    they spent $33 more per week on healthier foods--including fruits and
    vegetables, but they also spent $21 more per week on less healthy
    foods, such as snack foods (Cawley, et al., 2016). Some of the money
    they saved on the healthy foods, they appeared to spend on less healthy
    foods.
        Although both of these are single, preliminary white papers in the
    National Bureau of Economic Research, they point at the idea that extra
    money--in the form of SNAP benefits or subsidies--changes the way
    people shop. They do buy more of the healthy, incentivized foods, but
    they also buy more of the less healthy foods. They just use their own
    money instead.
        A key question, however, is ``Who has the most potential to eat
    better?''
    The Hierarchy of Health Predisposition
        When I was the Executive Director of the USDA's Center for
    Nutrition Policy and Promotion, I saw people off-handedly dismiss
    potentially useful ideas for new initiatives if they would not benefit
    100% of the population under discussion.
        In trying to solve difficult problems, it is very useful to not
    view 100% of all people--such as all SNAP benefit recipients--as the
    same. Some people already eat very healthy, some people do not want to
    eat healthy, and some people want to, but they need help. When trying
    to predict how a SNAP shopper would respond to a restriction, it is
    useful to understand that there is a Hierarchy of Health
    Predisposition.
        Not all SNAP shoppers shop alike and we can view them--like all
    shoppers--on how predisposed they are to wanting to make a healthier
    shopping decision. We can view them as belonging to one of three fluid
    groups within a Hierarchy of Health Predisposition. The top segment of
    this hierarchy are Health Vigilant shoppers. They are highly informed,
    conscious of calories, and they are influenced by nutrition
    information. At the bottom extreme, Health Disinterested shoppers have
    little interest in changing their eating choices because of either the
    effort, sacrifice, or perceived futility of doing so. The segment in
    the middle are the Health Predisposed shoppers. They would prefer to
    make healthier food choices, but they have difficulty consistently
    doing so unless it involves very little sacrifice on their part. This
    Predisposed segment is the one that buys the 100 calorie packages of
    snacks and the sugar-free yogurt. For all people, this segment is
    larger on New Years Day than it was in December; it was larger this
    past Monday morning than it was during the prior Friday night's
    shopping trip.
    The Hierarchy of Health Predisposition

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

        One reason nutrition guidance systems (such traffic lights or
    Guiding Stars) have had only modest influences on the sales of healthy
    food may be because they mainly resonate with only the top of the
    Hierarchy. Health Disinterested shoppers ignore these programs, and
    Heath Predisposed shoppers inconsistently follow them. If the only
    segment they reach are the Vigilant shoppers, interventions like this
    will have hardly any impact on sales since this segment is already
    shopping in a healthy way.
        This is important because SNAP restrictions may not have the same
    impact on healthy shopping behavior that we desire. The Health Vigilant
    shoppers will already be shopping healthy, and they do not need them.
    At the other extreme, Healthy Disintereseted shoppers might simply
    rechannel their own money toward what they would have bought anyway.
    What this importantly raises is the question as to whether there other
    ways to guide SNAP shoppers to eat healthier--particularly those in
    this middle section.
    Non-Restrictive Options to Encourage Healthier SNAP Shopping Patterns
        One extreme way to try and encourage SNAP shoppers to eat better is
    to restrict what they can purchase. Some people might say this is not
    practical for retailers. Other people might say this is not respectful
    of the dignity or free choice of SNAP shoppers.
        What is not asked when it comes to restricting SNAP purchases is,
    ``Will it even work?'' As just noted, for the Health Vigilant, it
    wouldn't have any impact because they already eat healthy. At the other
    end, for the Health Disinterested, it may not work because they will
    simply spend their cash on what they would have otherwise bought
    anyway. There are two open questions: (1) Will a restriction work with
    the Health Predisposed--this middle segment, and (2) Would something
    else work better?
        First, as said earlier, it is not clear if the retail hassles and
    the shopper dignity and free choice issues related to a restriction
    would merit a change. There may be a solution to this, however. Suppose
    a nutritionally predisposed shopper had one of two options. One option
    would be to have 100% of their SNAP benefits to purchase whatever they
    wanted (foods that are currently eligible). A second option would be
    that they could agree to self-restrict themselves from buying certain
    foods in exchange for, say, 125% of their SNAP benefits. In effect, if
    they agreed to restrict their SNAP benefits to buy only predetermined
    healthy foods--say fruits, vegetables, whole grains, lean meat and
    dairy--they would get more 25% (or however much) more buying power.
    Such a system would still give people an option--they could either
    choose the 100% unrestricted plan or they could choose the 125%
    restricted plan--and it would help those who wanted to eat better to
    more easily do so. Of course, we have no evidence of how effective this
    would be in practice, but it is an idea that merits pilot testing. It
    lets people be free to choose while also providing them an incentive to
    eat better. The SNAP recipient chooses what they want.
        A second option is far easier to implement and can be scaled
    quickly. It involves providing simple guidelines to retailers--perhaps
    even a certification--on how to make it easier for SNAP shoppers (and
    all shoppers) to buy healthier foods by making it more convenient,
    attractive, and normal (the CAN framework) to do so. This notion of
    ``Healthy Shopping by Design'' is fashioned off of the Smarter
    Lunchroom Movement which is a USDA-sponsored initiative that trains
    food service directors on the dozens of ways they can guide students
    toward making healthier selections in the school lunchroom (Hanks, et
    al., 2013). The 66-point scorecard shows whether the way they set up,
    serve, and promote foods make kids fit or fat. For instance, a score of
    25 out of 66 indicates there is easy room for improvement, but also
    points at the 41 other changes they could make (Appendix).
        There is precedent for a Healthy Shopping by Design program that is
    beginning to work in food deserts. In 2016, the National Association of
    Convenience Stores, working with the Cornell Food and Brand Lab
    developed and launched a new toolkit titled, ``Ideas That Work to Grow
    Better-for-You Sales,'' and they include evidence-based tactics to
    increase the sales of healthier foods. It is one reason you can often
    buy a banana when you buy gas--they are sitting right next to the cash
    register (Lenard and Schare 2016). These are small easy changes to
    make, but they are win-win and benefit both retailers and (food desert)
    shoppers.
        Systematically giving other retailers the guidance of how to make
    healthy nudges, and the credit for doing so could change healthy
    shopping for SNAP shoppers just as the Smarter Lunchroom Movement is
    changing lunchtime for school children (Wansink 2017; 2014). In Norway,
    this is currently underway as a Nordic Solution to sustainability and
    obesity (which is related to the EAT Foundation and GreeNudge). Over
    there, supermarkets are being guided how to make small changes to the
    signage, structure, and service, and the results have been increased
    fruit and vegetable sales for all (Wansink, Karvold, and Tran 2017).
    Summary
      1.  Giving SNAP recipients more benefits or restricted benefits may
                not lead them to only buy healthier food (they will also
                buy more convenient foods and less healthier foods).

      2.  There are three segments of shoppers: the Health Vigilant, the
                Health Predisposed, and the Health Disinterested. The
                easiest win will be to focus efforts programming on the
                Health Predisposed segment.

      3.  There are at least two ways to try and influence the Health
                Predisposed segment. One might be giving them 100% of their
                unrestricted benefits, or 130% of restricted benefits. A
                second would be to work with retailers to show them how
                they can be even more profitable by making it convenient,
                attractive, and normal for SNAP shoppers--indeed all
                shoppers--to shop healthier. Just as this program is
                responsible for putting bananas by the convenience store
                checkouts, and more vegetables in Norwegian shopping carts,
                it could be successful on a larger scale with supermarkets
                and other stores accepting SNAP benefits.

        Thank you for this opportunity to share my perspective with you.
    References
        Cawley, John, Andrew S. Hanks, David R. Just, and Brian Wansink
    (2016), ``Incentivizing Nutrition Diets: A Field Experiment of Relative
    Price Changes and How They Are Framed,'' National Bureau of Economics
    Research, Working paper 21929.
        Hanks, Andrew S., David R. Just, and Brian Wansink (2013),
    ``Smarter Lunchrooms Can Address New School Lunchroom Guidelines and
    Childhood Obesity,'' Journal of Pediatrics, 162: 4 (April), 867-869.
        Hastings, Justine and Jesse M. Shapiro (2017), ``How are SNAP
    Benefits Spent? Evidence from a Retail Panel,'' National Bureau of
    Economic Research, Working paper.
        Lenard, Jeff and Carolyn Schnare (2016), ``Eight Low-Cost--and
    Proven--Tactics for How C-Store Operators and Grow Their Healthy
    Offer,'' NACS Magazine, August, 30-36.
        NACS (2016), ``NACS Toolkit Helps C-Stores Grown Better-for-You
    Sales,'' May 26 http://www.nacsonline.com/Media/Daily/Pages/
    ND0526161.aspx#.WKPMM
    neZNPs.
        Wansink, Brian (2014), Slim by Design--Mindless Eating Solutions
    for Everyday Life, New York, NY: William Morrow.
        Wansink, Brian, Knut Karevold, and Huy Tran (2017), ``Supermarket
    Interventions to Sell Sustainable Fruits and Vegetables: The Nordic
    Solution to Healthier Shopping,'' Cornell Food and Brand Lab, working
    paper.
        Wansink, Brian (2017), ``Healthy Profits: An Interdisciplinary
    Retail Framework that Increases the Sales of Healthy Foods, Journal of
    Retailing, in press.
        Appendix. Example of Scorecards that Encourage Healthier Choices

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

                                   Exhibit 1
    How Are SNAP Benefits Spent? Evidence from a Retail Panel
    Justine S. Hastings, Jesse M. Shapiro
    Working Paper 23112
    http://www.nber.org/papers/w23112

        This work has been supported (in part) by awards from the Russell
    Sage Foundation, the Robert Wood Johnson Foundation's Policies for
    Action program, and the Laura and John Arnold Foundation. Any opinions
    expressed are those of the author(s) alone and should not be construed
    as representing the opinions of these Foundations. This project
    benefited from the suggestions of Ken Chay, Raj Chetty, David Cutler,
    Amy Finkelstein, Xavier Gabaix, Peter Ganong, Ed Glaeser, Nathan
    Hendren, Hilary Hoynes, Larry Katz, David Laibson, Kevin Murphy, Mandy
    Pallais, Devin Pope, Diane Whitmore Schanzenbach, and Andrei Shleifer,
    from audience comments at Brown University, Clark University, Harvard
    University, the Massachusetts Institute of Technology, and the
    Quantitative Marketing and Economics Conference, and from comments by
    discussant J.P. Dube. We thank our dedicated research assistants for
    their contributions. The views expressed herein are those of the
    authors and do not necessarily reflect the views of the National Bureau
    of Economic Research.
        At least one co-author has disclosed a financial relationship of
    potential relevance for this research. Further information is available
    online at http://www.nber.org/papers/w23112.ack.
        NBER working papers are circulated for discussion and comment
    purposes. They have not been peer-reviewed or been subject to the
    review by the NBER Board of Directors that accompanies official NBER
    publications.
        2017 by Justine S. Hastings and Jesse M. Shapiro. All rights
    reserved. Short sections of text, not to exceed two paragraphs, may be
    quoted without explicit permission provided that full credit, including
     notice, is given to the source.
    Abstract
        We use a novel retail panel with more than 6 years of detailed
    transaction records to study the effect of participation in the
    Supplemental Nutrition Assistance Program (SNAP) on household spending.
    We frame our approach using novel administrative data from the state of
    Rhode Island. The marginal propensity to consume SNAP-eligible food
    (MPCF) out of SNAP benefits is 0.5 to 0.6. The MPCF out of cash is much
    smaller. These patterns obtain even for households for whom SNAP
    benefits are economically equivalent to cash in the sense that benefits
    do not cover all food spending. We reject the hypothesis that
    households respect the fungibility of money in a semiparametric setup.
    A post-hoc model of mental accounting rationalizes these facts and
    others.

    Justine S. Hastings,                 Jesse M. Shapiro,
    Brown University,                    Economics Department,
    Department of Economics,             Box B,
    64 Waterman Street,                  Brown University,
    Providence, RI 02912,                Providence, RI 02912,
    and NBER,                            and NBER,
    justine_hastings@brown.edu;          jesse_shapiro_1@brown.edu.

        A online appendix is available at http://www.nber.org/data-
    appendix/w23112.
    1  Introduction
        This paper studies how receipt of benefits from the Supplemental
    Nutrition Assistance Program (SNAP) affects household spending. SNAP is
    of special interest to economists for at least two reasons. First, the
    program is economically important: it is the second-largest means-
    tested program in the United States after Medicaid (Congressional
    Budget Office 2013), enrolling 19.6 percent of households in fiscal
    2014.\1\
    ---------------------------------------------------------------------------
        \1\ There were 22,743,911 participating households in fiscal 2014
    (FNS 2016a) and 116,211,092 households in the U.S. on average from
    2010-2014 (U.S. Census Bureau 2016).
    ---------------------------------------------------------------------------
        Second, the program's stated objectives sit awkwardly with economic
    theory. On signing the bill to implement the predecessor Food Stamp
    Program, President Lyndon Johnson declared that the program would
    ``enable low-income families to increase their food expenditures''
    (Johnson 1964). The Food and Nutrition Service of the USDA says that
    SNAP is important for ``helping low-income families put food on the
    table'' (FNS 2012). Yet although SNAP benefits can only be spent on
    food, textbook demand theory (Mankiw 2000; Browning and Zupan 2004)
    predicts that, for the large majority of SNAP recipients who spend more
    on food than they receive in benefits,\2\ SNAP benefits are
    economically equivalent to cash.\3\ As typical estimates of the
    marginal propensity to consume food (MPCF) out of cash income are close
    to 0.1,\4\ the textbook treatment says that SNAP benefits should mostly
    subsidize non-food spending.
    ---------------------------------------------------------------------------
        \2\ Hoynes, et al., (2015) find that spending on food at home is at
    or above the SNAP benefit level for 84 percent of SNAP recipient
    households. Trippe and Ewell (2007) report that 73 to 78 percent of
    SNAP recipients spend at least ten percent more on food than they
    receive in SNAP benefits.
        \3\ Consider a household with monthly income y and SNAP benefits b.
    If the household spends  on SNAP-eligible food then she has
    y^max (0,^b) available to buy other goods. Let U
    (,n) denote the household's strictly monotone,
    differentiable, and strictly quasiconcave utility function defined over
    the dollar amount of SNAP-eligible food consumption  and
    other consumption n. Suppose that there is a solution
    * = arg max  U
    (,y^max(0,^b)) such that *>b.
    The first-order necessary condition for this program is a necessary and
    sufficient condition for a solution to the program max fU
    (;y+b^) in which the benefits are given in cash.
    Therefore * = arg max
    fU(,y+b^).
        \4\ Castner and Mabli (2010) estimate an MPCF out of cash income of
    0.07 for SNAP participants. Hoynes and Schanzenbach (2009) estimate an
    MPCF out of cash income of 0.09-0.10 for populations with a high
    likelihood of participating in the Food Stamp Program.
    ---------------------------------------------------------------------------
        Estimating the effect of SNAP benefits on spending is challenging
    because it requires good measurement of household spending and suitably
    exogenous variation in program participation or benefits. Survey-based
    measures of household spending are error-prone and sensitive to the
    mode of elicitation (Ahmed, et al., 2006; Browning, et al., 2014;
    Battistin and Padula 2016). Important components of SNAP eligibility
    and benefit rules are set nationally, and major program changes have
    often coincided with other policy changes or economic shocks
    (Congressional Budget Office 2012), making it difficult to separate the
    effect of SNAP from the effect of these contextual factors.
        In this paper we analyze a novel panel consisting of detailed
    transaction records from February 2006 to December 2012 for nearly \1/
    2\ million regular customers of a large U.S. grocery retailer. The data
    contain information on method of payment, including whether payment was
    made using a government benefit card. We use the panel to study the
    effect of transitions on and off of SNAP, and of legislated changes in
    SNAP benefits, on household spending.
        We adopt three approaches to isolating the causal effect of SNAP on
    spending: a panel event-study design using trends prior to SNAP
    adoption to diagnose confounds, an instrumental variables design
    exploiting plausibly exogenous variation in the timing of program exit,
    and a differences-in-differences design exploiting legislated changes
    to benefit schedules.
        We motivate each of these approaches with findings from novel Rhode
    Island administrative data. The data show that household income and
    size change in the months preceding a household's transition on to
    SNAP, motivating our panel event-study design. The data also show that
    SNAP spell lengths are typically divisible by 6 months because of the
    recertification process, motivating our instrumental-variables design.
    National administrative records show discrete jumps in SNAP benefits
    associated with legislated program changes in 2008 and 2009, motivating
    our differences-in-differences design.
        By construction our retail panel includes purchases at a single
    grocery chain. Rhode Island administrative data show that it is
    possible to reliably infer transitions on to SNAP using data from a
    single grocery chain, by focusing on consecutive periods of non-SNAP
    use followed by consecutive periods of SNAP use. Additional data,
    including a survey conducted by the retailer, show that SNAP
    participation is only weakly related to a household's choice of
    retailer.
        Graphical analysis of our panel event-study design shows that after
    adoption of SNAP, households in the retailer panel increase SNAP-
    eligible spending by about $110 a month, equivalent to a bit more than
    \1/2\ of their monthly SNAP benefit. There is no economically
    meaningful trend in SNAP-eligible spending prior to adoption of SNAP.
    Graphical analysis of our instrumental-variables and differences-in-
    differences designs also implies an MPCF out of SNAP in the range of
    0.5 to 0.6.
        We exploit large swings in gasoline prices during our sample period
    to estimate the MPCF out of cash for the retail panelists. We observe
    gasoline spending at the retailer and confirm that increases in
    gasoline prices lead to significant additional out-of-pocket expenses
    for panelist households. We estimate that every $100 per month of
    additional gasoline spending reduces food spending by less than $10, in
    line with past estimates of the MPCF out of cash for the SNAP-recipient
    population (e.g., Castner and Mabli 2010) but far below the estimated
    MPCF out of SNAP.
        Turning to SNAP-ineligible spending at the retailer, we estimate an
    MPC of 0.02 out of SNAP benefits, and a (statistically
    indistinguishable) MPC of 0.04 out of cash.
        We develop an economic model of food spending by households for
    whom SNAP benefits do not cover all food spending and are therefore
    fungible with cash. We show how to test the hypothesis of fungibility,
    allowing for the endogeneity of cash income and SNAP benefits, and for
    the possibility that different households' consumption functions do not
    share a common parameterization or parametric structure. Our tests
    consistently reject the null hypothesis that households treat SNAP
    benefits as fungible with other income.
        We extend our economic model to include mental accounting following
    the approach in Farhi and Gabaix (2015). The extension is post-hoc. By
    design, it rationalizes the finding that the MPCF is greater out of
    SNAP benefits than out of cash. It also predicts that, following SNAP
    receipt, households will allocate relatively less effort to bargain-
    hunting in the food domain than in the non-food domain. We find that
    SNAP receipt reduces the store-brand share of expenditures and the
    share of items on which coupons are redeemed, but only for SNAP-
    eligible foods.
        We also discuss the responses from qualitative interviews conducted
    at a food pantry as part of a Rhode Island pilot proposal to modify
    SNAP benefit timing. Respondents were not scientifically sampled, and
    it is not appropriate to derive general conclusions from these
    interviews. Nevertheless, we find that they provide useful context for
    our analysis.
        This paper contributes to a large literature on the effects of SNAP
    and the predecessor Food Stamp Program on food spending, recently
    reviewed by Bitler (2015) and Hoynes and Schanzenbach (2016). There are
    four strands to this literature. The first strand studies the effect of
    converting food stamp benefits to cash. Moffitt (1989) finds that a
    cashout in Puerto Rico did not affect food spending. Wilde and Ranney
    (1996) find that behavior in two randomized cashout interventions is
    not consistent with fungibility; Schanzenbach (2002) finds that
    behavior in these same interventions is consistent with fungibility.\5\
    The second strand, reviewed in Fox, et al. (2004), either compares
    participants to nonparticipants or relates food spending to the size of
    a household's benefit, either across households or over time. Wilde
    (2001) and Hoynes and Schanzenbach (2009), among others, criticize this
    strand of the literature for using a source of variation in program
    benefits that is likely related to non-program determinants of
    spending.\6\ The third strand studies randomized evaluations of program
    extensions or additions. Collins, et al. (2016) study a randomized
    evaluation of the Summer Electronic Benefit Transfer for Children
    program and use survey data to estimate an MPCF out of program benefits
    of 0.58.
    ---------------------------------------------------------------------------
        \5\ Fox, et al. (2004) question the validity of the findings from
    Puerto Rico and one of the randomized interventions, arguing that the
    best evidence indicates that cashout reduces food spending.
        \6\ Wilde, et al. (2009) address the endogeneity of program
    benefits by exploiting variation in whether household food spending is
    constrained by program rules. Li, et al. (2014) use panel data to study
    the evolution of child food insecurity in the months before and after
    family entry into the food stamp program.
    ---------------------------------------------------------------------------
        The fourth strand exploits policy variation in program availability
    and generosity. Studying the initial rollout of the Food Stamp Program
    using survey data, Hoynes and Schanzenbach (2009) estimate an MPCF out
    of food stamps of 0.16 to 0.32, with confidence interval radius ranging
    from 0.17 to 0.27. Hoynes and Schanzenbach (2009) estimate an MPCF out
    of cash income of 0.09 to 0.10 and cannot reject the hypothesis that
    the MPCF out of food stamps is equal to the MPCF out of cash income.
    Studying the effect of a 2009 SNAP benefit expansion using survey data,
    Beatty and Tuttle (2015) estimate an MPCF out of SNAP benefits of 0.53
    to 0.64 (they do not report a confidence interval on these values) and
    an MPCF out of cash income of 0.15.\7\ Closest to our study, Bruich
    (2014) uses retail scanner data with method-of-payment information to
    study the effect of a 2013 SNAP benefit reduction, estimating an MPCF
    out of SNAP benefits of 0.3 with confidence interval radius of 0.15.\8\
    Bruich (2014) does not report an MPCF out of cash income. We estimate
    an MPCF out of SNAP benefits of 0.5 to 0.6 with confidence interval
    radius as low as 0.015, and an MPCF out of cash income of no more than
    0.1.
    ---------------------------------------------------------------------------
        \7\ Nord and Prell (2011) estimate the effect of the 2009 benefit
    expansion on food security and food expenditures. Ratcliffe, et al.
    (2011) and Yen, et al. (2008) estimate the effect of SNAP and food
    stamps, respectively, on food insecurity, using state-level policy
    variables as excluded instruments.
        \8\ Andreyeva, et al. (2012) and Garasky, et al. (2016) use retail
    scanner data to describe the food purchases of SNAP recipients, but not
    to estimate the causal effect of SNAP on spending.
    ---------------------------------------------------------------------------
        This paper contributes new evidence of violations of fungibility in
    a large-stakes real-world decision with significant policy relevance.
    That households mentally or even physically separate different income
    sources according to spending intentions is well-documented in
    hypothetical-choice scenarios (e.g., Heath and Soll 1996; Thaler 1999)
    and ethnographic studies (e.g., Rainwater, et al., 1959). Much of the
    recent literature documenting this behavior in real-world markets
    focuses on consumer choice settings with little direct policy relevance
    (e.g., Milkman and Bashears 2009; Hastings and Shapiro 2013; Abeler and
    Marklein forthcoming). Important exceptions include Kooreman's (2000)
    study of a child tax credit in the Netherlands, Feldman's (2010) study
    of a change in U.S. Federal income tax withholding, and Benhassine, et
    al.'s (2015) study of a labeled cash transfer in Morocco.
        Methodologically, this paper shows how to test for the fungibility
    of money without assuming that the consumption function takes a
    particular parametric form or that the consumption function is
    identical for all households.\9\ Our approach nests Kooreman's (2000),
    but avoids the concern that a rejection of fungibility is due to
    misspecification of functional forms (Ketcham, et al., 2016).
    ---------------------------------------------------------------------------
        \9\ Whereas classical tests of consumer rationality (Varian 1983;
    Blundell, et al., 2003) require observing price changes, we provide a
    set of intuitive sufficient conditions on the model and the measurement
    process that permit testing based on income variation alone.
    ---------------------------------------------------------------------------
        Finally, the paper presents new evidence from novel administrative
    data on SNAP recipients in Rhode Island, including the first evidence
    we are aware of from state administrative data on how household wage
    income evolves before and after entry into SNAP.\10\ Although we
    present these findings primarily as background, they are of interest in
    their own right as evidence on the contextual factors associated with
    SNAP adoption.
    ---------------------------------------------------------------------------
        \10\ Other recent studies analyzing linked unemployment insurance
    and SNAP data include Anderson, et al., (2012) and Leung and O'Leary
    (2015).
    ---------------------------------------------------------------------------
    2  Background and Evidence from Administrative and Survey Data
    2.1  Rhode Island Administrative Data
        We use Rhode Island state administrative records housed in a secure
    facility at the Rhode Island Innovative Policy Laboratory at Brown
    University. Personally identifiable information has been removed from
    the data and replaced with secure identifiers that make it possible to
    link different records associated with the same individual or
    household. These records are not linked to our retail panel.
        We obtain the state's SNAP records from October 2004 through June
    2016. These data define the months of benefit receipt and the
    collection of individuals associated with every household on SNAP in
    every month. We assume that a household's composition is unchanged
    prior to its first benefit receipt and that it does not change from its
    most recent composition between the end of any given period of benefit
    receipt and the start of the next period. We exclude from our analysis
    any household whose membership we cannot uniquely identify in every
    month,\11\ or whose adult composition changes during the sample period.
    The final sample consists of 185,534 unique households.
    ---------------------------------------------------------------------------
        \11\ This can occur either because we lack a unique identifier for
    a member individual or because a given individual is associated with
    multiple households in the same month.
    ---------------------------------------------------------------------------
        From SNAP records we compute, for each household and month, the
    total number of children in the household under 5 years old. From the
    records of the state unemployment insurance system we compute, for each
    household and quarter,\12\ the sum of total unemployment insurance
    benefits received from and total earnings reported to the state
    unemployment insurance system by all individuals who are in the
    household as of the quarter's end.\13\ We refer to this total as
    household income, but we note that it excludes income not reported to
    the Rhode Island unemployment insurance system, such as social security
    benefits and out-of-state earnings.
    ---------------------------------------------------------------------------
        \12\ Data on earnings are missing from our database for the fourth
    quarter of 2004 and the second quarter of 2011.
        \13\ We exclude from our analysis any household-quarter in which
    the household's total quarterly earnings exceed the 99.9999th
    percentile or in which unemployment insurance benefits in any month of
    the quarter exceed three times the 4 week equivalent of the 2016
    maximum weekly benefit of $707 (Rhode Island Department of Labor and
    Training 2016).
    ---------------------------------------------------------------------------
        We also obtain records of all debits and credits to SNAP Electronic
    Benefit Transfer (EBT) cards for the period September 2012 through
    October 2015. From these we identify all household-months in which the
    household received a SNAP benefit and all household-months in which the
    household spent SNAP benefits at a large, anonymous retailer in Rhode
    Island (``Rhode Island Retailer'') chosen to be similar to the retailer
    that provided our retail panel. Although these data can be linked to
    the SNAP records using a household identifier, we do not exploit that
    link in the analysis that follows.
    2.2  Changes in Household Circumstances Around SNAP Adoption
        Household income and household size are major determinants of SNAP
    eligibility (FNS 2016b). We therefore hypothesize that entry into SNAP
    is associated with a decline in household income and a rise in
    household size. Figure 1 shows that this hypothesis is confirmed in our
    administrative data. The figure shows panel event-study plots of
    household income and number of children as a function of time relative
    to SNAP adoption, which we define to occur on the first quarter or
    month, respectively, of a household's first SNAP spell. In the period
    of SNAP adoption, household income declines and the number of children
    rises, on average.
        Past research shows that greater household size and lower household
    income are associated, respectively, with greater and lower at-home
    food expenditures among the SNAP-recipient population (Castner and
    Mabli 2010).\14\ It is therefore unclear whether these contextual
    factors should contribute a net rise or fall in food expenditures in
    the period of SNAP adoption. Because Figure 1 shows that these factors
    trend substantially in the periods preceding SNAP adoption, we can
    assess their net effect by studying trends in spending prior to
    adoption.
    ---------------------------------------------------------------------------
        \14\ Past research also finds that unemployment--a likely cause of
    the decline in income associated with SNAP adoption--is associated with
    a small decline in spending on food for home consumption. Using cross-
    sectional variation in the Continuing Survey of Food Intake by
    Individuals, Aguiar and Hurst (2005) estimate that unemployment is
    associated with nine percent lower at-home food expenditure. Using
    pseudo-panel variation in the Family Expenditure Survey, Banks, et al.
    (1998) estimate that unemployment is associated with a 7.6 percent
    decline in the sum of food consumed in the home and domestic energy.
    Using panel variation in the Panel Study of Income Dynamics, Gough
    (2013) estimates that unemployment is associated with a statistically
    insignificant one to four percent decline in at-home food expenditure.
    Using panel variation in checking account records, Ganong and Noel
    (2016) estimate that the onset of unemployment is associated with a 3.1
    percent decline in at-home food expenditure. Aggregate data seem to
    confirm these findings: real average annual at-home food expenditure
    fell by 1.6 percent from 2006 to 2009, during which time the
    unemployment rate more than doubled (Kumcu and Kaufman 2011).
    ---------------------------------------------------------------------------
        Figure 1 therefore motivates our panel event-study research design,
    in which we use trends in spending prior to SNAP adoption to diagnose
    the direction and plausible magnitude of confounds.
    2.3  Length of SNAP Spells and the Certification Process
        When a state agency determines that a household is eligible for
    SNAP, the agency sets a certification period at the end of which
    benefits will terminate if the household has not documented continued
    eligibility.\15\ The certification period may not exceed 24 months for
    households whose adult members are elderly or disabled, and may not
    exceed 12 months otherwise (FNS 2014). In practice, households are
    frequently certified for exactly these lengths of time, or for other
    lengths divisible by 6 months (Mills, et al., 2014).
    ---------------------------------------------------------------------------
        \15\ Federal rules state that ``the household's certification
    period must not exceed the period of time during which the household's
    circumstances (e.g., income, household composition, and residency) are
    expected to remain stable'' (FNS 2014).
    ---------------------------------------------------------------------------
        Figure 2 shows the distribution of SNAP spell lengths in Rhode
    Island administrative data. The figure shows clear spikes in the
    density at spell lengths divisible by 6 months.
        Figure 2 motivates our instrumental variables research design,
    which exploits the 6 month divisibility of certification periods as a
    source of plausibly exogenous timing of program exit.
    2.4 Legislated Changes in SNAP Benefit Schedules
        Appendix Figure 1 shows the average monthly SNAP benefit per U.S.
    household from February 2006 to December 2012, which coincides with the
    time frame of our retail panel. The series exhibits two discrete jumps,
    which correspond to two legislated changes in the benefit schedule: an
    increase in October 2008 due to the 2008 Farm Bill and an increase in
    April 2009 due to the American Recovery and Reinvestment Act.
        Appendix Figure 1 motivates our differences-in-differences research
    design, which exploits these legislated benefit increases.
    2.5  Inferring SNAP Adoption from Single-Retailer Data
        Households can spend SNAP at any authorized retailer. We will
    conduct our analysis of food spending using data from a single retail
    chain. Changes in a household's choice of retailer could be mistaken
    for program entry and exit in single-retailer data. We use our EBT
    panel to evaluate the importance of these mistakes and to determine how
    best to infer program transitions in single-retailer data.
        For each K . 1,-,12  and for each household in our EBT panel, we
    identify all cases of K consecutive months without SNAP spending at the
    Rhode Island Retailer followed by K consecutive months with SNAP
    spending at the Rhode Island Retailer. We then compute the share of
    these transition periods in which the household newly enrolled in SNAP
    within 2 months of the start of SNAP spending at the retailer, where we
    define new enrollment as receipt of at least $10 in SNAP benefits
    following a period of at least 3 consecutive months with no benefit.
        Figure 3 plots the share of households newly enrolling in SNAP as a
    function of the radius K of the transition period. For low values of K,
    many transitions reflect retailer-switching rather than new enrollments
    in SNAP. The fraction of transitions that represent new enrollments
    increases with K. For K = 6 and above, the fraction constituting new
    enrollments is over 86 percent. When we focus on households who do the
    majority of their SNAP spending at the retailer in question--arguably a
    sample more comparable to the households in our retail panel--this
    fraction rises to 96 percent.
        Figure 3 motivates our definition of SNAP adoption in the retailer
    data.
    2.6  SNAP Participation and Choice of Retailer
        Even if we isolate suitably exogenous changes in SNAP participation
    and benefits, our analysis of single-retailer data could be misleading
    if SNAP participation directly affects retail choice.
        Ver Ploeg, et al. (2015) study the types of stores at which SNAP
    recipients shop using nationally representative survey data collected
    from April 2012 through January 2013. For 46 percent of SNAP
    recipients, the primary grocery retailer is a supercenter, for 43
    percent it is a supermarket, for three percent it is another kind of
    store, and for eight percent it is unknown. The corresponding values
    for all U.S. households are 45 percent, 44 percent, four percent, and
    seven percent. As with primary stores, the distribution of alternate
    store types is nearly identical between SNAP recipients and the
    population as a whole. SNAP recipients' choice of store type is also
    nearly identical to that of low-income non-recipients. While this
    evidence does not speak directly to the causal effect of SNAP on choice
    of store type, it seems to cast doubt on the hypothesis that SNAP
    receipt per se is a major factor determining where households shop.
        As further evidence, a companion note to this paper analyzes
    Nielsen Homescan data and finds little relationship at the state-year
    level between changes in the market shares of major retailers and
    changes in the number of SNAP recipients in the state.
        In the next section we present further evidence on retailer
    substitution using survey data collected by the retailer that supplied
    our panel.
    3  Retailer Data and Definitions
    3.1  Purchases and Demographics
        We obtained anonymized transaction-level data from a large U.S.
    grocery retailer with gasoline stations on site. The data comprise all
    purchases in five states made using loyalty cards by households who
    shop at one of the retailer's stores at least every other month. We
    observe 6.02 billion purchases made on 608 million purchase occasions
    by 486,570 households from February 2006 through December 2012. We
    exclude from our analysis the 1,214 households who spend more than
    $5,000 in a single month.
        For each household, we observe demographic characteristics
    including age, household composition, and ZIP [C]ode. We use these data
    in robustness checks and to study heterogeneity in our estimates.
        For each item purchased, we observe the quantity, the pre-tax
    amount paid, a flag for the use of WIC, and the dollar amount of
    coupons or other discounts applied to the purchase. For each purchase
    occasion, we observe the date, a store identifier, and a classification
    of the store into a retailer division, a grouping based on the store's
    brand and distribution geography. We also observe the main payment
    method used for the purchase, defined as the payment method (e.g.,
    cash, check, government benefit) accounting for the greatest share of
    expenditure. For purchase occasions in March 2009 and later, we
    additionally observe the exact breakdown of spending by payment method.
        We classify a purchase occasion as a SNAP purchase occasion if the
    main payment method is a government benefit and WIC is not used. Using
    the detailed payment data for purchase occasions in March 2009 and
    later, we calculate that SNAP is used in only 0.23 percent of the
    purchase occasions that we do not classify as SNAP purchase occasions.
    The appendix table shows that our key results are not sensitive to
    excluding WIC users from the sample.
        We define a SNAP month as any household-month with positive total
    spending across SNAP purchase occasions.\16\ Of the household-months in
    our panel, 7.8 percent are SNAP months. Of the households in our panel,
    43 percent experience at least 1 SNAP month.
    ---------------------------------------------------------------------------
        \16\ Using our detailed payment data for March 2009 and later, we
    can alternatively define a SNAP month as any month in which a household
    uses SNAP. This definition agrees with our principal definition in all
    but 0.27 percent of household-months.
    ---------------------------------------------------------------------------
    3.2  Product Characteristics
        The retailer provided us with data on the characteristics of each
    product purchased, including an indicator for whether the product is
    store-brand, a text description of the product, and the product's
    location within a taxonomy.
        We classify products as SNAP-eligible or SNAP-ineligible based on
    the retailer's taxonomy and the guidelines for eligibility published on
    the USDA website.\17\ Among all non-fuel purchases in our data, 71
    percent of spending goes to SNAP-eligible products, 25 percent goes to
    SNAP-ineligible products, and the remainder goes to products that we
    cannot classify.
    ---------------------------------------------------------------------------
        \17\ Grocery and prepared food items intended for home consumption
    are generally SNAP-eligible (FNS 2017). Alcohol, tobacco, pet food, and
    prepared food intended for on-premise consumption are SNAP-ineligible
    (FNS 2017).
    ---------------------------------------------------------------------------
        We use our detailed payment data for purchases made in SNAP months
    in March 2009 or later to validate our product eligibility
    classification. Among all purchases made at least partly with SNAP in
    which we classify all products as eligible or ineligible, in 98.6
    percent of cases the expenditure share of SNAP-eligible products is at
    least as large as the expenditure share paid with SNAP. Among purchases
    made entirely with SNAP, in 98.7 percent of cases we classify no items
    as SNAP-ineligible. Among purchases in which all items are classified
    as SNAP-ineligible, in more than 99.9 percent of cases SNAP is not used
    as a payment method.
    3.3  Shopping Effort
        For each household and month we compute the store-brand share of
    expenditures and the share of items for which coupons are redeemed for
    both SNAP-eligible and SNAP-ineligible purchases. Prior evidence
    suggests that both of these can serve as a proxy for households'
    efforts to save money.\18\ We adjust these measures for the composition
    of purchases as follows. For each item purchased, we compute the store-
    brand share of expenditure among other households buying an item in the
    same product category in the same retailer division and the same
    calendar month and week. The expenditure-weighted average of this
    measure across purchases by a given household in a given month is the
    predicted store-brand share, i.e., the share of expenditures that would
    be store-brand if the household acted like others in the panel who buy
    the same types of goods. Likewise, we compute the share of other
    households buying the same item in the same retailer division, month,
    and week who redeem coupons, and compute the average of this measure
    across purchases by a given household in a given month to form a
    predicted coupon use. We subtract the predicted from the actual value
    of each shopping effort measure to form measures of adjusted store-
    brand share and adjusted coupon redemption share.
    ---------------------------------------------------------------------------
        \18\ Store-brand items tend to be less expensive than national-
    brand alternatives, and correspondingly are more popular among lower-
    income households (Bronnenberg, et al., 2015). Coupon use rose during
    the Great Recession, reflecting households' greater willingness to
    trade time for money (Nevo and Wong 2015).
    ---------------------------------------------------------------------------
    3.4  Monthly Spending and Benefits
        For each household in our panel we calculate total monthly spending
    on SNAP-eligible items, fuel, and SNAP-ineligible items excluding fuel.
    We calculate each household's total monthly SNAP benefits as the
    household's total spending across all SNAP purchase occasions within
    the month.\19\
    ---------------------------------------------------------------------------
        \19\ Our concept of total SNAP benefits has a correlation of 0.98
    with the exact amount of SNAP spending calculated using detailed
    payment information in SNAP months March 2009 and later.
    ---------------------------------------------------------------------------
        Our data corroborate prior evidence (e.g., Hoynes, et al., 2015)
    that, for most households, SNAP benefits do not cover all SNAP-eligible
    spending. For 93 percent of households who ever use SNAP, average SNAP-
    eligible spending in non-SNAP months exceeds average SNAP benefits in
    SNAP months. SNAP-eligible spending exceeds SNAP benefits by at least
    $10 in 93 percent of SNAP months and by at least five percent in 92
    percent of SNAP months. The appendix table reports estimates of key
    parameters for the subset of households for whom, according to various
    definitions, SNAP benefits are inframarginal to total food spending.
    3.5  SNAP Adoption
        Motivated by the analysis in section 2.5, we define a SNAP adoption
    as a period of 6 or more consecutive non-SNAP months followed by a
    period of 6 or more consecutive SNAP months. We refer to the first SNAP
    month in an adoption as an adoption month. We define a SNAP adopter as
    a household with at least one SNAP adoption. Our panel contains a total
    of 24,456 SNAP adopters.
        Panel A of Figure 4 shows the share of SNAP adopters with positive
    SNAP spending in each of the 12 months before and after a household's
    first SNAP adoption. Panel B of Figure 4 shows average SNAP benefits
    before and after adoption. Following adoption, the average household
    receives about $200 in monthly SNAP benefits. For comparison, the
    average U.S. SNAP benefit per household in fiscal 2009, roughly at the
    midpoint of our sample period, was $276 (FNS 2016a).
        We conduct the bulk of our analysis using the sample of SNAP
    adopters. The appendix tablepresents our key results for alternative
    samples.
    3.6  Retailer Share of Wallet
        Spending patterns suggest that panelists buy a large fraction of
    their groceries at the retailer. Mabli and Malsberger (2013) estimate
    average 2010 spending on food at home by SNAP recipients of $380 per
    month using data from the Consumer Expenditure Survey. Hoynes et al.
    (2015) find that average per-household food expenditures are 20 to 25
    percent lower in the Consumer Expenditure Survey than in the
    corresponding aggregates from the National Income and Product Accounts.
    In the 6 months following a SNAP adoption, average monthly SNAP-
    eligible spending in our data is $469.
        Panelists also seem to buy a large fraction of their gasoline at
    the retailer: average monthly fuel spending at the retailer is $97 in
    the 6 months following SNAP adoption, as compared to Mabli and
    Malsberger's (2013) estimate of $115.
        Survey data from the retailer suggest that SNAP use is associated
    with a reduction in the retailer's share of overall category spending.
    During the period June 2009 to December 2011, the retailer conducted an
    online survey on a convenience sample of customers. The survey asked:

              About what percentage of your total overall expenses for
            groceries, household supplies, or personal care items do you,
            yourself, spend in the following stores?

    Respondents were presented with a list of retail chains including the
    one from which we obtained our data. Excluding responses in which the
    reported percentages do not sum to 100, we observe at least one
    response from 961 of the households in our panel. Among survey
    respondents that ever use SNAP, the average reported share of wallet
    for the retailer is 0.61 for those surveyed during non-SNAP months (N =
    311 survey responses) and 0.53 for those surveyed during SNAP months (N
    = 80 survey responses).\20\ The same qualitative pattern obtains among
    SNAP adopters, and in responses to a retrospective question about
    shopping frequency.\21\
    ---------------------------------------------------------------------------
        \20\ The difference in means is statistically significant (t =
    2.15, p = 0.032).
        \21\ The question asks, ``In your opinion, do you think you,
    yourself have been shopping more, less, or about the same amount at the
    retailer over the past 3 months?'' Among households surveyed in a SNAP
    month, 60 percent report that their frequency of shopping at the
    retailer has stayed ``about the same.'' Among those saying that it has
    not stayed the same, a majority (59 percent) say that it has decreased.
    ---------------------------------------------------------------------------
        Taken at face value, these findings suggest that retailer
    substitution will tend, if anything, to bias downward the estimated
    effect of SNAP participation on food spending. In the appendix table we
    verify that our results are robust to restricting attention to
    households with relatively few supermarkets in their county, for whom
    opportunities to substitute across retailers are presumably more
    limited.
    4  Descriptive Evidence
    4.1  Marginal Propensity To Consume Out of SNAP Benefits
        Figure 5 shows the evolution of monthly spending before and after
    SNAP adoption for our sample of SNAP adopters. Each plot shows
    coefficients from a regression of spending on a vector of indicators
    for months relative to the household's first SNAP adoption. Panel A
    shows that SNAP-eligible spending increases by approximately $110 in
    the first few months following SNAP adoption. Recall from Figure 4 that
    the average household receives monthly SNAP benefits of approximately
    $200 following SNAP adoption. Taking the ratio of the increase in
    spending to the benefit amount, we estimate an MPCF out of SNAP
    benefits between 0.5 and 0.6.
        Panel B shows that SNAP-ineligible spending increases by
    approximately $5 following SNAP adoption, implying an MPC of a few
    percentage points. The increase in SNAP-ineligible spending is smaller
    in both absolute and proportional terms than the increase in SNAP-
    eligible spending. The online appendix shows directly that the share of
    spending devoted to SNAP-eligible items increases significantly
    following SNAP adoption. This finding is not consistent with the
    hypothesis that SNAP leads to a proportional increase in spending
    across all categories due to substitution away from competing
    retailers.
        Following the analysis in section 2.2, trends in spending prior to
    adoption should provide a sense of the influence of changes in
    contextual factors on spending. Panel A shows very little trend in
    SNAP-eligible spending prior to SNAP adoption. Panel B shows, if
    anything, a slight decline in SNAP-ineligible spending prior to
    adoption, perhaps due to economic hardship. Neither of these patterns
    seems consistent with the hypothesis that the large increase in SNAP-
    eligible spending that occurs at SNAP adoption is driven by changes in
    contextual factors.
        Figure 6 shows the evolution of monthly spending during a monthly
    clock that begins at SNAP adoption and resets every 6 months. Panels A
    and B show that SNAP participation and benefits fall especially quickly
    in the first month of the clock, consistent with the finding in section
    2.3 that SNAP spell lengths tend to be divisible by 6 months.
    Participation and benefits also fall more quickly in the sixth month,
    perhaps reflecting error in our classification of adoption dates.
        Panel C of Figure 6 shows that the pattern of SNAP-eligible
    spending closely follows that of SNAP benefits. Benefits decline by
    about $12 more in the first month of the cycle than in the second.
    Correspondingly, SNAP-eligible spending declines by $6 to $7 more in
    the first month than in the second. Taking the ratio of these two
    values implies an MPCF out of SNAP benefits between 0.5 and 0.6,
    consistent with the evidence in Figure 5.
        Appendix Figure 2 plots the evolution of SNAP-eligible spending
    around the legislated benefit changes described in section 2.4. The
    plot shows that likely SNAP recipients' SNAP-eligible spending
    increases relative to that of likely non-recipients around the periods
    of benefit increases. The online appendix reports the results of a
    differences-in-differences analysis of these changes in the spirit of
    Bruich (2014) and Beatty and Tuttle (2015). We estimate an MPCF out of
    SNAP benefits of 0.53, and if anything a negative effect of benefit
    expansions on SNAP-ineligible spending.
    4.2  Marginal Propensity To Consume Out of Cash
        Two pieces of indirect evidence suggest that an MPCF out of SNAP of
    0.5 to 0.6 is too large to be consistent with households treating SNAP
    benefits as fungible with other income.
        The first is that, for the average SNAP recipient, food at home
    represents only 22 percent of total expenditure (Castner and Mabli
    2010). Engel's Law (Engel 1857; Houthakker 1957) holds that the budget
    share of food declines with total resources, and hence that the budget
    share exceeds the MPCF. Engel's Law is not consistent with a budget
    share of 0.22 and an MPCF of 0.5 to 0.6.
        The second is that prior estimates of the MPCF out of cash for low-
    income populations are far below 0.5. Castner and Mabli (2010) estimate
    an MPCF of 0.07 for SNAP recipients. Hoynes and Schanzenbach (2009)
    estimate an MPCF of 0.09-0.10 for populations with a high likelihood of
    entering the Food Stamp Program. Assessing the literature, Hoynes and
    Schanzenbach (2009) note that across ``a wide range of data (cross
    sectional, time series) and econometric methods'' past estimates of the
    MPCF out of cash income are in a ``quite tight'' range from 0.03 to
    0.17 for low-income populations.
        For more direct evidence, we study the effect on spending of the
    large changes in gasoline prices during our sample period. These
    changes affect the disposable income available to households and
    therefore give us a window into the MPCF out of cash income.
        Panel A of Figure 7 shows the time-series relationship between
    gasoline prices and fuel expenditure for SNAP adopters at different
    quartiles of the distribution of average fuel expenditure. Those
    households in the upper quartiles exhibit substantial changes in fuel
    expenditure when the price of gasoline changes. For example, during the
    run-up in fuel prices in 2007, part of an upward trend often attributed
    to increasing demand for oil from Asian countries (e.g., Kilian 2010),
    households in the top quartile of fuel spending increased their
    spending on fuel by almost $100 per month. Households in lower
    quartiles increased their fuel spending by much less.
        Panel B of Figure 7 shows the time-series relationship between
    gasoline prices and SNAP-eligible expenditure for the same groups of
    households. The relationship between the two series does not appear
    consistent with an MPCF out of cash income of 0.5 to 0.6. For example,
    if the MPCF out of cash income were 0.5 we would expect households in
    the top quartile of fuel spending to decrease SNAP-eligible spending
    significantly during the run-up in fuel prices in 2007. In fact, we see
    no evidence of such a pattern, either looking at the top quartile in
    isolation, or comparing it to the lower quartiles.
        The absence of a strong response of SNAP-eligible spending to fuel
    prices is consistent with prior evidence of a low MPCF out of cash. It
    is not consistent with the hypothesis that changes in income drive
    large changes in the retailer's share of wallet, as such income effects
    would lead to a relationship between gasoline prices and measured SNAP-
    eligible spending.
    4.3  Quantitative Summary
        Table 1 presents two-stage least squares (2SLS) estimates of a
    series of linear regression models. In each model the dependent
    variable is the change in spending from the preceding month to the
    current month. The endogenous regressors are the change in the SNAP
    benefit and the change in the additive inverse of fuel spending. The
    coefficients on these endogenous regressors can be interpreted as MPCs.
    Each model includes calendar month fixed effects. (Household fixed
    effects are implicit in the first-differencing of the variables in the
    model.)
        All models use the interaction of the change in the price of
    regular gasoline and the household's average monthly number of gallons
    of gasoline purchased as an excluded instrument. This instrument
    permits estimating the MPC out of cash following the logic of Figure 7.
        Models (1), (2), and (3) of Table 1 all use the change in SNAP-
    eligible spending as the dependent variable. The models differ in the
    choice of excluded instruments for SNAP benefits. In model (1), the
    instrument is an indicator for whether the month is an adoption month.
    In model (2), it is an indicator for whether the month is the first
    month of the 6 month SNAP clock. These instruments permit estimating
    the MPCF out of SNAP following the logic of Figures 5 and 6,
    respectively. In model (3), both of these instruments are used.
        Estimates of models (1), (2), and (3) indicate an MPCF out of SNAP
    between 0.55 and 0.59 and an MPCF out of cash close to 0. In model (3),
    confidence intervals exclude an MPCF out of SNAP below 0.57 and an MPCF
    out of cash above 0.1. In all cases, we reject the null hypothesis that
    the MPCF out of SNAP is equal to the MPCF out of cash.
        Model (4) parallels model (3) but uses SNAP-ineligible spending as
    the dependent variable. We estimate an MPC out of SNAP of 0.02 and an
    MPC out of cash of 0.04. We cannot reject the hypothesis that these two
    MPCs are equal.
        The appendix table shows that the conclusion that the MPCF out of
    SNAP exceeds the MPCF out of cash holds when we exclude households for
    whom SNAP benefits may not be economically equivalent to cash, and
    restrict to single-adult households to limit the role of intra-
    household bargaining.
        The online appendix reports that the implied MPCF out of SNAP is
    slightly higher in the household's first SNAP adoption than in
    subsequent SNAP adoptions. We cannot reject the hypothesis that the
    MPCF is equal between first and subsequent adoptions. The online
    appendix also reports estimates of the MPCF out of SNAP and cash for
    various demographic groups.
    5  Model and Tests for Fungibility
    5.1  Model
        In each month t . 1,-,T , household i receives SNAP benefits
    bit % 0 and disposable cashincome yit > 0. The
    household chooses food expenditure fit and nonfood expenditure nit to
    solve
    (1)

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    where jit is a preference shock and Ui () is a
    utility function strictly increasing in  and n. The variables
    (bit,yit, xit) are random with support
    Vi.
        Assumption 1. For each household i, optimal food spending can be
    written as
    (2)

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    where fi () is a function with range [0,yit +
    bit].
        A sufficient condition for assumption 1 is that, for each household
    i, at any point (b,y,j) . Vi the function Ui
    ( ,y+b^;j) is smooth and strictly concave in
     and has a stationary point * > b. Then
    optimal food spending exceeds the level of SNAP benefits even if
    benefits are disbursed as cash, so the ``kinked'' budget constraint in
    (1) does not affect the choice of fit.
        For each household and month, an econometrician observes data
    (it,bit,yit,zit)
    where zit is a vector of instruments. A concern is that
    xit is determined partly by contextual factors such as job
    loss that directly affect yit and bit.
        Assumption 2. Let nit =
    (yit+bit)^E(yit+bit D
    zit). For each household i, the instruments zit
    satisfy
    (3)

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        Proposition 1. Under assumptions 1 and 2, for each household i
    (4)

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    for some function qi ().
        Proof. Let Pi denote the CDF of
    (jit,vit). Then

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    where the first equality follows from assumption 1 and the second from
    assumption 2. See Blundell and Powell (2003, p. 330).
        Example. (Cobb-Douglas) Suppose that for each household i there is
    bi . (0,1) such that:
    (5)

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    with bi (y+b)+j > b and (1^bi) (y+b) > j at all
    points in Vi. Then assumption 1 holds with
    (6)

    and, under assumption 2, proposition 1 applies with
    (7)

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    for ai 6 E(jit).
        Remark 1. In his study of a child tax credit in the Netherlands,
    Kooreman (2000) assumes a version of (6), which he estimates via
    ordinary least squares using cross-sectional data under various
    restrictions on ai, bi, and jit.
    5.2  Testing for Fungibility
        Index a family of perturbations to the model by g. Let
    git be food spending under perturbation g, with
    (8)

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    for i () the function defined in assumption 1. We
    may think of g as the excess sensitivity of food spending to SNAP
    benefits. The null hypothesis that the model holds is equivalent under
    (8) to g = 0.
        Let Yit = E(yit +
    bitDzit) and Bit =
    E(bitDzit) and observe that
    (9)

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    where E(eitDYit,Bit) = 0. The nuisance
    terms qi () have been ``partialled out'' of (9) as in
    Robinson (1988). The target g can be estimated via OLS regression of
    (git ^ E
    (gitDYit)) on (Bit ^E
    (BitDYit)).
        Remark 2. It is possible to allow for measurement error in
    it that depends on
    (yit+bit). Say that for known function m(),
    unobserved measurement error hit independent of
    zit, and unknown function lit () we have that
    measured food spending fit follows
    (10)

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    Then under perturbations m((git) =
    m(it) + gbit an analogue of (9) holds,
    replacing git with m(git).
    Examples include additive measurement error, where m() is the identity
    function, and multiplicative measurement error, where m() is the
    natural logarithm. The latter case has a simple interpretation as one
    in which the econometrician observes spending at a single retailer
    whose share of total household food spending is given by exp (lit
    (yit+bit,hit)).
        Remark 3. The reasoning above is unchanged if bit and
    yit are each subject to an additive measurement error that
    is mean-independent of zit. In this case, we can simply let
    Yit and Bit represent the conditional
    expectations of the corresponding mismeasured variables.
    5.3  Implementation and Results
        With (9) in mind, estimation proceeds in three steps:

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        We let git be SNAP-eligible spending, bit
    be SNAP benefits, and yit be the additive inverse of fuel
    spending. We let the instruments zit be given by the number
    of SNAP adoptions experienced by household i as of calendar month t,
    and the product of the average price of regular gasoline with the
    household's average monthly number of gallons of gasoline purchased.
        In step 1, we estimate (Yit,Bit) via first-
    differenced regression of (yit+bit) and bit
    on zit.
        In step 2, we consider four specifications for estimating
    (E(gitDYit) ,
    E(BitDYit)). In the first, we estimate these via
    first-differenced regression of git and Bit
    on Yit, pooling across households. In the second, we
    estimate these via first-differenced regression of git
    and Bit on Yit, separately by household. In the
    third, we estimate these via first-differenced regression of
    git and Bit on indicators for the
    quintiles of Yit, separately by household. In the fourth, we
    estimate these via locally weighted polynomial regression of
    git and Bit on Yit,
    separately by household. Thus, the first specification implicitly
    treats qi as linear and homogeneous across households, the
    second treats qi as linear and heterogeneous across
    households, and the third and fourth allow qi to be
    nonlinear and heterogeneous across households.

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        Table 2 presents the results. Across all three specifications, our
    estimates of g are 0.5 or greater, and in all cases we can reject the
    null hypothesis that g = 0 with a high level of confidence.
    6  Interpretation
        We speculate that households treat SNAP benefits as part of a
    separate mental account, psychologically earmarked for spending on
    food. In this section we discuss results of qualitative interviews
    conducted at a food pantry in Rhode Island. We then present
    quantitative evidence that we think suggests a mental accounting
    explanation, and present a post-hoc model of mental accounting that
    rationalizes this evidence.
    6.1  Qualitative Interviews with SNAP-Recipient Households
        As part of preparation related to a state proposal to pilot a
    change to SNAP benefit distribution, Rhode Island Innovative Policy
    Laboratory staff conducted a series of qualitative interviews at a
    large food pantry in Rhode Island in May, July, and August 2016.
    Interviewees were approached in the waiting room of the pantry and were
    offered a $5 gift card to a grocery retailer in exchange for
    participating. Interviews were conducted in English and Spanish.
        Interviewees were selected from those waiting to be served at the
    food pantry and were not sampled scientifically. Interviews were
    conducted primarily to inform the implementation of the pilot program
    and the responses should not be taken to imply any generalizable
    conclusions. We report them here as context for our quantitative
    evidence.
        Of the 25 interviews conducted, 19 were with current SNAP
    recipients. Of these, all but three reported spending non-SNAP funds on
    groceries each month, with an average out-of-pocket spending of $100
    for those reporting positive out-of-pocket spending.
        Each interviewee was asked the following two questions, which we
    refer to as SNAP and CASH:

              (SNAP) Imagine that in addition your current benefit, you
            received an extra $100 in SNAP benefits at the beginning of the
            month. How would this change the way that you spend your money
            during the month? [emphasis added]
              (CASH) Imagine that you received an additional $100 in cash
            at the beginning of the month. How would this change the way
            that you spend your money during the month? [emphasis added]

    Of the 16 SNAP-recipient interviewees who report nonzero out-of-pocket
    spending on groceries, 14 chose to answer questions SNAP and CASH.
        Interviewers recorded verbal responses to each question as
    faithfully as possible. The most frequently occurring word in response
    to the SNAP question is ``food,'' which occurs in eight of the 14
    responses. Incorporating mentions of specific foods or food-related
    terms like ``groceries,'' the fraction mentioning food rises to ten out
    of 14 responses. The word ``food'' occurs in three of the 14 responses
    to CASH; more general food related terms occur in five of the 14
    responses to CASH.
        Several responses seem to suggest a difference in how the household
    would spend $100 depending on the form in which it arrives. For
    example, in response to question SNAP one interviewee said ``[I would]
    buy more food.'' In response to CASH the same interviewee said ``[I
    would buy] more household necessities.'' Another interviewee said in
    response to SNAP that ``[I would buy] more food, but the same type of
    expenses. If I bought $10 of sugar, now [I would buy] $20.'' In
    response to CASH, the same interviewee said that ``[I would spend it
    on] toilet paper, soap, and other necessary home stuff, or medicine.''
    A third interviewee said in response to SNAP that ``I would buy more
    food and other types of food . . .'' and in response to CASH that ``I
    could buy basic things that I can't buy with [SNAP].'' \22\
    ---------------------------------------------------------------------------
        \22\ The bracketed term is a translation for the Spanish word
    cupones. This word is literally translated as ``coupons'' but is often
    used to refer to SNAP. (See, for example, Project Bread 2016.)
    ---------------------------------------------------------------------------
        Some responses suggest behavior consistent with inframarginality.
    For example one interviewee's answer to SNAP included the observation
    that ``I would probably spend $100 less out of pocket,'' although this
    interviewee also mentions increasing household expenditures on seafood
    and produce. Another interviewee answered SNAP with ``[I] would spend
    all in food, and also buy soap [and] things for [my] two kids.''
    6.2  Quantitative Evidence on Shopping Effort
        If SNAP recipients consider SNAP benefits to be earmarked for food,
    they may view a dollar saved on food as less valuable than a dollar
    saved on non-food purchases. To test this hypothesis, we study the
    effect of SNAP on bargain-seeking behavior.
        Figure 8 shows the evolution of the adjusted store-brand share
    before and after SNAP receipt for our sample of SNAP adopters. Each
    plot shows coefficients from a regression of the adjusted store-brand
    share on a vector of indicators for months relative to SNAP adoption.
    Among SNAP-eligible items, panel A shows a trend towards a greater
    store-brand share prior to SNAP adoption, perhaps reflecting the
    deterioration in households' economic well-being that normally triggers
    entry into a means-tested program. Once households adopt SNAP, there is
    a marked and highly statistically significant drop in the store-brand
    share. Because we have adjusted store-brand share for the composition
    of purchases, this decline is driven not by changes in the categories
    of goods purchased, but by a change in households' choice of brand
    within a category.
        Panel B of Figure 8 shows an analogous plot for SNAP-ineligible
    items. The adjusted storebrand share of SNAP-ineligible expenditure
    rises before SNAP adoption and does not decline significantly following
    adoption. Regression analysis presented in the online appendix shows
    that we can confidently reject the hypothesis that the change in
    adjusted store-brand share at SNAP adoption is equal between SNAP-
    eligible and SNAP-ineligible products.
        Figure 9 shows analogous evidence for coupon use. Following SNAP
    adoption, the average adjusted coupon redemption share declines for
    both SNAP-eligible and SNAP-ineligible products, but the decline is
    more economically and statistically significant for SNAP-eligible
    products than for SNAP-ineligible products. Because we have adjusted
    the coupon redemption share for the basket of goods purchased, these
    patterns are not driven by changes in the goods purchased, but rather
    by households' propensity to redeem coupons for a given basket of
    goods. Regression analysis presented in the online appendix shows that
    we can reject the hypothesis that the change in the adjusted coupon
    redemption share at SNAP adoption is equal between SNAP-eligible and
    SNAP-ineligible products.
    6.3  Post-Hoc Model of Mental Accounting
        To fix ideas and rationalize the preceding evidence, we specify a
    model of mental accounting based on Farhi and Gabaix (2015). Return to
    the setup of section 5, considering for ease of notation a single
    household and time period, and ignoring the preference shock j. Let
    preferences over food consumption  and non-food consumption n
    be Cobb-Douglas, and suppose that the household can exert effort
    sf % 0 and sn % 0, respectively, to reduce the
    cost of a given unit of consumption in the food and non-food domains,
    respectively. Finally, suppose that the household exhibits a distaste
    for deviating from a psychological default level of food spending,
    determined in part by the earmarking of SNAP benefits. Formally, write
    the household's problem as
    (11)

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Here, the function c (), which is smooth and strictly increasing in its
    argument, describes the cost of shopping effort. The function d (),
    which is smooth, strictly decreasing and strictly convex, describes the
    return to shopping effort in terms of prices paid. The parameter k > 0
    indexes the importance of sticking to the household's default plan to
    spend amount b of SNAP benefits and amount by of cash income on food.

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

        In this sense, the model in (11) can rationalize both the tendency
    to consume food out of SNAP in greater proportion than out of cash
    income, and the tendency to reduce bargain-hunting in the food domain
    (relative to the non-food domain) after receipt of SNAP. The model is
    post-hoc in that the specification of the target spending (by + b) is
    arbitrary and does not derive from portable psychological primitives.
    7  Conclusions
        We use data from a novel retail panel to study the effect of the
    receipt of SNAP benefits on household spending behavior. Novel
    administrative data motivates three approaches to causal inference. We
    find that the MPCF out of SNAP benefits is 0.5 to 0.6 and larger than
    the MPCF out of cash. We argue that these findings are not consistent
    with households treating SNAP funds as fungible with non-SNAP funds,
    and we support this claim with formal tests of fungibility that allow
    different households to have different consumption functions.
        We speculate that households treat SNAP benefits as part of a
    separate mental account. Responses to hypothetical choice scenarios in
    qualitative interviews suggest that some households plan to spend SNAP
    benefits differently from cash. Quantitative evidence shows that, after
    SNAP receipt, households reduce shopping effort for SNAP-eligible
    products more so than for SNAP-ineligible products. A post-hoc model of
    mental accounting based on Farhi and Gabaix (2015) rationalizes these
    facts.

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    Table 1: Estimated Marginal Propensities To Consume

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Table 2: Tests of Fungibility

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Figure 1: Household income and size before and after SNAP adoption
    Panel A: Household Income

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: Number of Children Under Five Years of Age

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Data are from Rhode Island administrative records from
            October 2004 through June 2016. See section 2.1 for details on
            sample definition and variable construction. Each panel plots
            coefficients from a regression of the dependent variable on a
            vector of lead and lagged indicators for periods relative to
            SNAP adoption, defined as the first period in which the
            household receives SNAP. The period immediately prior to
            adoption (``^1'') is the omitted category. Each regression
            includes time period fixed effects, household fixed effects,
            and indicators for observations more than 1 year before or
            after adoption. In panel A, a time period is a calendar quarter
            and the unit of analysis is a household-quarter. In panel B, a
            time period is a month and the unit of analysis is the
            household-month. In both panels, the error bars are R2
            coefficient standard errors and standard errors are clustered
            by household. Dotted lines show the sample mean of the
            dependent variable across observations within 1 year (4
            quarters or 12 months) of SNAP adoption. Each coefficient
            series is shifted by a constant so that the observation-count-
            weighted mean of the regression coefficients is equal to the
            sample mean of the corresponding dependent variable.
    Figure 2: Distribution of Lengths of SNAP Spells

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Data are from Rhode Island administrative records from
            October 2004 through June 2016. See section 2.1 for details on
            sample definition and variable construction. The plot shows a
            histogram of the distribution of SNAP spell lengths, where a
            spell is defined as a set of consecutive months in which the
            household is entitled to a SNAP benefit in each month according
            to state program records. Spells longer than 36 months are
            excluded from the sample.
    Figure 3: Inferring SNAP Adoption from Single-Retailer Data

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Data are from Rhode Island EBT transaction records
            from September 2012 through October 2015. See section 2.1 for
            details on sample definition and variable construction. The
            figure plots the fraction of transition periods of a given
            radius in which the household newly enrolled in SNAP within 2
            months of the start of SNAP spending at the Rhode Island
            Retailer. We define new enrollment as the receipt of at least
            $10 in SNAP benefits following a period of at least 3
            consecutive months with no benefit. A transition period of
            radius K is a period in which a household exhibits K
            consecutive months without SNAP spending at the Rhode Island
            Retailer followed by K consecutive months with SNAP spending at
            the Rhode Island Retailer. Households who mainly spend SNAP at
            the Rhode Island Retailer are those who spend at least \1/2\ of
            their total EBT expenditures between September 2012 and October
            2015 at the Rhode Island Retailer.
    Figure 4: SNAP Use and Benefits Before and After SNAP Adoption
    Panel A: SNAP Use
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: SNAP Benefits
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: The sample is the set of SNAP adopters. Panel A plots
            the share of households with positive SNAP spending in each of
            the 12 months before and after the household's first SNAP
            adoption. Panel B plots the average SNAP benefit in each of the
            12 months before and after the first SNAP adoption.
    Figure 5: Monthly Expenditure Before and After SNAP Adoption, By SNAP
            Eligibility of Product
    Panel A: SNAP-Eligible Spending
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: SNAP-Ineligible Spending
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Each figure plots coefficients from a regression of
            SNAP-eligible or SNAP-ineligible spending on a vector of lead
            and lagged indicators for month relative to the household's
            first SNAP adoption, with the month prior to SNAP adoption
            (``^1'') as the omitted category. The unit of observation for
            each regression is the household-month. Error bars are R2
            coefficient standard errors. Standard errors are clustered by
            household. Each regression includes calendar month fixed
            effects, household fixed effects, and two indicators for
            observations before and after 12 months of SNAP adoption. The
            dotted lines show the sample mean of household monthly
            expenditure across observations within 12 months of SNAP
            adoption. Each coefficient series is shifted by a constant so
            that the observation-count-weighted mean of the regression
            coefficients is equal to the sample mean of the corresponding
            dependent variable.
    Figure 6: Participation, Benefits, and Spending Over the 6 Month SNAP
            Clock
    Panel A: SNAP Use
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: SNAP Benefits
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel C: SNAP-Eligible Spending
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Each figure plots coefficients from a regression of
            the dependent variable on a vector of indicators for the
            position of the current month in a monthly clock that begins in
            the most recent adoption month and resets every 6 months or at
            the next SNAP adoption, whichever comes first. The unit of
            observation for each regression is the household-month. The
            sample is the set of SNAP adopters. Error bars are R2
            coefficient standard errors. Standard errors are clustered by
            household. Each regression includes calendar month fixed
            effects. The omitted category consists of the first 6 months
            (inclusive of the adoption month) after the household's most
            recent SNAP adoption, all months after the first 24 months
            (inclusive of the adoption month) following the household's
            most recent adoption, and all months for which there is no
            preceding adoption. In Panel A, the dependent variable is the
            change in an indicator for whether the household-month is a
            SNAP month. In Panel B, the dependent variable is the change in
            monthly SNAP benefits. In Panel C, the dependent variable is
            the change in monthly SNAP-eligible spending.
    Figure 7: Monthly Expenditure and the Price of Gasoline
    Panel A: Fuel Spending
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: SNAP-Eligible Spending
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Panel A plots average monthly fuel spending by
            quartile of average monthly fuel spending. Panel B plots
            average monthly SNAP-eligible spending by quartile of average
            monthly fuel spending. The unit of observation is the
            household-month and the sample is the set of SNAP adopters who
            ever purchase fuel. The lower portion of both plots shows the
            price of gasoline, computed as the quantity-weighted average
            spending per gallon on regular grade gasoline among all
            households before any discounts or coupons.
    Figure 8: Store-Brand Share Before and After SNAP Adoption, By SNAP
            Eligibility of product
    Panel A: SNAP-Eligible Products
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: SNAP-Ineligible Products
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Each figure plots coefficients from a regression of
            adjusted store-brand share of expenditures on a vector of lead
            and lagged indicators for month relative to the household's
            first SNAP adoption, with the month prior to SNAP adoption
            (``^1'') as the omitted category. The unit of observation for
            each regression is the household-month. Error bars are R2
            coefficient standard errors. Standard errors are clustered by
            household. Each regression includes calendar month fixed
            effects, household fixed effects, and two indicators for
            observations before and after 12 months of SNAP adoption. The
            dotted line shows the sample mean of the store-brand share of
            expenditure across observations within 12 months of SNAP
            adoption. Each coefficient series is shifted by a constant so
            that the observation-count-weighted mean of the regression
            coefficients is equal to the sample mean of the store-brand
            share of expenditure in the given SNAP eligibility group.
    Figure 9: Coupon Use Before and After SNAP Adoption, By SNAP
            Eligibility of Product
    Panel A: SNAP-Eligible Products
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Panel B: SNAP-ineligible products
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Each figure plots coefficients from a regression of
            the adjusted coupon redemption share on a vector of lead and
            lagged indicators for month relative to the household's first
            SNAP adoption, with the month prior to SNAP adoption (``^1'')
            as the omitted category. The unit of observation for each
            regression is the household-month. Error bars are R2
            coefficient standard errors. Standard errors are clustered by
            household. Each regression includes calendar month fixed
            effects, household fixed effects, and two indicators for
            observations before and after 12 months of SNAP adoption. The
            dotted line shows the sample mean of the share of purchases
            using a coupon across observations within 12 months of SNAP
            adoption. Each coefficient series is shifted by a constant so
            that the observation-count-weighted mean of the regression
            coefficients is equal to the sample mean of the share of
            purchases using a coupon in the given SNAP eligibility group.
    Appendix Table: Results for Alternative Samples and Specifications
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Appendix Figure 1: Legislated Changes in SNAP Benefits
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: This figure plots the average monthly SNAP benefit per
            U.S. household between February 2006 and December 2012. The
            series was obtained directly from the United States Department
            of Agriculture Food and Nutrition Service via http://
            www.fns.usda.gov/sites/default/files/pd/
            SNAPZip69throughCurrent.zip. The vertical lines at October 2008
            and April 2009 denote the implementation dates of changes in
            SNAP benefits due to the farm bill and American Recovery and
            Reinvestment Act (ARRA), respectively.
    Appendix Figure 2: Monthly SNAP Benefits and SNAP-Eligible Spending
            Around Benefit Changes
            [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: The sample includes all households in the retailer
            panel that have at least 2 consecutive SNAP months during the
            panel. The figure plots coefficients from a regression of SNAP
            benefits and SNAP-eligible spending on interactions between the
            share of calendar months between February 2006 and December
            2007 during which each household used SNAP and calendar month
            indicators, with the January 2008 interaction normalized to
            zero. The unit of observation is the household-month and only
            months from January 2008 to December 2009 are included in the
            regression. Error bars and shaded region represent R2
            coefficient standard errors. Standard errors are clustered by
            household. Each regression includes household and calendar
            month fixed effects. Each coefficient series is seasonally
            adjusted by subtracting from each coefficient the corresponding
            coefficient from an auxiliary regression of the dependent
            variable on interactions between the share of months between
            February 2006 and December 2007 during which each household
            used SNAP and year and seasonal month indicators. The auxiliary
            regressions include household, year, and seasonal month fixed
            effects and are estimated using only data from January 2010 to
            December 2012. Each coefficient series is shifted by a constant
            so that the observation-count-weighted mean of the regression
            coefficients is equal to the sample mean of the corresponding
            dependent variable among households who used SNAP in every
            month between February 2006 and December 2007. Vertical lines
            at October 2008 and April 2009 denote the implementation dates
            of changes in SNAP benefits due to the farm bill and American
            Recovery and Reinvestment Act (ARRA), respectively.
                                   Exhibit 2
    Incentivizing Nutritious Diets: A Field Experiment of Relative Price
            Changes and How They Are Framed
    John Cawley, Andrew S. Hanks, David R. Just, Brian Wansink
    Working Paper 21929
    http://www.nber.org/papers/w21929

        We gratefully acknowledge financial support from the National
    Institutes of Health (NIH) grant 1RC1HD063370-01. The NIH played no
    other role in the conduct of the study. Cawley gratefully acknowledges
    support from an Investigator Award in Health Policy Research from the
    Robert Wood Johnson Foundation. The Cornell University Institutional
    Review Board approved the design of this study (Protocol
    ID#1110002491). For helpful comments and suggestions, we thank Heather
    Royer and participants at the American Society of Health Economists
    biennial conference, the NBER Summer Institute, the International
    Health Economics Association conference, the TIGER conference in
    Toulouse France, and seminar participants at the Indiana University,
    McGill University, University of Oxford, the University of
    Pennsylvania, and the University of Sydney. The views expressed herein
    are those of the authors and do not necessarily reflect the views of
    the National Bureau of Economic Research.
        At least one co-author has disclosed a financial relationship of
    potential relevance for this research. Further information is available
    online at http://www.nber.org/papers/w21929.ack.
        NBER working papers are circulated for discussion and comment
    purposes. They have not been peer-reviewed or been subject to the
    review by the NBER Board of Directors that accompanies official NBER
    publications.
        2016 by John Cawley, Andrew S. Hanks, David R. Just, and Brian
    Wansink. All rights reserved. Short sections of text, not to exceed two
    paragraphs, may be quoted without explicit permission provided that
    full credit, including  notice, is given to the source.
    Abstract
        This paper examines how consumers respond to price incentives for
    nutritious relative to less-nutritious foods, and whether the framing
    of the price incentive as a subsidy for nutritious food or a tax on
    non-nutritious food influences consumers' responses. Analyzing
    transaction data from an 8 month randomized controlled field experiment
    involving 208 households, we find that a 10% relative price difference
    between nutritious and less nutritious food does not significantly
    affect overall purchases, although low-income households respond to the
    subsidy frame by buying more of both nutritious and less-nutritious
    food.

    John Cawley,                         David R. Just,
    2312 MVR Hall,                       Cornell University,
    Department of Policy Analysis and    210C Warren Hall,
     Management and Department of        Ithaca, NY 14850,
     Economics,
    Cornell University,                  drj3@cornell.edu;
    Ithaca, NY 14853,
    and NBER,
    JHC38@cornell.edu;
    Andrew S. Hanks                      Brian Wansink,
    Ohio State University                Cornell University,
    130A Campbell Hall                   475H Warren Hall,
    1787 Neil Ave.                       Ithaca, NY 14850,
    Columbus, OH 43210                   wansink@cornell.edu.
    hanks.46@osu.edu;

    Introduction
        Diet-related chronic disease is a global problem. Worldwide, the
    annual deaths due to high blood pressure total 7.5 million, high blood
    glucose (diabetes) 3.4 million, overweight and obesity 2.8 million, and
    high cholesterol 2.6 million (WHO, 2009). In the U.S., 37% of the adult
    population has cardiovascular disease, 16% has high total blood
    cholesterol, 34% has hypertension, 11% has diabetes, and it is
    estimated that 41% will be diagnosed with some form of cancer during
    their lifetime (USDA, 2010). Moreover, 35.1% of adults and 16.9% of
    youths in the U.S. are obese (Ogden, et al., 2014). Even in low-income
    countries, the top ten risk factors for preventable death include high
    blood pressure, high blood glucose, and high cholesterol (WHO, 2009).
    The problems with many modern diets, which contribute to these high
    rates of chronic disease (McCullough, et al., 2002), are that they
    contain too much saturated fats, cholesterol, added sugars, added
    sodium, and refined grains, and too little whole grains and fresh
    fruits and vegetables (USDA, 2010).
        As a result of the high rates of chronic disease, there have been
    calls for taxes on energy-dense less-nutritious foods from many medical
    and public health organizations, such as the World Health Organization
    (2015), U.S. Dietary Guidelines Advisory Committee (2015), British
    Medical Association (2015), Institute of Medicine (2009), and the
    International Obesity Task Force (2005), which urged all European Union
    member countries to enact taxes on energy-dense foods. There have also
    been numerous calls in medical journals for taxes to incentivize a
    healthy diet (e.g., Brownell and Frieden, 2009, and Jacobson and
    Brownell, 2000). Taxes on energy-dense foods are arguably the most
    commonly-advocated anti-obesity policy.
        Policymakers worldwide have responded to this call for action.
    Numerous countries, such as Australia, Canada, Denmark, Fiji, Finland,
    France, Hungary, Norway, and Mexico, have recently implemented taxes on
    energy-dense, less-nutritious foods (see e.g., World Health
    Organization, 2015, Sassi, et al., 2013, and Thow, et al., 2011). In
    the U.S., 34 states tax soft drinks sold in grocery stores, at an
    average rate of 4.02%, and 15 states tax snacks sold in grocery stores
    at an average rate of 1.2% (Chriqui, et al., 2008). In early 2015,
    Berkeley, California became the first U.S. city to impose an excise tax
    on sugar-sweetened beverages (Cawley and Frisvold, 2015).
        To some extent, an individual's diet and any resulting chronic
    disease or premature mortality can be seen as a private, individual
    decision. However, there are two economic rationales for government
    intervention to incentivize healthier diets. First, there are external
    costs of a poor diet that operate through private and public health
    insurance (Cawley, 2015). Premiums that fund private health insurance,
    and the taxes that fund public health insurance, are not a function of
    diet, and as a result, the costs of treating diet-related chronic
    disease are borne not only by those with the disease but also by others
    in the same insurance pools and by taxpayers. The exact magnitude of
    these external costs is not known, but they are undoubtedly large given
    the enormous medical care costs. Indeed, it is estimated that the
    annual direct medical care costs total $273 billion for cardiovascular
    disease (CDC, 2015a), $315.8 billion for obesity (Cawley, Meyerhoefer,
    et al., 2015), $116 billion for diabetes (CDC, 2015b), and $263.8
    billion for cancer (this includes both direct and indirect costs; CDC
    2015c). To pool these separate estimates would result in some degree of
    double-counting, but the overall cost of these diseases is clearly very
    high.
        Behavioral economics offers a second rationale for government
    intervention to incentivize healthier diets. Individuals may have time-
    inconsistent preferences; they may want to eat a nutritious diet so as
    to be healthy in the future, but in the short run may be tempted by
    immediate gratification (Laibson, 2014). Some have argued that optimal
    taxes should reflect not only externalities but also internalities
    associated with time-inconsistent preferences, and that in such cases
    sin taxes can make those who engage in such activities happier because
    it helps them help themselves (Gruber and Mullainathan, 2005).
        Whether or not food taxes and subsidies are effective is an
    empirical question. However, it is challenging to estimate the effect
    of existing food taxes on purchases and consumption. In the U.S.,
    state-level taxes are so small that it is very difficult to measure
    their effects (Fletcher, Frisvold, and Tefft, 2010; Chaloupka, et al.,
    2011; Fletcher, et al., 2011). For national taxes, it is difficult to
    disentangle the effect of the tax from time effects; i.e., it is hard
    to identify a geographic control group. For both, policy endogeneity is
    a problem.
        As an alternative approach, researchers have used field experiments
    to measure consumer responsiveness to price changes. For example, the
    USDA's Healthy Incentives Pilot for recipients of the Supplemental
    Nutrition Assistance Program (SNAP) offered a 30 rebate to the
    Electronic Benefit Transfer card for each dollar spent on fruits and
    vegetables. The program resulted in 0.22 cups/day more fruits and
    vegetable consumed by participating adults (USDA, 2013). Other field
    experiments paired their price changes with related interventions such
    as signs or marketing, the effect of which is confounded with the price
    change. For example, a set of experiments conducted by researchers at
    the University of Minnesota manipulated prices in cafeterias and
    vending machines (but also increased signage) and found that a 50%
    subsidy for fruits and salads tripled sales, but sales fell to baseline
    after the subsidy was removed (French, et al., 1997; Jeffrey, et al.,
    1994). Elbel, et al. (2013) opened their own store in a hospital, and
    imposed a 30% tax on unhealthy foods, which they juxtaposed next to
    healthier alternatives. They estimate that the tax increased the
    probability of consumers choosing healthier alternatives by 11
    percentage points. The generalizability is unclear given that the store
    was a researcher-created environment that involved deliberate
    juxtapositioning of healthier and less healthy options.
        This paper contributes to the literature that uses field
    experiments to measure consumer responsiveness to changes in food
    prices. A review of the literature by Epstein, et al. (2012) finds only
    four studies that manipulated prices of foods in supermarkets; all
    provided discounts for healthy foods, and three of the four examined
    only purchases of a subset of available foods. Other experiments
    manipulating food prices took place in laboratories, cafeterias and
    restaurants, farmer[s'] markets, and vending machines (Epstein, et al.,
    2012). In a recent study, nutritious foods were subsidized 12.5% or 25%
    and less-nutritious items were taxed 12.5% or 25%, depending on the
    treatment, in a simulated online market place with 6000 food items.
    Calories purchased of taxed foods decreased and calories purchased of
    subsidized foods increased, but overall calories did not change between
    baseline and price change interventions, suggesting substitution of
    calories towards foods neither taxed nor subsidized. Yet, there is
    evidence of improved nutrient quality of foods purchased in the subsidy
    condition (Epstein, et al., 2015).
        Another relevant recent study is that of List, Samek, and Zhu
    (2015). They conducted a field experiment at a grocery store in a high-
    poverty area of Chicago. They enlisted 222 participants for a 6.5 month
    study and examined the effect of two treatments: $1 incentive to
    purchase at least 5 cups of fresh fruits and vegetables on their
    shopping trip, and information on preparing fruits and vegetables. They
    find little effect from the information, but find large effects of the
    incentives (it doubles purchases of fresh fruits and vegetables) that
    persist after the incentives end.
        The contribution of this research is to estimate the responsiveness
    of consumers to a price change--with no other interventions such as
    additional signage or juxtapositioning of alternatives--in the
    consumer's usual retail environment. In other words, we observe
    consumers buying their usual items in the supermarket in which they
    typically shop. We observe all food purchases made at the supermarket
    (and provide incentives for subjects to do all of their food shopping
    at the supermarket), and we rely on an objective system that classifies
    food as nutritious and less-nutritious and which is already in place in
    the supermarket.
        We conduct a randomized controlled field experiment in order to
    measure the impact of a 10% relative price difference between
    nutritious and less-nutritious food in order to answer three research
    questions: (1) Are consumers' food purchases responsive to less-
    nutritious food being made 10% more expensive than nutritious food? (2)
    Does that responsiveness depend on whether the price change is framed
    as a tax on less-nutritious food, a subsidy for nutritious food, or
    both? (3) Do the answers differ by the education or income of the
    consumer?
        We hypothesize that the relative price change will decrease
    purchases of less-nutritious foods and increase purchases of nutritious
    foods. We also hypothesize that those told that the 10% price
    difference is a tax will respond more, relative to those who are told
    that the 10% price difference is a subsidy; this is motivated by
    prospect theory, which posits that people interpret gains and losses
    relative to a reference point (Kahneman and Tversky, 1979). In
    particular, people may respond more when the tradeoff is framed as a
    loss rather than a foregone reward (Gachter, et al., 2009; Homonoff,
    2015), which suggests that people may be more responsive to the frame
    of a tax on less-nutritious food than that of a subsidy for nutritious
    food.
        Additionally, we hypothesize that responses to the relative price
    change may differ by socioeconomic status, measured by income and
    education, though the direction of the response is unclear. Consumer
    response may differ by income for several reasons. Mullainathan and
    Shafir (2013) argue that poverty consumes mental bandwidth, which
    implies that lower-income individuals may pay less attention to the
    price change. On the other hand, other evidence suggests that lower-
    income individuals may be more responsive to the relative price change.
    Low-income individuals who receive public assistance (such as food
    stamps or social security) exhibit ``first of the month effects''--
    their spending on food decreases as the month progresses (Hastings and
    Washington, 2010; Shapiro, 2005). This suggests that they may be credit
    constrained and perhaps price reductions could have substantial income
    effects. Furthermore, other research suggests that the income
    elasticity of body weight is greater for low-income individuals (Akee,
    et al., 2013; Schmeiser, 2009).
        Second, consumer response may also differ by education. The better
    educated tend to demand more health and be more efficient producers of
    their own health (Grossman, 1972) and thus may have a more elastic
    demand for nutritious food. In addition, the better educated may simply
    better understand the treatment or respond to changing prices in
    general.
    Data and Methods
    The Field Experiment
        Controlled field studies with random assignment have the potential
    to clearly identify causal effects (List, 2009, 2011) and can have high
    levels of both internal and external validity (Roe and Just 2009).
    Thus, these types of studies can be uniquely effective for measuring
    the impact of potential policy instruments.
    Identifying Nutritious and Less-Nutritious Foods
        Any experiment designed to manipulate the prices of nutritious and
    less-nutritious foods faces the challenge of defining those two
    categories. We relied upon a supermarket shelf-label nutrition guidance
    system that had already been in place in the supermarket for several
    years prior to this experiment.* \2\ This proprietary system, called
    Guiding Stars, scores foods based on their nutritional value. More
    specifically, it takes into account vitamins, minerals, fiber and whole
    grains (which raise the score) and saturated fat, trans fat,
    cholesterol and added sugar and sodium (which lower the score).
    Ultimately, foods are rated on a scale from zero stars (poor
    nutritional value) to three stars (best nutritional value), and this
    score is displayed on the supermarket shelf label below each food item
    (retail price and unit price). Over 60,000 food items are rated. The
    few foods that are not rated are new (and thus not yet rated), seasonal
    (not consistently available), or have no calorie or nutrient content
    (such as dried spices or dried coffee or tea). For more information on
    Guiding Stars, see Fischer, et al. (2011).
    ---------------------------------------------------------------------------
        * Editor's note: There is no footnote no. 1 in this working paper,
    as submitted.
        \2\ Sales data suggest that consumers use and respond to the
    Guiding Stars information; see Cawley, Sweeney, Just, et al. (2015).
    However, this information was in place well before and throughout the
    experiment and is thus not confounded with the treatment effects we
    estimate.
    ---------------------------------------------------------------------------
        For our experiment, we defined less-nutritious food as that which
    receives zero stars, and defined nutritious food as that which receives
    any stars (one, two, or three). An incentive scheme could offer more
    finely-tuned subsidies based on whether the item received one, two, or
    three stars, but that would also involve the tradeoff of increased
    complexity that could cause confusion for study participants. We chose
    to make the intervention simple to understand, and divided foods into
    those with zero stars (which were made relatively more expensive) and
    those with one or more stars (which were made relatively cheaper).\3\
    Of the rated food items observed in our data, 29% have at least one
    star and are thus classified as nutritious.
    ---------------------------------------------------------------------------
        \3\ The prices of unrated items were not altered.
    ---------------------------------------------------------------------------
    Participation and Incentives
        Between May 1 and June 30, 2010, we recruited 239 loyalty card
    shoppers to participate in the study. Individuals were recruited via
    face-to-face contact at the entrances to two grocery stores in upstate
    New York. These stores are part of a regional supermarket chain that is
    located in the Northeast U.S. In order to ensure a diverse set of
    participants, subjects were recruited at various days and times, as
    well as at two different stores of the same chain in neighborhoods of
    differing socioeconomic status. In addition, to be eligible for
    inclusion in the study, participants had to have children under the age
    of 18 years living at home, do at least 75% of their shopping at the
    supermarket chain, and do a majority of the household's shopping.
        After enrollment, subjects were sent an e-mail with a link to
    complete a survey on their household characteristics and shopping
    patterns. After repeated requests, fourteen subjects did not complete
    the survey and were dropped. One household later attrited from the
    study and so we drop data for that household. In 16 households, two
    individuals claimed to each do \1/2\ of the household's shopping. Both
    were enrolled but purchases were aggregated to the household level. As
    a result, we have complete information, survey responses and
    expenditure data, for 208 households.
        Soon after enrollment, participating households received two
    cards.\4\ A scanner card (with the subject's name and photograph) was
    used to track purchases at the supermarket checkout lane. A debit card
    was used to deliver incentives and subsidies, which were electronically
    credited on a weekly basis. We observed households' food purchases
    (through their use of the scanner card) for a total of 33 weeks,
    including an 8 week baseline period before the relative prices of
    nutritious and less-nutritious foods were altered.\5\ To encourage
    households to conduct all of their food shopping at the participating
    supermarket, during this baseline period, they received a 10% discount
    on purchases of all rated food items, defined as any foods rated with
    0, 1, 2, or 3 stars.
    ---------------------------------------------------------------------------
        \4\ In the 16 households in which two members enrolled in the
    study, each enrollee received his/her own set of cards.
        \5\ Households signed up 5-8 weeks before the treatment period;
    thus, we have baseline data for every household for at least 4 weeks
    and up to 8 weeks for some households.
    ---------------------------------------------------------------------------
    Treatment Conditions
        At the conclusion of the baseline period, subjects were randomized
    into one of four groups. The control group (N=52 households) continued
    to receive a 10% discount on all rated food items. For the treatment
    group (N=156), nutritious food was made 10% cheaper than less-
    nutritious food. How this price wedge was framed differed based on the
    treatment group into which the subject was randomized. The tax group
    (N=51) was told that they received a 15% discount on all rated food
    items, but were taxed 10% (and thus received only a 5% discount) on
    less-nutritious food. The subsidy group (N=55) was told it received a
    5% discount on all rated food items, plus an additional 10% subsidy on
    nutritious food, for a total of 15% off nutritious food. The tax/
    subsidy group (N=50) was told that it received a 10% discount on all
    rated food items, plus an additional 5% subsidy on nutritious food (for
    a total subsidy of 15%) but was taxed 5% on less-nutritious food (for a
    net subsidy of 5%). In all three treatment conditions, nutritious food
    was subsidized 15% and less-nutritious food was subsidized 5%; thus
    each group faced a 10% price wedge between nutritious and less-
    nutritious food. The only way the treatments differed was in how that
    relative price difference was framed.
        Households were notified of their respective treatment via e-mail
    and phone calls. Out of concern that subjects may not check their e-
    mail or voice messages, the enrolled representative from each household
    was also individually contacted by phone and notified directly; this
    process took 12 days. We removed these 2 weeks from analysis because
    some subjects during that time may not have yet been aware of their
    treatment condition.
        In a voluntary field experiment, it is not possible to impose taxes
    on less-nutritious foods greater than the participation incentive, or
    subjects would likely buy these foods elsewhere and such expenditures
    would not be recorded as part of the study. To address this, the
    participation incentive was always greater than the tax imposed,
    ensuring that shoppers could not be worse off by shopping at the study
    stores. Because the participation incentive was also offered during the
    baseline period, we are able to identify the effect of price changes
    using the relative price changes between nutritious and less-nutritious
    foods that were imposed between the baseline and treatment periods. See
    Table 1 for the relative price changes at baseline and during the
    treatment period, and details of the framing of the treatment.
        To clarify, prices on the supermarket shelves were not altered. The
    participating supermarket was understandably unwilling to allow the
    researchers to manipulate shelf prices for all of their customers.
    Instead, subjects' purchases were tracked using the scanner cards, and
    the discounts, net of taxes, were uploaded weekly to the debit card. To
    ensure the salience of the price changes, each subject received a
    weekly e-mail notifying them of the amount of incentive or subsidy they
    had received, and reminding them which foods were taxed and which were
    subsidized. We acknowledge that this may affect the generalizability of
    these results, an issue we return to in the Discussion. The treatment
    period lasted for 25 weeks and ended without prior notice. See Figure 1
    for a detailed timeline of the study.
    Data
        Itemized grocery purchases of each subject were tracked by the
    supermarket for the entire 33 weeks of the study using the scanner
    cards. The item-level transaction data include: date, quantity of item,
    expenditures on item, Guiding Stars score of each item (0, 1, 2, or 3
    stars), and the description of the item. These transactions were
    aggregated by household and week, with weeks defined as Monday through
    Sunday. We merge the information from the baseline survey with the
    transaction data.
        We focus on two main outcomes: the household's expenditures
    (defined before any subsidies or taxes applied by the experiment) and
    quantity purchased. Quantity purchased is measured in units, which is a
    limited measure because it does not account for size differences. For
    example, a \1/2\ gallon and a gallon of milk each count as one unit, as
    do two different-sized boxes of the same cereal. Thus, this measure of
    quantity is a noisy measure of the quantity of food purchased. We
    examine these two outcomes for all food purchases, as well as
    separately for nutritious food and less-nutritious food.
        If a household did not buy any food in that category in that week,
    the values of expenditures and quantity purchased are set to zero. The
    exception to this occurred during the first 3 weeks of the baseline
    period when households were still being enrolled in the study. During
    these 3 weeks, weeks with no expenditures were treated as missing until
    the household recorded their first shopping trip.
    Hypotheses and Empirical Methods
        We test the following hypotheses:

              H1: Increasing the price of less-nutritious food relative to
            the price of nutritious food will decrease purchases of less-
            nutritious food and increase purchases of nutritious food;
              H2: Framing the relative price change as a subsidy for
            nutritious food will increase the extent to which the price
            change increases purchases of nutritious food;
              H3: Framing the relative price change as a tax on less-
            nutritious food will increase the extent to which the relative
            price change decreases purchases of less-nutritious food;
              H4: These effects will vary by income and education.

        In order to test these hypotheses, we estimate difference-in-
    differences models of expenditures and quantities. Randomization into
    the treatment and control groups allows for interpretation of the
    difference-in-differences estimator as a causal effect of the
    treatment. We first estimate these models assuming no framing effects
    and thus pool all three treatment conditions--tax, subsidy, and tax/
    subsidy--into a single treatment condition. We then subsequently
    estimate the models testing for framing effects, with each of the three
    frames as a separate treatment.
        To estimate the average effect of the price change, ignoring the
    possibility of framing effects, we estimate the following two-way fixed
    effects model:
    (1)
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    The data are aggregated by household (h) and week (w). The difference-
    in-differences estimator is b0. This coefficient measures
    the change between the baseline and treatment period for the treatment
    group relative to the control group. In order to control for time-
    invariant unobserved heterogeneity among households, the model controls
    for household fixed effects Ih. In order to control for time
    effects, such as the seasonal availability of fresh fruits and
    vegetables and changes in demand due to holidays, the model controls
    for week fixed effects Iw. The OLS regression model is
    estimated for all food purchases, as well as separately for purchases
    of nutritious food and less-nutritious food. The null hypothesis is
    that the 10% price wedge has no impact on purchases: b0=0.
    To account for possible correlation in errors for the same household
    over time, standard errors are clustered by household.
        In order to test whether the framing of the price change affects
    consumers' response to the price change, we estimate the following
    model, which estimates a separate difference-in-differences effect for
    each of the three treatment groups (tax, subsidy, tax and subsidy):
    (2)
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    The null hypothesis is that the framing of the treatment as either a
    tax on less-nutritious food, a subsidy of nutritious food, or both,
    does not alter the treatment effect; i.e., that
    b1=b2=b3.
        To test whether the treatment effect varies by income, we estimate
    models (1) and (2) separately for those whose household income is (a)
    below or (b) above 130% of the Federal Poverty Line (FPL), which is the
    eligibility threshold for the Supplemental Nutrition Assistance Program
    (SNAP) and is close to the eligibility threshold for Medicaid (133% of
    FPL).
        To test whether the treatment effect varies by education, we
    estimate the model separately for those whose educational attainment is
    (a) a high school degree or less or (b) some college or more.
        We emphasize that, given our overall sample size, we have limited
    statistical power for subgroups. When we divide the sample by income,
    we have 36 households below and 155 households above 130% of the FPL.
    When we divide the sample by education, we have 18 participants with a
    high school education or less, and 182 participants with some college
    or more education (see Table 2). These subtotals do not sum to our
    total of 208 households because of non-response to the questions about
    income and education.
    Empirical Results
    Summary Statistics
        Tables 2 and 3 list summary statistics for the study participants,
    with columns for the whole sample, control group, all treatment groups
    pooled, and each treatment group separately. Table 2 reports sample
    sizes for the socioeconomic subgroups. Tables 3a and 3b report summary
    statistics for additional household characteristics, such as income,
    number of children at home, household size, marital status, and race/
    ethnicity, which are all controlled for in our model through the
    inclusion of household fixed effects.
        The summary statistics indicate that our sample is relatively well
    educated (91% have more than a high school education) and white
    (93.7%). This is a reflection of the fact that our sample consists of
    individuals in upstate New York and the participating supermarket chain
    is relatively high-end. By construction, all families have at least one
    child under the age of 18 years in the household.
        Table 4 lists unconditional weekly expenditures on foods (overall,
    all rated, less nutritious, nutritious) for the entire sample and by
    group (control, all treatment, each treatment group). Household weekly
    food expenditures at this supermarket averaged $89.83 during the
    baseline period, and $100.88 during the treatment period. In
    comparison, data from the Consumer Expenditure Survey indicate that on
    average U.S. households spent $76 per week on food purchased for at-
    home consumption in 2013 (BLS, 2015). Notably the BLS estimate is
    unconditional, whereas our sample consists of households with at least
    one child under the age of 18 years, and are thus likely to be above-
    average in terms of food expenditures.
        The increase in average weekly food expenditures for all treatment
    groups ($10.95) is roughly equal to that for the control group
    ($11.32); this unconditional difference-in-differences suggests that
    the treatment did not significantly affect overall expenditures on
    food. The increase in expenditures on nutritious food was also similar
    for all treatment groups pooled ($4.69) and the control group ($3.30).
    Overall Effect of Relative Price Change
        Table 5 lists results of the difference-in-differences models for
    expenditures and quantities. Our hypothesis is that the 10% relative
    price change increased the quantity demanded of nutritious food, and
    decreased the quantity demanded of less-nutritious food. Table 5 shows
    that the point estimates of the coefficients are consistent with these
    hypotheses, but the coefficients are not statistically significant. For
    example, we find that creating a 10% price difference between
    nutritious and less-nutritious foods raised spending on nutritious food
    by $1.11 per week and lowered spending on less nutritious food by $1.55
    per week, neither of which is statistically significant. On net,
    spending on all food rated by Guiding Stars (whether nutritious or less
    nutritious) fell by $0.44 per week, which was not statistically
    significant. In terms of quantities, the 10% relative price difference
    increased weekly purchases of nutritious food by 0.95 units and lowered
    weekly purchases of less nutritious food by 0.87 units; overall
    purchases of foods rated by Guiding Stars rose by .08 units. None of
    those changes are statistically significant.
        In summary, we are unable to reject the null hypothesis of no
    effect of the relative price change on purchases of nutritious and
    less-nutritious foods.
    Effect of Framing of Relative Price Change
        Next we test whether the effect of the relative price change
    differed by the way in which it was framed: as a tax on less-nutritious
    food, a subsidy for nutritious food, or both. It is possible that,
    because of loss aversion, the tax frame may exhibit a greater treatment
    effect than the subsidy frame. Moreover, given the difference in
    salience, we may see a greater increase in purchases of nutritious food
    for the subsidy frame, but a greater decrease in purchases of less-
    nutritious food for the tax frame.
        Table 6 presents the results of the difference-in-difference models
    that estimate separate effects by frame. In no case are the treatment
    effects significantly different across frames (whether tax versus
    subsidy, tax versus tax/subsidy, or subsidy versus tax/subsidy). In
    addition, no estimated treatment effect for nutritious or less-
    nutritious food is significantly different from zero. However, some
    point estimates are substantial; e.g., the effect of the relative price
    change for those in the tax frame to increase their weekly purchases of
    nutritious food by $4.52 (relative to a mean of $36.55) and for those
    in the tax/subsidy frame to decrease their weekly purchases of less
    nutritious food by $4.40 (relative to a mean of $49.59).
        In summary, we are unable to reject the null hypothesis of no
    framing effect for the relative price change.
    Differences by Income and Education
        In our next analyses, we test whether the overall price treatment
    effects differed by income or education. For the sake of simplicity, we
    report results for expenditures (but not those for quantities). Table 7
    presents results of the overall price treatment effects separately for
    households with incomes below and above 130% of the Federal Poverty
    Line.
        Although the difference in results across income was not
    statistically significant, the point estimates suggest that the
    treatment was associated with lower-income households spending $7.03
    more per week on nutritious food and $7.11 more per week on less-
    nutritious food. In contrast, higher-income households spent $1.27 less
    on nutritious food per week and $4.02 less on less-nutritious food per
    week. None of these point estimates are statistically significant.
        Table 8 presents the results of models estimated separately by
    education. Again, we find no statistically significant difference
    between the effect of the relative price change for the two
    socioeconomic groups. Moreover, the difference in point estimates is
    considerably smaller across education groups than across income groups.
        We next test whether framing effects differed by income or
    education. Table 9 reports results for the model that estimates
    treatment effects by frame, with the model estimated separately by
    income category. There are large and statistically significant
    differences in the effects of the frame by income. Specifically, low-
    income households that were given the subsidy frame (i.e., told that
    the 10% relative price change represented a subsidy for nutritious
    food) significantly increased their purchases of less-nutritious food
    (by $21.23 per week). The increase in purchases of nutritious foods was
    $11.58, but not statistically significant. Overall, purchases of foods
    rated by Guiding Stars rose $32.81 per week on average for this group.
        In contrast, higher-income households that were given the subsidy
    frame decreased their weekly purchases of both nutritious food ($4.55)
    and less-nutritious food ($7.55), although these are not significantly
    different from zero. The effects of the price change on less nutritious
    foods and all rated foods are, however, significantly different for the
    low-income and high-income groups given the subsidy frame.
        In addition, within each income group, there is a significant
    difference in framing effects. As stated above, the low-income
    individuals given the subsidy frame significantly increased their
    purchases of less-nutritious food (by $21.23 per week); in contrast,
    the low-income individuals given the tax frame decreased their
    purchases of less-nutritious food (by $9.04, which is not statistically
    significant). That difference across frames is statistically
    significant. The responses of the tax and subsidy frame among the low-
    income participants also significantly differed for expenditures on all
    rated items, unrated items, and all items. They did not significantly
    differ in their treatment effect on expenditures on nutritious foods.
        Table 10 presents results for models that estimate treatment
    effects by frame, with the models estimated separately by education
    category. There are no statistically significant differences in framing
    effects by education. Moreover, within educational group there are no
    statistically significant differences in framing effects; i.e., we
    cannot reject the null hypothesis that the effect was the same for each
    treatment group or frame.
        In summary, we find significant differences in framing effects by
    income. Specifically, the treatment effect is much greater for the low-
    income households given the subsidy frame than those given the tax
    frame; they buy more of even what the relative price change was seeking
    to discourage: less-nutritious food.
    Extension: Permutation Tests
        Given our sample size (208 households' weekly purchases over 8
    months) we seek additional confirmation of both the result of
    significant treatment effects among low-income households given the
    subsidy frame, and the inability to reject the null of no effect for
    the overall sample. To that end, we conducted permutation tests
    (Kaiser, 2007) in which households were randomly re-labeled as being in
    one of the three treatment groups or the control group, after which the
    expenditure models were re-estimated. This was repeated 1,000 times and
    we compare the statistical significance of the treatment effect in our
    primary models to the distribution of treatment effects estimated in
    the 1,000 permutations. A p value of (e.g.) 0.05 indicates that only 5%
    of the permutations yielded more statistically significant results than
    our primary models, which would suggest that the original result was
    not due to chance.
        The results of the permutation tests are provided in Appendix
    Tables 1-3. In general, these results confirm both of our major
    findings. First, for the overall sample we cannot reject the null
    hypothesis of no effect of the price change treatment. Appendix Table 1
    shows that, for both nutritious and less-nutritious foods, 70% or more
    of the permutations yielded more statistically significant treatment
    effects than the ones estimated in our primary model. Table 2 shows
    that the permutation tests are also consistent with our inability to
    reject the null hypothesis of no effect of framing for the overall
    sample. Appendix Table 3 shows that the permutation test confirms our
    finding of a significant positive effect of the treatment for low-
    income households given the subsidy frame; specifically, the
    permutation test p value is 0.056, indicating that the finding in our
    primary model is more significant than 94.4% of the permutations based
    on random re-labeling of groups. The result for the purchase of
    nutritious foods by the low-income households given the subsidy frame
    falls just short of statistical significance (p=.102).
        Overall, the results of the permutation test confirm the earlier
    results--we cannot reject the null of a zero treatment effect for the
    overall sample, and we find evidence that low-income households given
    the subsidy frame buy significantly more less-nutritious foods.
    Extension: Share of Purchases that was Nutritious
        As another extension, we examine the proportion of expenditures on
    nutritious foods (the denominator includes expenditures on all rated
    foods). Table 11 presents results for the difference-in-differences
    model in which the dependent variable is the percent of expenditures
    that was on nutritious foods. The effect of the relative price change
    was to increase the share of expenditures devoted to nutritious food by
    1.08 percentage points, relative to a mean of 42.5%. However, this
    increase was not statistically significant. Subsequent columns in the
    table list the effects for high and low-income, and the high and low
    education groups. In each case the change in the percent of nutritious
    purchases resulting from the tax is small and not statistically
    significant.
    Extension: Purchases of Unrated Foods
        As described in the Data section, the Guiding Stars system rates
    virtually all foods in the supermarket. Those that are not rated
    include items that are new and have simply not yet been rated, or
    seasonal and therefore not consistently available. However, foods that
    have no calorie content are also not rated. This includes some items
    that are relatively uninteresting from a health perspective (e.g.,
    dried spices) but it also includes bottled water, alcoholic beverages,
    and dried tea and coffee. These are of interest because after the
    relative price change consumers may shift away from sugar-sweetened
    beverages to these other drink options. In order to test for any such
    effects, we estimate difference-in-differences models of expenditures
    and quantities purchased in that category. The results appear as
    additional columns in each of the earlier tables. We also include a
    column for All Items, which includes not just rated foods but also
    unrated foods.
        Table 5 shows that the main effect of the treatment is a very small
    change in weekly expenditures on unrated items ($0.81), which is not
    statistically significant. However, the treatment results in an
    increase in the quantity of unrated foods purchased per week of 0.66
    units, which is statistically significant. Table 6 provides information
    on the effect of the framing of the relative price change. In five out
    of six cases, the effect of the treatment on purchases of unrated food
    items is not statistically significant; the exception is that those
    given the subsidy frame purchased 0.92 more units of unrated food per
    week. The results in Table 9 indicate that this effect is concentrated
    among the lower-income households in the subsidy frame, who increased
    their purchases of unrated food items by $5.78 per week.
    Extension: Change in Treatment Effects over Time
        The dynamics of treatment effects can be interesting; a large
    initial effect that falls over time could be due to novelty or
    salience, while a small initial effect that increases over time is
    consistent with habit formation. To investigate this, we estimated our
    model of the overall treatment effect (i.e., ignoring framing effects)
    for each week, and plot the results in Figure 1. Although our sample
    size precludes us from drawing strong conclusions, the negligible
    effect in the first 7 weeks of the treatment, combined with the larger
    treatment effects later in the treatment period, are consistent with
    gradual habit formation.
    Robustness Checks
        To verify our initial results, we conduct a variety of additional
    robustness checks. First, we re-estimate our models excluding the
    baseline data and find very similar results. Second, we estimate our
    original difference-in-differences models dropping the weeks with
    holidays (Thanksgiving, Christmas, and New Year's); the main difference
    is that the treatment effect is significant for low-income households'
    spending on nutritious foods (it rises by $9.43 per week). This is
    concentrated among the low-income households given the subsidy frame,
    who increase their spending on nutritious food by $16.80 per week.
    Third, most of the subjects are women, so we drop the men and re-
    estimate the models using only the female subjects. The main difference
    is that the results for higher-income households become more
    significant; e.g., the high-income households in the subsidy frame
    decrease their spending on nutritious food ($8.87 less per week), less
    nutritious foods ($10.93 less per week), all rated foods ($19.80 less
    per week) and all items ($20.45 less per week). Fourth, we sought to
    investigate the large treatment effects exhibited by the low-income
    households given the subsidy frame. In particular, we investigated
    whether these households were buying non-perishables (stocking up for
    future consumption) or were buying perishables (for immediate
    consumption). Estimating our models separately for expenditures on
    perishables and non-perishables, we find that the low-income households
    given the subsidy frame generally bought more of everything, but the
    increases were statistically significant for perishables that were
    nutritious and less-nutritious, and for non-perishables that were less-
    nutritious. In other words, the low-income households given the subsidy
    frame were not just using the treatment as an opportunity to ``stock
    up''; they were also buying more perishables for immediate consumption.
    Extension: Subjects' Interpretations of the Relative Price Change
        In order to better understand why there might be framing effects,
    we examine the results of a survey we administered to study
    participants after the treatment period ended. Participants were asked
    how they interpreted the treatment. Specifically, they were presented
    with seven statements describing the treatment, and were asked to rate
    their agreement with each of them on a Likert scale that ranged from 1
    (strongly disagree) to 9 (strongly agree). Table 12 presents the
    unconditional mean responses for the entire sample as well as the
    control group, the entire treatment group, and each treatment group
    separately.
        One important result that stands out is that participants, no
    matter what their frame, tended to interpret the relative price change
    as a subsidy for nutritious food rather than a tax on less-nutritious
    food. For example, for the sample as a whole, the mean agreement that
    the debit card payments were a ``reward for eating healthy food''
    averaged 6.2 on the nine-point scale, whereas ``penalty for eating
    unhealthy food'' averaged 2.9. In addition, for the sample as a whole,
    the mean agreement that it represented a ``discount for eating healthy
    foods'' was 6.4 out of 9, whereas the agreement that it was a ``tax on
    unhealthy foods'' was 3.4 out of 9.
        This is not to say that the framing had no effect on subjects'
    perceptions. There was a statistically significant difference in the
    mean agreement that the treatment was a ``penalty for eating unhealthy
    food'' (3.4 in the tax frame versus 2.4 in the subsidy frame) as well
    as in the mean agreement that the treatment was a ``tax on unhealthy
    foods'' (3.7 in the tax frame versus 2.8 in the subsidy frame). Thus,
    the frame did have a detectable effect on perceptions of the treatment,
    but participants in all groups tended to interpret the treatment as
    more of a subsidy of nutritious food than a tax on less-nutritious
    food.
    Extension: Subjects' Interpretations of their Change in Shopping During
            Treatment
        In the survey conducted after the treatment concluded, subjects
    were also asked whether or not participating in the study influenced
    their shopping. The unconditional means by group are reported in Table
    12. Those in the treatment groups (all pooled) expressed greater
    agreement with the statements that they were buying more starred
    (nutritious) foods, more healthier foods, and a higher percentage of
    healthier foods, but the difference between the treatment and control
    groups is not statistically significant in any of those cases.
        There are significant differences in the mean response to these
    questions by frame. Specifically, those in the tax/subsidy frame tend
    to express greater agreement that the study led them to buy more
    nutritious foods, buy healthier foods, and buy a higher percentage of
    healthier foods, relative to those in the subsidy frame. Notably, we
    did not see such a difference in our data in the actual expenditures
    and quantities purchased.
    Discussion
        This paper contributes to the literature on the effects of food
    taxes and subsidies through an 8 month field experiment that created a
    10% price wedge between nutritious and less-nutritious foods. We find
    that, on the whole, expenditures and quantities purchased did not
    change significantly in response to the price change. The point
    estimates suggest that the treatment group spent slightly less on less-
    nutritious food and slightly more on nutritious food, but these changes
    were not statistically significant. Some of the point estimates are
    substantial in magnitude, and their lack of statistical significance is
    due in part to imprecision of the estimates and to limited statistical
    power from 208 households.
        Although we hypothesized that the framing of the relative price
    change as either a subsidy for nutritious food or a tax on less-
    nutritious food could alter the treatment effect, we find no
    significant differences in effects by frame. We do, however, find
    effects of framing by income. Specifically, lower income households to
    whom the relative price change was framed as a subsidy bought
    significantly more less-nutritious food (and more of all food) than
    low-income households to whom it was framed as a tax. Permutation tests
    are consistent with these results, suggesting that they are not due to
    chance.
        One possible explanation for lower-income households buying more of
    all food, including the relatively more expensive less-nutritious food,
    is that lower-income households may experience a large income effect of
    a price decrease. In a related finding, List, et al. (2015) estimate
    that a $1 reward for buying any fresh fruits and vegetables caused the
    patrons of a grocery store in a low-income neighborhood of Chicago to
    double their purchases of produce. Previous research has also
    documented that food purchases drop significantly in the course of the
    benefit month for low-income households (e.g., Hastings and Washington,
    2010, Shaprio, 2005) and that income increases obesity for low-income,
    but not other, households (see the review in Cawley, 2015). Another
    possibility is that poverty consumes mental bandwidth for low-income
    individuals (Mullainathan and Shafir, 2013) or causes distractions
    sufficient to result in cognitive deficits (Mani, et al., 2013), such
    that households may have misunderstood the subsidy for nutritious food
    as a general ``food subsidy.''
        Although we hypothesized that better educated individuals might
    respond differently to the treatment, we find no evidence of
    differences in the treatment effect or in the framing effects by
    education.
        Taxes on energy-dense foods are arguably the most commonly-
    advocated anti-obesity policy. The results of this paper have several
    implications for such policies to promote more nutritious diets. First,
    taxes may need to be large to change behavior. In the U.S., taxes on
    soda pop and snacks average one to four percent (Chriqui, et al.,
    2014), but we find no significant impact on expenditures or purchases
    from a ten percent relative price change. Second, price changes may
    have different impacts by income; we find that subsidies for nutritious
    food may lead low-income households to buy more of all food, including
    more of the less-nutritious food that the policy is attempting to
    discourage.
        It should be noted that even if taxes do not change behavior, these
    policy instruments can still internalize external costs, thereby
    addressing a market failure. Moreover, if consumers do not
    significantly alter their purchases, it implies that the tax results in
    relatively little deadweight loss and thus is a relatively efficient
    way for the government to collect revenue.
        Strengths of this study include a randomized controlled field
    experiment, with actual consumers making real purchases of actual
    products in their usual retail environment. Such controlled field
    experiments represent a strong design for estimating casual effects
    (List, 2009). The present study is a relatively long experiment of this
    type, with an 8 week baseline and 25 week treatment period.
        The greatest limitation of the study is the limited statistical
    power associated with observing 208 households for 33 weeks; this is
    particularly acute when studying subsamples and testing for differences
    between income or education groups. In some cases, we estimate
    substantial point estimates but because of their imprecision they are
    not statistically significant. Given our limits with statistical power,
    we cannot rule out price elasticities common in the literature.\6\
    However, the permutation tests are consistent with our main results of
    a null effect for the overall sample but that low-income households
    given the subsidy frame spend more on less-nutritious food. Another
    limitation is a lack of data from after the intervention ended;
    however, we find no significant main effects of the treatment, so there
    is little reason to look for habit persistence after the treatment
    ended.
    ---------------------------------------------------------------------------
        \6\ The 95% confidence intervals for the implied price elasticities
    of demand are quite large: ^3.5, ^10.3) for nutritious food and (2.5,
    6.2) for less-nutritious foods.
    ---------------------------------------------------------------------------
        Readers should exercise caution when generalizing from the results
    associated with this relatively white, well-educated and high-income
    sample from upstate New York. In addition, although we observe detailed
    information on food purchases, we do not observe food consumption,
    which would be informative about the health consequences of taxes on
    energy-dense foods.
        Furthermore, the effects estimated in this paper may be influenced
    by the design of the experiment. Consumer responsiveness may have been
    attenuated by the fact that the price changes were less salient than
    usual. Our relative price changes were not reflected on supermarket
    shelves; consumers had to note the number of Guiding Stars for the item
    and take into account the subsidy or tax they received. This may have
    led to less responsiveness because of the mental cost of calculating
    the relative price change, or consumers may have overlooked the price
    change at times because it was less salient (Finkelstein, 2009).
        In addition, participation and subsidies, minus taxes, were paid
    weekly, and this departure from immediacy may have also muted consumer
    responsiveness. Given that participants knew they were participating in
    a study, they may have perceived the price changes as temporary and not
    bothered changing their usual food habits.
        In this study consumers were directed to the Guiding Stars
    nutrition guidance system to determine the amount of the tax or subsidy
    (if any). Thus, there was not only a price effect but also potentially
    an effect from nutrition information. This would also be true of any
    salient tax placed on energy-dense foods, such as a ``fat tax'' or tax
    on sugar-sweetened beverages. It also implies that the consumer
    responses we estimate may be greater than those that would be observed
    from a tax on certain foods that was implemented simply for revenue
    reasons and was not directly linked to the nutrition of the items.
        Important directions for future research include estimating the
    impacts of greater price changes, testing for changes in treatment
    effects over time (they may increase due to habit formation or decrease
    due to diminishing salience or novelty), and continuing to refine how
    to frame price changes to maximize their intended impact.

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    Figure 1: Study Timeline
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Note: Weeks are defined as Monday through Sunday.
    Figure 2: Estimated Coefficients for Overall Price Treatment by Week
    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Notes: Week 11 is the first week of the intervention period
            and begins on Mon, Sep. 20, 2010. Thanksgiving occurred during
            week 20 and Christmas occurred during week 24.

               Table 1: Comparison of Treatment and Control Groups
    ------------------------------------------------------------------------
                                                                  Treatment
                            Control     Treatment    Treatment     Group 3:
                             Group       Group 1:     Group 2:   Subsidy and
                                         Subsidy        Tax          Tax
    ------------------------------------------------------------------------
    Discount on all Food          10%           5%          15%          10%
     Items as a Reward
     for Participation
    Subsidy on                     --          10%           --           5%
     Nutritious Foods
    Tax on Less-                   --           --          10%           5%
     Nutritious Foods
    Reduction in the             None          10%          10%          10%
     Relative Price of
     Nutritious vs Less-
     Nutritious Foods
    ------------------------------------------------------------------------

                   Table 2: Descriptive Measures of Household Demographic Variables Used in Regression
                                          (standard deviations in parentheses)
    ----------------------------------------------------------------------------------------------------------------
                                                                   All
                                  Whole Sample     Control      Treatment      Subsidy         Tax      Tax/ Subsidy
                                                                 Groups
    ----------------------------------------------------------------------------------------------------------------
    More than high school             91.00%        92.00%        90.70%        90.60%        91.80%        89.60%
     education
      St. dev.                        (0.287)       (0.274)       (0.292)       (0.295)       (0.277)       (0.309)
    N (> HS ed.)                     182            46           136            48            45            43
    N (5 HS ed.)                      18             4            14             5             4             5
    Above 130% of FPL                 81.20%        75.00%        83.20%        82.40%        82.60%        84.80%
      St. dev.                        (0.392)       (0.438)       (0.375)       (0.385)       (0.383)       (0.363)
    N (Above 130% of FPL)            155            36           119            42            48            39
    N (At or below 130% of FPL)       36            12            24             9             8             7
    Income > $80,000                  31.41%        27.08%        32.87%        25.49%        34.78%        39.13%
      St. dev.                        (0.465)       (0.449)       (0.471)       (0.440)       (0.482)       (0.493)
    N (Inc. > $80K)                   60            13            47            13            16            18
    N (Inc. <= $80K)                 131            35            96            38            30            28
    More than one child under 18      58.70%        59.60%        58.40%        54.70%        56.90%        64.00%
      St. dev.                        (0.494)       (0.495)       (0.494)       (0.503)       (0.500)       (0.485)
    N (> 1 child)                    121            31            90            29            29            32
    N (= 1 child)                     85            21            64            24            22            18
    ----------------------------------------------------------------------------------------------------------------
    * p<.1. ** p<0.05. *** p<0.01. Note that the asterisks represent differences of the annotated value from the
      corresponding value of the control group at the respective level of significance. FPL stands for Federal
      Poverty Line.

                                   Table 3: Additional Household Demographic Measures
                                     a. Food Assistance, Household Size, and Income
                                          (standard deviations in parentheses)
    ----------------------------------------------------------------------------------------------------------------
                                                                   All
                                  Whole Sample     Control      Treatment      Subsidy         Tax      Tax/ Subsidy
                                                    Group        Groups
    ----------------------------------------------------------------------------------------------------------------
    % Households Enrolled in WIC       4.8%          5.8%          4.5%          1.8%          2.0%         10.2%
                                      (0.215)       (0.235)       (0.208)       (0.135)       (0.140)       (0.306)
    % Households Enrolled in           4.3%          5.8%          3.9%          3.6%          3.9%          4.1%
     SNAP
                                      (0.204)       (0.235)       (0.194)       (0.189)       (0.196)       (0.200)
    % Households Not Receiving        89.9%         87.7%         90.7%         94.4%         87.3%         89.8%
     Food Assistance
                                      (0.282)       (0.318)       (0.270)       (0.205)       (0.297)       (0.306)
    Average Household Size             3.93          3.92          3.93          3.76          4.04          4.02
                                      (1.076)       (1.064)       (1.084)       (1.027)       (1.190)       (1.031)
    Average Number of Children         2.2           1.8           2.3           3.0           1.9           1.8
     Under 18
                                      (3.852)       (0.936)       (4.412)       (7.295)       (1.051)       (0.889)
    % Household Shopping at           83.58         82.09         84.07         83.15         82.24         87.02
     Hannaford
                                     (13.894)      (15.754)      (13.230)      (13.687)      (14.960)      (10.211)
    $10K-$20K                          9.4%         10.4%          9.0%         11.8%          4.1%         10.9%
                                      (0.291)       (0.309)       (0.286)       (0.325)       (0.196)       (0.315)
    $20K-$30K                         19.0%         19.5%         18.9%         19.6%         15.2%         21.7%
                                      (0.392)       (0.393)       (0.393)       (0.401)       (0.363)       (0.417)
    $30K-$40K                          9.7%         10.4%          9.4%          7.8%         13.0%          7.6%
                                      (0.294)       (0.309)       (0.290)       (0.272)       (0.341)       (0.257)
    $40K-$50K                          9.5%         12.5%          8.4%          3.9%         14.3%          7.6%
                                      (0.288)       (0.334)       (0.271)       (0.196)       (0.341)       (0.257)
    $50K-$60K                         12.2%         11.5%         12.4%         10.9%         13.5%         13.0%
                                      (0.322)       (0.314)       (0.325)       (0.303)       (0.340)       (0.341)
    $60K-$70K                         10.2%          8.3%         10.8%         12.7%          8.7%         10.9%
                                      (0.301)       (0.279)       (0.309)       (0.329)       (0.285)       (0.315)
    $70K-$80K                          4.9%          8.3%          3.7%          3.9%          2.8%          4.3%
                                      (0.213)       (0.279)       (0.186)       (0.196)       (0.153)       (0.206)
    $80K-$90K                         11.5%         10.2%         11.9%         21.6%          6.5%          6.5%
                                      (0.315)       (0.288)       (0.325)       (0.415)       (0.250)       (0.250)
    $90K-$100K                         4.7%          2.1%          5.5%          0.0%          8.5%          8.7%
                                      (0.204)       (0.144)       (0.220)       (0.000)       (0.257)       (0.285)
    >$100K                             6.4%          2.6%          7.7%          5.9%          8.7%          8.7%
                                      (0.244)       (0.148)       (0.267)       (0.238)       (0.285)       (0.285)
    ----------------------------------------------------------------------------------------------------------------
    * p<0.1. ** p<0.05. *** p<0.01. Note that the asterisks represent differences of the annotated value from the
      corresponding value of the control group at the respective level of significance.

                                   Table 3: Additional Household Demographic Measures
                                               b. Marital Status and Race
                                          (standard deviations in parentheses)
    ----------------------------------------------------------------------------------------------------------------
                                                                   All
                                  Whole Sample     Control      Treatment      Subsidy         Tax      Tax/ Subsidy
                                                    Group        Groups
    ----------------------------------------------------------------------------------------------------------------
    Divorced                           5.1%          8.0%          4.1%          5.7%          2.1%          4.3%
                                      (0.220)       (0.274)       (0.198)       (0.233)       (0.144)       (0.204)
    Married                           80.2%         74.0%         82.3%         77.2%       * 87.3%         83.0%
                                      (0.381)       (0.419)       (0.366)       (0.409)       (0.297)       (0.380)
    Separated                          1.5%          2.0%          1.4%          1.9%          2.1%          0.0%
                                      (0.122)       (0.141)       (0.116)       (0.137)       (0.144)       (0.000)
    Widowed                            9.6%         12.0%          8.8%          9.4%          4.2%         12.8%
                                      (0.295)       (0.328)       (0.284)       (0.295)       (0.202)       (0.337)
    Single                             1.0%          0.0%          1.4%          3.8%          0.0%          0.0%
                                      (0.100)       (0.000)       (0.116)       (0.192)       (0.000)       (0.000)
    African American                   1.7%          2.0%          1.6%          1.9%          0.7%          2.1%
                                      (0.125)       (0.143)       (0.119)       (0.137)       (0.047)       (0.146)
    American Indian or Alaska          0.5%          0.0%          0.7%          1.9%          0.0%          0.0%
     Native
                                      (0.071)       (0.000)       (0.082)       (0.137)       (0.000)       (0.000)
    Asian                              1.5%          2.0%          1.4%          0.0%          0.0%          4.3%
                                      (0.123)       (0.143)       (0.116)       (0.000)       (0.000)       (0.204)
    White                             93.7%         91.8%         94.3%         94.2%         94.9%         93.6%
                                      (0.214)       (0.236)       (0.207)       (0.208)       (0.162)       (0.247)
    Hispanic or Latino                 0.5%          2.0%        * 0.0%          0.0%          0.0%          0.0%
                                      (0.071)       (0.141)       (0.000)       (0.000)       (0.000)       (0.000)
    Not Hispanic or Latino            96.9%         94.0%       * 97.9%         98.0%         95.6%     ** 100.0%
                                      (0.127)       (0.193)       (0.094)       (0.089)       (0.134)       (0.000)
    ----------------------------------------------------------------------------------------------------------------
    * p<0.1. ** p<0.05. *** p<0.01. Note that the asterisks represent differences of the annotated value from the
      corresponding value of the control group at the respective level of significance.

                          Table 4: Weekly Expenditures: Unconditional Means by Treatment Group
                                          (standard deviations in parentheses)
    ----------------------------------------------------------------------------------------------------------------
                                                                   All
                                  Whole Sample     Control      Treatment      Subsidy         Tax      Tax/ Subsidy
                                                    Group        Groups
    ----------------------------------------------------------------------------------------------------------------
                                                     Baseline Period
    ----------------------------------------------------------------------------------------------------------------
    All Foods                        $89.83        $89.90        $89.81        $99.99        $81.82        $86.76
                                    (116.035)      (95.315)     (122.488)     (119.643)      (81.283)     (157.529)
    All Rated Foods                  $78.80        $78.25        $79.00        $88.59        $70.25        $77.43
                                    (105.460)      (83.229)     (112.223)     (113.315)      (69.960)     (143.396)
    Foods Rated Less Nutritious      $45.65        $44.72        $45.98        $50.73        $41.51        $45.35
                                     (62.311)      (48.867)      (66.384)      (65.884)      (43.122)      (85.031)
    Foods Rated Nutritious           $33.15        $33.52        $33.02        $37.86      * $28.74        $32.08
                                     (47.030)      (40.335)      (49.170)      (51.713)      (31.500)      (60.313)
    ----------------------------------------------------------------------------------------------------------------
                                                    Treatment Period
    ----------------------------------------------------------------------------------------------------------------
    All Foods                       $100.88       $101.22       $100.76     ** $109.56       $98.97     ** $92.91
                                    (102.566)     (108.558)     (100.503)     (102.659)      (97.627)     (100.332)
    All Rated Foods                  $88.13        $88.31        $88.08     ** $95.53        $86.33      * $81.66
                                     (89.686)      (94.830)      (87.917)      (89.599)      (85.050)      (88.394)
    Foods Rated Less Nutritious      $50.65        $51.49        $50.37        $54.65        $49.37     ** $46.68
                                     (54.582)      (57.214)      (53.681)      (53.898)      (53.374)      (53.471)
    Foods Rated Nutritious           $37.48        $36.82        $37.71     ** $40.88        $36.95        $34.98
                                     (40.427)      (42.804)      (39.606)      (41.832)      (37.198)      (39.259)
    ----------------------------------------------------------------------------------------------------------------
    Because weeks were classified as Monday through Sunday, the baseline period ended with week 8, which is the full
      week prior to households receiving notice of their treatment group. In the baseline period, values are set to
      missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study
      (by week 4), any missing value was set to zero. Since households received their notices between September 7-
      15, weeks including these dates were omitted from the analysis. As a result, the treatment period begins with
      week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01. Note that the asterisks represent differences of the annotated value from the
      corresponding value of the control group at the respective level of significance.

                                     Table 5: Overall Price Effect on Weekly Household Expenditures and Quantities Purchased
                                                                (standard errors in parentheses)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                       Expenditures                                                                  Quantities
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                         Less        All Rated                   All                      Less        All Rated
                        Nutritious    Nutritious       Items        Unrated     Items    Nutritious    Nutritious       Items        Unrated      All Items
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    All Treatment          $1.11        ^$1.55        ^$0.44         $0.81      $0.37        0.951        ^0.873         0.078       * 0.661         0.739
     Groups
                           (3.010)       (4.042)       (6.780)       (1.138)   (7.606)      (1.347)       (1.607)       (2.822)       (0.387)       (3.091)
    Weekly Dummy
     Variables                                                                      e
    N                   6,572         6,572         6,572         6,572         6,572    6,572         6,572         6,572         6,572         6,572
    Unconditional         $36.55        $49.59        $86.14        $11.86     $98.50       16.132        18.853        34.985         3.609        38.744
     mean of
     dependent
     variable
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Participants in the intervention conditions were all combined. Regression coefficients were estimated using a fixed effects regression with weekly dummy
      variables. For the sake of space, coefficients from the weekly dummy variables were not included in the table. Because weeks were classified as Monday
      through Sunday, the baseline period ended with week 8, which is the full week prior to households receiving notice of their treatment group. In the
      baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study (by
      week 4), any missing value was set to zero. Since households received their notices between September 7-15, weeks including these dates were omitted
      from the analysis. As a result, the treatment period begins with week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01.

                                             Table 6: Impact of Price Frame on Expenditures and Quantities Purchased
                                                                (standard errors in parentheses)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                       Expenditures                                                                  Quantities
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                         Less        All Rated                   All                      Less        All Rated
                        Nutritious    Nutritious       Items        Unrated     Items    Nutritious    Nutritious       Items        Unrated      All Items
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Subsidy               ^$0.78        ^$2.29        ^$3.07         $1.60     ^$1.47        0.523        ^1.220        ^0.698      ** 0.917         0.220
                           (3.655)       (4.914)       (8.225)       (1.376)   (9.041)      (1.600)       (1.884)       (3.327)       (0.450)       (3.627)
    Tax                    $4.52         $1.89         $6.41        ^$0.07      $6.34        2.287         0.896         3.182         0.306         3.489
                           (3.489)       (4.784)       (7.908)       (1.460)   (9.015)      (1.564)       (1.925)       (3.325)       (0.461)       (3.654)
    Tax/Subsidy           ^$0.42        ^$4.40        ^$4.82         $0.84     ^$3.98       ^0.002        ^2.384        ^2.386         0.752        ^1.634
                           (4.371)       (5.831)       (9.942)       (1.466)   (11.010      (1.876)       (2.293)       (4.044)       (0.527)       (4.399)
                                                                                    )
    Weekly Dummy
     Variables                                                                      e
    N                   6,572         6,572         6,572         6,572         6,572    6,572         6,572         6,572         6,572         6,572
    Unconditional         $36.55        $49.59        $86.14        $11.86     $98.50       16.132        18.853        34.985         3.609        38.744
     mean of
     dependent
     variable
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Participants in the intervention conditions were all combined. Regression coefficients were estimated using a fixed effects regression with weekly dummy
      variables. For the sake of space, coefficients from the weekly dummy variables were not included in the table. Because weeks were classified as Monday
      through Sunday, the baseline period ended with week 8, which is the full week prior to households receiving notice of their treatment group. In the
      baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study (by
      week 4), any missing value was set to zero. Since households received their notices between September 7-15, weeks including these dates were omitted
      from the analysis. As a result, the treatment period begins with week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01.
    a p<0.05 for difference between Subsidy and Tax.
    b p<0.05 for difference between Subsidy and Tax/Subsidy.
    c p<0.05 for difference between Tax and Tax/Subsidy.

                                            Table 7: Overall Price Effect on Weekly Household Expenditures, by Income
                                                                (standard errors in parentheses)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                  Households at or Below 130% of the Federal Poverty Line                         Households Above 130% of the Federal Poverty Line
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                         Less        All Rated                   All                      Less        All Rated
                        Nutritious    Nutritious       Items        Unrated     Items    Nutritious    Nutritious       Items        Unrated      All Items
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    All Treatment          $7.03         $7.11        $14.14         $2.47     $16.61      ^$1.27        ^$4.02        ^$5.29         $0.24        ^$5.05
     Groups
                           (6.010)       (9.793)      (15.460)       (2.597)   (17.420      (3.707)       (4.543)       (7.898)       (1.313)       (8.893)
                                                                                    )
    Weekly Dummy
     Variables                                                                      e
    N                   1,141         1,141         1,141         1,141         1,141    4,904         4,904         4,904         4,904         4,904
    Unconditional         $28.28        $41.04        $69.32         $9.17     $78.85      $38.36        $50.70        $89.06        $12.25       $101.81
     mean of
     dependent
     variable
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Participants in the intervention conditions were all combined. Regression coefficients were estimated using a fixed effects regression with weekly dummy
      variables. For the sake of space, coefficients from the weekly dummy variables were not included in the table. Because weeks were classified as Monday
      through Sunday, the baseline period ended with week 8, which is the full week prior to households receiving notice of their treatment group. In the
      baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study (by
      week 4), any missing value was set to zero. Since households received their notices between September 7-15, weeks including these dates were omitted
      from the analysis. As a result, the treatment period begins with week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01.
    d p<0.05 difference of estimates for the same type of food (all items, all rated items, etc.) but across demographic comparisons.

                                          Table 8: Overall Price Effect on Weekly Household Expenditures, by Education
                                                                (standard errors in parentheses)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                               High School Education or Less                                               More than High School Education
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                         Less        All Rated                   All                      Less        All Rated
                        Nutritious    Nutritious       Items        Unrated     Items    Nutritious    Nutritious       Items        Unrated      All Items
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    All Treatment          $2.36        ^$4.02        ^$1.65         $6.18      $4.52       $0.52        ^$2.17        ^$1.65         $0.46        ^$1.19
     Groups
                          (11.190)      (20.950)      (31.600)       (4.130)   (34.200      (3.091)       (3.925)       (6.714)       (1.139)       (7.528)
                                                                                    )
    Weekly Dummy
     Variables                                                                      e
    N                     567           567           567           567           567    5,759         5,759         5,759         5,759         5,759
    Unconditional         $25.16        $39.92        $65.08         $8.76     $74.23      $37.73        $50.41        $88.14        $12.05       $100.67
     mean of
     dependent
     variable
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Participants in the intervention conditions were all combined. Regression coefficients were estimated using a fixed effects regression with weekly dummy
      variables. For the sake of space, coefficients from the weekly dummy variables were not included in the table. Because weeks were classified as Monday
      through Sunday, the baseline period ended with week 8, which is the full week prior to households receiving notice of their treatment group. In the
      baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study (by
      week 4), any missing value was set to zero. Since households received their notices between September 7-15, weeks including these dates were omitted
      from the analysis. As a result, the treatment period begins with week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01.
    d p<0.05 difference of estimates for the same type of food (all items, all rated items, etc.) but across demographic comparisons.

                                                Table 9: Impact of Price Frames on Weekly Expenditures, by Income
                                                                (standard errors in parentheses)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                              Poverty Income Ratio <= 1.3                                                   Poverty Income Ratio >1.3
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                     Less        All Rated                    All                       Less         All Rated
                    Nutritious    Nutritious       Items         Unrated     Items    Nutritious     Nutritious        Items         Unrated      All Items
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Subsidy            11.58     * a $21.23    * a, d $32.81  ** a $5.78    ** a, d   a ^$4.548    * a d ^$7.546  a, d ^$12.09        $0.414    d ^$11.68
                                                                            $38.59
                       (6.914)      (10.780)       (16.990)       (2.802)   (18.990      (4.434)        (5.521)         (9.534)       (1.608)      (10.490)
                                                                                 )
    Tax                $0.30      a ^$9.037      a ^$8.735     a ^$3.38     a ^$12.    a $3.832         $3.62         a $7.451        $0.588        $8.039
                                                                                11
                       (8.190)      (12.470)       (20.380)       (4.138)   (23.370      (4.180)        (5.334)         (9.015)       (1.540)      (10.230)
                                                                                 )
    Tax/Subsidy        $9.14         $8.14         $17.28      ** $5.13     $22.40      ^$2.831        ^$7.931        ^$10.76        ^$0.327      ^$11.09
                       (6.874)       (9.965)       (16.310)       (2.039)   (17.710      (5.338)        (6.790)        (11.800)       (1.750)      (13.080)
                                                                                 )
    Weekly Dummy
     Variables                                                                   e
    N               1,141         1,141          1,141         1,141         1,141    4,904          4,904           4,904         4,904         4,904
    Unconditional     $28.28        $41.04         $69.32         $9.17     $78.85      $38.36         $50.70          $89.06        $12.25       $101.81
     mean of
     dependent
     variable
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Participants in the intervention conditions were all combined. Regression coefficients were estimated using a fixed effects regression with weekly dummy
      variables. For the sake of space, coefficients from the weekly dummy variables were not included in the table. Because weeks were classified as Monday
      through Sunday, the baseline period ended with week 8, which is the full week prior to households receiving notice of their treatment group. In the
      baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study (by
      week 4), any missing value was set to zero. Since households received their notices between September 7-15, weeks including these dates were omitted
      from the analysis. As a result, the treatment period begins with week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01.
    a p<0.05 for difference between Subsidy and Tax.
    b p<0.05 for difference between Subsidy and Tax/Subsidy.
    c p<0.05 for difference between Tax and Tax/Subsidy.
    d p<0.05 difference of estimates for the same type of food (all items, all rated items, etc.) but across demographic comparisons.

                                              Table 10: Impact of Price Frame on Weekly Expenditures, by Education
                                                                (standard errors in parentheses)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                               High School Education or Less                                               More than High School Education
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                         Less        All Rated                   All                      Less        All Rated
                        Nutritious    Nutritious       Items        Unrated     Items    Nutritious    Nutritious       Items        Unrated      All Items
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Subsidy               ^$0.65        ^$3.86        ^$4.51         $7.38      $2.87      ^$0.97        ^$2.71        ^$3.68         $1.37        ^$2.31
                          (11.440)      (21.320)      (32.150)       (6.381)   (34.410      (3.824)       (4.986)       (8.414)       (1.343)       (9.226)
                                                                                    )
    Tax                    $2.26        ^$5.53        ^$3.26       * $6.79      $3.53       $4.19         $2.34         $6.53        ^$0.44         $6.09
                          (12.020)      (23.800)      (34.630)       (3.621)   (36.810      (3.536)       (4.636)       (7.781)       (1.523)       (8.963)
                                                                                    )
    Tax/Subsidy            $5.64        ^$2.81         $2.83         $4.35      $7.17      ^$1.81        ^$6.52        ^$8.33         $0.39        ^$7.94
                          (13.210)      (24.060)      (36.560)       (4.385)   (39.780      (4.705)       (5.961)      (10.400)       (1.533)      (11.470)
                                                                                    )
    Weekly Dummy
     Variables                                                                      e
    N                     567           567           567           567           567    5,759         5,759         5,759         5,759         5,759
    Unconditional         $25.16        $39.92        $65.08         $8.76     $74.23      $37.73        $50.41        $88.14        $12.05       $100.67
     mean of
     dependent
     variable
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Participants in the intervention conditions were all combined. Regression coefficients were estimated using a fixed effects regression with weekly dummy
      variables. For the sake of space, coefficients from the weekly dummy variables were not included in the table. Because weeks were classified as Monday
      through Sunday, the baseline period ended with week 8, which is the full week prior to households receiving notice of their treatment group. In the
      baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all households were enrolled in the study (by
      week 4), any missing value was set to zero. Since households received their notices between September 7-15, weeks including these dates were omitted
      from the analysis. As a result, the treatment period begins with week 11, which is after all households received notice of their treatment.
    * p<0.1. ** p<0.05. *** p<0.01.
    a p<0.05 for difference between Subsidy and Tax.
    b p<0.05 for difference between Subsidy and Tax/Subsidy.
    c p<0.05 for difference between Tax and Tax/Subsidy.
    d p<0.05 difference of estimates for the same type of food (all items, all rated items, etc.) but across demographic comparisons.

          Table 11: Overall Price Effect on Shares of Expenditures on Nutritious Foods, by Income and Education
                                            (standard errors in parentheses)
    ----------------------------------------------------------------------------------------------------------------
                                                               At or Below   Above 130%    HS Educ. or  More than HS
                                                     All        130% FPL         FPL          Less          Educ.
    ----------------------------------------------------------------------------------------------------------------
    All Treatments                                   0.0108        0.00359       0.00834      ^0.0057        0.00928
                                                    (0.01)        (0.03)        (0.01)        (0.03)        (0.01)
    Weekly Dummy Variables
    N                                            4,816           769         3,637           342         4,266
    Unconditional Mean Shares                        0.425         0.406         0.433         0.369         0.431
    ----------------------------------------------------------------------------------------------------------------
    Shares of less nutritious and nutritious foods were calculated using only rated food purchases, thus the sign of
      the share is opposite when comparing nutritious and less nutritious foods. Participants in the intervention
      conditions were all combined. Regression coefficients were estimated using a fixed effects regression with
      weekly dummy variables. For the sake of space, coefficients for the constants and the weekly dummy variables
      were not included in the table. Because weeks were classified as Monday through Sunday, the baseline period
      ended with week 8, which is the full week prior to households receiving notice of their treatment group. In
      the baseline period, values are set to missing prior to the first shopping trip in the first 3 weeks. Once all
      households were enrolled in the study (by week 4), any missing value was set to zero. Since households
      received their notices between September 7-15, weeks including these dates were omitted from the analysis. As
      a result, the treatment period begins with week 11, which is after all households received notice of their
      treatment.
    * p<0.1. ** p<0.05. *** p<0.01.
    d p<0.05 difference of estimates for the same type of food (all items, all rated items, etc.) but across
      demographic comparisons.

                                       Table 12: Results of Post-Experiment Survey
                                                (on 9-point Likert Scale)
    ----------------------------------------------------------------------------------------------------------------
                                                                   All
                                  Whole Sample     Control      Treatment      Subsidy         Tax      Tax/ Subsidy
                                                    Group        Groups
    ----------------------------------------------------------------------------------------------------------------
                                               Interpretation of Treatment
    ----------------------------------------------------------------------------------------------------------------
    Penalty for eating unhealthy       2.9           2.6           3.0         a 2.4         a 3.4           3.2
     food
                                      (1.937)       (1.739)       (2.003)       (1.662)       (2.100)       (2.161)
    Reward for eating healthy          6.2           6.1           6.3           6.0           6.0           6.9
     food
                                      (2.286)       (2.515)       (2.211)       (2.362)       (2.394)       (1.641)
    Tax on unhealthy foods             3.4           2.8         * 3.6         b 2.8         * 3.7       **b 4.4
                                      (2.076)       (1.796)       (2.141)       (1.696)       (2.237)       (2.218)
    Discount for eating healthy        6.4           5.8         * 6.6           6.7           6.2         * 6.9
     foods
                                      (2.225)       (2.543)       (2.077)       (2.157)       (2.313)       (1.595)
    Effective in changing what I       4.5           4.2           4.6           4.8           4.2           5.0
     usually buy
                                      (2.419)       (2.444)       (2.413)       (2.250)       (2.452)       (2.568)
    ----------------------------------------------------------------------------------------------------------------
                             How much did being a part of the study influence your shopping?
    ----------------------------------------------------------------------------------------------------------------
    Buy more starred foods             5.0           4.5           5.1         b 4.8         c 4.8      b, c 5.9
                                      (2.084)       (2.152)       (2.048)       (2.009)       (2.060)       (1.950)
    Buy more non-starred foods         3.1           3.2           3.1           3.0           3.2           3.0
                                      (1.421)       (1.567)       (1.373)       (1.650)       (1.050)       (1.401)
    Buy healthier food                 5.3           4.7           5.5         b 5.0           5.3         b 6.2
                                      (2.146)       (2.271)       (2.078)       (2.048)       (2.357)       (1.541)
    Buy a higher percentage of         5.3           4.8           5.5         b 4.9           5.5         b 6.2
     healthy food
                                      (2.200)       (2.360)       (2.124)       (2.043)       (2.407)       (1.595)
    ----------------------------------------------------------------------------------------------------------------
                                           In general, over the entire program
    ----------------------------------------------------------------------------------------------------------------
    Shopped healthier at the           3.3           3.1           3.4           3.4           3.1           3.6
     beginning than at the end
                                      (1.725)       (1.555)       (1.784)       (1.845)       (1.465)       (2.077)
    ----------------------------------------------------------------------------------------------------------------
    Note that the asterisks represent differences of the annotated value from the corresponding value of the control
      group at the respective level of significance. All responses were based on a 9 point Likert scale from
      Strongly Disagree (1) to Strongly Agree (9).* p<0.1. ** p<0.05. *** p<0.01.
    a p<0.05 for comparison between Subsidy and Tax groups.
    b p<0.05 for comparison between Subsidy and Tax/Subsidy groups.
    c p<0.05 for comparison between Tax and Tax/Subsidy groups.

         Appendix Table 1: Permutation Tests for Combined Interventions
    ------------------------------------------------------------------------
         Combined                             95% Lower         95% Upper
       Interventions         P-value      Confidence Level  Confidence Level
    ------------------------------------------------------------------------
    All Households:
      Less-Nutritious.           0.700             0.671             0.728
      Nutritious......           0.724             0.695             0.752
    At or below 130%
     FPL:
      Less-Nutritious.           0.481             0.450             0.512
      Nutritious......           0.253             0.226             0.281
    Above 130% FPL:
      Less-Nutritious.           0.401             0.370             0.432
      Nutritious......           0.714             0.685             0.742
    ------------------------------------------------------------------------

          Appendix Table 2: Permutation Tests for Individual Treatments
    ------------------------------------------------------------------------
         Combined                             95% Lower         95% Upper
       Interventions         P-value      Confidence Level  Confidence Level
    ------------------------------------------------------------------------
    Less-Nutritious:
      Subsidy.........           0.645             0.614             0.675
      Tax.............           0.709             0.680             0.737
      Tax/Subsidy.....           0.455             0.424             0.486
    Nutritious:
      Subsidy.........           0.825             0.800             0.848
      Tax.............           0.193             0.169             0.219
      Tax/Subsidy.....           0.928             0.910             0.943
    ------------------------------------------------------------------------

    Appendix Table 3: Permutation Tests for Separate Interventions When Data
                        Are Separated Into Income Groups
    ------------------------------------------------------------------------
         Combined                             95% Lower         95% Upper
       Interventions         P-value      Confidence Level  Confidence Level
    ------------------------------------------------------------------------
                              At or Below 130% FPL
    ------------------------------------------------------------------------
    Less-Nutritious:
      Subsidy.........           0.056             0.043             0.072
      Tax.............           0.480             0.449             0.511
      Tax/Subsidy.....           0.448             0.417             0.479
    Nutritious:
      Subsidy.........           0.102             0.084             0.122
      Tax.............           0.969             0.956             0.979
      Tax/Subsidy.....           0.204             0.179             0.230
    ------------------------------------------------------------------------
                                 Above 130% FPL
    ------------------------------------------------------------------------
    Less-Nutritious:
      Subsidy.........           0.179             0.156             0.204
      Tax.............           0.511             0.480             0.542
      Tax/Subsidy.....           0.242             0.216             0.270
    Nutritious:
      Subsidy.........           0.298             0.270             0.327
      Tax.............           0.360             0.330             0.391
      Tax/Subsidy.....           0.611             0.580             0.641
    ------------------------------------------------------------------------

                                  Attachment 1
    Excerpt from Slim by Design_Mindless Eating Solutions for Everyday Life
            *
    ---------------------------------------------------------------------------
        * Editor's note: The original format of the book, Slim by Design--
    Mindless Eating Solutions for Everyday Life, has an entire section
    devoted to endnotes for all of the chapters. In this reproduction the
    endnotes are set as footnotes.
    ---------------------------------------------------------------------------
      slim by design. Copyright 2014 by Consumer Psych Labs, Inc. All
    rights reserved. Printed in the United States of America. No part of
    this book may be used or reproduced in any manner whatsoever without
    written permission except in the case of brief quotations embodied in
    critical articles and reviews. For information address HarperCollins
    Publishers, 195 Broadway, New York, NY 10007.
      HarperCollins books may be purchased for educational, business, or
    sales promotional use. For information please e-mail the Special
    Markets Department at SPsales@harpercollins.com.

    First Edition
    Designed by Paul Kepple and Ralph Geroni at Headcase Design
    Illustrations by Mitch Blunt
    Library of Congress Cataloging-in-Publication Data has been applied
    for.
    ISBN 978-0-06-213652-7
    14 15 16 17 18 ov/rrd 10 9 8 7 6 5 4 3 2 1
    Contents
                    Introduction

                    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          One: Mindless Eating Solutions

                    Your Food Radius
                    Nobody Wants Us to Be Fat
                    Chinese Buffet Confidential
                    Starting Small to Get Slim
                    Sixteen Pounds from Happiness
                    Becoming Slim by Design

                  [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          Two: Your Slim-For-Life Home

                    Fat-Proofing the Rich and Famous
                    The Syracuse Study
                    Step One: The Kitchen Makeover
                    Step Two: Tablescape Redesign
                    Step Three: Snack-Proofing
                    Scoring Big at Home

                  [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          Three: Restaurant Dining By Design

                    In Praise of Leftovers
                    Show Me to a Slim Table
                    One Antidote for Fast-Food Fever
                    ``Can I Take Your Order?''
                    Half-Plate Profits
                    Smaller and Taller
                    Bread and Water
                    Faster Food and Happier Meals
                    What Would Batman Eat?
                    Transforming a Town
                    Is Your Favorite Restaurant Making You Fat?

                    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          Four: Supermarket Makeovers

                    The Desserted Island of Denmark
                    Half-Cart Solutions
                    Healthy First and Green Line Guides
                    Wide Aisles and High Products
                    Groceries and Gum
                    Lights, Stars, Numerology!
                    Using the Half-Plate Rule
                    The Three Checkouts
                    Back to Bornholm
                    How Your Grocery Store Can Make You Slim

                   [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          Five: Office Space and Workplace

                    Move Away from the Desk
                    Rethinking Corporate Wellness
                    Break-Room Makeovers
                    Trimming the Google-Plex of Food
                    Cafeteria Cuisine
                    The Company Health Club
                    Coaching and Weight-Loss Programs
                    Would You Sign a Health Conduct Code?
                    Design Your New Boss's Job Description!
                    Think Summer Camp, Not Boot Camp

                    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          Six: Smarter Lunchrooms

                    School Lunch 101
                    When Chocolate Milk Attacks
                    More Fruit by Design
                    The Salad Bar Solution
                    Lunch-Line Redesign, MTV-Style
                    What's Your Lunchroom Score?
                    The Lunchtime Report Card
                    Designing a Smarter Lunchroom Tray
                    Helping Your School Become Slim by Design

                   [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

          Seven: Slim By Design for Life

                    From Can't to CAN
                    From Me to We
                    Getting Started
                    Design Trumps Discussion
                    Sample Scripts
                    Make It Happen

                    Acknowledgments
                    Notes
                    Index
              * * * * *
    Chapter Four
    Supermarket Makeovers
        You've Never Seen A Kleenex Cam. That's why it works so well--it
    sees you, but you don't see it. It's helped us learn why the crazy
    things grocery shoppers do aren't as crazy as they seem.

        Back in 2001, I asked some clever engineering students at the
    University of Illinois at Urbana-Champaign to rig up a small, remotely
    controlled movie camera into what looked like an ordinary box of
    Kleenex.\1\ Using this invisible camera we could follow shoppers to
    learn exactly how they shop. We took our Kleenex Cams and stacked them
    on top of ``deserted'' shopping carts, hid them on shelves next to
    Fruity Pebbles cereal, and positioned them in our carts so we could
    follow shoppers as they moved through the aisles. The Kleenex Cams
    showed us what catches a person's eye, what they pick up and put back,
    why they buy things they'll never use,\2\ when shopping lists don't
    matter, and how they shop differently in the ``smelly'' parts of a
    grocery store. Again, these studies were all university approved.\3\
    ---------------------------------------------------------------------------
        \1\ The only remaining photo of the original Kleenex Cam is in this
    newspaper article below. By today's tech standards, it's pretty boring,
    but back then it was really souped up. Read about it at
    SlimByDesign.org/GroceryStores/.
        \2\ One interesting category of items that are most likely to
    become cabinet castaways are unusual foods that people are buying for a
    specific occasion. When that occasion never happens, the food just sits
    and sits. This is a neat article on that: Brian Wansink, S. Adam
    Brasel, and Stephen Amjad, ``The Mystery of the Cabinet Castaway: Why
    We Buy Products We Never Use,'' Journal of Family and Consumer Science
    92, no. 1 (2000): 104-8.
        \3\ All of these studies are preapproved. Today--compared to twenty
    or even 10 years ago--studies to be approved by a university's
    Institutional Review Board to make sure that they are safe and to make
    sure all of the data is collected anonymously and that no one will ever
    know about that day you bought that EPT kit and the two pints of
    Chocolate Fudge Swirl. Some studies--like many shopping studies--are
    observational, but others might ask a person to complete a
    questionnaire at the end of a trip in exchange for a small amount of
    money, free food, movie tickets, and so on.
    ---------------------------------------------------------------------------
        But let's back up and set the stage. Our best and worst eating
    habits start in a grocery store. Food that's bought here gets moved
    into our homes. Food in our homes gets eaten.\4\ If we bought more bags
    of fruit and fewer boxes of Froot Loops, we would eventually eat more
    of the first and less of the second. Although bad for the Froot Loops
    Corporation, it's great for us--and great for grocery stores. The
    typical grocery store makes more profit by selling you $10 more fruit
    than $10 more Froot Loops. There's a higher markup on fruit, and--
    unlike the everlasting box of Froot Loops--fruit spoils, and spoiled
    fruit spoils profits. You have to sell it while you can.
    ---------------------------------------------------------------------------
        \4\ That is, about 88 percent of this food will be eaten. The 12
    percent that's wasted, however, isn't the candy, chips, and ice cream;
    it's typically the spoiled fruit and vegetables, leftovers, and cabinet
    castaways. Brian Wansink, ``Abandoned Products and Consumer Waste: How
    Did That Get into the Pantry?,'' Choices (October 2001): 46.
    ---------------------------------------------------------------------------
        So if a grocery store makes more by selling healthy foods like
    fruit, why don't they do a better job of it? They try--but what they
    really need is a healthy dose of redesign.

              Our best and worst eating habits start in a grocery store.

        We've been following grocery shoppers since 1995, and some things
    have changed since then. For one, we no longer have to wrestle with
    Kleenex Cams. Our newer cameras are so small they're embedded into
    Aquafina water bottles with false bottoms.\5\ The technology is sexier,
    but the results are e-x-a-c-t-l-y the same.\6\ Wherever we've done
    these studies--corner markets in Philadelphia or warehouse stores in
    France, Brazilian superstores or Taiwanese night markets--people pretty
    much shop in the same time-stressed, sensory-overwhelmed way. But
    knowing what can be done to get them to buy a healthier cartful of food
    is good for shoppers, for grocers, and even for governments.
    ---------------------------------------------------------------------------
        \5\ A cool example of all of these hidden cameras in use can be
    found at http://www.youtube.com/watch?v=2B0Ncy3Gz24. It's not at a
    grocery store but in a lunchroom. Same approach.
        \6\ Lots of people visit our Lab (even from way overseas) like it's
    some weird trip to Consumer Mecca. Something I've heard a number of
    times is ``Wow . . . this isn't really very high-tech!'' No, it isn't.
    What we'd like to think, however, is that insights trump glitzy
    technology every day of the week. We've got low-definition hidden
    cameras, hidden scales, counters, and timers, because we don't need
    holograms or brain-scan machines to nail down the reality--not the
    theory--of why people do what they do. You don't need infrared sensors
    to see someone eating twice as many Cheetos when you change what
    they're watching on TV.
    ---------------------------------------------------------------------------
        Wait. Governments?
        What jump-started a lot of our recent thinking was a request we
    received from the Danish Government. In April 2011, they sent a six-
    person delegation out to my Lab. Their mission: to help Danish grocery
    stores make it easier for shoppers to shop healthier. Our mission, if
    we chose to accept it: develop a healthy supermarket makeover plan that
    would be cheap, easy, and profitable for Danish grocery stores to
    implement. Our makeover plan had to be profitable for stores because
    that's the only way it would work. But here's the cool clincher: They'd
    give us an entire island on which to test our plan.
    The Desserted Island of Denmark
        Bornholm Is A Danish Island with forty-two thousand inhabitants
    that sits in the Baltic Sea, one hundred miles east of Copenhagen.\7\
    The Government of Denmark wanted us to help change the grocery stores
    on the entire island so they could profitably help these islanders shop
    healthier. They wanted to turn it from a Dessert Isle into a Salad
    Aisle.
    ---------------------------------------------------------------------------
        \7\ Denmark Islands. Denmark actually has a number of little
    islands, but none like poor Bornholm. It never gets any peace.
    Strategically located in the Baltic Sea, it was occupied by the Germans
    during almost all of World War II and the Russians right after that.
    And probably by the Vikings way before that.

        Anyone who's read or seen H.G. Wells's The Island of Dr. Moreau
    knows that islands are a researcher's dream. You can do all sorts of
    crazy, mad scientist things on them and not worry about the rest of the
    world bothering you. You can change the shopping carts or layout of all
    the stores on the island, and if the sales of Crisco and Pixy Stix drop
    by 20 percent, you know it's not because people are swimming over to
    buy them in Lapland.
        Until they came to talk with us, the Danish Government was
    considering three types of changes: tax it, take it, or teach it.\8\
    But taxing food or taking it away creates pushback. Shoppers don't like
    it, grocers don't like it, and so it can often backfire. For instance,
    when we did a 6 month study on taxing soft drinks in grocery stores in
    Utica, New York, a medium-size city in the United States, we found that
    the only people who bought fewer soft drinks were beer-buying
    households--and they just bought a lot more beer.\9\ People had to
    drink something with their pizza and burgers, and it wasn't going to be
    tap water or soy milk. They changed from Coke to Coors.
    ---------------------------------------------------------------------------
        \8\ People--whether public health professionals or politicians--can
    often get very dramatic in what they tell grocery stores they should
    do. Dramatic, but not always realistic or right.
        \9\ This is an interesting paper of unintended consequences: Brian
    Wansink et al., ``From Coke to Coors: A Field Study of a Sugar-
    Sweetened Beverage Tax and Its Unintended Consequences,'' May 26, 2012,
    available at http://ssrn.com/abstract=2079840 or http://dx.doi.org/
    10.2139/ssrn.2079840.
    ---------------------------------------------------------------------------
        And teaching doesn't work much better.\10\ As shoppers, we don't
    behave the way we're supposed to because (1) we love tasty food, and
    (2) we don't like to think very hard. Because of our love for both
    tasty food and for mindless shopping, we don't approach grocery
    shopping like a nutrition assignment. We just do it and move on to the
    next fifty-seven items on our to-do list. With this mindless mindset,
    when we're shopping at 5:45 on a Friday evening, we're not about to be
    fazed by there being a few more calories in pizza crust than in pita
    bread.
    ---------------------------------------------------------------------------
        \10\ This is controversial for me to admit since I'm the immediate
    past president of the Society for Nutrition Education and Behavior and
    because I was the White House-appointed person (2007-2009) in charge of
    promoting the [D]ietary [G]uidelines for the USDA.

        Maybe the best way we can change grocery shopping habits is to make
    them more mindlessly healthy--make it more convenient, attractive, and
    normal to pick up and buy a healthier food.\11\ So here's what we did
    in Bornholm. Based on our ``Kleenex Cam'' recordings,\12\ notes,
    stopwatch times, and data from thousands of similar shoppers, we
    focused on design changes in five areas of the store: carts, layouts,
    aisles, signs, and checkout lines. We had two criteria: (1) all the
    changes had to make the store more money in a month than they cost to
    implement, and (2) they all had to help make people slim by design.
    Let's start with a shopping cart.
    ---------------------------------------------------------------------------
        \11\ This was one focus of my book Mindless Eating. The basic idea
    is that making small changes around you that you don't even really
    notice has a tremendous long-term impact on changing behavior and
    weight.
        \12\ We no longer use the Kleenex Cam but we still call it that. We
    now use our bottles, hats, and iPhones.
    ---------------------------------------------------------------------------
    Half-Cart Solutions
        Here's a Ten-Word Description of how most people shop for
    groceries: They throw things in their cart and they check out. What's
    the right amount of fruits and vegetables to put in a cart? We don't
    really know because we don't really care. Yet imagine what would happen
    if every time we put something in our cart we had to ask ourselves
    whether it was healthy or not. It would be irritating--for sure--but
    after a while we'd think twice about what we casually threw in. Just
    stopping and thinking for a split second would be enough to snap us out
    of our mindlessly habitual zombie shopping trance.13-14
    ---------------------------------------------------------------------------
        \13\ A number of years ago we gave secretaries dishes of chocolate
    Kisses that we either placed on their desk or 6 from their desk. We
    found that those who had to walk only 6 ate \1/2\ as much candy (100
    calories less; four each day instead of nine). Yet when we asked them
    if it was because the 6 walk was too far or too much of a hassle,
    their answer surprised us. They said instead that the 6 distance gave
    them a chance to pause and ask themselves if they were really that
    hungry. Half the time they'd answer ``no.'' The key was that
    something--that distance--caused them to pause and interrupt their
    mindlessness: Brian Wansink, James E. Painter, and Yeon-Kyung Lee,
    ``The Office Candy Dish: Proximity's Influence on Estimated and Actual
    Candy Consumption,'' International Journal of Obesity 30, no. 5 (May
    2006): 871-75.
        \14\ Anything that stops and makes a person pause--even for a split
    second--might be enough to knock them out of their mindless trance and
    rethink.

        Back to the cart. When most of us shop, fruits and vegetables take
    up only 24 percent of our cart.\15\ But suppose your grocery store
    sectioned a cart in \1/2\ by taping a piece of yellow duct tape across
    the middle interior. And suppose they put a sign in the front of the
    cart that recommended that you put all the fruits and vegetables in the
    front and all the other foods in the back. This dividing line in the
    cart doesn't moralize or lecture. It just encourages shoppers to ask
    themselves whether the food in their hand goes in the front or back of
    the cart. There's nothing to resist or rage against--they're simply
    sorting their food . . . if they want to.
    ---------------------------------------------------------------------------
        \15\ The average grocery shopper buys only 24 percent of fruits and
    vegetables. Simone French, Melanie Wall, Nathan R. Mitchell, Scott T.
    Shimotsu, and Ericka Welsh, ``Annotated Receipts Capture Household Food
    Purchases from a Broad Range of Sources,'' International Journal of
    Behavioral Nutrition and Physical Activity 6, no. 37 (2009).
    ---------------------------------------------------------------------------
        When you use duct tape at home, you become MacGyver. When it's used
    to divide your grocery cart, you become healthier.\16\
    ---------------------------------------------------------------------------
        \16\ Brian Wansink, C.R. Payne, K.C. Herbst, and D. Soman, ``Part
    Carts: Assortment Allocation Cues That Increase Fruit and Vegetable
    Purchases,'' Journal of Nutrition Education and Behavior 45 (2013): 4S,
    42.
    ---------------------------------------------------------------------------
        We made a few dozen of these divided carts to test at supermarkets
    in Williamsburg, Virginia, and Toronto, Canada.\17\ When people
    finished shopping and returned their souped-up, tricked-out carts, we
    gave them a gift card to a local coffee shop if they would answer some
    questions and give us their shopping receipt.
    ---------------------------------------------------------------------------
        \17\ Brian Wansink, Dilip Soman, Kenneth C. Herbst, and Collin R.
    Payne, ``Partitioned Shopping Carts: Assortment Allocation Cues that
    Increase Fruit and Vegetable Purchases,'' under review.
    ---------------------------------------------------------------------------
        Shoppers with these divided carts spent twice as much on fruits and
    vegetables. They also spent more at the store--about 25 percent more.
    Not only did this fruit and vegetable divider make them think twice
    about what they bought; it also made them believe that buying more
    fruits and vegetables was normal. Who knows how much healthy stuff your
    neighbor buys? It must be about \1/2\, people think as they throw in
    some pears and three more red peppers.

    ------------------------------------------------------------------------
                       How Your Grocer Can Help You . . .
    -------------------------------------------------------------------------
                            Test the Half-Cart Waters
    ------------------------------------------------------------------------
        Will a divided, half-cart approach be profitable? It can if it can
     sell more perishable produce--like fruits and vegetables. All that's
     needed is a visual divider in a few of your carts and a sign in the
     front that says, ``Put your fruits and vegetables in the front of your
     cart.''
        If your grocery store doesn't want to bust out the duct tape, they
     can use printable mats for the bottom of the cart that make the same
     suggestion--fruits and vegetables in the front \1/2\ and everything
     else in back (download at SlimByDesign.org).
    ------------------------------------------------------------------------

    The Miracle of Duct Tape
    A Half-Cart Solution

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Do it yourself. Divide your cart with your coat, your purse,
            or your briefcase. Or bring your own duct tape.

    ------------------------------------------------------------------------
                              What You Can Do . . .
    -------------------------------------------------------------------------
                          Hints for Half-Cart Shopping
    ------------------------------------------------------------------------
        Your local supermarket might not have divided carts yet, and you
     probably don't travel with your own. Here's what you can do . . .

       Decide what you want to buy more of. For instance, a shopper
       with children might want to be nudged to buy more fruits and
       vegetables, and a shopper with high blood pressure might want to buy
       more low-sodium foods. A dieter might want to be nudged to buy more
       low-carb foods, and a diabetic might want to buy more foods with a
       low glycemic index.

       Physically divide your cart by putting something across the
       middle. This could be a purse, backpack, scarf, briefcase, coat, or a
       sleeping child you want to keep an eye on. You can then claim the
       front half of . . . our cart for whatever you want to purchase more
       of. If that target space isn't full, you'll naturally tend to buy
       more to balance things out.
    ------------------------------------------------------------------------

              You're 11 percent more likely to take the first vegetable you
            see than the third.
              When opening your cupboard, you're three times as likely to
            take the first cereal you see as you are the fifth.
    Healthy First and Green Line Guides
        When You Walk Up To A Buffet, you're 11 percent more likely to take
    the first vegetable you see than the third.\18\ When opening your
    cupboard, you're three times as likely to take the first cereal you see
    as you are the fifth.\19\ The same is true in grocery stores. When you
    start shopping, you can't wait to start piling things in your cart. But
    after it starts filling up, you become more selective. If stores could
    get you to walk by more of the healthy--and profitable--foods first,
    they might be able to get you to fill up the cart on the good stuff,
    and squeeze out any room for the Ben & Jerry's variety pack.
    ---------------------------------------------------------------------------
        \18\ A really robust finding. A great reason why you should also
    pass around the salad and green beans to your kids at dinnertime before
    you bring out the lasagna. Brian Wansink and David Just, ``Healthy
    Foods First: Students Take the First Lunchroom Food 11% More Often than
    the Third,'' Journal of Nutrition Education and Behavior 43 (2011):
    4S1, S9.
        \19\ You can just believe me, or you can read ponderous evidence of
    why this happens: Pierre Chandon and Brian Wansink, ``When Are
    Stockpiled Products Consumed Faster? A Convenience-Salience Framework
    of Postpurchase Consumption Incidence and Quantity,'' Journal of
    Marketing Research 39, no. 3 (2002): 321-35.

              We spend less than 6 minutes in the fruit and vegetable
    ---------------------------------------------------------------------------
            section.

        Most grocery stores in the United States place the fruit and
    vegetable section on the far right of the store. It's the first thing
    we see and wander over to. The bad news is that many of us spend less
    than 6 minutes there.\20\ We pick up some apples and lettuce and then
    wander over to the next aisle. But if stores could get us to linger
    there a little longer, we'd buy a little bit more.
    ---------------------------------------------------------------------------
        \20\ This is a really neat finding, but it seems like it will take
    a miracle to get it published. In the meantime, you can find it on
    SSRN: Brian Wansink and Kate Stein, ``Eyes in the Aisle: Eye Scanning
    and Choice in Grocery Stores,'' 2013.
    ---------------------------------------------------------------------------
        The secret might lie in the fact that we're wanderers--we're not
    always very deliberate. What if they put a dashed green line that
    zigzagged through the produce section, and what if they put floor
    decals in front of food shelves that offer healthy meal ideas? Just
    like that dashed yellow line on the highway that keeps you mindlessly
    on the road and the billboards that keep you mindlessly amused, maybe
    putting a dashed green line and floor decals would also have us
    wandering the produce section a bit longer.
        To test this, we proposed Operation: Green Highway on our mad
    scientist island in Denmark. Supermarkets could put a 2" wide dashed
    green line through the produce section--around the apples and oranges,
    over to the lettuce, past the onions and herbs, and back around to the
    berries and kumquats. They could even include some kid-friendly visuals
    or floor graphics. If a shopper followed this green highway, he or she
    might be tempted to buy more fruits and vegetables.
        To test this, we had people initially trace their way through
    grocery stores that either did or did not have Health Highway lines.
    Did people stay on the line? Of course not, but they would have spent
    an average equivalent of 3 more minutes in the produce section. At
    about $1/minute, this would mean they could spend as much as $3 more on
    fruits and vegetables than they otherwise would have.21-22
    ---------------------------------------------------------------------------
        \21\ Would this dashed green line work through the rest of the
    store? It could go down some of the healthier aisles--say canned fruits
    and vegetables or foods with whole grains--and around much of the
    perimeter of the store. Yet to use the quotation from Spinal Tap again,
    ``It's a fine line between clever and stupid.'' This line might work
    well in the produce section, but don't take it overboard. It might be
    irritating or too strange in the rest of the store--particularly
    because these long aisles might make it look like a highway divider.
        \22\ My good colleagues Collin Payne and David Just have early
    evidence that this works well when it's first laid out. See Collin R.
    Payne and David R. Just, ``Using Floor Decals and Way Finding to
    Increase the Sales of Fruits and Vegetables,'' under review.
    ---------------------------------------------------------------------------
        But what about the other store aisles? Let's say that you have two
    favorite grocery stores: Tops and Hannaford. At Tops, the aisle after
    the produce section--let's call it Aisle 2--is the potato chips,
    cookies, and soft drinks aisle. At Hannaford, the potato chips,
    cookies, and soft drinks are in Aisle 15--the second-to-last aisle in
    the store. If you're on a diet, which store should you choose?
        We followed 259 shoppers in Washington, D.C., grocery stores to see
    if a person shops differently depending on which aisle they're in.\23\
    We discovered that most people with shopping carts behave the same way:
    They walk through the produce section, then turn and go down Aisle 2
    (which leads back toward the front of the store). It almost doesn't
    matter what's in the aisle--health food, dog food, or mops. At this
    point, shopping's still a fun adventure. But after Aisle 2, shoppers
    get mission-oriented and start skipping aisles as they look for only
    what they think they need. So, Aisle 2 gets the most love and attention
    from the most shoppers.
    ---------------------------------------------------------------------------
        \23\ Wansink and Stein, ``Eyes in the Aisle.''
    ---------------------------------------------------------------------------
        So, what's in Aisle 2 at your favorite grocery store? It's often
    soft drinks, chips, or cookies as in the Tops store. To make a grocery
    store more slim by design, managers could easily load up this aisle
    with whatever healthier food is most profitable for them. This might be
    store-brand canned vegetables, whole-grain foods, or high-margin lower-
    calorie foods. First in sight is first in cart.

    ------------------------------------------------------------------------
                       How Your Grocer Can Help You . . .
    -------------------------------------------------------------------------
                        Guiding Angles, Aisles, and Lines
    ------------------------------------------------------------------------
        One way to help shoppers fill up their carts with healthy foods is
     to make sure those are the aisles they visit first and stay in longest.
     People cherry-pick their favorite fruits and vegetables and quickly
     move to the center of the store, but you can keep them in the produce
     area longer by angling displays so they guide shoppers through the
     store--think of the 30 and 45 angles you used to see in those old-
     school pinball games. Also, green lines--Green Highways--seem to nudge
     most of us, at least occasionally, to turn in a direction we otherwise
     wouldn't have turned in.
        Since shoppers are more likely to buy healthy foods when their carts
     are empty, stores should load up Aisles 1, 2, and 3 with whatever's
     healthiest and most profitable.
    ------------------------------------------------------------------------

    ------------------------------------------------------------------------
                              What You Can Do . . .
    -------------------------------------------------------------------------
                         Wander the Healthy Aisles First
    ------------------------------------------------------------------------
        Following the green line works well if there is a green line. But if
     there isn't one, you can always make your own.

       Make a point of wheeling through as many of the produce
       aisles as possible. Even if it's fast and furious, simply seeing more
       fruits and vegetables while your cart is empty makes them more
       tempting.

       Hit the other healthier aisles--like those with canned and
       frozen fruits and vegetables--before you head for the Crunch & Munch
       section.
    ------------------------------------------------------------------------

    Wide Aisles and High Products \24\
    ---------------------------------------------------------------------------
        \24\ If you want a beleaguered researcher's view of how this works,
    here's an op-ed: Kate Stein, ``Shop Faster,'' New York Times, April 15,
    2009, p. A29.
    ---------------------------------------------------------------------------
        The More Time You Spend in a store, the more you buy. Similarly,
    the more time you spend in an aisle, the more you buy.25 In
    order for us to buy a healthy food, we need to (1) see it and (2) have
    the time to pick it off the shelf.
    ---------------------------------------------------------------------------
        \25\ One source for this is Brian Wansink and Aner Tal,
    ``Correlates of Purchase Quantities in Grocery Stores,'' under review.

        But not all shelves are the same. Food placed at eye level is
    easier to spot and buy. For instance, kids' foods are placed at their
    eye level, so that they can irritate us into buying them (``I want it!
    I want it! I want it!'').
        This works for Count Chocula and our kids, but would it for kale
    chips and us? We returned to our ``I-Spy'' habits and observed 422
    people purchasing thousands of products in the Washington, D.C., area.
    First we estimated the height of each shopper using a series of pre-
    marked shelves they walked by (picture those height-marker decals on
    the doors of convenience stores).\26\ We then measured the height of
    each product they looked at. Based on where they looked, we could
    figure out what percent of the foods they bought were at eye level.\27\
    ---------------------------------------------------------------------------
        \26\ Of course this is less accurate than measuring people barefoot
    with a German-made stadeometer, but knowing someone's relative height
    is probably sufficient. Being able to document that a 6 male is taller
    than a 5 5" female is close enough for this calibration. This issue of
    precision does raise to mind the comedian Ron White's quote ``I'm a
    pretty big guy--between 6 and 6 6"--depending on what convenience
    store I'm coming out of.''
        \27\ In this study with Kate Stein, we tracked what people put in
    their carts but we didn't track them to the cash register. Still,
    unless someone changes their mind when in the National Enquirer
    checkout line, we assume that what they took, they probably bought.
    ---------------------------------------------------------------------------
        If you're shopping in a narrow aisle, 61 percent of everything
    you'll buy is within 1 of your eye level--either 1 above or 1
    below.\28\ This is useful to know if you're a grocery-store owner who
    wants to sell us healthier foods. Smart store managers can put these
    profitable healthy foods at eyeball level. If the product is one that's
    typically bought by males, it can be placed even 5" higher, since the
    average male is that much taller than the average female.
    ---------------------------------------------------------------------------
        \28\ And 12" is even a stretch. Most purchased products were within
    a 6 range--higher or lower--of eye level for a particular shopper.
    This includes 37 percent of what women put in their cart and 44 percent
    for men. To stretch the range of products purchased even further, widen
    the shopping aisles. If an aisle is narrow--6 or less--61 percent of
    the products you buy will be within 12" of eye level. But if you're in
    a wider aisle, you look higher and lower. If it's only 2 wider, \1/2\
    of what you buy will be outside this eye zone. But wide aisles also
    have something else going for them.
    ---------------------------------------------------------------------------
        One well-known finding among people watchers is that nothing causes
    a person to scoot out of an aisle faster than when someone accidentally
    brushes against their behind. In his book Why We Buy, Paco Underhill
    refers to this as the ``butt brush.'' \29\ Think of the last time this
    happened to you--five seconds later you had pretty much teleported
    yourself to another spot in the store. Since brushing against people
    probably happens much more in narrow grocery store aisles than wide
    ones, people might spend less time and buy fewer items there. Many
    grocery store aisles range from 6 to 8 wide. In the Washington, D.C.,
    grocery stores mentioned earlier, we measured the width of all the
    aisles and timed how long the average shopper spent in them. Indeed,
    the wider the aisle, the more they bought. It didn't matter what was
    there--canned Brussels sprouts, twenty-pound bags of cat food,
    dishwashing liquid--the more time they spent in the aisles, the more
    items they bought.\30\
    ---------------------------------------------------------------------------
        \29\ Paco Underhill, Why We Buy: The Science of Shopping (New York:
    Simon & Shuster, 2000).
        \30\ There's also an irritation factor with narrow aisles. If a
    person can't see a clear way through an aisle, they might be less
    likely to go down it. And if you keep getting interrupted by people as
    you're trying to shop because they're scooting by you, you're less
    likely to linger.
    ---------------------------------------------------------------------------
        Your grocer could put more healthy, high-margin food in wider
    aisles and less healthy food in narrower ones. Identifying or creating
    healthy food aisles that are wider would be one solution. Another
    solution--make sure the healthier foods are at eye level.\31\
    ---------------------------------------------------------------------------
        \31\ Kate Stein and Brian Wansink, ``Eye Height and Purchase
    Probability,'' under review.
    ---------------------------------------------------------------------------
    Eye-Level Shopping Bull's-Eye

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              * 60 percent of what shoppers buy is within 12" of their eye
            height.
    Slim-By-Design Grocery Shopping

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Groceries and Gum
        Most of Us Know that it's a bad personal policy to go shopping on
    an empty stomach. We think it's because we buy more food when we're
    hungry--but we don't. In our studies of starving shoppers, they buy the
    exact same amount of food as stuffed shoppers. They don't buy more, but
    they buy worse.\32\ When we're hungry, we buy foods that are convenient
    enough to eat right away and will stop our cravings.\33\ We don't go
    for broccoli and tilapia; we go for carbs in a box or bag. We go for
    one of the ``Four C's'': crackers, chips, cereal, or candy. We want
    packages we can open and eat with our right hand while we drive home
    with our left.
    ---------------------------------------------------------------------------
        \32\ Here's the best proof of why you shouldn't shop when you're
    hungry: Brian Wansink, Aner Tal, and Mitsuru Shimizu, ``First Foods
    Most: After 18-Hour Fast, People Drawn to Starches First and Vegetables
    Last,'' Archives of Internal Medicine 172, no. 12 (June 2012): 961-63.
        \33\ This is a current working paper by Brian Wansink and Drew
    Hanks, ``Timing, Hunger, and Increased Sales of Convenience Foods.''
    Hopefully it will be published in time for our retirement.

        When it comes to cravings, our imagination is the problem. The
    cravings hit us super-hard when we're hungry because our hunger leads
    us to imagine what a food would feel like in our mouth if we were
    eating it. If your Girl Scout neighbor asked you to buy Girl Scout
    cookies, you'd buy one or two boxes. But if she were to instead ask you
    to describe what it's like to eat your favorite Girl Scout cookie, you
    would start imagining the texture, taste, and chewing sensation, and
    wind up ordering every life-giving box of Samoas she could carry. (Keep
    this in mind the next time your daughter wants to win the gold medal in
    ---------------------------------------------------------------------------
    cookie sales.)

              Starving shoppers don't buy more, but they buy worse.

        Most food cravings--including those that occur when we shop--are
    largely mental. As with the Girl Scout cookies, they seem to be caused
    when we imagine the sensory details of eating a food we love--we start
    imagining the texture, taste, and chewing sensation. But if we could
    interrupt our imagination, it might be easier to walk on by.
        One way we can interrupt these cravings is by simply chewing gum.
    Chewing gum short-circuits our cravings. It makes it too hard to
    imagine the sensory details of crunchy chips or creamy ice cream. My
    colleague Aner Tal and I discovered this when we gave gum to shoppers
    at the start of their shopping trip. When we reconnected with them at
    the end of their trip, they rated themselves as less hungry and less
    tempted by food--and in another study we found they also bought seven
    percent less junk food than those who weren't chewing gum.\34\ If you
    shop for groceries just before dinner, make sure the first thing you
    buy is gum--and our early findings show that sugarless bubble gum or
    mint-flavor might work best.
    ---------------------------------------------------------------------------
        \34\ One of the ways we've tested this is by intercepting grocery
    shoppers in the parking lot on their way into a store. We ask them to
    answer a couple of questions about the store and if we can talk to them
    after they shop. If they say yes, we tag their cart so we can catch
    them as they check out. At that time, we ask them a few questions about
    their experience and if we can have a copy of their shopping receipt. A
    second group of people get the exact same treatment, except that
    they're also given a piece of sugarless gum as a thank-you. We tag
    their cart with a different color tag, and again catch them as they
    check out.

              Most food cravings--including those that occur when we shop--
            are largely mental.
              Chewing gum short-circuits our cravings. It makes it too hard
            to imagine the sensory details of crunchy chips or creamy ice
            cream.
    Lights, Stars, Numerology!
        Supermarkets Could Make Us slim by design if they only told us what
    foods were the healthiest, right? Not really. Supermarkets and food
    companies have endlessly experimented with little stickers and icons
    that they hoped would help us to eat better. They'd say things like
    ``Good for You,'' ``Better for You,'' ``Don't Have a Stroke,'' and so
    on. The United Kingdom even uses a traffic light--each food has a green
    (go), yellow (slow), or red (no) icon on it.

        Do you remember these icons? Of course you don't. Most of us
    ignored them because they were too confusing, self-serving, or
    unconvincing. Oh, and even when people did pay attention to them, they
    often backfired. Some people believed the green and yellow foods were a
    lot healthier than they actually were and gorged out on them. Then food
    companies got tricky and took advantage of this by producing foods that
    barely met the minimum requirements for a green or yellow icon. Getting
    the healthy icon then became more important than actually coming up
    with a healthier product.

              Most labeling systems seem to backfire because we ignore them
            or we game them.

        One exception seems to be the Guiding Stars program. Back in 2005,
    an innovative, brilliant, high-end grocery store in New England--
    Hannaford Brothers--boldly stuck its neck out by putting bright yellow
    stars next to the healthiest foods on their shelves--super-healthy
    foods even got three stars. So, did people buy better food? Well,
    according to one study, they didn't initially seem to buy any more of
    the starred food. But they initially did buy less of the unstarred
    foods. They didn't buy more tofu, though this led them to think twice
    about the Doritos.\35\
    ---------------------------------------------------------------------------
        \35\ This is a great study that shows surprisingly that either
    taxing bad foods or subsidizing good foods seems to backfire. When you
    subsidize healthy foods, people buy more of both healthy and unhealthy
    foods. When you tax unhealthy foods, shoppers by less of both unhealthy
    and healthy foods. John Cawley et al., ``How Nutrition Rating Systems
    in Supermarkets Impact the Purchases of Healthy and Less Healthy
    Foods,'' under review.
    ---------------------------------------------------------------------------
        But here's why most of these labeling systems seem to backfire: (1)
    We don't believe them, or (2) we game them. We know an apple gets a
    green light, an A+, or a 100 percent rating. And we know a Twinkie gets
    a red light, a D^, and a two percent rating. It's the stuff in the
    middle that turns us into nonbelievers. If a food gets a rating that
    doesn't line up with our intuition, it totally loses credibility. When
    the magic formula is too complicated or too secret, we dismiss these
    ratings as ridiculous and ignore them.
        But worse than our ignoring them is when we game the system. We're
    experts at getting around something we don't want to do or believe. If
    one type of cracker is rated five points higher than another type of
    cracker, we choose it instead of an orange.\36\ Then we end up
    rewarding ourselves by eating more of them.\37\
    ---------------------------------------------------------------------------
        \36\ This is an award-winning article that opened a lot of eyes
    with the health halo concept: Pierre Chandon and Brian Wansink, ``The
    Biasing Health Halos of Fast Food Restaurant Health Claims: Lower
    Calorie Estimates and Higher Side-Dish Consumption Intentions,''
    Journal of Consumer Research 34, no. 3 (October 2007): 301-14.
        \37\ There's a ton of evidence here that's compelling, but way too
    detailed to talk about in the text. It happens with both low-fat foods
    and with foods with healthy names. Knock yourself out reading these two
    detailed (but award-winning papers): One's mentioned in the prior note
    and the other one is Brian Wansink and Pierre Chandon, ``Can Low-Fat
    Nutrition Labels Lead to Obesity?,'' Obesity 14 (September 2006): A49-
    50.

    ------------------------------------------------------------------------
                              What You Can Do . . .
    -------------------------------------------------------------------------
                Use Your Intuition First and Their Labels Second
    ------------------------------------------------------------------------
        Relying too much on ratings is confusing and can backfire. Even if
     your grocery store is using them, rely first on your common sense and
     only use the ratings to break ties between brands--Count Chocula beats
     Cap'n Crunch.
        But don't celebrate your slightly smarter choice with a double-wide
     candy bar. That's the compensation danger in a health halo world.
    ------------------------------------------------------------------------

    Using the Half-Plate Rule
        Each Spring, Wegmans, a popular grocery chain in the Northeast,
    does a big health promotion push called ``Eat well. Live well.'' From
    time to time, we've helped develop new ideas for their stores. In 2009,
    they visited our Lab to see if we could help develop a program that
    would encourage their own employees to eat more fruit and vegetables.
    They were thinking of providing some sort of education or promotion
    program. Instead, we were thinking of giving them a simple, visual rule
    of thumb. What we told Wegmans worked great for them, and it can work
    great for you in the store and even when you get home.

        In the good old days when we were kids, eating was easy. Your
    grandmother piled dishes of food on the table, you'd take a little of
    each, and--ta-da--that was nutrition! Today, the 273-page United States
    Dietary Guidelines tips the scale at almost 3 pounds. But there's an
    easier way for most people. When I was the executive director in charge
    of the Dietary Guidelines and people asked me how they should eat,
    although not the official USDA-sanctioned answer, my shortcut answer
    was to simply encourage them to use my Lab's Half-Plate Rule.\38\ Half
    of their plate had to be filled with fruit, vegetables, or salad, and
    the other \1/2\ could be anything they wanted. It could be lamb, a
    blueberry muffin, a handful of cheese . . . anything. They could also
    take as many plates of food as they wanted. It's just that every time
    they went back for seconds or thirds, \1/2\ their plate still had to be
    filled with fruit, vegetables, or salad.
    ---------------------------------------------------------------------------
        \38\ Wansink, Mindless Eating, pp. 178-9+.
    ---------------------------------------------------------------------------
    Half-Plate Healthy

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              * Follow the Half-Plate Rule.

        Could a person load up \1/2\ of their plate with Slim Jims and pork
    bellies? Sure, but they don't. Giving people freedom--a license to eat
    with only one simple guideline--seems to keep them in check. There's
    nothing to rebel against, resist, or work around. As a result, they
    don't even try. They also don't seem to overeat.\39\ They may want more
    pasta and meatballs or another piece of pizza, but if they also have to
    balance this with a \1/2\ plate of fruit, vegetables, or salad, many
    people decide they don't want it bad enough.\40\
    ---------------------------------------------------------------------------
        \39\ Check out the article Brian Wansink and Kathryn Hoy,``Half-
    plate Versus MyPlate: The Simpler the System, the Better the
    Nutrition,'' forthcoming, and Brian Wansink and Alyssa Niman, ``The
    Half-Plate Rule vs. MyPlate vs. Their Plate: The Effect on the Caloric
    Intake and Enjoyment of Dinner,'' Journal of Nutrition Education and
    Behavior 44, no. 4 (July-August 2012): S33.
        \40\ The more latitude we give, the more likely they'll follow our
    advice. When rules become just a little too complicated or vague, we
    find reasons to stop following them. This was an early problem with
    MyPlate. When somebody starts questioning ``Where does my dessert go?''
    or ``How am I supposed to eat fruit with dinner,'' the more likely they
    are to simply say ``Whatever'' and ignore it.

              Using our Half-Plate Rule works amazingly well at home, but
    ---------------------------------------------------------------------------
            only if you also use it when you shop.

        Using our Half-Plate Rule works amazingly well at home, but only if
    you also use it when you shop.\41\ To use it, you need to have enough
    fruits, vegetables, and salad around in the first place. If as you shop
    you think about you and your family being half-plate healthy, you'll
    buy healthier and you'll also spend more. The first is good for you;
    the second is good for the store.\42\
    ---------------------------------------------------------------------------
        \41\ A recap of this done by Jane Andrews, Wegmans dietitian, can
    be found at http://rochester.kidsoutandabout.com/node/1901.
        \42\ See more at Wansink and Niman, ``The Half-Plate Rule vs.
    MyPlate vs. Their Plate.''
    ---------------------------------------------------------------------------
        Wegmans jumped on our idea. Within 2 years, it was rolled out to
    all their stores, and you can now get Half-Plate place mats, magnets,
    posters. (They renamed it the trademarkable Half-Plate Healthy.) You
    can see it in action in any of their stores, and the only place it
    works better than in a grocery store is in your home.
        Supermarkets don't have to talk about servings of fruits and
    vegetables to get the point across. All they need to do is to reinforce
    the idea that \1/2\ a plate could hold whatever fruit, vegetables, or
    salad a person wanted. They can do this on signs, specials, recipes, or
    in-store promotions--and subtly encourage people to fill their cart
    with slightly more fruits and vegetables than they typically do.\43\
    ---------------------------------------------------------------------------
        \43\ Learn more about how Wegmans implemented our idea at http://
    www.wegmans.com/webapp/wcs/stores/servlet/
    ProductDisplay?storeId=10052&partNumber=UNIVERSAL_20235.

    ------------------------------------------------------------------------
                              What You Can Do . . .
    -------------------------------------------------------------------------
                           The Half-Plate Rule at Home
    ------------------------------------------------------------------------
        ``Fill \1/2\ your plate with fruit, vegetables, or salad, and fill
     the other \1/2\ with whatever you want.'' We've given this simple rule
     to tens of thousands of people because it works. People often report
     back to us that they eat fewer calories and they eat a lot more
     ``balanced'' diet than they did before. They also say they eat until
     they're full but not stuffed.\44\
    \44\ Wansink and Hoy, ``Half-plate Versus MyPlate.''
        Nobody likes to be told they can't do something. With the Half-Plate
     Rule there's nothing you can't eat. You just have to eat an equal
     amount of fruit, vegetables, or salad. At some point, getting that
     fourth piece of pizza just isn't worth having to eat another \1/2\
     plate of salad. But, most important, you're the one who made that
     decision.
    ------------------------------------------------------------------------

              After forty-five minutes of seeing food, guess what we want?
              It's not a snack-size can of lima beans.
    The Three Checkouts
        Grocery Shopping Isn't Exactly a trip to Fantasy Island, but the
    checkout line can be an exception. It's filled with guilty-pleasure
    rewards at the end of the ho-hum errand of shopping. There are bizarre
    new gum flavors like mango chutney mint, meal-size candy bars, and
    irresistibly tacky tabloids with headlines like ``Cellulite of the
    Stars.'' These aisles are entertaining, but if you're with kids, you're
    doomed. Kids in grocery checkout lines are like kids in toy stores.
    They grab, bug, beg, pout, and scream. And if we cave in to buying pink
    marshmallow puff candy shaped like Hello Kitty, we also cave in to
    buying something with lots of chocolate--for us. There's usually
    nothing in the aisle that we actually need, but after forty-five
    minutes of seeing food, guess what we want? It's not a snack-size can
    of lima beans. So we buy the Heath bar we swore we'd never buy again,
    finish it by the time we leave the parking lot, and shake our head on
    the way home . . . just as we did last week.

              Mothers shopping with children wanted more foodfree cashier
            lines. Fathers shopping with children didn't exist.

        One supermarket solution is to set up at least one checkout line so
    it's totally candy-free.\45\ Just as large supermarkets have different
    lines for ``10 items or less'' or ``cash only,'' some lines could have
    candy, others could have healthy snacks, and some could totally be free
    of food. The stores could still sell magazines and other crazy things--
    like eyeglass repair kits and superglue--but one or two aisles wouldn't
    have any food at all.
    ---------------------------------------------------------------------------
        \45\ See Ulla M. Toft, Lise L. Winkler, Charlotte Glumer, and Brian
    Wansink (2014), ``Candy Free Checkout Aisles: Decreasing Candy Sales in
    Bornholm Island Supermarkets,'' under review.
    ---------------------------------------------------------------------------
        To see what tired shoppers in grocery store parking lots thought of
    this idea, we asked, ``If your favorite supermarket had ten checkout
    lines, how many should be candy lines, healthy lines, or food-free
    lines?'' Here's what we found:

       Men shopping alone wanted all candy lines.

       Women shopping alone wanted more of the healthy food lines.

       Mothers shopping with children wanted more food-free lines.

       Fathers shopping with children didn't exist.

        An easier first step would be to help convince your local
    supermarket manager to start by simply adding a healthy line--perhaps
    selling fresh fruit, granola bars, and so on. It might be the one
    longer line shoppers wouldn't mind waiting in. When the manager sees
    those lines getting longer, he'll quickly make the bigger steps. If he
    doesn't, there are other places you can shop.

    ------------------------------------------------------------------------
                       How Your Grocer Can Help You . . .
    -------------------------------------------------------------------------
                    What If All the Aisles Were Candy Aisles?
    ------------------------------------------------------------------------
        If you want that food-free checkout experience but all the aisles
     are loaded up with Skittles and SweeTarts, here's what you do:

        1.  Tell the manager that you want to avoid impulse-buying candy
         while you're in the checkout line. Ask him or her which of the open
         checkouts would be least tempting for a dieter or a shopper with
         children.

        2.  While the manager is thinking, ask if they would consider
         putting in a candy-free aisle. You can mention that other stores
         (such as Hy-Vee, Wegmans, and HEB) have at least one candy-free
         checkout aisle, and you've heard they're popular with both dieters
         and parents shopping with kids. If one of those stores you mention
         happens to be a nearby competitor, it might not be too many more
         trips before you have your candy-free aisle. That will be a good
         time to say ``thank you.'' \46\
    \46\ More at Ulla M. Toft, Charlotte Glumer, Lise L. Winkler, and Brian
     Wansink (2015), ``Food Free Checkout Aisles: A Danish Field Study of
     Becoming Slim by Design,'' under review.
    ------------------------------------------------------------------------

    Which of These Would You Like To See at Your Grocery Store?

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Back to Bornholm
        After Watching, Coding, and Analyzing Shoppers on the Danish island
    of Bornholm, we generated a small list of changes--baby steps--these
    grocers could make to profitably help shoppers become slim by design.
    We were scheduled to present these ideas to all nine grocery store
    managers at the Bornholm Island Hall after they got off work a couple
    of days later at seven thirty.

    ------------------------------------------------------------------------
                       How Your Grocer Can Help You . . .
    -------------------------------------------------------------------------
                 The Original Slim-By-Design Supermarket Pledge
    ------------------------------------------------------------------------
        When the Danish Government said they'd be willing to try almost
     anything we recommended, here's what we first suggested, and here's
     what paved the way for the full 100-point Supermarket Scorecard at the
     end of this chapter. We asked them to try the three changes that would
     be easiest and most profitable for them.

          1.  Provide divided \1/2\ carts that encourage people to put their
         fruits and vegetables in front. The dividers can be made from
         paint, duct tape, mats, etc.

        2.  Angle produce displays and use floor decals (such as green
         lines) to guide and keep people shopping longer in the produce
         section.

        3.  Place the healthiest foods in Aisles 1 through 3.

        4.  Make the healthiest aisles the widest and put healthy products
         at eye level or on end-of-aisle displays (endcaps).

        5.  Use the ``Half-Plate Rule'' promotion.

        6.  On end-of-aisle displays, combine the regular promotion with a
         healthy food complement.

        7.  Have two or three types of checkout lines: standard, food-free,
         and healthy foods only.
    ------------------------------------------------------------------------

        Unfortunately, 2 days later at seven thirty my five-person
    delegation of researchers almost equaled the six grocery managers who
    actually showed up. Strike one. After starting the presentation with
    the only Danish word I knew--``Velkommen'' (welcome)--I told them the
    night was all about ``new ways you can sell more of your healthier
    foods and make more money.'' We then went on to give a punchy
    presentation on seven easy changes that we knew would work well. We had
    photos, video clips of shoppers, cool study results, numbers, and funny
    stories. It was great . . . except that nobody laughed, asked a
    question, moved, or even seemed to blink. It was like Q&A hour in a wax
    museum. Strike two.

              We generated a small list of changes these grocers could make
            to profitably help shoppers become slim by design.

        Because there were no signs of life, I idled down my enthusiasm and
    wrapped up our presentation a half hour early so my Danish colleagues
    could try to salvage the evening. Once they started talking in Danish,
    some sort of switch flipped in the managers. They started talking
    louder, started to un-Danishly interrupt each other, and then started
    arguing. Thinking things were getting out of control, I suggested we
    call it a night before they started to break furniture. My Danish
    colleagues waved me off and the melee continued. An hour later, things
    had slowed down, and the managers thanked us and cleared out. Before we
    started cleaning up, I asked my Danish colleagues why they were so
    irate. They said, ``Oh, no. They like the changes and they'll make most
    of them. The rest of the time they were talking about the other changes
    they wanted to make, like having more produce tastings, more pre-
    prepared salads, and bundling meat and vegetable specials together.''
        After all our supermarket makeovers, does every Bornholmian look
    like a sleek, slim, Danish version of Mad Men? As I mentioned earlier,
    it's still too soon to say (we're posting updates at
    www.SlimByDesign.org/Bornholm), but with every trip I make, all signs
    point in the right direction.
        One way to tell how well a new idea is working is by how many
    people want to jump in and be a part of it. The more changes we made to
    the grocery stores in Bornholm, the more other groups got involved.
    Before long, a public health advertising campaign was being rolled out,
    petitions were launched, and local ordinances were proposed. After the
    kitchen smoke clears, it will be difficult to see which of these moved
    the dial the most--but the people on the island are buying in to
    becoming slim by design.
        There's a humbling expression: ``Success has a thousand fathers,
    but failure has only one.'' If there are dramatic changes in the foods
    these Danes buy, the public health people will say it was because of
    their ads, the activists will say it was because of their tireless
    petition drives, and charismatic politicians will say it was because of
    their bold regulations. But if nothing happens and the whole plan ends
    up being a failure, which father will take the blame? It won't be the
    public health adviser or the politician. They'll abandon the program in
    a heartbeat. Unsuccessful public health campaigns cost lots of money.
    Unsuccessful ordinances can cost political careers.

              We projected each change would turn a profit within a month
            if not immediately.

        Yet these supermarket makeovers were cheap and easy to make. Many
    were done over a weekend, and we projected each of them would turn a
    profit within a month if not immediately. Still, if even one works,
    stores will be further ahead than before. On my most recent trip, they
    asked me to help expand it to the mainland, so some hidden sales
    numbers must be looking pretty good. It's the beauty of being slim by
    design.
    How Your Grocery Store Can Make You Slim
        There Are Dozens of Ways your favorite grocery store could
    profitably help you shop a little healthier. In April 2014, I shared
    the Bornholm story with some of the innovative American grocery stores
    that sponsored some of the studies you've read about throughout this
    chapter. They all had clever ideas they were trying out in their stores
    to help their customers shop a little healthier, but they were all
    doing something different--and often repeating each other's mistakes.
    If we could pool together all of my Lab's slim-by-design research
    findings with some of the ideas they were successfully experimenting
    with, we could make a supermarket scorecard that could help guide all
    of them to make profitable healthy changes.

              This supermarket scorecard tells shoppers what they should
            look for or ask their local grocery manager to do.

        Grocery chains are competitive--and not just for shoppers. Even
    though a grocery chain in Texas doesn't compete for the same shoppers
    as a grocery chain in Chicago, they all want to win awards for Most
    Popular, Prettiest, Smartest, or Most Likely to Succeed at their annual
    Grocery Store-a-Palooza Award Conference. Because having a scorecard
    means there might be yet another new award they could compete on, most
    were eager to help develop one. But more important than enabling
    grocery chains to compete with each other, this supermarket scorecard
    will transparently show them exactly how to compete. Also, it will tell
    shoppers what they should look for or ask their local grocery store
    manager to do. If all these changes help grocery stores make a little
    more money, grocers will want to make the changes. If all these changes
    help shoppers shop a little healthier, shoppers will want to hassle
    their favorite grocer until he or she makes changes.

             Slim-by-Design Grocery Store Self-Assessment Scorecard

    ------------------------------------------------------------------------
        Okay, so your favorite grocery store has great prices, selection,
     and convenience, but it might still be making you fat and happy instead
     of happy and slim. This scorecard tells you what your store is doing to
     help you eat better. Our Lab has been working with top grocery chains
     around the nation to help them make you slim by design. You can use a
     scorecard like this to compare your favorite grocery stores, but it
     will also tell you what you can ask them to do to make you and your
     family more slim--and more loyal to their store. Some items on this
     scorecard might initially seem to have nothing to do with food--like
     having restrooms and a drinking fountain in the front of the store--but
     together they will make you less anxious or more comfortable, and
     others will slow you down and relax you. In the end, even some of these
     nonfood changes can lead you away from impulsively buying Chunky Monkey
     ice cream and more toward intelligently buying bananas. This is a
     start--every year this scorecard is updated with the best practices and
     the best research that helps us shop better (and helps stores make
     money). The newest can be found at SlimByDesign.org.
    ------------------------------------------------------------------------
                                    Entrance
    ------------------------------------------------------------------------
     Assign designated parking spots      The first area entered by most
     (similar to handicapped spots) for   shoppers is the produce section.
     pregnant women and mothers with      Free healthy samples are near the
     infants.                             entrance.
     Offer preprinted shopping lists of   There's a small ``grab and go''
     basic staples near the entrance.     area in the front of the store
     Provide information sheets near      with a small selection of milk and
     the entrance on healthy ways to      bread for the in- and-out, or
     shop.                                ``fill-in'' shopper.
     Offer healthier foods near the       There's a small ``grab and go''
     entrance to prime healthy            area in the front of the store
     shopping.                            with a small selection of milk and
     Two sizes of shopping carts are      bread for the in- and-out, or
     available.                           ``fill-in'' shopper.
     Handbaskets are available.
     Divided shopping carts with a
     ``place fruits and vegetables
     here'' section are provided.
    ------------------------------------------------------------------------
                              Services and Signage
    ------------------------------------------------------------------------
     Signs promote seasonal               Signs provide ``Did you know?''
     combinations of fruits and           facts about the health benefits of
     vegetables.                          specific foods.
     Educational posters are located      There are specific perimeter
     around the stores to educate         promotions for lean dairy.
     people about healthy eating (for     There are specific promotions for
     example, the Half-Plate Rule).       whole-grain products, such as
     Local and seasonal foods are         bread and pasta.
     clearly promoted.                    Calorie information is available
     There is a special section for       in the meat section.
     organic fruits and/or vegetables.    Healthy food apps such as
     The organic section is boldly and    Fooducate and QR codes are
     clearly labeled.                     promoted.
     At least one produce-tasting         A kiosk with tear-off recipes is
     station is near the entrance.        available in the produce section.
     A wide range of precut fruits and    Combo packs are available that co-
     vegetables are available.            promote healthy foods (such as
                                          tomatoes and mozzarella).
     There are separate in-aisle          A guidance system such as Guiding
     promotions for canned fruits.        Stars or a stoplight approach is
                                          used.
     There are separate in-aisle          A dietitian is available and
     promotions for canned vegetables.    visible in the store a couple of
                                          days each week.
     There are separate in-aisle          Unit pricing ($/oz) is available
     promotions for frozen vegetables.    where relevant.
     There are specific perimeter
     promotions for lean meat.
    ------------------------------------------------------------------------
                              Layout and Atmosphere
    ------------------------------------------------------------------------
     Relaxing music is played in the      Lighting varies throughout the
     produce section.                     store, but is always brightest on
     Show price per unit along with       the healthier foods.
     price per weight for healthy food,   Healthy tear-off recipe cards are
     for ease of calculation.             provided near the fruits and
     Floor decals are used for way-       vegetables.
     finding to healthy sections.         Recipe ingredients for the recipe
                                          cards are located next to the
                                          cards.
    ------------------------------------------------------------------------
                               Aisles and Shelves
    ------------------------------------------------------------------------
     Some fruits are bundled into         Ingredients are organized by
     family-size packs.                   preparation type (stir-fry versus
     Some vegetables are bundled into     salad)--for example, put
     family-size packs.                   mushrooms, eggplants, and peppers
                                          in a ``stir-fry'' section.
     A complementary fresh produce        Expiration dates are visible (at
     display is available in the meat     front of package or on signs).
     section (such as one containing      Aisles with healthy foods are the
     broccoli, peas, cauliflower, and     widest.
     peppers).                            Less healthy foods are
     A complementary fresh produce        inconveniently placed very low or
     display is available in the          very high on the shelves.
     seafood section (such as lemons,     Healthier foods are conveniently
     tomatoes, beans, and asparagus).     placed at eye level.
     A complementary fresh produce        Aisles with healthy food are
     display is available in the frozen   brighter than aisles with
     food section.                        unhealthy food.
     Displays of single fruits (such as   Hard-to-decide-upon foods (``long-
     oranges, apples, pears,              buy'' items), such as soups,
     nectarines, and apricots) are next   dressings, and baby foods are
     to desserts.                         located in less busy aisles so
     Ready-to-eat fruits and vegetables   people are relaxed enough to
     are available in variety packs.      comparison shop.
    ------------------------------------------------------------------------
                               Prepared Food Area
    ------------------------------------------------------------------------
     Fruit is available in all            The healthy daily targeted entrees
     foodservice areas.                   have creative or descriptive
     Vegetables are available in all      names.
     food-service areas.                  Posters displaying healthy foods
     A mix of whole fruit options is      or a guidance system (such as the
     displayed in an attractive bowl or   Half-Plate Rule) are visible in
     basket.                              the dining area.
     The ``pick me up'' or prepared       The cafeteria tracks the
     food section has healthy default     popularity and frequency of
     foods.                               healthy-option orders to see what
     A daily fruit or vegetable option    promotions work most effectively.
     is bundled into all grab-and-go      All promotional signs and posters
     meals.                               are rotated, updated, or changed
     A salad bar is available.            at least monthly.
     All beverage coolers have both       Half portions are available for
     water and white milk available.      all entrees.
     Alternative healthy entree options   Half portions are available for
     (salad bar, yogurt parfaits, and     all desserts.
     the like) are highlighted on         Takeout boxes are available for
     posters or signs within all dining   leftovers not eaten in the
     areas.                               cafeteria.
     The healthy daily targeted entree
     is placed as the first one seen in
     all dining areas.
    ------------------------------------------------------------------------
                           Shopper Comfort and Service
    ------------------------------------------------------------------------
     Restrooms are easily accessible in   Health and nutrition games
     the front of the store.              dominate the playroom.
     A drinking fountain is located in    A local fitness club is co-
     the front of the store.              promoted.
     There is an area for shoppers to     A small discount to a local
     sit and relax.                       fitness club is given to loyalty
     There is an area for shoppers to     club shoppers.
     eat.                                 There is a drive-through where you
                                          can pick up your groceries, if you
                                          call ahead.
     There is a supervised playroom for   Home delivery is available (for an
     children.                            extra charge).
    ------------------------------------------------------------------------
                     Engagement: Employees and Social Media
    ------------------------------------------------------------------------
     The produce-department manager and   All employees are trained to
     staff are specifically trained to    suggest healthy complementary
     suggest healthy answers to shopper   products when asked about a
     questions.                           particular item.
     The meat-department manager and      There are plentiful staff in the
     staff are trained to suggest         meat and produce sections who are
     healthy answers to shopper           trained to suggest healthy upsells
     questions.                           or substitutes.
     The dairy-department manager and     Store or chain has an eng aging
     staff are trained to suggest         website that has a health-related
     healthy answers to shopper           blog featuring local or seasonal
     questions.                           products.
     The bakery-department manager and    The website has shopper loyalty
     staff are trained to suggest         specials.
     healthy answers to shopper           Tips, features, or videos
     questions.                           involving better shopping and
                                          better living (such as ``Shopping
                                          with Kids'') are available.
    ------------------------------------------------------------------------
                                    Checkout
    ------------------------------------------------------------------------
     Loyalty programs specifically        Receipt provides an indication of
     reward fruit and vegetable           what percentage of purchases were
     consumption.                         fruits and vegetables, low-fat
     Receipts are itemized in             meat, and low-fat dairy.
     categories or otherwise coded to     A default shopping ``starter''
     indicate how healthy you're          list is made available to each
     shopping.                            shopper at the front of the store
     The back of receipts feature         with a number of the major staples
     coupons for healthy foods.           preprinted on it.
     There is at least one food-free      The same healthy shopping-tips
     checkout aisle.                      brochure available at the
     A discount is offered if a certain   beginning of the shopping trip is
     percentage of purchases are fruits   also available at the checkout
     and vegetables.                      register.
     Individual containers of precut      ``Don't Forget'' signs are placed
     fresh fruit are available next to    at the register to remind
     at least one cashier.                customers about certain healthy
     Healthy snack options are offered    foods.
     next to the cashiers.                A ``fruits and vegetables only''
     Receipt uses loyalty card            self-checkout station is provided
     information to show how much was     for quick purchases of produce.
     spent on fruits and vegetables
     compared to past trips.
    ------------------------------------------------------------------------
                                Scoring Brackets
    ------------------------------------------------------------------------
         70-100--Slim-by-Design Grocery Store--Gold

         50-69--Slim-by-Design Grocery Store--Silver

         30-49--Slim-by-Design Grocery Store--Bronze
    ------------------------------------------------------------------------

                                  Attachment 2
    Healthy Profits: An Interdisciplinary Retail Framework that Increases
            the Sales of Healthy Foods
    Brian Wansink a-b, *
    ---------------------------------------------------------------------------
        \a\ Dyson School of Applied Economics and Management, Cornell
    University, United States.
        \b\ Cornell Food and Brand Lab, Cornell University, United States.
        * Correspondence to: 475 H Warren Hall, Cornell University, Ithaca,
    NY 14853, United States. Fax: +1 607 255 9984.
        E-mail addresses: bcw28@cornell.edu, foodandbrandlab@cornell.edu.

      http://dx.doi.org/10.1016/j.jretai.2016.12.007**
    ---------------------------------------------------------------------------
        ** Please cite this article in press as: Wansink, Brian, Healthy
    Profits: An Interdisciplinary Retail Framework that Increases the Sales
    of Healthy Foods, Journal of Retailing (xxx, 2017), http://dx.doi.org/
    10.1016/j.jretai.2016.12.007.
    ---------------------------------------------------------------------------
      0022-4359/' 2017 New York University. Published by
        Elsevier Inc. All rights reserved.
    Abstract
        Disruptive layouts, smart carts, suggestive signage, GPS alerts,
    and touch-screen preordering all foreshadow an evolution in how healthy
    foods will be sold in grocery stores. Although seemingly unrelated,
    they will all influence sales by altering either how convenient,
    attractive, or normal (CAN) it is to purchase a healthy target food. A
    Retail Intervention Matrix shows how a retailer's actions in these
    three areas can be redirected to target shoppers based on whether the
    shoppers are Health Vigilant, Health Predisposed, or Health
    Disinterested. For researchers, this review offers an organizing
    framework that integrates marketing, nutrition, psychology, public
    health, and behavioral economics to identify next generation research.
    For managers, this framework underscores how dozens of small, low cost,
    in-store changes are available to each that can surprisingly increase
    sales of entire categories of healthy food.

              2017 New York University. Published by Elsevier Inc. All
            rights reserved.
    Introduction
    ---------------------------------------------------------------------------
         Editor's note: The article is in press, consequently, the
    endnotes are unnumbered. In the submitted article pdf the referenced
    works have the author'(s) name(s) highlighted for hyperlinking, but
    they are not linked; therefore, the endnotes are in order as printed
    and not in order as referenced.
    ---------------------------------------------------------------------------
        Our best and worst eating habits start in the grocery store.
    Although critics claim that retailers are primarily motivated to sell
    unhealthy processed food--Froot Loops instead of fruit or fish sticks
    instead of fish--the opposite is true for the savvy ones. If the fruit
    turns mushy and the fish begins to smell, retailers may lose more money
    in sunk inventory costs then they would otherwise gain by selling the
    processed versions. Grocers are motivated to sell healthy, profitable
    foods. Unfortunately, they do not know how to effectively do so
    (Chandon and Wansink 2012; Guthrie 2017; Inman and Nikolova 2016), so
    retail fruit and vegetable sales continue to drop (Haywood 2016;
    Produce for Better Health 2015).
        Each issue of Supermarket News and Progressive Grocer highlights
    clever twists on how retailers can increase sales: novel POP displays,
    creative cross-promotions, compelling incentive programs, colorful
    floor decals, and trendy planogram arrangements. Most of these tactics
    are driven by manufacturers of branded, less-than-healthy packaged
    goods. In contrast, most of the newest and most creative solutions for
    selling unbranded healthy products--such as fish, poultry, fruits, and
    vegetables--have been discovered in academia (Johnson, et al., 2012).
        Regretfully, however, many of these discoveries are not widely
    adopted or used beyond one or two field test stores (Inman 2012).
    First, these discoveries appear disorganized or disjoint because
    together they use a wide range of interventions to investigate a wide
    range of outcomes (such as sales, satisfaction, loyalty, repatronage,
    eye-tracking, and so on). This combination is overwhelming to a manager
    who is looking for a single solution, such as how to simply sell more
    fish. Instead of giving managers a useful toolbox of organized
    solutions, what we give them is more like a shoebox full of tax-time
    receipts.
        The second reason our work is infrequently translated into practice
    is because its conclusions are either uncompelling or inconsistent
    (Vermeir and Van Kenhove 2005).We tend to focus on interactions or
    boundary conditions where an intervention might work with some
    customers and with some food categories, but not with others (List,
    Samek, and Zhu 2015). For instance, a Traffic Light rating system may
    be useful to some shoppers (Dzhogleva, Inman, and Maurer 2013; Grunert,
    Bolton, and Raats 2011; Trudel, et al., 2015), but to others it might
    be a glaring warning sign that the food will taste bad (Werle, et al.,
    2011). Academia thrives on interactions and exceptions, but the rest of
    the world runs on main effects.
        The future of healthy retailing will be guided by the future of new
    research. All of the research in this review has been published or
    conducted after 2011 and \1/2\ are still working papers.
        They comprise a framework that integrates the newest discoveries in
    marketing, health psychology, public health, consumer research,
    nutrition, and behavioral economics to identify what might be the most
    actionable and compelling new research to influence practice and
    theory. First, the framework collapses the myriad of individual
    differences among shoppers into a three-segment hierarchy which
    summarizes their healthy shopping disposition. Second, it offers a
    useful way to organize the receipt box full of findings in a way that
    shows how various interventions work (improving convenience,
    attractiveness, and norms) and where they can work within grocery
    stores (by altering the signage, structure, service mix). Fig. 1
    foreshadows how these pieces will combine to eventually create a Retail
    Intervention Matrix framework that can organize existing findings and
    stimulate useful new insights.
    Fig. 1. How and Where Retail Interventions Can Influence Shoppers

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    The Hierarchy of Health Predispostion
        Not all shoppers shop alike. Health food enthusiasts shop
    differently than mothers shopping with kids; a ``hot'' fast-thinker
    shops differently than a ``cold'' slow-thinker; and variety-seekers
    shop differently than budget-constrained shoppers (Hui, Huang, et al.,
    2013; Verhoef and van Doorn 2016). There will always be an exception or
    an untested segment. This sometimes leads our results to appear
    frustratingly inconclusive when we have to admit that we do not know
    whether our new intervention works the same way with elderly shoppers
    as it does with shoppers using SNAP benefits (Guthrie 2017).
        One solution is to only view shoppers based on how predisposed they
    are to making a healthier shopping decision. We can view them as
    belonging to one of three fluid groups that belong to a Hierarchy of
    Health Predisposition. The top segment of this hierarchy are Health
    Vigilant shoppers (Fig. 2). They are highly informed, conscious of
    calories, and are influenced by nutrition information. At the bottom
    extreme, Health Disinterested shoppers have little interest in changing
    their eating choices because of either the effort, sacrifice, or
    perceived futility. The segment in the middle are the Health
    Predisposed shoppers. They would prefer to make healthier food choices,
    but they have difficulty consistently doing so unless it involves very
    little sacrifice. This Predisposed segment is the one that buys the
    100-calorie packages of snacks and the sugar-free yogurt. This segment
    is larger on New Year's Day than it was in December; it was larger this
    past Monday morning than it was during the prior Friday night's
    shopping trip.
        One reason nutrition guidance systems (such traffic lights or
    Guiding Stars) have had only modest influences on the sales of healthy
    food (Cawley, et al., 2015; Nikolova and Inman 2015) may be because
    they mainly resonate with only the top of the Hierarchy. Health
    Disinterested shoppers ignore these programs, and heath predisposed
    shoppers inconsistently follow them. If the only segment they reach are
    the vigilant shoppers, interventions like this will have hardly any
    sizable impact on health since this segment is already shopping in a
    healthy way. Even if the same intervention is perfectly targeted at the
    bottom portion of the Hierarchy, it would have hardly any impact
    because the bottom segment does not care.
    Fig. 2. The Hierarchy of Health Predisposition

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    The CAN Approach to Improving Healthy Shopping
        Changing widespread eating behavior does not happen by convincing
    shoppers that an apple is healthier than a Snickers nor does it happen
    by coaching them to improve their imperfect willpower. While these may
    be reminders to Health Vigilant shoppers, they will not reliably work
    with Health Predisposed shoppers, and almost certainly will not work
    with Health Disinterested shoppers. Instead, a more sensible and cost-
    effective solution would be to simply make sure that the apple is much
    more convenient, attractive, and normal to choose than the Snickers.
    Offering an apple sample at the front of the store primes more fruit
    sales (Tal and Wansink 2015) and offering an apple display at the
    checkout helps pre-empt Snickers sales (Winkler, et al., 2017). Such
    changes are effective because they influence passive shoppers and not
    just the vigilant ones.
        In 2011, Denmark started a public health initiative to reduce
    obesity--partly by trying to increase the sales of fish, fruits, and
    vegetables (fresh, frozen, and canned) in grocery stores (thereby
    hopefully decreasing the sales of less healthy foods). Starting with a
    list of dozens of retail changes that were believed to be revenue
    positive (see Appendix A), six were selected to be implemented over a 2
    year period on the isolated Danish island of Bornholm (population
    42,000). The six interventions selected were ones that retailers
    believed would both be profitable and easy to implement and maintain:

      1.  Fruit displays within 10 of the entrance

      2.  At least one candy-free check-out line

      3.  Traffic interrupters (displays of healthy foods in the
                wideraisles)

      4.  End-aisle displays of fish

      5.  Traffic Light (``Green Key'') labeling

      6.  In-Store Promotions = \1/2\ Plate Rule Guidance System

        In combination, these retail interventions were successful because
    they made it more convenient, attractive, and normal to purchase fish,
    fruits, and vegetables. For instance, putting fruit in an attractive
    display made it appear more normal (typical, or reasonable) to take
    fruit--partly because it was now also more convenient and looked more
    attractive. It was the CAN approach to changing behavior (Wansink
    2015). Looking toward the future of retailing, the key to doing this
    successfully is to not handicap our imagination by too narrowly
    defining what is meant by convenient, attractive, and normal (Bommelaer
    and Wansink, 2017).
    More Convenient to Select
        As Fig. 3 illustrates, a manager can help make healthy foods more
    convenient to see, to consider, and to purchase (Desai and Trivedi
    2014; Gilbride, Inman, and Stilley 2015). For instance, one of the
    biggest barriers to purchasing fish is that many shoppers are not
    confident about how to prepare and serve it. With these shoppers, no
    nutrition scale or promotion would lead a person to buy more fish until
    they understood that it could be integrated into cooking routines that
    were familiar and convenient for them. This was similar with tofu and
    to counter this, the largest tofu manufacturer in the U.S. launched an
    in-store campaign that clearly illustrated that tofu is convenient to
    buy and to cook (``Fridge to pan in 10 minutes'' and ``Cooks like
    chicken'') which helped increase both shopper confidence and retail
    sales (Hsu 2014).
        Even when shopping for familiar foods in familiar aisles, small
    changes can conveniently guide shoppers to make healthier choices.
    Vegetables placed near the front entrances are selected eight percent
    more than those that are not (Wilson, et al., 2016), floor decals that
    guide people to other vegetable displays increased sales by nine
    percent (Payne and Niculeseu 2012), and center-of-aisle ``traffic
    interrupter'' displays repeatedly increased 1 day sales of overlooked
    vegetables by 400% in Denmark. Convenience also helps explain why about
    43% of interior aisle grocery sales are within 12" of eye level (Stein
    2018). This ``you buy what you see'' continues all the way to the
    checkout where fruit displays can increase short-term sales by 35% (van
    Kleef, Often, and van Tripj 2012).
    Fig. 3. The CAN Approach To Influencing Shopping Decisions

        Along with saving physical effort, convenience can also refer to
    saving cognitive effort. This ranges from using easier-to-understand
    product category layouts (de Wijk, et al., 2016; van Herpen 2016) to
    leveraging technology in the form of GPS alerts or personal shopping
    profiles (Sciandra and Inman 2014). Such reminders can guide shoppers
    to healthier choices by making it both more cognitively convenient to
    select and more convenient to visualize this food being prepared and
    eaten at a home meal (Hui, Inman, et al., 2013; Lowe, Souza-Monteiro,
    and Fraser 2013).
    More Attractive to Select
        The second principle of the CAN approach is that the healthy choice
    needs to be made more attractive relative to less healthy (but usually
    more tastier) options. It could be more attractively named, more
    attractive in appearance, more attractively priced (Hampson and
    McGoldrick 2013), or it could evoke more attractive taste expectations
    than it usually does (Trivedi, Sridhar, and Kumar 2016; Vega Zamora, et
    al., 2014). Fruit that is haphazardly piled onto a flat table is less
    attractive than fruit that is angled on a display with a colored frame
    around it (Stein 2018). Even simply giving a fruit or vegetable a
    descriptive name--crisp carrots or Michigan cherries--makes them more
    attractive and increases a person's taste expectations (Spence and
    Piqueras-Fiszman, 2014) and selection by sixteen percent or more
    (Wansink, et al., 2012).
        Attractive packaging, descriptive names, color, labels, and
    appearance have all been shown to bias evaluations of taste. Food can
    also be more attractive simply by being novel (curried pumpkin),
    attention-getting (heirloom Indian corn), or even more ethically
    attractive (meat-free turkey). Both the sustainability movement and the
    ``ugly vegetable'' movement have capitalized on ethically-motivated
    shoppers who find sustainable products to be more attractive.
        Making a food more attractive by altering its price is a popular
    tool of behavioral economists, and it takes the standard form of taxes,
    subsidies, rebates, coupons, and bundling (Carroll, Samek, and Zepeda
    2016). Unfortunately, when price rebates have been offered on fruits
    and vegetables, they can sometimes backfire by increasing both the
    sales of healthy produce in addition to the sales of unhealthy foods--
    especially in low-income households (Cawley, et al., 2016). That is,
    the money saved on fruit is then spent on Froot Loops (Cawley, et al.,
    2016).
    More Normal to Select
        Last, many shoppers often prefer to buy the foods they believe are
    normal or popular to purchase, serve, and eat. For instance, signs that
    told people that chick peas were the favorite bean in that area
    (Harlem) shifted 21% of all bean selections over to chick peas (Bhana
    2017). This also works with quantities. Shopping cart signs that stated
    that the average shopper purchased at least five fruits and vegetables
    increased produce sales by ten percent (Payne, et al., 2014). Moreover,
    even the size of the store might subtly suggest to a customer how much
    is normal to purchase during a shopping trip (Ailawadi, Ma, and Grewal
    2016).
        Benchmarks provide visual purchase norms. Consider two benchmarks
    that increase fruit and vegetable sales. One is the Half-Plate rule
    which was originally designed to help consumers operationalize the
    spirit of USDA's MyPlate guidance system (Wansink and Tran 2017). The
    Half-Plate rule simply states that in order to eat more balanced meals,
    \1/2\ of your plate needs to be fruits, vegetables, or salad and the
    other \1/2\ can be whatever you wanted. You can have a second or third
    helping if you want, but \1/2\ of your plate always has to be fruits,
    vegetables, or salad. This was successfully implemented in the leading
    grocery chain in the United States (Kell 2016) as ``Half-Plate
    Healthy'' because it had been shown to encourage shoppers to buy
    ``considerably more'' produce (Wansink 2014). After all, if consumers
    were going to eat half-plate healthy, they needed to shop half-plate
    healthy (see Fig. 4).
    Fig. 4. The Half-Plate Rule and the Half-Cart Both Suggest Larger
            Portion Size Norms for Fruits and Vegetables

            [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

        One of the reasons the half-plate healthy approach was effective
    for this leading retailer was because it offered a simple visual
    benchmark about how much fruit and vegetables are the right amount to
    eat--half the plate. Similarly, when consumers shop, little thought may
    be given as to whether a food is healthy or not. Yet if asked to
    categorize and separate each food they buy according to whether it is
    either a fruit or a vegetable (versus neither), it forces more mindful
    shopping. One set of studies involved shopping carts that had been
    physically divided across the middle and were accompanied with a sign
    in the front that instructed people to place their fruits and
    vegetables (fresh, frozen, or canned) in the front \1/2\ of the cart
    and everything else in the back \1/2\. Using this Half-Cart approach
    increased the sales of fruits and vegetables by eighteen percent
    (Wansink, Payne, and Herbst 2017). In a second set of studies, when the
    proportion of the cart allocated to fruits and vegetables was either at
    the 35% level or the 65% level, the amount that shoppers spent
    increased from $14.97 to $17.54 (Wansink, Soman, and Herbst 2017). When
    the same type of dividing lines were added to online shopper order
    forms for grocery delivery, the same results were found. The size of
    partitions indeed matters to shoppers.
        Nearly all healthy interventions in retailing influence shoppers by
    increasing how convenient, attractive, or normal it is to purchase one
    food instead of another--an apple or a fish instead of crackers and
    beef (Bommelaer and Wansink, 2017). By organizing how our discoveries
    work, we open up new possibilities of influence. The CAN approach
    enables us to organize how our interventions influence shoppers. As
    Table 1 foreshadows, the next section shows where they will work best
    in a store.
    The Signage, Structure, Service Mix: Where Retailers Can Best Change
            Behavior
        Although nearly all shopping interventions influence shoppers by
    altering how convenient, attractive, or normal it is to buy a product,
    there are endless ways they can do so. There are also three different
    areas where retailers can influence shoppers by using these tools.
    Shoppers can be influenced through signage (inside and outside the
    store), by the structure of the store (layout and product positioning),
    and by the service the store provides (on-line, in-person, or on-site).
    This signage, structure, service mix influences different shoppers in
    different ways. Improving service might work best for Health Vigilant
    shoppers (because they are most likely to seek out the extra
    information or assistance). Improving signage might work best for
    Health Predisposed shoppers (as well as those who are and Vigilant).
    Changing the store's structure might work well for all three segments.
    Signage
        Signage overlaps with the traditional ``Promotion P'' of the 4-P's
    framework. It involves all out-of-store, in-store, and online efforts
    that are directed toward influencing what a shopper buys (Kovacheva and
    Inman 2014). Outside the store it includes fliers, circulars,
    commercials, outdoor advertising, and coupons. Inside the store it
    includes posters, signs, shelf-hangers, floor decals, and kiosks as
    well as take-home media such as recipes, brochures, and magazines, and
    more stylized or person-based media, such as tailored ads, feedback or
    messages on shopping receipts (Otterbring, et al., 2014), and GPS
    alerts for promotions. On-line it includes the website, on-line tools,
    social media, e-mail alerts, sponsored apps, and GPS alerts for
    promotions that can be triggered both in and out of the store.

      Table 1. How Sample Findings Fit Into the Retail Intervention Matrix
    ------------------------------------------------------------------------
                         More convenient    More attractive   More normal to
                           to  purchase       to  purchase       purchase
    ------------------------------------------------------------------------
    Signage              Floor      New        Signa
                         decal arrow        recipe ideas, co-  ge stating
                         stickers asking    promotions, and    that garbonzo
                         people to follow   end-of-aisle       beans were
                         the arrows to      displays           the most
                         eat more           increased canned   popular
                         nutritiously       fish sales by      beans,
                         lead to a nine     eighteen percent   increased
                         percent increase   (Toft, et al.,     selection by
                         in produce sales   in preparation)    fourteen
                         (Payne, et al.,    Starring   percent
                         2014)              items as more      (Bhana 2017)
                         Joint      healthy            Shopp
                         efforts to         decreased the      ing cart
                         provide fish       purchase of        signs stating
                         dinner recipe      unstarred (less    that the
                         cards and          healthy foods)     average
                         grilling           by two percent     shopper
                         instruction        (Cawley, et al.,   purchased at
                         brochures were     2015)              least five
                         part of a larger                      fruits and
                         campaign that                         vegetables
                         increased fish                        increased
                         sales by 28%                          produce sales
                         (Karevold, Tran,                      by ten
                         and Wansink                           percent
                         2017)                                 (Payne, et
                                                               al., 2014)
    Structure            A fruit    Fruit      Visua
                         display near       samples provided   lly diving a
                         cash register      to consumers       shopping cart
                         increased sales    upon entering      in \1/2\ and
                         35%, even when     the store          suggesting
                         product was not    increased sales    that \1/2\
                         discounted (van    fruit sales by     should be
                         Kleef, Often,      seven percent      used for
                         and van Tripj      (Tal and Wansink   fruits and
                         2012)              2015)              vegetables,
                         Items      People     increased
                         (including         were sixteen       their sales
                         produce) that      percent more       by fourteen
                         was within 12"     likely to          percent
                         of a shopper's     purchase a         (Wansink,
                         eye-level          product from the   Payne, and
                         comprised over     first full aisle   Herbst 2017;
                         43% of all sales   they entered       Wansink,
                         (Stein 2018)       than any           Soman, and
                                            subsequent aisle   Herbst 2017;
                                            (Stein 2017)       Wansink,
                                                               Tran, and
                                                               Karevold
                                                               2017)
                                                               Using
                                                               more islands
                                                               than aisles
                                                               in produce
                                                               aisles
                                                               increased
                                                               shopping time
                                                               and items
                                                               purchased
                                                               (Mukund,
                                                               Atakan, and
                                                               Wansink 2018)
    Service              Healthy    In-store   ``Hal
                         ``Grab and Go''    suggestions by     f-Plate
                         lines in store     staff              Healthy'' on-
                         cafeterias led     contributed to     line planner,
                         to a 82%           increased fish     led to higher
                         increase in        sales (Karevold,   produce sales
                         healthy food       Tran, and          and more
                         sales (Hanks, et   Wansink 2017)      balanced
                         al., 2012)         One        meals a
                         Mobil      loyalty program    Shopp
                         apps that          rewarded fruit     ing receipt
                         indicated what     and vegetable      ``scorecards'
                         percent of your    purchases by       ' showed
                         food is healthy    providing a        consumers how
                         and which were     scaled discount    the
                         missing, was       based on how       percentage of
                         rating as being    much was           fruits and
                         most attractive    purchased a        vegetables
                         to in-store                           purchased in
                         consumers (Mao                        this trip
                         and Atakan 2017)                      compared with
                                                               past trips
                                                               (based on
                                                               loyalty card
                                                               data) a
    ------------------------------------------------------------------------
    a Unpublished findings based on proprietary studies.

        Signage builds awareness, offers reminders, changes attitudes,
    encourages comparisons, and so on. It can change the perceived
    convenience of purchasing healthy foods by making it more convenient or
    easy to consider (``Having turkey for dinner sounds good''), by
    changing perceptions of how attractive it would be to add organic
    parsnips into a routine meal, or changing how normal it would be to
    have a full fruit bowl sitting out when the kids return home from
    school (see Fig. 5).
    Fig. 5. The Signage-Structure-Service Mix

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

    Structure
        The structure of a store includes its layout and where and how
    foods are positioned, such as whether the healthier foods are nearest
    the door, at eye level, co-promoted with other displayed products, and
    whether they are located in the first two aisles where a consumer
    shops. But structure also influences people before they even enter the
    store. Starting in the entryway, the size and shape of the shopping
    carts structurally influences how much is purchased (bigger carts lead
    to bigger shopping trips) and what is purchased (divided carts lead to
    more fruit and vegetable sales). Any changes related to shopping carts
    and hand baskets continue to influence shoppers throughout their entire
    shopping trip, but shopping carts have their biggest impact before it
    fills up because this makes a shopper's budget constraints more salient
    (van Ittersum, et al., 2013).
        A store's structure can be changed by using traffic interrupters
    and islands (instead of aisles) in the produce section. A recent
    analysis of 1,242 shoppers in four different sections of various
    grocery stores shows that while purchases in many sections of a grocery
    store (such as meat and cereal) begin to level off after 2 minutes of
    shopping, the total number of dollars spent in the produce section
    continues rising for about 12 min. at a rate of $1.84/min. One
    objective for a store, therefore, is to determine how to keep people
    shopping in the produce section for up to 12 min. Islands (instead of
    aisles) may help. They appear to slow shoppers down which relates to
    them spending more money on produce (Mukund, Atakan, and Wansink 2018).
    Service
        Most obviously, service includes the sunny appearance, helpfulness,
    and friendliness of greeters, butchers, and cashiers (Huneke, et al.,
    2015; Keeling, McGoldrick, and Sadhu 2013), the cleanliness of the
    store, and the restocking and upkeep of shelves (Robinson, et al.,
    2016). Yet much of the service that really guides shoppers to healthier
    choices is surprisingly less face-to-face. It starts with how
    technology can influence the goals and expectations customers have
    before they enter the store (Gustafsson, et al., 2016; Hunneman,
    Verhoef, and Sloot 2015; Lee 2015), such as when a Health Vigilant
    shopper reads a store blog on healthy food substitutes and prints off
    the related coupons. Once in the store, service can be efficiently
    boosted by new technologies, such as kiosks that give tailored recipes
    or a GPS cart-mounted tablet that gives real-time shopping advice
    (Block and Platt 2014). Last, service can influence a shopper's comfort
    and mood (Atalay and Meloy 2011; Chen, Lee, and Yap 2011). While the
    location of the restrooms and drinking fountains or the availability of
    near-the-entrance parking for new mothers appears to have little to do
    with sales, it increases a person's shopping time and store
    satisfaction, and it may indirectly trigger healthier sales (Atakan and
    Finch 2018).
        Signage, structure, and service are the areas of the store where
    the CAN approach can be much more creatively leveraged to sell
    healthier foods. Still, aggressively pressuring shoppers to fill their
    shopping carts with healthy foods has diminishing returns, especially
    as their shopping trip progresses (Biswas, Szocs, and Inman 2016;
    Sheehan and van Ittersum 2016; Van der Heide, van Ittersum, and van
    Doorn 2016). There is a limit to how much more produce shoppers can be
    nudged to take (Toft, et al., in preparation; Trivedi, Gauri, and Ma
    2016). Unless total shopping volume rises, a short intervention study
    might heroically claim 30% increases in fruit and vegetable purchases,
    but a sustained long-term sales increase of three percent would be more
    realistic.
        Although a long-term increase in sales of three percent for one
    intervention is much less exciting than 30%, there is an entire
    shopping experience or journey that needs to be taken into account
    (Beatty, et al., 2015; Lemon and Verhoef 2016). This gradual healthy
    shift in the entire shopping experience could form the habits (Cleeran,
    et al., 2016) that can nurture healthier store loyalty and healthier
    bodies.
    Shaping Future Healthy Shopping
        Organizing our findings into a Retail Intervention Matrix helps us
    make them more useful to retailers. If we can better see how one of our
    new discoveries influences choice (through the CAN Approach), and then
    better imagine where it will work best (the signage, structure, service
    mix of a store), we can help retailers far more than if we give them a
    nuanced, isolated finding. Moreover, knowing that there are three
    segments of shoppers with different degrees of health disposition
    (Vigilant, Predisposed, and Disinterested), helps us more realistically
    point to who we will have an impact on and who we will not.
    Thinking Deeper
        Within the signage, structure, service mix, much of the
    interdisciplinary retailing research focuses on using signage to make a
    healthy food more attractive through the way it is positioned or priced
    (Shah, et al., 2013). As the upper right corner of Fig. 6 indicates,
    what is less known is how signage can be used to establish new purchase
    norms or consumption norms (Van Doorn and Verhoef 2015). For instance,
    over the past 40 years, foods like yogurt and granola have gone from
    being foreign oddities to favorite staples. Knowing what created these
    new norms could help engineer sustainable healthy food trends of the
    future--regardless of whether they involve tofu or lab-grown meat
    (Purdy 2016).
    Fig. 6. Where Research Is Most Needed

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

        In contrast to signage, changes in ``structure'' have generally
    focused only on making a healthy food more convenient: Move the fruit
    to front of the store, over to the cash register, to eye level, to an
    end-aisle display, and so on. Now it is time for bigger questions such
    as how structure can make a healthy food more attractive or more normal
    or popular to buy. Again, consider healthy, high-margin,
    environmentally sustainable tofu (Groening, Inman, and Ross 2014).
    Using a store's structure to make tofu become more popular and trendy
    could be surprisingly transforming for retailers, manufacturers, and
    consumers.
        Service is sometimes too narrowly defined as face-to-face or voice-
    to-voice encounters. New technologies both inside and outside the store
    give service the most unrealized potential by leveraging eye-tracking,
    smart shopping carts, video-tracking, and GPS technology (Hue, et al.,
    2013; Nikolova, et al., 2014). Whereas most interventions cannot easily
    show which of the three Hierarchy of Health predisposition segments
    they impact most, new technologies could show the results of these
    interventions by either directly linking them to sales or indirectly
    doing so through shopper loyalty cards.
    Applying Wider
        Some of what we know about improving healthy shopping in grocery
    stores has already been systematically adopted into the growing 24-h
    lifestyle of convenience stores, corner stores, and mini-stores (Lenard
    and Schnare 2016). In 2016, the National Association of Convenience
    Stores launched a new toolkit titled, ``Ideas That Work to Grow Better-
    for-You Sales,'' and they include evidence-based tactics including (1)
    grab them immediately, (2) variety sells produce, (3) use creative
    adjectives, (4) remember the convenience factor, (5) have multiple
    displays, (6) let your store ``talk,'' (7) direct their feet, and (8)
    remind them (Lenard and Schnare 2016). Given this success in C-Stores
    (note the fruit baskets that are now near most cash registers), there
    are three other retailing frontiers that are deserving of our
    attention.
    Concessions and Kiosks
        Entrenched managers in food concessions and kiosks have long
    justified their unhealthy food portfolio mix my reactively claiming
    they simply ``sell what people buy.'' Yet they say this without really
    having given healthier food much of a chance. Indeed, when a healthier
    range of snacks (fruit, chicken sandwiches, granola bars, low-fat
    string cheese, trail mix, and so on) were offered alongside existing
    concession foods during one Iowa football season, sales of healthy
    snacks rose with each high school game until they comprised nine
    percent of sales in less than 2 months because of both switching and
    new sales (Laroche, et al., 2015). When Disney World followed by
    changing the defaults on kids' meals at their kiosks and offering fruit
    instead of french fries, it too generated more praise than pushback
    (Peters, et al., 2016). Discovering simple, evidence-based steps that
    help retail concessions profitably move from selling snack foods to
    selling meal substitutes could be game changing (Laroche, et al.,
    2017).
    On-line Shopping and Delivery
        After its initial growing pains, on-line shopping and delivery has
    been consistently growing across both North America and Europe. Yet the
    new adopters of this service are often families with children who
    steadily use the service once a week for a month; use it less
    consistently for the next 2 months; and often become inactive after
    that. Other than focusing on price promotions or loyalty programs
    (Bodur, Klein, and Arora 2015), a better solution would be to determine
    how to increase retention in a way that transforms how they eat in the
    same way it transformed how they order (Marinova, et al., 2016). The
    opportunity to help people transform the way they view themselves (and
    their health) because of how they order food could sustain both this
    industry and their families (Lund and Marinova 2014).
    Food Pantries
        Helping food pantry shoppers make healthier decisions has typically
    involved research replicated from other contexts (Bhana and Contento
    2017; Wilson 2016). There are limited numbers of products in food
    pantries and there are binding constraints (such as how much one can
    carry, or how much a person is allowed to take from a category such as
    pastries). Yet these limitations are precisely why a food pantry is a
    rich context for discovery. Without economic considerations, how do
    food shoppers behave? If they still take no fruits and vegetables, this
    might suggest that subsidizing cucumbers and taxing cupcakes may not
    have the intended policy impact that public health policy makers
    believe it would have (Bhana 2017; Cawley, et al., 2015). Aside from
    being a rich context for research, applying useful insights to food
    pantries provides a world of value far from the office.
    Why Healthy Field Study Interventions Appear to Fail
        Applying this Retail Intervention Matrix framework is enticing. Yet
    one frustration when applying our theories deeper and wider is that
    health-focused interventions often fail when we move from the lab to
    the field (e.g., van Herpen, et al., 2016). We usually believe it was
    because of poor implementation by our retail partner, or it was because
    of a noisy measurement problem. Instead, there are two reanalyses we
    could make ex post to more precisely determine if an intervention was
    more effective than it initially appears. We need to analyze the right
    people, and we need to analyze the right days of the week.
    We Do Not Analyze the Right Consumer Segment
        Not all interventions work with all people (recall Fig. 2). An
    expensive, digital, in-store calorie education program with a hip
    spokesperson and viral social media support will still have no impact
    on the top or bottom segments of this hierarchy. This is because the
    Health Vigilant Shoppers already know it, and the Health Disinterested
    Shoppers do not care. Yet most retail field studies show
    disappointingly modest results because they do not try to disaggregate
    the data and focus their analysis on the segment it was most intended
    to influence. A more targeted analysis could be done by segmenting
    shoppers into the Vigilant, Predisposed, or Disinterested segments
    based on their purchase history (which is linked to their loyalty
    cards) and then reanalyzing each segment.
        Different interventions influence different segments (Table 2).
    Setting up a study when and where it is most likely to influence a
    targeted segment will better help sift out which interventions are
    actually working in the way they intended. Aside from segmenting
    shoppers based on their loyalty card purchase records, shoppers could
    also be segmented or targeted by where they shop (e.g., Whole Foods,
    Target, Wal-Mart, the Co-op, and so on). If neither is possible,
    shoppers could be targeted by the time of the day or the day of the
    week when they shop.

       Table 2. A Retail Intervention Matrix of How Scandinavian Retailers
                        Doubled the Sales of Frozen Fish
    ------------------------------------------------------------------------
                     More convenient to  More attractive to   More normal to
      Mix element         purchase            purchase           purchase
    ------------------------------------------------------------------------
    Signage           Created     Co-         Create
                      recipe cards        promoted the fish   d ``Native
                      titled ``Fish in    with vegetables     Norway'' logos
                      15'' (min)          (suck as leeks      to promote
                      Offered a   and broccoli)       fish as local
                      ``Grill Tips''      Named       Used
                      flier for the       select fish and     ``Local
                      grilling salmon     included a map      Favorite'' and
                                          showing the part    ``Managers
                                          of the world        Special''
                                          where it was        stickers
                                          caught
    Structure         Utilized    Moved       Placed
                      vertical display    fish displays       the single
                      cases; moved fish   immediately after   servings of
                      to eye level and    vegetables          fish and some
                      processed foods     Included    of the lower
                      to the bottom       a buffer of         priced ``sales
                                          frozen vegetables   specials''
                                          between the fish    near the
                                          and the beef so     highest
                                          people would not    traffic edges
                                          make an unfair      of the
                                          sensory             displays
                                          comparison with
                                          beef
    Service           Offered     Offered     Employ
                      frozen freezer      smaller, one-       ees were
                      packages to keep    portion servings    instructed to
                      fish frozen until   Put         suggest the
                      home                markings on the     two best
                      Offered     wrapper to show     selling types
                      plastic bags to     how much to         of fish and
                      put shrink-         prepare for one,    the two most
                      wrapped fish in     two, three, or      common items
                      for extra           four persons        with which
                      separation          E-mail      they were
                      protection from     promotions were     prepared
                      other foods in      send to loyalty     (e.g., rice
                      the basket          card holders,       pilaf and
                                          with recipe ideas   broccoli)
                                          and web-links to    Employ
                                          downloadable        ees were
                                          coupons             trained to
                                                              suggest
                                                              additional
                                                              items commonly
                                                              bought along
                                                              with specific
                                                              types of fish
    ------------------------------------------------------------------------

    We Do Not Analyze the Right Days of the Week
        It is not surprising that people shop much less healthy at the end
    of the year--October through December--than they do after January 1st.
    The dollar amount of the healthy food we purchase increases 29.4% right
    after the first of the year (Pope, et al., 2014). This is not
    surprising but it would suggest that if an intervention has any chance
    of working, it would be better to test it in mid-January than in mid-
    December or even mid-June. In general, a healthy intervention's
    effectiveness might continually decline throughout the year. That is,
    healthy shopping-focused interventions may be most effective in the
    first quarter, moderately effective in the second quarter and third
    quarter, and least effective in the fourth quarter.
        Yet if shoppers are on their best healthy shopping behavior during
    January, something similar may happen the beginning of each week in a
    smaller way. After a weekend of indulging, some people might have an
    unstated resolution to try and shop better, which makes them more
    susceptible to in-store nudges on a Monday than they would have been
    the prior Friday night. This Monday Morning Effect has been recently
    shown in both in cafeterias and grocery stores (Wansink, Tran, and
    Karevold 2017). In a 3 month study of over 15,000 diners, putting fish
    first (and beef last) on a buffet line increased fish selections on
    Mondays to Wednesdays but had no influence after Wednesday. Analogous
    results were found in grocery stores. Among people who made larger
    purchases (over $50 USD), interventions were most effective early in
    the week (Monday-Wednesday) than on Thursday-Sunday. If a field study
    intervention does not seem to have worked, reanalyze the sales results
    for only Mondays, Tuesdays, and Wednesdays. It may give a more accurate
    assessment of whether the intervention is worth dropping, reporting, or
    improving.
    Using the Retail Intervention Matrix to Sell More Fish
        Until now, the Retail Intervention Matrix has been presented as a
    way to organize research findings based on how they work (making
    healthier foods more convenient, attractive, or normal) and where they
    are implemented in the store (within the signage, structure, service
    mix). This framework can be used to organize key findings into a
    sensible pattern that is also useful in practice.
        For example, a large Scandinavian grocer had the marketing
    objective of growing their market share by repositioning itself as the
    most environmentally sustainable retailer in Norway. One way they
    planned to accomplish this was by increasing their sales of fresh and
    frozen fish, which are much more environmentally sustainable than beef,
    pork, and lamb. They planned to first increase the variety of fish they
    offered (types, sizes, packaging, and so on) and to more actively
    promote this fish though advertising campaigns and price promotions. In
    addition to these traditional 4-P marketing mix methods of growing this
    category, the Retail Intervention Matrix was then used to create a
    broader set of interventions that could be used to further push the
    sales of fish by focusing on changes in the signage, structure, and
    service mix.
        All 457 stores in the chain used the traditional marketing mix
    approach of altering the variety, packaging, advertising, and price
    promotions of fish. Over a 2 year period, these marketing efforts
    consistently increased sales by nine percent. Following this, 239
    stores selected various additional changes to make (see the Retail
    Intervention Matrix for increasing fish sales in Table 2). Because of
    these changes, the average store generated 28% more fresh fish sales
    per transaction than those stores that had initially changed only the
    marketing mix (Karevold, Tran, and Wansink 2017).
        This brief example involving Norwegian fish shows one way research
    findings can be extrapolated, organized, and presented in a way that is
    compelling for mangers who have little time or tolerance for ambiguity
    and nuance. Showing how an intervention might work (the CAN approach)
    and where it can be implemented (through the signage, structure,
    service mix) enabled this retailer to provide a menu of actions or
    changes that each of its stores could pick and choose from. Similar
    adoptions of retail-based findings are also being explored by an
    American consortium of grocers (Borstein 2015) who are assembling an
    industry-wide Grocery Retail Scorecard that will show retailers how
    they can profitably help their customers shop healthier
    (Convergencepolicy.org/scorecard/).
    Conclusion
        Retailing research in the future will be different than that of the
    past. It will be partly judged on whether it delivers fresh, useful
    solutions. A common view in the past was that an academic's role was to
    generate insights, and the role of managers was to determine how to use
    them. In the future, determining and discovering which insights have
    the biggest impact will be broadly rewarded. Using the Retail
    Intervention Matrix--including the CAN approach and the signage,
    structure, service mix--can help determine what is known and what needs
    to be discovered. Last, the Hierarchy of Health Predisposition can show
    where an intervention can be most effective, most immediately.

      Appendix A. An Abbreviated Scorecard To Help Retailers By Organizing
             Sample Findings Into the Retail Intervention Matrix a	c
    ------------------------------------------------------------------------
                         More convenient    More attractive   More normal to
                           to purchase        to purchase        purchase
    ------------------------------------------------------------------------
    Signage              Use        Use a      Displ
                         display signs to   guidance system,   ay
                         draw attention     such as Guiding    educational
                         to and promote     Stars or a         posters
                         the store's        stoplight          around the
                         selection          approach, at the   store that
                         seasonal fruits    shelf edge         encourage
                         and vegetables     Use        healthy
                         with display       display signs to   eating, such
                         signs              draw attention     as the Half-
                         Provide    to and promote     Plate Rule
                         information        seasonal fruits    Co-
                         sheets on          and vegetables     promote
                         healthier ways     with display       healthier
                         to shop near all   signs              options
                         entrances          Use        together in
                         Directs    signs which        snack aisles
                         traffic entering   provide ``Did      Highl
                         the store such     You Know?''        ight healthy
                         that most          health benefit     alternative
                         shoppers begin     facts, positive    entree
                         in the produce     messages about     options such
                         section            specific           as the salad
                         Provide    healthful foods    bar on
                         a circular/ad      throughout the     posters or
                         publication        store, or both     signs within
                         featuring and      Bundle     all dining
                         promoting          recipe             areas
                         healthier value    ingredients for    Place
                         options at least   family meals       posters
                         once per week      next to recipe     displaying
                                            cards for a        healthier
                                            healthy meal       foods or a
                                            Make       guidance
                                            sure that soda     system such
                                            and low-nutrient   as the Half-
                                            snacks (i.e.,      Plate Rule in
                                            chips) are not     visible areas
                                            displayed or       in the dining
                                            merchandised in    area
                                            the produce
                                            section
    Structure            Offer a    Assign     Offer
                         ``grab and go''    designated         at least
                         area in the        parking spots      three
                         front of the       near at least      healthier
                         store with a       one entrance for   foods for
                         small selection    pregnant women     sale at all
                         of low fat milk,   and mothers with   entrances to
                         eggs, 100%         infants (similar   prime
                         juice, low-fat     to handicapped     healthier
                         yogurt, and        spots) d           shopping
                         whole grain        Create a   Offer
                         bread for the in-  fresh produce      pre-printed
                         and-out shopper    display in the     shopping
                         Organize   seafood section    lists of
                         ingredients for    including items    basic staples
                         a healthy meal     such as lemons,    near all
                         by preparation     tomatoes, beans,   entrances
                         method, such as    and asparagus      Offer
                         a stir-fry         Display    healthier
                         section that       whole fruits       food samples
                         includes           such as oranges,   or
                         mushrooms,         apples, pears,     demonstration
                         eggplants,         nectarines, and    s near at
                         peppers, and so    apricots next to   least one
                         forth              prepared           entrance and
                         Place      desserts           at least once
                         healthier foods    Make       per week
                         conveniently at    sure that there    Offer
                         eye level          is at least one    \1/2\
                         Make       checkout aisle     portions for
                         available one      in which the       all entrees
                         percent or fat     only food for      and desserts
                         free milk, 100%    sale qualifies     that are
                         juice, and water   as healthier (no   served or pre-
                         in all mini        candy aisle)       packaged,
                         fridges in                            smaller
                         checkout aisles                       containers
                         Make                          for self-
                         sure there is at                      service
                         lest one                              entrees and
                         checkout aisle                        desserts, or
                         [i]n which the                        both
                         only food for                         Make
                         sale qualifies                        sure that
                         as healthier (no                      takeout boxes
                         candy aisle)                          are available
                         Make                          for leftovers
                         sure that all                         not eaten in
                         beverage coolers                      the dining
                         have both water                       area
                         and low-fat non-                      Offer
                         flavored milk                         divided
                         stocked and                           shopping
                         available                             carts with a
                                                               ``place
                                                               fruits and
                                                               vegetables
                                                               here''
                                                               section
    Service              Supply     Provide    Suppl
                         simple five-       calorie            y useful tips
                         ingredient         information on     related to
                         recipes as tear-   different types    preparation,
                         off cards next     and cuts of meat   storage, and
                         to specific        in the form of     food safety
                         produce in-        posters,           in produce
                         store, on the      brochures, or      section, via
                         store's website,   labels             mobile phone
                         mobile phone       Make       app, or both
                         app, or both       sure that the      Use a
                         Make pre-  store's website,   receipt
                         cut vegetables     mobile app, or     program which
                         available in the   both (if they      can create an
                         meat section       have one) has      itemized list
                         Provide    Shopper Loyalty    indicating
                         an area in the     specials that      what
                         store for          include deals on   percentage of
                         shoppers to sit    healthier items    purchases
                         and relax d        Provide    were fruits
                         Provide    a loyalty card     and
                         an area in the     program which      vegetables,
                         store for          rewards            low-fat meat,
                         shoppers to eat    customers with     and low-fat
                         d                  incentives such    dairy
                         Offer a    as bonus points    Use a
                         salad bar that     or coupons for     receipt
                         includes lower     purchasing         program that
                         calorie            fruits and         uses loyalty
                         dressings          vegetables,        card
                         options such as    making healthier   information
                         oil and vinegar    choices, or both   to show how
                         Promote    Offer a    much was
                         mobile phone       discount for       spent on
                         apps that          customers if a     fruits and
                         encourage          certain            vegetables,
                         healthful eating   percentage of      and compares
                         such as            purchases are      this amount
                         Fooducate,         fruits and         to past trips
                         MyFitnessPal or    vegetables
                         other Barcode/QR   Offer at
                         code scanners      least two daily
                         Offer      healthier grab &
                         tips, features,    go breakfast,
                         or videos          lunch, and
                         involving better   dinner options
                         shopping and
                         better living on
                         the store's
                         website or
                         social media
                         outlets
    ------------------------------------------------------------------------
    a  Reprinted, with permission, Slim by Design, Wansink (2014).
    b Findings are from published papers, working papers, and unpublished
      pilot studies (Wansink 2014).
    c Comfort measures reduce stress. People make better food decisions when
      they are under lower stress conditions.
    d Editor's note: No footnote in submitted article.

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        The Chairman. I thank our panel, terrific. I want to remind
    our Members that I am going to be relatively strict with the 5
    minute clock in order to try to get everybody through the
    system. So if you want to use most of your 5 minutes to make
    editorial comments and ask a question with a second left on the
    clock, I will ask our witnesses to submit the answers for the
    record. I am just trying to be fair to everybody.
        So with that, I will recognize the Chairman of the
    Subcommittee on Nutrition for his 5 minutes. G.T.?
        Mr. Thompson. Thank you, Mr. Chairman. Thank you, members
    of the panel, for everything that you do, supporting the
    nutritional needs of American families. It is greatly
    appreciated.
        This is such a great topic, obviously one that I am
    passionate about. We are looking at how Americans find
    themselves, and American families, individuals, a lot of
    children find themselves in some pretty challenging financial
    circumstances, get access to nutrition. Certainly in addition
    to personal resources and family support, community programs,
    and obviously our TEFAP program and other ways that this
    Committee supports those community programs, and then we have
    SNAP, the Supplemental Nutritional Assistance Program.
        And this is an appropriate place to have this discussion.
    Quite frankly, this is the appropriate jurisdiction when you
    look, because there are two basic principles. First, nutrition
    matters in so many different ways; and second, it is farmers'
    feed.
        And so my first question is to the gentleman from the
    Keystone State, Mr. Weidman. It is good to see you. Thank you
    for being here today, and congratulations on The Food Trust's
    25th anniversary. We appreciate all that, sir, your
    organization does to improve access for those in need to
    affordable and nutritious food.
        Your testimony mentions that in Pennsylvania, nutrition
    education programming is in both urban and rural environments.
    I represent the Pennsylvania 5th district. Obviously, on this
    topic I am concerned with all Americans, but in the 5th
    district, which is very rural by definition, 24 percent of the
    land mass of Pennsylvania, how does SNAP-Education reach into
    those rural areas?
        Mr. Weidman. Thank you, Congressman Thompson.
        In Pennsylvania, we have a great SNAP-Ed program. There is
    a little variability from state to state in how the program is
    operated. In Pennsylvania, it is led by Penn State, and they do
    a great job. Because of the extension program, they have a lot
    of breadth to cover rural areas. We have stuff happening in
    almost every county in Pennsylvania. And it is similar to the
    work that we are doing in Pennsylvania, working with children,
    working with adults to get them to learn more about where food
    comes from, sometimes nutrition science can be confusing to all
    of us, so helping them, kind of guide them to make good choices
    of the food around them.
        One of the programs we work with is the Share Our Strength
    Program called Cooking Matters in the supermarkets. It is
    really taking seniors and other adults on tours of a grocery
    store literally and teaching them about how to shop healthy,
    how to shop on a budget. And this kind of work is happening all
    around the country. There is a great rural example of SNAP-Ed
    happening in New Mexico, the CHILE (Child Health Initiative for
    Lifelong Eating and Exercise) Plus Program, and that is doing
    work in Head Start centers as well as pre-K, working with kids
    and their families, basically, to help them, again, guide them
    on making healthier choices, teaching them how to cook healthy
    recipes, taste tests, and that is happening on Tribal lands as
    well in New Mexico, in addition to other sites. It is at about
    80 sites in all in rural areas of New Mexico. And I am sure
    there are plenty of other examples.
        SNAP-Ed is a great way to get at both this problem of
    improving health in urban and rural communities.
        Mr. Thompson. It seems like from the testimony and past
    discussions I have had with key stakeholders and folks making
    sure that nutritional needs are met is really strengthened by a
    collaborative process, and obviously with programs like SNAP-
    Ed, food insecurity, nutrition incentives, Healthy Food
    Financing Initiative, all those, can you expand just in the
    short time we have on other types of collaboratives, other
    folks who have sat at the table. You mentioned my alma mater,
    the great land-grant university of Penn State. Are there other
    examples of collaboratives?
        Mr. Weidman. Sure.
        Mr. Thompson. It seems like a model we should continue to
    strengthen.
        Mr. Weidman. Yes, There are great examples of
    collaboratives, a lot with the grocers. We work with a great
    local grocery chain in Pennsylvania called The Fresh Grocer,
    and The Fresh Grocer is partnering with us to provide us space
    for doing nutrition education, SNAP-Ed programming in their
    stores. As Brian said, these stores are a great place to meet
    customers where they shop and help guide them to make healthier
    choices. That same grocer is also helping us with SNAP
    incentives, doing our Philly Food Bucks inside The Fresh
    Grocer. Every time a customer spends $5, the grocer is the one
    that created the whole technology to put out a coupon, an
    electronic coupon for $2 in free fruits and vegetables at that
    store. And, again, this is something that we are seeing
    nationally, great partners with grocers, with farmers certainly
    at all of our farmers' markets in Pennsylvania and around the
    country have been great partners.
        I also just quickly would mention that the U.S. Chamber of
    Commerce today in D.C. is having a conference called the Health
    Means Business conference, and they are recognizing
    partnerships between nonprofits and the corporate sector aimed
    at improving health. GSK has funded a citywide initiative
    called Get Hype Philly, working to get youth to be leaders in
    making healthy changes in their community. So we are working
    with nine other nonprofits and 50,000 kids in Philadelphia with
    GSK, and then Campbell Soup Foundation in Camden, New Jersey is
    midway through a 10 year initiative working with a number of
    groups to improve health and childhood obesity.
        Mr. Thompson. That is great, Mr. Weidman. Thank you.
        I see my time has expired.
        Mr. Weidman. Okay, thank you.
        The Chairman. The gentleman's time has expired.
        Mr. Scott, 5 minutes.
        Mr. David Scott of Georgia. Thank you, Mr. Chairman.
        This whole issue, to me, strikes right at the nerve of the
    foundation of our great country, which is founded on the
    principles of life, liberty, and the pursuit of happiness. And
    there is no other area of human endeavor that best manifests
    our foundation of life, of liberty, and happiness than our
    choice of food.
        Think of what makes you happy. I know there are many things
    out there individually that make us happy, but none greater
    than food. And what bothers me with this is that we want to
    make subjections here that are just absolutely not true. Sodas,
    candy, sweet things, that is not what makes us obese. It is the
    lack of our children exercising. Look at the history of this
    country. Look at us 30 years ago, 20 years ago. What has
    happened? Our children and us, we don't go and exercise. We
    don't have physical education in the schools anymore. But what
    we have is this Blackberry, this Facebook, this going on the
    Internet. And instead of children going and saying let's go
    play basketball or let's hook up a game here, they go in the
    basement or they go in their room and they stay hour after hour
    on that.
        My whole point is this. Food surveillance violates the
    basic principles of this great country, and first of all, you
    are going to discriminate between a low-income person simply
    because for 6 months on average that is all they stay on food
    stamps. They are gone. Look at the complexity you are going to
    put into the grocery store. Who is going to pick up that extra
    cost to have the food police there monitoring, and why?
        Now I think that a better way of going about solving many
    of these things is to look at how we educate people. You can't
    force them. You can't deny them their freedoms to be able to
    make choices without violating their pursuit of happiness.
        Think about it. When Thomas Jefferson wrote those words, he
    said to himself, and he wrote in one particular pamphlet, and
    he wrote this to his arch competitor, Alexander Hamilton. And
    what he said was, in this way, he said, ``What I have declared
    here, my dear Mr. Hamilton, is has come to me these words,
    life, liberty, and the pursuit of happiness.'' He said by some
    divine providence intervention. In other words, what he was
    saying was those words, life, liberty, and the pursuit of
    happiness, he came and he wrote that Declaration of
    Independence under the inspiration of God Almighty. Let us not
    go against that.
        Thank you, Mr. Chairman.
        The Chairman. The gentleman yields back.
        Mr. Crawford, 5 minutes.
        Mr. Crawford. Thank you, Mr. Chairman. That is a tough act
    to follow, Mr. Scott. I appreciate that.
        I represent a part of the country, the Delta region,
    probably better than \1/2\ of my district is, and as you can
    imagine, working with a high degree of poverty. So many of my
    constituents are heavily dependent on SNAP benefits, and the
    problem they confront is that over the years, we have seen a
    decline in the number of supermarkets. So what we are dealing
    with ultimately here, ironically, is one of the most productive
    agricultural regions in the country is effectively a food
    desert. We have limited access to the healthy foods, so they
    rely on convenience stores and things like that. To restrict
    SNAP purchases to healthier food products, my question is would
    the compliance costs outweigh the benefits of accepting SNAP
    benefits at retail locations, or would it encourage SNAP
    retailers to offer a wider variety of healthy food products?
    And I will just leave that to any or all that want to make a
    comment on that.
        Ms. Sarasin. It depends, frankly, on how any changes to the
    program were structured. Obviously, retailers want very much to
    be in areas where they can meet customer needs, and if the
    customer base is there and they can be profitable and
    successfully meet the needs locally, they will, and they want
    to.
        The kinds of proposals that we are talking about here will
    definitely have an impact on how these companies can function.
    The potential increase in the administrative costs for a
    program that limits certain products, whatever they are,
    whatever kind of products we are talking about, is going to be
    oppressive, as I indicated in my testimony, given the sheer
    volume of products that are available in supermarkets today,
    and the number of new products that are introduced every year.
    The creation of a structure to monitor that and determine which
    products are in and which ones are out, is going to necessarily
    create pressure on the system, and also create pressure at the
    retail level for stores that are in existence, for stores that
    are being contemplated to be created, and the result could be
    that stores can't function profitably any longer in some areas.
    It could also be that some stores will have to determine that
    the administrative costs are so great that they would have to
    leave the SNAP program entirely.
        Dr. Schanzenbach. Thank you.
        I would echo that. I would be particularly concerned that
    these increased regulatory burdens would drive out some of the
    smaller retailers, especially in rural areas.
        The other thing that I would like to add is that, as an
    economist, all of this comes down to supply and demand, and I
    have heard a lot of conversation about how do we increase the
    demand for healthy foods, whether that is through education,
    whether that is through pricing incentives. If people demand
    more healthy foods in those areas, those grocery stores are
    going to respond by supplying more of them. So that is why I
    would like to see the market work in this, and not restrict.
        Mr. Weidman. And I would just agree with you of the need
    for more grocery stores in the Delta. We are working with the
    Michael and Susan Dell Foundation and Hope Enterprises located
    in Jackson, Mississippi, to incentivize more grocery stores to
    come to the Delta region. I also think the USDA through the
    farm bill, the Healthy Food Financing Initiative offers real
    opportunities to bring more grocery stores to the region.
        Mr. Crawford. Dr. Rachidi, do you want to weigh in on that?
        Dr. Rachidi. Sure, just real quickly. If you placed
    restrictions on a very narrowly defined product such as
    sweetened beverages, it would not be overly burdensome for
    retailers, and I agree that it is really a supply and demand
    issue. So if you did a restriction on sweetened beverages, for
    example, which drove up demand for healthier products because
    that is all people could use their SNAP benefits for, you would
    hope that the retailers would then respond by providing more
    healthy options.
        Dr. Schanzenbach. And just respectfully, we think based on
    economic theory that that is not what will happen. So many
    people are using both SNAP benefits and their own cash, it
    won't actually change behavior.
        Ms. Sarasin. And if I could also respond to that.
        I think we end up on a slippery slope when we start talking
    about sweet beverages, because I don't know what that means,
    and like most things, the devil is in the details. Because when
    we start talking about sweetened beverages, are we talking, I
    don't know exactly we are talking about. I mean, there are
    juices that bring lots of nutrition that are sweetened
    beverages. There are yogurt drinks that bring all kinds of
    nutrients to the consumers of them that also have sugar in
    them. We need to be careful about how we are discussing these,
    because we are talking about a category of products as if we
    all understand what that means.
        Mr. Crawford. Thank you. My time has expired.
        The Chairman. The gentleman's time has expired.
        Mr. McGovern, 5 minutes.
        Mr. McGovern. Well thank you.
        It is safe to say that we all can make better choices and
    healthier choices, SNAP recipients and non-SNAP recipients. The
    avoidable health care costs that taxpayers pay for non-SNAP
    recipients, they get diabetes, heart disease. We all need to do
    better. But I don't think by limiting the choices of SNAP
    recipients you get there.
        In fact, Ms. Rachidi said that we have a new President.
    Maybe this is a time to try a pilot project. So when you say
    that, I Googled Donald Trump's eating habits, and it is not a
    pretty picture. Domino's Pizza, Kentucky Fried Chicken,
    McDonald's, Diet Cokes. I mean, maybe we ought to begin with a
    pilot project that limits access to unhealthy foods at the
    White House, because we all pay for that. The taxpayers pay for
    that.
        If we are serious about it, this ought to be a bigger
    discussion. And one of the things we ought not to do, and this
    is out of this Committee's purview, is cut back on the
    nutritional standards of the school feeding programs, which
    some have suggested. We ought to figure out the things that
    have worked. I visited a place in Dorchester, Massachusetts,
    called Daily Table. They provide access to nutritional foods at
    a lower cost. A lot of these vegetables and foods would
    otherwise be discarded by other grocery stores, but people go
    there and they can afford to be able to make healthier choices.
        I personally think that one of the things that we could do
    is increase the SNAP benefit. It is about $1.40 per person per
    meal. You can't make a lot of choices in general with that kind
    of benefit. Research from the Center on Budget and Policy
    Priorities found that increasing SNAP benefits by a mere $30
    per month would lower food insecurity, decrease fast food
    consumption, and increase vegetable consumption. We have seen
    the Healthy Incentives Pilot which found that an ongoing
    investment of less than 15 per person per day may result in 25
    percent increase in fresh fruit and vegetable consumption. And
    out of this pilot came the FINI grants, which are working
    across the country to incentivize healthy eating. All very
    positive stuff.
        I have been to SNAP-Education programs, and I will be
    honest with you, the critique I get from some who attend these
    programs is that the ability to buy the stuff to have a
    healthier diet is difficult, because in their neighborhoods;
    they don't have supermarkets. They have to rely on convenience
    stores, and there are a lot of issues here that we need to talk
    about.
        In our school programs, we ought to stress nutrition
    education at an earlier age. It is a lot easier to get people
    on a healthy pathway when they are younger.
        But let me ask, Dr. Schanzenbach, do you support increasing
    SNAP benefits? Do you think that would promote healthy eating?
        Dr. Schanzenbach. There is good evidence that an increase
    in SNAP benefits would increase consumption of healthy foods.
    Just like was testified earlier, when people have really tight
    budgets, they concentrate on getting the lowest cost calories;
    and then, if we expand purchasing power over time, then people
    will increase both the quantity and the quality of foods that
    they are eating.
        We have really good evidence from the Summer Feeding
    Program, the Summer EBT Program that says, additional resources
    improve nutrition outcomes, and similar, this work that you
    cited from the Center on Budget and Policy Priorities suggests
    that additional $30 per month would change how people eat and
    make them consume more healthy foods.
        Mr. McGovern. And I agree with what Ms. Sarasin said about
    how do you define a sweetened beverage. Does cranberry juice
    fall into that category? There are lots of nutritional benefits
    to cranberry juice, but it is a sweetened beverage. And would
    you take that off the list?
        And again, from my experience talking to people on SNAP, a
    lot of times it comes down to the affordability as well as the
    access. We have lots of pilot programs going on all across the
    country. You mentioned one going on in Pennsylvania, all very,
    very positive stuff. We ought to understand that is how you do
    it, not by going and telling somebody that we are going to
    restrict your choices. I think that is something that we ought
    not to be doing here in Washington. But if you want to do a
    pilot program, I am happy to cosponsor one at the White House,
    because I am worried about our President's eating habits right
    now.
        So thank you.
        The Chairman. The gentleman's time has expired.
        Mr. LaMalfa, for 5 minutes. Mr. LaMalfa, for 5 minutes? You
    pass? Mr. Davis, 5 minutes.
        Mr. Davis. Thank you, Mr. Chairman, and thank you, Mr.
    LaMalfa.
        Mr. LaMalfa. You are very welcome.
        Mr. Davis. I appreciate that. It is always actually great
    to follow my colleague, Mr. McGovern, and outside of the
    comments about the President's eating habits, I actually agree
    with him on some of these issues that maybe we ought to look at
    incentives. Having this debate is great for all of us, because
    this is isn't a partisan issue. I would challenge my colleague,
    Mr. McGovern, to go to some of those restaurants that he named
    and I believe he is going to be able to find that he can make
    healthy choices at every single one of those restaurants, and
    that is what is great about what we have seen in our country,
    in our access to healthy foods. The marketplace is demanding
    healthier choices, and all of those restaurants that he
    mentioned have so many more today at a very much more
    affordable cost than what they had even 5, 10 years ago.
        So the marketplace is actually helping to supply that
    demand for healthier choices, and I agree with Mr. McGovern. I
    don't think that we have a role here in being the food police.
    And he mentioned some critics of the School Nutrition Program.
    Yes, I am one of those, and it is because the lunch ladies tell
    me stories about how kids are throwing food away that they are
    not eating. We don't have an adequate supply of healthy food to
    serve in our school lunches that tastes good. Kids are throwing
    it away, so how do we fix that? We do it by actually offering
    more healthier choice, but in a way that is less of a top down
    approach. Maybe incentivize it.
        It is great to see so much testimony about expanding
    purchasing options. I was a big supporter of the Double Bucks
    Program in the last farm bill, and Dr. Wansink, I was actually
    leaving to go to another hearing, but listening to your
    testimony, and you talked about how do we have more incentives?
    What can we do to incentivize rather than punish? Because I
    don't drink cranberry juice. Sorry. It is probably good for me,
    Jim.
        Mr. McGovern. It is.
        Mr. Davis. I don't drink it. It tastes like syrup to me. I
    can't handle the sugar content in it. But if I was a SNAP
    beneficiary, would I be able to buy cranberry juice and not
    what I live off of, Diet Coke or Diet Pepsi? Who is going to
    make that choice? It has zero calories. Actually, cranberry
    juice has a lot more sugar and a lot more calories. So I don't
    know who is going to make those choices, and frankly, I haven't
    seen the Federal Government be a good barometer of making
    choices like that for the constituents that I serve.
        But Dr. Wansink, can you tell us what type of incentive
    program would you recommend?
        Dr. Wansink. Thank you very much.
        Well if we can use schools as a parallel, as was brought
    up. One of the ways that we found that it is best to guide kids
    to eat healthier in schools is not necessarily nutrition
    education programs, because they are costly and they are tough
    to get into schools, but instead simply making the healthier
    products more convenient, more attractive, more normal. Having
    a basket of apples next to the checkout line, making foods
    taste better, reducing waste and it also increases how much
    people eat. And there are 29,000 schools who are now on that
    program.
        Now a similar thing can be done in the stores, and you are
    right spot on when you say anybody goes in these restaurants
    can eat healthy, because there are the options that are now
    cheaper than they used to be. Making simple changes in grocery
    stores that are incentive compatible with the grocery stores
    that are either profit neutral or profitable for them.
        Mr. Davis. Haven't they already been doing that?
        Dr. Wansink. Not as widespread. I took last year off and
    went on sabbatical to implement this in Norway to show that it
    could be done as a tested concept, and even making small
    changes in these grocery stores, simply having things such as
    having fruits and vegetables within 10 of the doorway
    increases how much people take by three percent. Making these
    changes are things that grocery stores find profitable, but
    then it also benefits all of us, not just SNAP beneficiaries.
        Mr. Davis. But you wouldn't make the government force the
    stores to change?
        Dr. Wansink. Absolutely not.
        Mr. Davis. Okay.
        Dr. Wansink. No, we would make the profit argument to them
    that they can make more money making people healthier.
        Mr. Davis. Okay, because I know some stores would have to
    actually move their Starbucks out of the way to be within that
    10 of the door.
        Does anybody else on the panel want to address the
    incentivization?
        Ms. Sarasin. If I could just say that, apart from the
    incentive part of it, the thing that retailers are doing is a
    lot of the stuff is happening on their own without incentives.
    Our most recent data shows that something in the neighborhood
    of 95 percent of our member companies have nutritionists and
    dieticians onsite in their stores or at corporate headquarters
    helping direct what is going on with their customers and
    education. So there is a lot of this stuff that is happening
    even without the incentives.
        Mr. Davis. Thank you. My time has expired.
        The Chairman. The gentleman's time has expired.
        Ms. Lujan Grisham, 5 minutes.
        Ms. Lujan Grisham. Thank you, Mr. Chairman, and I want to
    thank my colleagues, Mr. McGovern and Mr. Davis. The focus of
    all of our conversations ought to be on the incentives, and I
    don't want to lose momentum. And we do really want very
    specific ideas. In my state, we have incentives and initiatives
    that are both authorized and supported by the farm bill, and
    many of those that are solely state or corporate private-public
    partnership initiatives. We have programs at WIC, we have
    programs at Head Start that are uniquely focused on SNAP-
    Education. We have a program called CHILE Plus. For those of
    you not from New Mexico, we are the leaders and have the best-
    tasting New Mexico chile anywhere. In fact, our state question
    is whether it is red or green? But it is the Child Health
    Initiative for Lifelong Eating and Exercise, and it really is
    focused to integrate both purchasing and education and cooking
    and eating healthy that we pushed out into the rural areas.
        The core issue is that we want the flexibility for states
    and rural communities and communities to really figure out how
    to do it, but we need the farm bill to be really clear that
    there is not only those incentives in terms of authorizations,
    but there is funding and incentives for those funding vehicles.
    I did the SNAP challenge, for $30, so I just had a protein
    shake. I really think, as nearly a 60 year old woman with a
    fairly sedentary public policy lifestyle I am really proud of,
    I try to be cognizant of my calorie intakes. I work very hard
    at it. Well during my SNAP challenge, I wasn't so good at it,
    all right? I ate ramen noodles. I am trying to think of the
    other high carbohydrate kinds of foods. I tried to get peanut
    butter, high fat, and I couldn't get any organics. I bought one
    banana and one apple for my weekly benefit if I was going to
    have enough food and $1.50 left over.
        Now if I am dealing with average benefits for my whole
    family, and God forbid somebody in your family is sick and they
    say we want high iron, high protein, you have a teenager who is
    playing football. With that SNAP benefit, you can try all you
    want to do healthy foods. It is impossible, because unhealthy,
    cheaper foods are all you can buy. And I ate it. I stayed true
    to doing what I was supposed to do, but it wasn't good.
        So if we don't deal with that, in my state, seniors are
    about to get their SNAP benefits cut: $33 a month with the
    state portion that they are going to cut. I don't know about
    you. I am a caregiver for my mom. If I go to the grocery store
    for $33, I can't get anything that she ought to be eating.
    Anything. So if we don't increase SNAP-Education funding and we
    don't really put resources to allow folks to do these
    incentives, we can talk about how great they are all the time,
    and they are. I agree with that, my colleagues on the other
    side of the aisle, we really shouldn't be the food police. We
    ought to do incentives. We ought to do something about obesity.
    You do something about obesity, you have hundreds of millions
    of dollars to put back into economic incentives and farm bill
    incentives to grow better food and to do more in the areas that
    we all care about on this Committee. How can you get us, one of
    the most bipartisan committees, to really think long and hard
    about putting the resources where they need to be and seeing
    the evidence-based outcomes that we have the research, the
    Chairman teases me about research all the time. We have the
    research that shows us that you have to educate people.
        Do you have ideas to help us get to that agreement about
    making sure that there are the resources that allow us to do
    the things that you know would make a difference?
        Dr. Wansink. I believe if we want to change things really
    quick, it is probably not going to be education. It is a nice
    long-term solution that is going to take a long time, and it is
    not going to be the payoff. Initially educating, in this case,
    retailers as to what they could do to guide people to these
    healthier options, which are also high margin foods, because
    they have to throw them away. If a banana goes bad, a retailer
    loses money on it. What they can do to guide people to these
    and get people to buy more of them. It is not just going to
    benefit SNAP recipients, but it is going to benefit all of us.
        Ms. Lujan Grisham. Anybody else? I have 10 seconds. Let's
    go.
        Dr. Rachidi. Just real quickly, there is really little
    evidence that, and I am in favor of incentive programs, but
    there is little evidence that incentive programs reduce
    consumption of unhealthy foods. And so I advocate for both, and
    so if you look at the integrity of the program, you could gain
    support for increasing incentive programs and education if you
    eliminate some of these other issues like allowing unhealthy
    foods to be purchased from the program.
        Ms. Lujan Grisham. My time is definitely up, Mr. Chairman.
        The Chairman. Thank you.
        Mr. Comer, 5 minutes. Mr. Comer, 5 minutes.
        Mr. Comer. I was Commissioner of Agriculture in Kentucky
    for 4 years, and one of the things that worked really well for
    us with being able to provide healthy options to people with
    EBT cards was when I first got elected, we only had 21 farmers'
    markets that took EBT cards. When I went out of office, all 225
    farmers' markets took EBT cards, and a lot of people said well,
    that will never be a factor in sales. In a lot of those
    farmers' markets, it was over 25 percent of the sales were from
    EBT cards because of food deserts, and access to healthy food.
        The farmers' markets are a great way, a great option for
    people on SNAP because there are no bad foods at a farmers'
    market, or I have never seen candy or soft drinks sold at any
    Kentucky farmers' market, so I just wanted to share that story.
    That was a pretty successful way to get healthy food options to
    people that need it because of the obesity problem that we
    clearly have.
        Shifting gears here, what percentage of people use their
    entire monthly SNAP benefits during the first week of the
    month? Does anybody know the answer to that?
        Ms. Sarasin. I don't know the percentage, but I can tell
    you that the data that we have seen shows that a tremendous
    amount of it is spent in the first week, and that those
    purchases tend to be the largest of the month.
        Mr. Comer. Right.
        Ms. Sarasin. And the ones that have the most protein and
    the things that we would tend to expect that they would buy
    first.
        Mr. Comer. In talking with retailers across the state about
    this issue, several have come up with this suggestion, and they
    use this example. The majority of the people that they deal
    with use their entire benefit, monthly benefit, the first week
    of the month. So if you want to provide milk and things like
    that, meat for low-income people to eat healthy, if this is
    their only source of revenue for their food, the milk expires
    or it is gone. They don't have access to milk or a lot of
    proteins that expire. I wonder how feasible it would be to have
    a bi-monthly benefit to encourage more people to try to manage
    their budgets to where they can have milk for the first half of
    the month and the second half of the month, because it is a big
    problem. I represent a very poor district and that is something
    that just about every retailer that I have talked to has
    mentioned that as a suggestion to be more efficient and to help
    the people. Because a lot of the people unfortunately don't
    have a high level of financial literacy, and that is an issue.
    So I just wanted to get your thoughts on that, Ms. Sarasin.
        Ms. Sarasin. As a Kentuckian myself, and from the next
    county over from you, I can totally understand the discussions
    that you have had. And what we find in many states is that they
    have gone to not having single dates of the month when the
    benefits are available. There are multiple points in the month
    when recipients have access to their benefits. And so in the
    states where that has happened, it has been very beneficial,
    certainly from the retail perspective because it allows us,
    instead of having to have such pressure on both our labor pool
    on a certain day or in a certain week of the month, but also on
    the supply chain issues so that we have enough milk in
    different quantities and different styles and different sizes,
    for example. Being able to move these things out over the
    course of a month would certainly, from a retail perspective,
    be a better situation for us.
        Mr. Comer. Yes, I am for less government, and I don't like
    the nanny state and all that, but is it clearly a problem, and
    the obesity issue, it is almost at epidemic levels. The poorer
    the county, the higher the obesity rate. And you can see that
    when you go into public schools and, unfortunately for the
    students in the poorer schools. You can just tell there is a
    higher obesity rate in those schools.
        Ms. Sarasin. A couple of things. One is the data seems to
    indicate that everybody is getting fat, rich kids, poor kids
    alike. But to give my perspective on your question about the
    twice a month. Something that people raise as a concern there,
    especially for people with limited access to places to shop,
    breaking this benefit up into twice a month might make it
    harder for them to get to the store, because now instead of one
    big shopping trip, they have to do multiple. So it is just
    something to consider.
        Mr. Comer. Thank you, Mr. Chairman.
        The Chairman. The gentleman's time has expired.
        Ms. Adams, 5 minutes.
        Ms. Adams. Thank you, and thank you, Mr. Chairman and
    Ranking Member Peterson, for hosting the hearing, and thank you
    to the witnesses for being here today.
        The SNAP program is very important to those in the 12th
    District of North Carolina. I represent that district, and the
    folks struggle with food insecurity a lot. We have a lot of
    food deserts. But as someone who lives with diabetes, I know
    that there will be times when someone that participates in the
    SNAP program and has diabetes will need to buy a candy bar to
    quickly raise their blood sugar, and they should be able to buy
    that candy bar with their SNAP benefits.
        Dr. Schanzenbach, could you provide a brief summary of the
    findings of your research on the long-term health impacts on
    individuals who participated in SNAP as infants and toddlers?
        Dr. Schanzenbach. Thank you. So my recent research study
    looked at the introduction of the Food Stamp Program, which was
    done over the 1960s and 1970s. Congress in its great wisdom
    decided to roll it out slowly, and so that gives us an
    opportunity to study, if you lived in this county when you were
    5 years old versus that county, you had different access to the
    Food Stamp Program, as it was then called. And so then we can
    tease out well, what happens if people are given access to the
    Food Stamp Program.
        What we found was a couple of things. First is children are
    born healthier if their moms have access to food stamps while
    she is pregnant. But then because this happened so long ago, we
    were able to follow the children who grew up in these areas
    over time. So now they are 40 and 50 years old. What we found
    was that we should really be thinking about food stamps as an
    investment in children. So we found that access to food stamps
    during childhood increased the likelihood that they graduated
    from high school by 18 percentage points. Furthermore, we were
    able to look at their adult outcomes. We found that they are
    healthier in adulthood. We looked at this thing called
    metabolic syndrome, which is a clustered association between
    obesity, diabetes, high blood pressure, et cetera. What we
    found there was more access to food in early life sets up
    systems in your body to actually make you less obese in later
    life.
        Then finally we found that, and this was particularly the
    case for women, that people who had access to food stamps in
    childhood grew up to be more economically self sufficient. They
    are more likely to be employed. They had higher earnings, and
    they themselves as adults were less likely to be reliant on
    food stamps or welfare programs.
        And of course, as an economist, what I think is going on
    here is that the children were better able to make investments,
    right? They weren't going to school hungry so they could pay
    attention in school better and learn more. And so this is very
    important evidence, evidence I certainly want the Committee to
    know about, to think about this program as an investment.
        Ms. Adams. Okay. So would you support a higher SNAP
    benefit?
        Dr. Schanzenbach. Certainly, it is very important to
    preserve the program as it is, so that is sort of always my
    first worry. But then I do think with separate evidence that
    there is good evidence that increasing the benefit levels will
    increase the amount of healthy foods purchased, will reduce
    food insecurity, and of course, one out of every five children
    in this nation lives in a food-insecure household right now,
    and in nine states, it is one out of four children live in a
    food-insecure household. I think that is too high for this
    great nation of ours.
        Ms. Adams. Okay. So why would SNAP restrictions on soft
    drinks, for example, be unlikely to change consumption patterns
    shared by all Americans?
        Dr. Schanzenbach. Sure. So of course, remember that food
    stamps benefits are relatively modest, $4.50 per person per
    day, and if we think about an average household, which gets
    about $250 in food stamp benefits, and then they have to
    supplement their food purchases by additional cash resources.
    So it is $100, $150 additional. Then on average, households
    spend about $12 to $14 a month on soda, right? So $250 SNAP,
    $100 in cash, $12 on soda. Be very straightforward that even if
    we go through all this red tape and debate what is in a soda
    and what is out of a soda and is this sugar sweetened or not,
    if we did that, when they get to the checkout line, they would
    be able to say, ``Okay, I still want to purchase my soda, my
    sugar sweetened beverage. I just need to do it out of this pot
    of money instead of that pot of money.'' That is a lot of red
    tape to go through to not change behavior.
        Ms. Adams. Thank you very much, Mr. Chairman. I yield back.
        The Chairman. The gentlelady yields back.
        Mr. Yoho, 5 minutes.
        Mr. Yoho. Thank you, Mr. Chairman, I appreciate it, and I
    appreciate you all being here. This is such an important topic
    that we look to reform and make it right, both for the
    recipient and for the taxpayers.
        Ms. Sarasin, one of the common arguments against
    restricting SNAP purchases has been the operational challenges
    of implementing restrictions, and if you have gone over that, I
    apologize, and if you haven't, with regard to the tech needed
    to track the restricted items, what do you see as a hold up on
    that, or is there anything that we can do better legislatively,
    or leave you guys alone?
        Ms. Sarasin. Well as I mentioned in testimony, one of the
    things that is challenging is that our cashiers end up being,
    to some degree, the food police at checkout time. And as you
    are probably aware, that holds up a line.
        Mr. Yoho. Yes.
        Ms. Sarasin. And if you have ever been in line behind
    somebody who is having a challenge like that, it is difficult.
    And sometimes, it ends up being a difficulty with some of our
    most vulnerable populations, and so it becomes also a stigma
    and a problem in that regard.
        But when you are operating a business that in general is on
    a one to two percent profit margin a year, every second that is
    delayed at the checkout line is a problem. Our companies
    measure it because they want to keep things moving.
        Mr. Yoho. Right.
        Ms. Sarasin. It creates a lot of issues for us at checkout,
    and just the administrative function of trying to figure out
    what is in, what is out, as if we went into the role of trying
    to determine that certain things shouldn't be allowed and
    certain things should be allowed, it would create real havoc in
    our stores.
        Mr. Yoho. Let me ask you this, because this has been
    brought up to me multiple times, in the big retailers' aisles
    that were restricted just to those things so people could go
    right there. It would expedite them going in there, buying
    those products, bringing them up and checking out with no
    confusion. Your thoughts on that, and then the other one is the
    financial impact. We hear people saying that on the retail side
    that this brings in `X' amount of dollars for us, and we can't
    change it because we are dependent upon that. What is the
    pushback that you have experienced in your industry?
        Ms. Sarasin. Well the real pushback is the administrative
    costs of trying to actually facilitate the program. One of the
    things that I hear regularly from our companies is that these
    programs are some of the most difficult regulatory programs for
    them to implement in their stores. And when you are talking
    about companies that have to deal with things like the Food
    Safety Modernization Act and all of the regulations that go
    along with that, if this is a more difficult challenge for
    them, that says a lot for what they are dealing with.
        The costs associated in the store with doing this on such a
    low margin business is significant, and not that there
    shouldn't be changes to the program if they are desirable and
    if they achieve a policy goal, but just to unilaterally
    identify that certain types of products should or should not be
    in without a real basis for making the decision is problematic
    for us.
        Mr. Yoho. Well, you can see how important it is, as many
    meetings as we have had on it, and I commend Chairman Conaway
    and the Chairwoman of the Nutrition Subcommittee last year,
    Jackie Walorski.
        Let me ask one other question, and this goes to Mr.
    Weidman. How is SNAP-Ed reached in the rural area? And I know
    in the State of Florida with the University of Florida, which
    is a land-grant, they have an extension office in every county,
    67 counties in Florida. And they seem to do a good job of doing
    it. The nutritional educational programs, are they different
    based on regions? Like we are in Florida. We have a hot, humid
    climate. How is it in your area, and then can you do a one size
    fits all for nutritional program for the whole nation, or
    should it be more regionalized?
        Mr. Weidman. Yes, that is a great question, and SNAP-Ed
    does great work in rural and urban areas all around the
    country. I mentioned earlier a rural program in New Mexico,
    CHILE Plus, which is doing great work in pre-K and Head Start
    programs. But yet, to your point, the great thing about the
    SNAP-Ed program is it does have kind of oversight and guidance
    to all of the programs that the different states are doing, but
    it allows for local on the ground sort of innovation so that
    the right type of nutrition education is happening, based on
    region and based on the population that you are serving.
        Mr. Yoho. Okay, I appreciate your time. I am out of time,
    and thank you. Mr. Chairman, I thank you.
        The Chairman. The gentleman yields back.
        Mr. Lawson, from Florida, 5 minutes.
        Mr. Lawson. Thank you, Mr. Chairman. I would like to thank
    all of you all who are here. I was just thinking, I am a
    country boy and so I couldn't think of anything more important
    on a Friday than RC Cola and a moon pie. And the other day, I
    was in the airport in Atlanta and I wanted to have a healthy
    choice, and I saw a long line at Subway, but there wasn't a
    line at Bojangles', so I tried to make the right decision, but
    Bojangles' won out. So I understand.
        What I really want to say is that it appears that when they
    did this survey, and anyone can answer, the FNS did a survey,
    and they said that in order to change the program, put
    restriction on the program, that it could cost as much as $400
    million or $600 million to administer the program. And I know
    that would be dollars well spent if you put that into the
    program, and people are going to do different things. And I
    have seen people go into these convenience stores, and even
    standing in line when they were making purchases, and saw that
    it was very difficult and they didn't really want to be there.
    But what I would say to you, and this question will go to
    anyone, is that in my state, we have an organization like Farm
    Share and Frenchtown Farmers Market that carry a similar
    initiative to alleviate hunger. From your success with Food
    Bucks programs and with nonprofit, how can I as a Congressman
    assist other food banks and various organizations to help be
    successful in this way and get this message out? Because you
    talk about the educational aspects of it, rural and urban. What
    can we do, because, you want to see this program continue, and
    I don't know whether the young people know about RC and a moon
    pie, but I want to make sure that it happens to all of us. But
    what can we do as legislators to help in those areas? Anyone
    can answer that.
        Mr. Weidman. I will. As I said in my testimony, I really
    think what is working is this comprehensive approach that
    includes nutrition education, and the SNAP-Ed program is doing
    a great job at that. Through incentives like the new FINI
    Program, and I really appreciate Congress for launching the
    FINI Program. We, for years, have been hearing that you get the
    farmers' market in the neighborhood or if you get a grocery
    store in the neighborhood, what about price, and that can be an
    issue. And we have heard that today. The FINI Program does a
    great job of both, making healthy foods more affordable, and
    also allowing for innovation, again, at the local level in
    places all around the country. And then last, actually getting
    the stores located in areas so that people don't have to take
    three buses to get to the grocery store. And I really
    appreciate, again, the leadership of Congresswoman Fudge and
    many others on this Committee for their support of the Healthy
    Food Financing Initiative, which is a proven model that was
    launched in Pennsylvania, working in partnership with the
    grocers and other food retailers, to locate in under-served
    urban and rural areas, create jobs, and provide access to
    healthy food.
        Mr. Lawson. Okay, and I have one more question for, is it
    Raskins?
        Ms. Sarasin. Sarasin.
        Mr. Lawson. Ms. Sarasin, okay. I'm seeing things--dyslexic.
    But why in the grocery stores are all the candies and stuff
    right up by the cash registers? It feels good to look at all of
    it, but I just ask that question, you know what I mean? Once
    you missed it you got it again. Once you miss it down in the
    candy aisle, it is back up there at the cash register.
        Ms. Sarasin. What you will find is that increasingly in our
    stores, while there are still aisles with candy right up front,
    increasingly there are stores that have lots of other things
    right up front as well. Mr. Wansink referred earlier to the
    increasing incidents of bowls of fruit and other healthy
    products that are available at checkout for consumers who are
    interested in having them.
        So from a retail perspective, our role is to provide the
    best service and create the best experience with the product
    lines that our customers seek, and at a price that they can
    afford, and hopefully as conveniently as possible. So that is
    what we strive to do for all of our customers, whether they be
    SNAP beneficiaries or others. And so we have this constant
    balance going on of trying to make sure that we are meeting all
    of these needs, and for some people, having a sweet treat as
    they walk out of the store is important. For others, it is
    other kinds of products. They would rather have a piece of
    fruit or they would rather have a yogurt as they walk out the
    door.
        So our goal is to try to provide a balance of products for
    all of our customers, depending on what they are looking for.
        The Chairman. The gentleman's time has expired.
        Mr. LaMalfa, 5 minutes.
        Mr. LaMalfa. Thank you, Mr. Chairman.
        So today we are talking about the SNAP program,
    Supplemental Nutrition Assistance Program. Supplemental meaning
    in addition to what might be someone's personal income, or
    other forms of aid a family might be receiving. Nutrition,
    generally thought of as something good for the body, making you
    healthier, stronger. Assistance, the idea that someone else is
    probably paying for this to help people.
        Ms. Sarasin, you talked repeatedly about how what basically
    a hassle this will be for stores to have the system in place to
    differentiate between more of these food products, so do people
    that come through the checkout line that are SNAP users not
    have other products that are ineligible for SNAP very
    frequently, such as house cleaning items, toiletries, other
    things that they are paying for that are not eligible? Is there
    anything that is not eligible for SNAP, I guess, that would
    have to cause a second transaction at the checkout counter?
        Ms. Sarasin. Yes. Yes, there are many types of products
    that are not----
        Mr. LaMalfa. Tobacco, alcohol, like that?
        Ms. Sarasin. Alcohol and tobacco are not SNAP eligible.
        Mr. LaMalfa. Okay.
        Ms. Sarasin. SNAP is applicable to food products.
        Mr. LaMalfa. Yes. So if you have someone in line that is
    making one trip to the store, they are buying all the needs for
    their household for the next week or 2. They are buying
    multiple items. Some are eligible, some are not.
        Ms. Sarasin. Correct.
        Mr. LaMalfa. So if we were to have this discussion about
    things that are nutritional and we have items on the list that
    maybe are now eligible for SNAP but determined somehow to not
    be nutritional, is it really that much tougher to differentiate
    between soda pop and tobacco?
        Ms. Sarasin. The challenge is in how you are defining soda
    pop or how you are defining nutrition or how you are defining a
    healthy product. We have had a lot----
        Mr. LaMalfa. Well shouldn't we try, because we are having
    all this effort made in recent years over fighting obesity and
    kind of differentiating between what things are contributing to
    obesity and what are not?
        Ms. Sarasin. We have had testimony this morning that has
    provided the evidence that doing so is going to be at great
    cost, and that the ultimate benefit----
        Mr. LaMalfa. It is great cost to the people that are the
    assistance part of this program, and it is also of great cost
    to the people, for lack of maybe knowledge or the idea that the
    government is incentivizing it, sending them home with candy
    bars and soda pop. So maybe it is worth the trouble.
        Let me shift to Dr. Rachidi here. I thank you for appearing
    as well. When we talk about the SNAP program's intention to
    alleviate hunger and malnutrition, and permit low-income
    households to obtain a more nutritious diet through normal
    sources, that is in statute, so with these aims and the idea
    that we are approaching nearly ten percent of beverages are
    accounting for expenditure, as was mentioned, we don't have
    data to determine how the restriction should impact the
    program, but we should at least try.
        The recent USDA study was troubling, and I think kind of a
    red flag for a lot of folks. A couple thoughts for you on that
    is you discussed a study also that evaluated the impact of a
    hybrid pilot of incentives and restrictions. So do you think
    this could be a feasible demonstration we could take more
    widely for entire states, and with some more cooperation from
    USDA, which seems to want to shut down states from making their
    own determination? Please expound upon that.
        Dr. Rachidi. Yes, I definitely think it is something that
    should be tested, and at the state level or the local level.
    Like I mentioned, we tried to do it in 2011 in New York City.
    The USDA at the time denied it, as they denied a few other
    states that had----
        Mr. LaMalfa. What do you think the USDA's incentive is to
    deny these possible studies and the learning we can get from
    that at state level or New York City level?
        Dr. Rachidi. I think there is a general aversion to
    restrictions, as we have heard today, and that is part of it.
    An additional reason that was given to us was also that it is,
    they felt that our evaluation was not going to be rigorous
    enough, which we did not----
        Mr. LaMalfa. Do you think we have rigor now in separating
    these----
        Dr. Rachidi. Meaning that the evaluation design was not
    rigorous enough that in the end, even with an evaluation, we
    still wouldn't have been able to tell if it was effective or
    not. Which we didn't necessarily agree with, but that was one
    of the reasons. And the other reason was what we have also
    heard today about the difficulties in defining what is a
    sweetened beverage or not. We actually came up with what we
    thought was a pretty clear definition, which is it excludes
    juice, 100 percent juice, and any other beverage that has 10
    calories per 8 ounces is a sweetened beverage, with a few
    exclusions like Pedialyte, for example. But it was a pretty
    straightforward definition.
        Mr. LaMalfa. So we have super computers that could probably
    program this in at the register and not make it that tough,
    right?
        Dr. Rachidi. Exactly, and we talked to retailers in New
    York City, and there have been other retailers that we have
    talked to through other efforts that have said exactly what you
    said. They already restrict alcoholic beverages, for example,
    non-food products, and this would just be one more thing to add
    to the list.
        Mr. LaMalfa. Thank you.
        The Chairman. The gentleman's time has expired.
        Mr. O'Halleran?
        Mr. O'Halleran. Thank you, Mr. Chairman. I just have a
    couple of brief statements. I will have plenty of questions for
    the record.
        But one of the statements I heard today was this pot
    instead of that pot, and another one was three buses. And my
    district is kind of a little bit different. It is a district
    the size of Pennsylvania. It has 12 Native American
    reservations on it, and some of the kids go to school on a bus
    2 hours one way. Some of them have anywhere from a 50 percent
    to an 80 percent unemployment rate. And sometimes, people can't
    get out of their homes after a big storm because of the
    condition of the roads to get to the store. So we have the
    urban setting, the rural setting, and then we have these very
    rural settings. And I am just trying caution us that as we look
    at this whole problem, the cost of stores is an important
    aspect to me, because in my area, stores are very far apart,
    obviously, and the food that is in those stores is much more
    limited in scope than other stores in urban areas. We also have
    the concern that the education level on nutrition is very low,
    and I appreciate the cooking classes and everything else, but
    it is kind of hard to get to a cooking class if you are 2 hours
    away from the nearest class.
        And so between the quality of the merchandise, the concern
    I have for the distances traveled, the unacceptable
    unemployment rates, I just want to just caution everybody when
    we start to think about this a little more that the entire
    process, and I don't think there is anybody here that doesn't
    care about nutrition for our families and our children, but we
    also have to understand the realities of life in some areas of
    America.
        Thank you. I yield back.
        The Chairman. The gentleman yields back.
        Mr. Marshall, 5 minutes.
        Mr. Marshall. Thank you, Mr. Chairman. My first question is
    for Dr. Rachidi.
        As you may know, I am an obstetrician and very familiar
    with WIC programs. Of all the things that my patients and
    nurses seem to think is a good thing, is WIC. What can we learn
    from WIC that we could apply to SNAP? What makes it successful?
    Tell me what we are doing differently between the two programs
    briefly, if you could?
        Dr. Rachidi. Well sure. Real briefly, I mean, WIC has a set
    of products that are eligible products to be purchased, and so
    there is a list that is put together and it is intended to be
    healthy products, and also they cater towards infants and new
    mothers and pregnant women. SNAP, on the other hand, does not
    have that. There are a few restrictions as we have heard today,
    alcoholic beverages, non-food items, hot prepared foods, but in
    general, there are no restrictions on what can be purchased
    with SNAP benefits.
        Mr. Marshall. Tell us a little bit about that education,
    what is going on with those pregnant women and breastfeeding
    moms that WIC is doing that seems to me to be so beneficial?
        Dr. Rachidi. Yes, so WIC also has a large education
    component, and again, it is a little bit of a different program
    because it is focused on new mothers and infants primarily, and
    young children. The education efforts are very much geared
    towards that, but also very much geared towards nutrition.
        On the SNAP side, as we have also heard today, there is a
    nutrition and education program, and it is very different
    across the states. States can choose how to implement it. Some
    choose to have very robust programs. Some choose to have maybe
    not so robust, but reach a lot of people, and so it is just a
    little bit different program than WIC.
        Mr. Marshall. Okay. Dr. Wansink, I guess my next question
    is for you.
        Certainly, I am concerned about health and diabetes and
    obesity and these things, but my question for you is: have any
    of the current educational or in city-based efforts resulted in
    large scale changes, in your opinion, large scale changes in
    dietary habits? Is it working?
        Dr. Wansink. There is some of this going on that is very
    good that has been effective, and back when I was Executive
    Director for the Center for Nutrition Policy and Promotion, I
    kind of said, this is too big of a thing for the government to
    figure out, because government can't be where everybody
    purchases and prepares food everywhere they work and they play,
    but all of the things around us can, the companies and things
    like this. So we started a program called Partnering with
    MyPyramid. It's now called Partnering with MyPlate. And the
    idea was to give credit and incentives to any company or any
    nonprofit that would help make it easier for people to move
    toward eating following the Dietary Guidelines. It was
    tremendously successful under the last year of President Bush's
    term, and it still is in place but it is not being encouraged
    as much as it could be. And that would be great, because it
    would enlist everybody to help more people eating toward the
    Dietary Guidelines.
        Mr. Marshall. Okay. I am going to stick with this theme of
    lifestyle changes a little bit, and this is probably your
    questioning, Dr. Wansink.
        In my lifetime experiences, as a physician, trying to
    change people's lifestyles, when they are pregnant seems to be
    their most willing to do it. I have given up trying to convince
    people to stop smoking unless they are pregnant or they ask me
    about it. Trying to help a newly developed diabetic pregnant
    woman to talk to them about diet modifications, they are very
    motivated. They start wearing seatbelts. There are reasons that
    this woman is motivated for lifestyle changes.
        Why are they so motivated, and how can we apply that to
    SNAP as well? I just think that pregnant women, by the time
    they are 45, it is too late, but when they are 21, there are
    opportunities here. So help me with what the next step is for
    SNAP to take?
        Dr. Wansink. I think that is an outstanding question,
    because you are looking at, there is somebody who is doing
    something for a bigger cause than themselves, and we see this
    with people making changes in their diet, too. They will do it
    for a bigger cause and become a vegetarian for a bigger cause,
    but not for their health. And in trying to apply some of these
    things to SNAP benefits, maybe what we need to do is we need to
    start focusing on the impact this has on a person's family or
    on their children, and start talking about SNAP benefits not in
    terms of, oh, he was going to buy some groceries, but on the
    implication this has on their family. And I love the stats that
    you had about what happens that graduation rates go up by 18
    percent for kids on SNAP benefits----
        Mr. Marshall. I am sorry to cut you off, but I appreciate
    the answer. My biggest concern is lack of activity as opposed
    to calories in. I think that is the biggest problem with
    obesity. Do any of you--can you--are we doing anything with
    SNAP related to encouraging activity as opposed to playing
    video games all day? My time is out. Sorry. I yield back.
        The Chairman. The gentleman yields back.
        Mr. Panetta, 5 minutes.
        Mr. Panetta. Thank you, Mr. Chairman. I appreciate it, and
    thanks to all of the witnesses who are here. I appreciate your
    testimony, your preparation. I know it took quite a bit of
    time, I am sure, to put together your statements today, so
    thank you very much. I appreciate that.
        My question kind of stems around education. As many Members
    are starting to know, and as many people do know, I come from
    the salad bowl of the world there on the central coast of
    California. But we are looking to change that name actually. We
    are going to call it the salad bar of the world. No, I am
    serious. The reason they are doing that is because a lot of the
    growers and the shippers, what they realized is the people who
    work for them weren't eating the same foods that they are
    picking. And they realized how to get to them is by getting to
    their kids. And so what a lot of our ag companies have done is
    donated salad bars, over 100, to the local schools to start
    getting our children, including my two daughters, to start
    eating more healthy foods, having that salad bar option. And
    they are doing that. And what they are seeing is that when
    their children start to eat more at schools, those trends go
    home and their parents start to develop those same trends, and
    that is actually working to a certain extent.
        And so my question is how do we continue, besides ag
    companies donating salad bars to our schools, how do we
    continue to educate our children when it comes to getting them
    to eat healthier in our schools? How do we do that?
        Ms. Sarasin. A couple of things that the food retailers are
    working on, one is a very high percentage of our companies do
    in-store tours. I mentioned earlier that about 95 percent of
    them have on staff nutritionists and dieticians, and what they
    are doing is actually bringing school groups into the stores,
    and the nutritionists and the dieticians take the children
    through the store, and help them understand about nutrition,
    help them understand the kinds of nutrients and vitamins they
    get from various products, and the balance that they need to be
    trying to achieve in their lives. So that is one thing that has
    worked well and will continue to work well.
        Another thing that we have done at FMI through our FMI
    Foundation is we just had our second annual National Family
    Meals Month in September. And the notion of National Family
    Meals Month is sort of multi-fold. One is that some of the
    societal challenges that we have are improved by having more
    frequent family meals, and I am talking now about school
    truancy, underage drinking, drug abuse, et cetera. The research
    shows that more family meals tends to bring down the incidences
    with young children and teenagers. But in addition to that,
    what we find is that children who engage with their families at
    mealtime, both by cooking, by purchasing the food, by being
    involved in preparation and serving, they tend to have a better
    understanding of nutrition and diet and health than those that
    don't. So we are promoting national family meals within our
    organization, but also at store level. And we have had, as I
    mentioned, our second annual in September of 2016, so this is
    something that we are doing on an annual basis so that our
    retailers can actually be engaged with their customers in
    helping children engage more with the preparation of food in
    their homes.
        Mr. Panetta. I appreciate that.
        With the FINI Program and the SNAP-Ed program, what do
    those entail?
        Mr. Weidman. Yes, I was just going to say we work in 100
    schools in Pennsylvania, doing SNAP-Ed, nutrition education
    work. So teaching kids to try new foods, a lot of it is also
    peer-to-peer marketing, so getting kids to be leaders in
    changing their school environment, youth-led wellness councils,
    and you really find that when the students are kind of
    marketing to their peers around healthier eating, that has a
    big impact. We also do, to the Congressman's point, our Get
    Hype Philly program is about healthy eating and exercise, so
    the combination of both of those is really important.
        Mr. Panetta. Great. In regards to you, Dr. Wansink, you
    talked about middle of the road consumers. You mentioned
    signage, service, and structure, is there anything else we can
    do to target them? What else can we do?
        Dr. Wansink. Well what can be done at a retail level is to
    make sure that the foods we want to guide them to are the
    healthier foods, and they are being the ones that are most
    convenient to purchase, they are most attractive to purchase,
    not just by price, but attractively looking, attractively
    named, attractively positioned, and then also that are more
    normal, because right now it is just not normal to buy a lot of
    healthy things at the grocery store, because you feel like you
    are kind of a strange person. Simply a lot of placement changes
    can make a big difference. Thank you very much for your
    questions.
        Mr. Panetta. Thank you. Thank you, Mr. Chairman.
        The Chairman. The gentleman yields back.
        Mr. Faso, 5 minutes.
        Mr. Faso. Thank you, Mr. Chairman. I am intrigued, we had a
    table here that came from USDA that suggests in 2011 that there
    were approximately six billion purchases of sweetened beverages
    in 2011. I don't know, do any of the witnesses have an idea of
    how much of that six billion would be what we call soda in the
    East and my colleagues like Mrs. Hartzler call pop in the West.
    Although in western New York, they do call soda pop.
        Dr. Rachidi. I believe it is a little more than \1/2\.
        Mr. Faso. A little more than \1/2\. And would any of the
    witnesses contend to me that soda, sweetened soda has
    nutritional value?
        This would be for Dr. Schanzenbach, and maybe Dr. Rachidi
    as well. I take it by no answer from any of the witnesses that
    no one believes soda has nutritional value. What would be the
    problem with our, especially if we are looking at more than $3
    billion of taxpayer money going to buy something that no one,
    as far as I can tell, believes has nutritional value? What
    would be the issue in your mind of a carefully designed study
    by the USDA to actually analyze this question as to whether if
    we had a restriction on certain sugared beverages that it could
    result in altered buying habits and dietary consequences and
    nutritional consequences for the families, particularly the
    children who live in those households where that $3 billion of
    taxpayer money is spent to buy soda?
        Dr. Schanzenbach. You are asking a researcher if we should
    have more research and that is the first thing they teach you
    in grad school is yes, I would welcome any sort of a
    demonstration program, but I would be quick to add that it
    needs to be high quality, and so in particular that includes it
    needs to be real randomized controlled trial, and that it also
    needs to do a couple of other things. One, it needs to measure
    consumption, not just compliance, but how does this change what
    people consume, because some of the research out there that
    maybe looks at the impact of soda taxes and other things like
    that show that yes, people substitute away from soda sometimes,
    but what they replace it with isn't necessarily much better.
        Mr. Faso. Right, and so how many people do you think would
    be appropriate in such a study?
        Dr. Schanzenbach. Oh boy. I can't do power calculations on
    the fly. I would be happy to submit something.
        Mr. Faso. Perhaps you could submit that for the record.
        Dr. Schanzenbach. I would be happy to.
        Mr. Faso. Ms. Sarasin, at the risk of getting my friends in
    the food merchants, and my friend, Mike Rosen, in Albany upset,
    the fact is that now that SNAP benefits are in EBT form by and
    large for the vast majority of those purchases, the merchants
    are able to differentiate among taxable items and non-taxable
    items. We had an issue in New York State for years where
    certain marshmallows that were used if you put them on a stick
    and you roasted them over the fire, those were tax exempt, but
    if you bought the small marshmallows, those were taxable. I
    realize the administrative complexity argument, but it does
    seem to me that we are now at a point where we could be able to
    more readily differentiate, just as we do with tobacco and
    beer. You can't buy that with food stamps.
        Ms. Sarasin. Well as I said in my testimony, could it be
    done, yes, probably so. The question is at what cost, and is
    the cost of trying to put together a means through which to
    define the products that are in clearly, define the products
    that are out clearly, such that electronically they could be
    contained in a system and therefore would be able
    electronically to be able to segregate? Absolutely, that would
    certainly help, but again, we are talking about many tens of
    thousands of products that would have to be done every year,
    and the infrastructure to be able to make those determinations.
        Mr. Faso. My point would be that we have these wonderful
    academic researchers and experts. Perhaps we could design a
    study that was statistically valid and which would consider the
    difficulty that the food merchants have, but also get to the
    core of the fact that when we were kids, the only time we ever
    had soda or pop was when it was someone's birthday. And when I
    see $6 billion, perhaps $3 billion of taxpayer dollars being
    spent on soda, which has no nutritional value, in a program
    that is called Supplemental Nutrition Assistance, something is
    wrong.
        Thank you, Mr. Chairman.
        The Chairman. The gentleman's time has expired.
        Mr. Soto, 5 minutes.
        Mr. Soto. Thank you, Mr. Chairman.
        In Florida, we have our Fresh From Florida Program, which
    has tried to cue in local farmers with our schools, which has
    had some pretty good success. In listening to your testimony,
    it appears that most of you are encouraging us to have
    incentives, to have a carrot rather than a stick, pun intended
    on that--and to have greater access to folks in food deserts
    rather than desserts. And I agree with both those things.
        I did, however, read a Washington Post article this morning
    that went right into this issue, and they had a conclusion that
    a SNAP purged of sodas or candy or both could be less
    vulnerable to cuts, and supporters can seek full funding. That
    every dollar for SNAP would help nurse the poor, just as
    Congress intended. And it got me thinking, first, how many of
    you by a show of hands would support a ban on soda and candy?
    Go ahead, how many? Okay, we have one. How many of you believe
    that it would save money if we banned these two products? Raise
    your hand. Okay.
        And so I think that is what my main quandary is now is
    whether or not the real goal is to have these sorts of bans to
    get people to eat healthier, whether the real goal would be to
    try to save money to expand a lot of the pilot programs that
    you all have discussed. And I am one who doesn't want food
    police or a big brother society or any of these other things
    that we are all so worried about. And so it would be great in
    the time I have remaining for you all to either support or not
    the concept of whether this would save money, and why? And I
    would like to hear from all of you on it.
        Dr. Rachidi. Well I guess I will start.
        In terms of saving money, just the opportunity or the
    potential to save medical-related expenses, especially on the
    public health side, Medicaid/Medicare, I think that there is
    potential there. And then----
        Mr. Soto. Excuse me, I didn't mean to interrupt. Just with
    regard to the SNAP program, whether we would save money in SNAP
    funds.
        Dr. Rachidi. Right. Well, I don't know if this is exactly
    what you are getting at, but in terms of the article this
    morning, again, I look at it as a program integrity issue. It
    is difficult to talk about expanding SNAP benefits, for
    example, when that ten percent of SNAP benefits are spent on
    sweetened beverages which have no nutritional value and do
    nothing to further the goals of the program.
        Dr. Schanzenbach. I think that this won't save SNAP
    dollars. In fact, as I testified earlier, it will increase the
    administrative cost of the program to no benefit. My
    professional opinion as an economist, I don't think it is going
    to change behavior.
        Ms. Sarasin. And as I have said before, I don't think it is
    going to save money either. The administrative costs associated
    with making these determinations in the context of USDA would
    be astronomical.
        Mr. Weidman. We recommend an access to healthy food
    incentives and nutrition education, and we think that approach
    is the best way to create jobs, lift people out of poverty so
    they don't need SNAP, and reduce healthcare costs.
        Dr. Wansink. There are easier ways to get at that
    objective, and I don't think just cutting that is going to have
    the benefits we want.
        Mr. Soto. Now my next question is what would be the
    administrative costs, knowing that we already ban alcohol, and
    that seems to be something that hasn't mushroomed costs.
        Dr. Rachidi. When I hear the discussion about how the cost
    would be astronomical, I don't quite understand how that could
    be with items, for example, like sweetened beverages that are
    very straightforward. I understand moving more towards a WIC
    model, how that could potentially increase administrative
    costs, but the things that I am talking about I don't see how
    that would increase administrative costs.
        Mr. Soto. And this is a reference just to a ban on candy
    and soda, no other items.
        Dr. Schanzenbach. So I guess I would add to that that
    restricting alcoholic beverages, that is sort of a different
    product category and it is real easy for the person who is
    checking you out to know oh, this is a bottle of wine and not
    something else. But when it comes to something like sugar
    sweetened beverages, what we saw in the New York pilot proposal
    was it is really hard to decide how to define this. For
    example, two what I would call similar beverages, V8 you could
    still purchase, but V8 Splash, which is the same sort of thing
    but it has a little kiwi fruit in it, was not eligible. I think
    that it gets to something that is very complicated at the
    store, and it is going to cause confusion. Do we have great
    estimates of how much it will cost? We have some evidence from
    the Healthy Incentives Pilot that maybe $5 billion a year,
    something like that.
        The Chairman. The gentleman's time has expired.
        Mr. Arrington, 5 minutes.
        Mr. Arrington. Thank you, Mr. Chairman. I admittedly come
    to the table to discuss as with tension between the consumers'
    freedom to choose what they purchase to eat, and our
    responsibility as stewards of taxpayer money to guide in the
    most responsible way. And I must say, I am undecided, quite
    frankly, and I am sorry I couldn't get all your testimonies and
    be a part of the discussion. I had another hearing.
        Dr. Rachidi, I understand that you ran the SNAP program for
    New York City and that you requested a waiver so that you could
    apply restrictions to people on SNAP and their purchases. Why
    were you denied that flexibility?
        Dr. Rachidi. And just to be clear, I didn't run the
    program, but I was the director for policy, and so we proposed
    the restriction.
        But ultimately, what we were told in terms of being denied
    was related to the evaluation design and that it wasn't
    rigorous enough to be able to conclude whether a restriction
    would be effective or not. And that was the main reason that
    was given, and then given that other states in the past had
    also proposed similar things, we suspected it was just a
    general aversion to wanting to do any type of restrictions.
        Mr. Arrington. Have they granted--go ahead.
        Ms. Sarasin. If I could, just one comment that I don't
    think has been mentioned today and it is worth mentioning in
    the context of waivers for various reasons. This Committee
    several years ago under the leadership of Mr. Goodlatte spent
    an awful lot of time and energy working toward a state by state
    interoperability type of process with SNAP. In this mobile
    society that we are in right now, there has been the need for
    SNAP recipients to be able to use their benefits where they
    find themselves, and so with EBT cards, et cetera, that has
    been facilitated, so these waivers have created a tension
    within USDA as well, because once you start doing waivers
    piecemeal around the country, the interoperability that this
    Committee spent so much time trying to achieve is compromised.
        Mr. Arrington. When is the last time the USDA has granted a
    waiver for such restrictions?
        Dr. Rachidi. They have not.
        Mr. Arrington. Ever, okay. Yes?
        Dr. Schanzenbach. But, if you wanted to do a real
    demonstration project, we would just really need to make sure
    that it is set up so that we can learn something from it. Not
    only studying the impact on consumption, which I will let you
    know I have a prediction what that will be, but also the impact
    on retailers and others. It is going to cost you if you elect
    to do it.
        Mr. Arrington. Yes, that is a good idea and it is fair to
    include all stakeholders, with states bearing much of the cost
    in healthcare, or let's just say significant costs for
    healthcare of their citizens, why not enter another freedom to
    choose? Why not block grant SNAP, let states choose if they
    want to go higher with support and supplemental support and
    work any reforms they want in on work requirements and other
    requirements and other reforms that have been discussed, not
    for this hearing? And then let them decide if they find it
    useful and meaningful to restrict purchases based on the
    nutritional value? Let states do that. Has that been discussed,
    and what are your thoughts about that?
        Dr. Schanzenbach. So my grave concern around a potential
    block grant is that one of the things that makes SNAP most
    successful, especially to the broader economy, is that it is
    designed to respond quickly to changing economic conditions and
    to times of need. So the program, as you saw during the great
    recession, expanded in response to the greater need that we
    saw. It is starting to come back down as the economy is
    starting to get a foothold.
        You may be aware that the dollars that we spend in SNAP
    also they are very promptly spent and they are spent in the
    local communities, and so they provide an economic stimulus to
    the whole area. For every dollar that we spend, at the height
    of the great recession we got $1.74 in local economic activity
    because of this. A block grant takes that important aspect of
    this program off the table. I think it would be a mistake.
        Mr. Arrington. So it seems to me that in terms of who is
    more nimble, the Federal Government, Federal program or a state
    and local government and program, I am going to put my money on
    the state and local program in terms of nimbleness. I don't
    think we have anything to compare it to with respect to this
    specific program, but I bet there are other ways to compare it.
        I am running out of time.
        The Chairman. The gentleman's time has expired.
        Mr. Evans. Mr. Evans, 5 minutes.
        Mr. Evans. Thank you, Mr. Chairman.
        One question that I have, and maybe all of you can deal
    with this, my inquiry is what is the impact a reduction in SNAP
    would mean for retailers from a job perspective? Can someone
    shed light on the impact of jobs and a reduction of SNAP would
    create?
        Mr. Weidman. One of the things that we have been doing
    around the country since we started in Pennsylvania with the
    Fresh Food Financing Initiative is convening groups that
    include grocers, but other stakeholders around the issue of
    access to healthy food and grocery store access. That is one
    thing that we heard loud and clear is that in order to have a
    successful enterprise in low-income communities, SNAP has
    become a very critical component there. So in our view,
    reductions to SNAP is not only going to result in more hunger
    and less food on the table for American families who are
    struggling with hard times, but it is going to have an economic
    effect. Oftentimes grocery stores are the anchor in a
    community, so if the grocery store closes down, that can have a
    domino effect, affecting other retail in the community. This
    happens in rural small towns and urban neighborhoods.
        Mr. Evans. Is anybody as, with the national retailer, able
    to quantify it in some way what you think it means in terms of
    numbers?
        Dr. Schanzenbach. Sure. During normal economic times, every
    dollar that we spend on SNAP returns about $1.25 to the local
    area, so I would think the way to think about it during normal
    economic times, although this would be worse during downturns,
    but during normal economic times if we took $1 away from SNAP,
    we would expect to see a reduction of $1.25 in local economic
    activity.
        Mr. Evans. Can each of you shed light from your perspective
    on what a SNAP benefit impact would be on recipients?
        Dr. Schanzenbach. Sure. We have strong predictions that if
    benefits were reduced, I would predict that we would see an
    increase in food insecurity. Currently one out of every five
    children in this great nation lives in a food-insecure
    household. I also think that, just the opposite of what I
    talked about before, having fewer dollars to spend at the
    grocery store means that people are going to substitute towards
    cheaper forms of calories, and that is exactly the opposite of
    the direction that we like to see people go. We like to see
    people eat healthier foods, which tend to be more expensive per
    calorie.
        Mr. Evans. Thank you, Mr. Chairman.
        The Chairman. The gentleman yields back.
        Mr. Allen, 5 minutes.
        Mr. Allen. Thank you, Mr. Chairman, and the reason I an the
    last one to ask questions is because I was in a conference
    meeting this morning talking about spiraling cost of healthcare
    in this country. And as I look at, statistically, at the growth
    of this program from 17 million people in 2000 to over 40
    million people today, and the fact that this program was
    initially started during World War II, because I am military,
    our generals felt like they didn't have the nourishment that
    they needed to battle the enemy. So we have seen tremendous
    growth in this program, and then we see tremendous growth in
    the cost of healthcare.
        We are talking about nutrition, and then what is that doing
    to healthcare? Do we have any studies that tell us, okay, are
    they related, and if they are related, how do we fix this?
        Dr. Schanzenbach. To be sure, obesity rates have
    skyrocketed, not just among the poor, but all across the
    distribution. And there are studies, we could nitpick them, but
    common sense dictates that this increase in obesity that we
    have seen across the income distribution has real ramifications
    for the cost of healthcare.
        Mr. Allen. Obviously, the retailers have a stake in this,
    the producers, our farmers obviously have a stake in this. We
    have talked about some options here available to us, but it
    sounds like to me we better fix this problem because when you
    look, for example, at Medicaid costs, I mean, it is
    skyrocketing and the number of people on Medicaid is
    skyrocketing. And it is because folks are having health
    problems because of, it may be other factors, but a large part
    of it is nutrition.
        Doctor, would you like to comment on what your thoughts
    are? I mean, how do we fix this?
        Dr. Wansink. Yes, absolutely. We have all the health
    concerns that we face, diet-related disease and obesity are the
    only ones that we can deal with and change immediately. Now you
    bring up a great point that most grocery stores, maybe they
    don't really care that much about the shoppers who are there,
    and to use a health motivation to try to encourage them to get
    people to buy more fruits and vegetables wouldn't be the right
    way to do it. But instead, it is aligned in their interest to
    get more people to buy fresh fruits and vegetables, lean meat
    and dairy, things like this because when that stuff goes bad,
    they actually lose money. The margin on it might be thin at the
    register, but the loss is huge compared to Fruity Pebbles if
    they don't sell it. Being able to show them that these are easy
    ways that we can help you get that stuff moving through your
    store is going to be a win/win situation, just like it was with
    convenience stores when the Association of Convenience Stores
    started giving their members ways that they could accelerate
    sales of healthy foods.
        Mr. Allen. I am sure you would like to respond to that.
        Ms. Sarasin. Yes, I would like to respond to that. Thank
    you.
        I think the notion that food retailers don't care about the
    health of their customers is just incorrect.
        Dr. Wansink. We will----
        Ms. Sarasin. It is incorrect. Just not factually correct.
    Of course we care about the health of our customers, and of
    course we are doing things to try to enhance the health of our
    customers. And we do that every single day, and in my longer
    testimony, there are multiple examples of the things that we do
    in store, in our communities, and across the board to try to
    make sure that we are doing everything we can to meet the needs
    of our customers.
        So while the convenience stores are relatively new to this
    process and apparently are doing some good things, that is
    wonderful, but your broad line grocers have been engaged in
    this process for decades in trying to assist their customers in
    meeting their dietary needs, and they do it by bringing in
    nutritionists and dieticians and other professionals in the
    store to work with their customers on a daily basis to meet
    those needs, and will continue to do so.
        Mr. Allen. And of course, we have the food deserts that we
    have to deal with now. We had testimony here with Amazon, which
    is becoming a big player in the grocery market. Obviously, we
    have to come up with a solution to this issue, and so thank you
    for your help here today, and hopefully we can get our arms
    around this and solve this problem.
        The Chairman. The gentleman's time has expired.
        I want to thank our witnesses. The great news about this
    Committee, and today's hearing is a terrific example of it, is
    that if you took the names off the questions and the comments
    made, you would be hard pressed to determine which were
    Republicans and which were Democrats. You all have given us
    great information. The panel has given us terrific information
    to chew on. This is not the last conversation we will have on
    SNAP restrictions. I have some folks who feel really strongly
    about both sides, and the Committee will work its will when we
    get to this point and place, but this is an important
    conversation to have had today. You have been incredibly
    respectful and I appreciate everyone's participation, and I
    wish more of our work here in the House was as nonpartisan as
    this is. Not a person here doesn't care about nutrition. Not a
    person here doesn't care that people eat healthy and that they
    exercise, and that they make good decisions.
        I was particularly informed by the triangle from Dr.
    Wansink. I wish it was reversed. I wish the health vigilant was
    the big piece and that the health-disinterested, or the ones
    who don't care, was the smaller piece of that triangle, but
    that is correct. There are far more people in America who
    really don't care. And then there is that group that we can
    hit, that can change their habits. It is a convenience issue.
    It is an opportunity to have their kids tell them to do it.
        So this program is important, and what they spend their
    benefit on is important. I am not convinced that the more
    decisions we make on people's behalf doesn't make them less
    capable of making good decisions on their own, so it takes
    education. Somebody said in their testimony there is no silver
    bullet to fixing this issue. Sugar drinks have a clear impact
    on people's health, but if we eliminated them off the face of
    the Earth, I don't know that obesity rates would be any
    different than they are right now. There are some other
    systemic changes that have to go on in people's choices and the
    way they conduct their lives to make this happen.
        Under the Rules of the Committee, the record of today's
    hearing will remain open for 10 calendar days to receive
    additional material and supplementary written responses from
    the witnesses to any question posed by a Member.
        This hearing of the Committee on Agriculture is adjourned.
    Thank you.
        [Whereupon, at 12:20 p.m., the Committee was adjourned.]
        [Material submitted for inclusion in the record follows:]
       Submitted Report by Hon. K. Michael Conaway, a Representative in
                              Congress from Texas
    Foods Typically Purchased by Supplemental Nutrition Assistance Program
            (SNAP) Households
    November 2016
    Nutrition Assistance Program Report
    Food and Nutrition Service, Office of Policy Support

    Authors:                             Submitted to:
      Steven Garasky                       Office of Policy Support,
      Kassim Mbwana                        Food and Nutrition Service,
      Andres Romualdo                      3101 Park Center Drive,
      Alex Tenaglio                        Alexandria, VA 22302-1500
      Manan Roy                          Project Officer:
    Submitted by:                          Sarah Zapolsky
      IMPAQ International, LLC,
      10420 Little Patuxent Parkway,
       Suite 300,
      Columbia, MD 21044
    Project Director:
      Steven Garasky

        This study was conducted under Contract number GS-10-F-0240U with
    the Food and Nutrition Service, United States Department of
    Agriculture.
        This report is available on the Food and Nutrition website: http://
    www.fns.usda.gov/research-and-analysis.

        Suggested Citation:

        Garasky, Steven, Kassim Mbwana, Andres Romualdo, Alex Tenaglio and
    Manan Roy. Foods Typically Purchased by SNAP Households. Prepared by
    IMPAQ International, LLC for USDA, Food and Nutrition Service, November
    2016.
    Table of Contents
        Executive Summary

              Purpose and Overview
              Methodology

                      Data Overview
                      Identifying SNAP Households and Creating Analysis
                    Categories
                      Data Caveats and Limitations

              Key Findings

                      Food Items Purchased by SNAP Households

        Chapter 1. Introduction and Background

              1.1  Introduction

              1.2  Background
              1.3  Research Questions
              1.4  Challenges of Collecting Point-of-Sale Data

        Chapter 2. Methodology

              2.1  Data Overview
              2.2  Identification of SNAP Households and Creation of
            Analysis Categories
              2.3  Data Caveats and Limitations

        Chapter 3. Findings: Top Expenditures by SNAP and Non-SNAP
    Households

              3.1  Distribution of Expenditures by Summary Categories
              3.2  Distribution of Expenditures by Commodities
              3.3  Distribution of Expenditures by Subcommodities
              3.4  Distribution of Expenditures by Household Demographics,
            Store Characteristics, Type of Resource Used, and Month of
            Purchase

        Chapter 4. Findings: Top Expenditures by USDA Food Pattern
    Categories

              4.1  Top Expenditures for Dairy
              4.2  Top Expenditures for Fruits
              4.3  Top Expenditures for Grains
              4.4  Top Expenditures for Oils
              4.5  Top Expenditures for Protein Foods
              4.6  Top Expenditures for Solid Fats and Added Sugars (SoFAS)
              4.7  Top Expenditures for Vegetables
              4.8  Top Expenditures for Composite Foods
              4.9  Top Expenditures for Other Subcommodities

        Chapter 5. Conclusion
        Appendix A. Top Purchases by Expenditure for SNAP and Non-SNAP
    Households *
    ---------------------------------------------------------------------------
        * Editor's note: the report entitled, Foods Typically Purchased By
    Supplemental Nutrition Assistance Program (SNAP) Households and Foods
    Typically Purchased By Supplemental Nutrition Assistance Program (SNAP)
    Households--Appendices are two different documents. For purposes of
    publication in this hearing they are treated as one document.
    ---------------------------------------------------------------------------
        Appendix B. Crosswalk of Top 1000 Subcommodities to Summary
    Categories
        Appendix C. Crosswalk of Subcommodities to USDA Food Pattern
    Categories
        Appendix D. Top 100 Subcommodities for SNAP Households by
    Expenditure for Each USDA Food Pattern Category
        Appendix E. Top 100 Subcommodities for SNAP Households by
    Expenditure by Demographic and Store Characteristics
    Table of Exhibits
        Exhibit 1: SNAP and Non-SNAP Household Food Expenditure Patterns
        Exhibit 2: Conceptual Map for Identification of SNAP Households in
    the POS Data
        Exhibit 3: Summary of SNAP and Non-SNAP Household Food Expenditures
    in the Dataset by Subcommodity
        Exhibit 4: Aggregating Food Items
        Exhibit 5: Summary Categories by Expenditure
        Exhibit 6: Top 100 Commodities for SNAP Households by Expenditure
        Exhibit 7: Top 100 Subcommodities for SNAP Households by
    Expenditure
        Exhibit 8: Top 25 SNAP Household Dairy Subcommodity Expenditures
        Exhibit 9: Top 25 SNAP Household Fruit Subcommodity Expenditures
        Exhibit 10: Top 25 SNAP Household Grains Subcommodity Expenditures
        Exhibit 11: Oils Subcommodity Expenditures
        Exhibit 12: Top 25 SNAP Household Protein Foods Subcommodity
    Expenditures
        Exhibit 13: Top 25 SNAP Household Solid Fats and Added Sugars
    (SoFAS) Subcommodity Expenditures
        Exhibit 14: Solid Fats and Added Sugars (SoFAS) Expenditures by
    Subcategory
        Exhibit 15: Top 25 SNAP Household Vegetables Subcommodity
    Expenditures
        Exhibit 16: Top 25 SNAP Household Composite Subcommodity
    Expenditures
        Exhibit 17: Composite Expenditures by Subcategory
        Exhibit 18: Top 25 SNAP Household Other Subcommodity Expenditures
        Exhibit 19: Other Expenditures by Subcategory
        Exhibit 20: SNAP and Non-SNAP Household Food Expenditure Patterns
    Executive Summary
    Purpose and Overview
        The Food and Nutrition Service (FNS) awarded a contract to IMPAQ
    International, LLC, to determine what foods are typically purchased by
    households receiving Supplemental Nutrition Assistance Program (SNAP)
    benefits. This study examined point-of-sale (POS) food purchase data to
    determine for what foods SNAP households have the largest expenditures,
    including both SNAP benefits and other resources, and how their
    expenditures compare to those made by non-SNAP households.
        SNAP, administered by FNS, is the nation's largest nutrition
    assistance program. In 2011, SNAP participants redeemed over $71
    billion in SNAP benefits in more than 230,000 SNAP-authorized
    stores.\1\ Given the magnitude of SNAP, FNS has a sustained interest in
    understanding the effects of the program. To date, FNS has studied SNAP
    household food consumption and expenditures using national surveys that
    generally rely on consumers to recall what they ate or to report or
    scan every purchase. This previous research has shown that the
    similarities in food purchases, consumption patterns, and dietary
    outcomes among low-income families and higher-income households are
    more striking than the differences.\2\
    ---------------------------------------------------------------------------
        \1\ USDA FNS. (2011). Supplemental Nutrition Assistance Program
    2011 Annual Report. Benefit Redemption Division. Available at http://
    www.fns.usda.gov/snap/retailers/pdfs/2011-annual-report-revised.pdf.
        \2\ See, for example, Office of Research and Analysis (2012).
    Building a Healthy America: A Profile of the Supplemental Nutrition
    Assistance Program. Food and Nutrition Service, USDA (available on line
    at www.fns.usda.gov/ora/MENU/Published/snap/FILES/Other/BuildingHealthy
    America.pdf).
    ---------------------------------------------------------------------------
        By using POS data to compare the purchases of SNAP households to
    those of non-SNAP households, the current study provides more detail on
    food expenditure patterns than previous studies. This study examines
    two major questions:

       What food items are purchased by SNAP households?

       How do foods purchased by SNAP households compare to food
            purchased by non-SNAP households?
    Methodology
    Data Overview
        POS transaction data from January 1, 2011 through December 31, 2011
    from a leading grocery retailer were examined for this study.\3\ The
    majority of stores from which the data came would be classified as
    grocery stores, supermarkets, and combination food and drug stores per
    FNS Retailer Policy and Management Division food retailer
    definitions.\4\ On average, each of the 12 monthly data files contained
    over one billion records of food items purchased by 26.5 million
    households, reflecting 127 million unique transactions. Each monthly
    data file included an average of 3.2 million SNAP households,
    identified using the methodology described below. Total expenditures on
    all SNAP-eligible food items in the dataset by SNAP and non-SNAP
    households over the 12 months were $39.0 billion, or approximately $3.3
    billion per month. SNAP households spent approximately $555 million on
    SNAP-eligible items each month in this dataset, using both SNAP
    benefits and other resources such as cash or credit cards.\5\
    ---------------------------------------------------------------------------
        \3\ Per the data sharing agreement between the data provider and
    IMPAQ, a description of the source of these data must be limited to the
    following: ``From a leading U.S. grocery retailer data examining POS
    transactions from January 1, 2011 through December 31, 2011 across
    approximately 11 million SNAP households. The majority of stores would
    be classified as grocery stores, supermarkets, and combination food and
    drug stores per USDA/FNS food retailer definitions.''
        \4\ Stores that opened or closed during 2011 were not included in
    these analyses.
        \5\ By way of comparison, in FY 2011, 21.1 million households
    participated in SNAP in an average month (http://www.fns.usda.gov/ora/
    MENU/Published/snap/FILES/Participation/2011Characteristics.pdf) and
    redeemed $6.0 billion in benefits in an average month (http://
    www.fns.usda.gov/snap/retailers/pdfs/2011-annual-report-revised.pdf).
    ---------------------------------------------------------------------------
    Identifying SNAP Households and Creating Analysis Categories
        SNAP households were identified in the data for each month. This
    identification was performed monthly because, in any given month, some
    households enter or leave the program. The analysis identified SNAP
    households each month by first identifying any transaction in which
    SNAP electronic benefit transfer (EBT) was used to pay for at least \1/
    2\ of the value of the purchase and designating the household that made
    that transaction as a SNAP household.\6\ It then linked all other
    transactions made by that household during that month to estimate total
    monthly spending by SNAP households. All other transactions in these
    stores were designated as non-SNAP household purchases.\7\
    ---------------------------------------------------------------------------
        \6\ SNAP transactions in which SNAP EBT was not the majority tender
    were not identifiable in the data.
        \7\ Some of these transactions may, in fact, have included SNAP
    purchases. Some SNAP households may never have presented EBT as the
    majority tender in any transaction, for example.
    ---------------------------------------------------------------------------
        IMPAQ analyzed SNAP-eligible food items given the focus of the
    study. Per the Food and Nutrition Act of 2008 (the Act), eligible food
    includes any food or food product for home consumption, as well as
    seeds and plants which produce food for consumption. The Act precludes
    alcoholic beverages, tobacco products, hot food and any food sold for
    on-premises consumption from being purchased with SNAP benefits.\8\ The
    unit of analysis for the study was a food-related subcommodity, with
    subcommodities and commodities defined by the data provider. Each
    subcommodity typically consisted of multiple food items, often
    distinguished by brand or package size, identified by a Universal
    Product Code (UPC) or a Price Look Up (PLU) code. Each commodity was an
    aggregation of similar subcommodities. The ``apples'' commodity group,
    for example, combined different varieties (Gala, Fuji, Honeycrisp) and
    forms (bagged, bulk) that were presented separately as subcommodities.
    ---------------------------------------------------------------------------
        \8\ See http://www.fns.usda.gov/snap/retailers/eligible.htm for
    more details.
    ---------------------------------------------------------------------------
        Although subcommodities and commodities provide adequate comparison
    reference points, these groupings were designed to help retailers
    classify purchases for their own needs (e.g., marketing purposes).
    Therefore, this study analyzed purchases at two higher levels of
    aggregation. Thirty summary categories were created--for example, meat/
    poultry/seafood, fruits, vegetables, and frozen prepared foods--to be
    roughly analogous to the major sections or departments in a typical
    grocery store. These categories were constructed to enhance discussion
    of similarities and differences between purchasing patterns of SNAP and
    non-SNAP households. Appendix B provides a crosswalk of subcommodities
    to summary categories.
        IMPAQ also mapped food subcommodities to USDA Food Pattern
    categories (dairy, fruits, grains, oils, protein foods, solid fats and
    added sugars (SoFAS), and vegetables). Not all subcommodities could be
    classified into a single Food Pattern category. Subcommodities
    incorporating multiple food categories, such as foods packaged as
    complete meals, were classified as composite foods. In addition, some
    subcommodities did not contain any Food Pattern categories, or the
    labels were not descriptive enough to permit categorization even with
    the addition of the composite category. A ninth category, other, was
    created to capture such subcommodities. ``Other'' captured all items
    that could not be classified using USDA Food Patterns, such as water,
    isotonic drinks, and baby food.
    Data Caveats and Limitations
        Although POS data provide a wealth of information on the food
    purchase patterns of SNAP households, some limitations existed in the
    data analyzed for this study. The data used for this study captured
    only transactions completed at a specific set of retail outlets. As
    stated before, the majority of stores from which the data came would be
    classified as grocery stores, supermarkets, and combination food and
    drug stores per FNS Retailer Policy and Management Division food
    retailer definitions.\9\ Purchases made at other SNAP-authorized
    retailers or other venues (e.g., farmers['] markets) were not included
    in these data. On average, SNAP households in the data spent
    approximately $229 per month on SNAP-eligible foods using a combination
    of SNAP benefits, cash and other forms of payment.\10\ In contrast, the
    national average monthly SNAP benefit per household was $284 in FY
    2011.\11\ Therefore, although these data account for a significant
    proportion of SNAP-eligible food expenditures by SNAP households, they
    do not include all SNAP benefit expenditures.
    ---------------------------------------------------------------------------
        \9\ Stores that opened or closed during 2011 were not included in
    these analyses.
        \10\ On average, SNAP households in the data made 8.5 transactions
    per month. The average total expenditure on SNAP-eligible foods per
    transaction was $26.99.
        \11\ http://www.fns.usda.gov/pd/19SNAPavg$HH.htm.
    ---------------------------------------------------------------------------
        SNAP transactions were identified as those for which a SNAP EBT
    card was the majority tender. Because some transactions included both
    SNAP and cash or credit tenders, these data could not differentiate
    between items purchased with SNAP benefits and those purchased with
    other funds. These data, therefore, represent food purchases made by
    SNAP households, rather than the foods purchased with SNAP EBT
    specifically.
        Rankings of expenditure categories depend in part on the level of
    food item aggregation (whether at the Food Pattern, summary, commodity
    or subcommodity levels). As discussed above, the data provider
    aggregated food items into subcommodities and commodities, considering
    other factors outside of the needs of this particular analysis. These
    classifications at times presented analytic challenges that may have
    affected the rank ordering of purchases. For example, subcommodity
    groups categorized as ``composite'' or ``other'' for these analyses
    likely included food items that would more appropriately be included in
    one of the Food Pattern categories had more information been available.
    Similarly, some distinctions of potential nutritional importance were
    not available in these data. For example, it was not possible to
    distinguish between fat-free or low-fat varieties of some dairy
    products, such as fluid milk or yogurt, from whole milk varieties.
    Key Findings
    Food Items Purchased by SNAP Households
        Overall, the findings from this study indicate that SNAP households
    and non-SNAP households purchased similar foods in the retail outlets
    in these data. Exhibits 1 and 2 summarize the findings.

       There were no major differences in the expenditure patterns
            of SNAP and non-SNAP households, no matter how the data were
            categorized. Similar to most American households:

         About 40 of every dollar of food expenditures by SNAP
                households was spent on basic items such as meat, fruits,
                vegetables, milk, eggs, and bread.

         Another 20 out of every dollar was spent on sweetened
                beverages, desserts, salty snacks, candy and sugar.

         The remaining 40 were spent on a variety of items
                such as cereal, prepared foods, dairy products, rice, and
                beans.

       The top ten summary categories and the top seven commodities
            by expenditure were the same for SNAP and non-SNAP households,
            although ranked in slightly different orders.

       Expenditure shares for each of the USDA Food Pattern
            categories (dairy, fruits, grains, oils, protein foods, solid
            fats and added sugars (SoFAS), and vegetables) varied by no
            more than 3 per dollar when comparing SNAP and non-SNAP
            households. Protein foods represented the largest expenditure
            share for both household types, while proportionally more was
            spent on fruits and vegetables than on SoFAS, grains, or dairy.

       Less healthy food items were common purchases for both SNAP
            and non-SNAP households. Sweetened beverages, prepared desserts
            and salty snacks were among the top ten summary categories for
            both groups. Expenditures were greater for sweetened beverages
            compared to all milk for both groups, as well.

       Expenditures were concentrated in a relatively small number
            of similar food-item categories. The top five summary groups
            totaled \1/2\ (50%) of the expenditures for SNAP households and
            nearly \1/2\ (47%) for non-SNAP households. Twenty-five
            commodities accounted for over forty percent of the food
            expenditures in these data with SNAP and non-SNAP households
            having 20 of them in common. The top 25 subcommodities for SNAP
            households and non-SNAP households, respectively, accounted for
            between \1/5\ to \1/4\ of total food expenditures for each
            group with 16 subcommodities in common for the two groups.

        Exhibit 1: SNAP and Non-SNAP Household Food Expenditure Patterns
    ------------------------------------------------------------------------
            Finding             SNAP Households        Non-SNAP  Households
    ------------------------------------------------------------------------
    Total annual            $6.7 billion             $32.3 billion
     expenditures on SNAP-
     eligible foods in
     dataset
    Percentage of all       12%                      88%
     transactions by all
     households
    Percentage of total     17%                      83%
     annual expenditures
     by all households
    Top 1,000 subcommodity  99%                      98%
     (of 1,792)
     expenditures as a
     percentage of all
     expenditures
    Top 100 subcommodity    51%                      46%
     expenditures as a
     percentage of all
     expenditures
    Top 25 subcommodity     25%                      21%
     expenditures as a
     percentage of all
     expenditures
    Top 25 commodity (of    45%                      41%
     238) expenditures as
     a percentage of all
     expenditures
    Top 10 summary          Meat/Poultry/Seafood     Meat/Poultry/Seafood
     categories (of 30) by
     expenditure
                            Sweetened Beverages      Vegetables
                            Vegetables               High-fat Dairy/Cheese
                            Frozen Prepared Foods    Fruits
                            Prepared Desserts        Sweetened Beverages
                            High-fat Dairy/Cheese    Prepared Desserts
                            Bread and Crackers       Bread and Crackers
                            Fruits                   Frozen Prepared Foods
                            Milk                     Milk
                            Salty Snacks             Salty Snacks
    Top 10 commodities (of  Soft Drinks              Fluid Milk Products
     238) by expenditure
                            Fluid Milk Products      Soft Drinks
                            Beef Grinds              Cheese
                            Bag Snacks               Baked Breads
                            Cheese                   Bag Snacks
                            Baked Breads             Beef Grinds
                            Cold Cereal              Cold Cereal
                            Chicken Fresh            Candy--Packaged
                            Frozen Handhelds and     Coffee and Creamers
                             Snacks
                            Lunchmeat                Ice Cream, Ice Milk,
                                                      and Sherbets
    Top 10 subcommodities   Fluid Milk/White Only    Fluid Milk/White Only
     (of 1,792) by
     expenditure
                            Soft Drinks 12-18 pack   Soft Drinks 12-18 pack
                            Lean Beef                Shredded Cheese
                            Kids' Cereal             Chicken Breast--
                                                      Boneless
                            Shredded Cheese          Frozen Premium
                                                      Nutritional Meals
                            2-Liter Soft Drink       Pure Orange Juice--
                                                      Dairy Case
                            Potato Chips             Lean Beef
                            Primal Beef              Potato Chips
                            Lunchmeat--Deli fresh    Large Eggs
                            Infant Formula/Starter   Bananas
                             Solution
    USDA Food Pattern
     categories, by
     expenditure:

       Dairy        9%                       10%
       Fruits       6%                       9%
       Grains       12%                      13%
       Oils         2%                       2%
       Protein      23%                      20%
       Foods
       Solid Fats   13%                      12%
       and Added Sugars
       Vegetables   8%                       10%
       Composite    19%                      16%
       Other        8%                       8%
    ------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ
      International, LLC, 2016.

    Chapter 1. Introduction and Background
    1.1  Introduction
        The Food and Nutrition Service (FNS) awarded a contract to IMPAQ
    International, LLC, to determine what foods are typically purchased by
    households receiving Supplemental Nutrition Assistance Program (SNAP)
    benefits. More specifically, this study examined POS food purchase data
    to determine for what foods SNAP households have the largest
    expenditures, including both SNAP benefits and other resources, and how
    these expenditures compare to those made by non-SNAP households.
    1.2  Background
        The mission of FNS is to provide children and needy families with
    improved access to food and a more healthful diet through a range of
    nutrition assistance programs and comprehensive nutrition education
    efforts. SNAP, administered by FNS, is the nation's largest nutrition
    assistance program, providing benefits to more than 15% of the U.S.
    population. In 2011, SNAP participants redeemed over $71 billion in
    SNAP benefits in more than 230,000 SNAP-authorized stores.\12\ Total
    program costs in FY 2011 were nearly $76 billion.\13\ Given the
    magnitude of SNAP, FNS has a sustained interest in understanding the
    effects of the program.
    ---------------------------------------------------------------------------
        \12\ USDA FNS. (2011). Supplemental Nutrition Assistance Program
    2011 Annual Report. Benefit Redemption Division. Available at http://
    www.fns.usda.gov/snap/retailers/pdfs/2011-annual-report-revised.pdf.
        \13\ http://www.fns.usda.gov/pd/SNAPsummary.htm.
    ---------------------------------------------------------------------------
        SNAP aims to alleviate hunger and improve the nutritional status of
    participants by increasing the resources available to households to
    purchase food. Paradoxically, one-in-six people in the U.S. experiences
    food insecurity,\14\ while \2/3\ of adults and \1/3\ of children are
    overweight or obese.\15\ These public health problems
    disproportionately affect low-income populations.\16\ While no evidence
    exists that SNAP participation causes obesity, the high rates of
    obesity and food insecurity among low-income Americans underscore the
    importance of exploring ways to continue to employ SNAP strategically
    as a tool to promote healthier nutrition, as well as to reduce obesity
    rates among program participants of whom nearly 50% are children.
    ---------------------------------------------------------------------------
        \14\ Coleman-Jensen, A., Nord, M., Andrews, M., & Carlson, S.
    (2011). Household food security in the United States in 2010. Economic
    Research Report, No. ERR-125. Available at http://www.ers.usda.gov/
    media/884525/err141.pdf.
        \15\ Flegal, K.M., Carroll, M.D., Ogden, C.L., & Curtin, L.R.
    (2010). ``Prevalence and trends in obesity among U.S. adults, 1999-
    2008,'' Journal of the American Medical Association, 303, 235-241;
    Burgstahler, R., Gundersen, C., & Garasky, S. (forthcoming). ``The
    Supplemental Nutrition Assistance Program, financial stress, and
    childhood obesity.'' Agricultural and Resource Economics Review;
    Eisenmann, J.C., Gundersen, C., Lohman, B.J., Garasky, S., & Stewart,
    S.D. (2011). ``Is food insecurity related to overweight and obesity in
    children and adolescents? A summary of studies, 1995-2009.'' Obesity
    Reviews, 12, e73-e83; Lohman, B.J., Stewart, S., Gundersen, C.,
    Garasky, S., & Eisenmann, J.C. (2009). ``Adolescent overweight and
    obesity: Links to food insecurity and individual, maternal, and family
    stressors.'' Journal of Adolescent Health, 45, 230-237; Gundersen, C.,
    Garasky, S., & Lohman, B.J. (2009) ``Food insecurity is not associated
    with childhood obesity as assessed using multiple measures of
    obesity.'' Journal of Nutrition, 139, 1173-1178.
        \16\ Trust for America's Health. (2011). F as in fat: How obesity
    threatens America's future. Available at http://healthyamericans.org/
    reports/obesity2010/Obesity2010Report.pdf.
    ---------------------------------------------------------------------------
    1.3  Research Questions
        The project addressed two key research questions.
        Research Question 1: What food items are purchased by SNAP
    households? Specifically, the study examined SNAP household food
    expenditure data by four categorizations: U.S. Department of
    Agriculture (USDA) Food Pattern categories, ``summary categories,''
    commodities, and subcommodities.
        Research Question 2: How do foods purchased by SNAP households
    compare to purchases made by non-SNAP households? Analyses paralleled
    those for Research Question 1, but for non-SNAP households. Comparisons
    were then drawn between the food expenditures of SNAP and non-SNAP
    households.
    1.4  Challenges of Collecting Point-of-Sale Data
        Understanding the food choices and purchasing patterns of SNAP
    participants is an important part of promoting healthy choices. FNS
    analyzes various extant data that describe the diets and food
    purchasing patterns of SNAP households. For example, The National
    Health and Nutrition Examination Survey is an annual nationally
    representative survey of approximately 5,000 respondents that collects,
    among other data, dietary behavior and 24-hour dietary recall data.\17\
    The Nielsen Homescan data include a panel of households that records
    grocery purchases using a scanning device.\18\ Panelists scan the
    barcodes of the products they purchase, recording information such as
    price and quantity. The Consumer Expenditure Survey gathers expenditure
    information from participants every 3 months over a 15 month period
    through interviews and a diary survey.\19\ The interview is designed to
    gather expenditure data on items that are easy to recall, while the
    diary survey records purchases made each day during a 2 week period.
    ---------------------------------------------------------------------------
        \17\ http://www.cdc.gov/nchs/tutorials/Dietary/SurveyOrientation/
    intro.htm.
        \18\ http://www.ncppanel.com.
        \19\ http://www.bls.gov/cex.
    ---------------------------------------------------------------------------
        An outstanding question is whether food purchase data collected at
    the point-of-sale offers a different or more detailed perspective on
    the food choices of SNAP and other households. Ideally, retail data on
    SNAP electronic benefit transfer (EBT) purchases would be collected in
    a timely manner--preferably at the point of sale--and with sufficient
    sample size to be nationally representative. To date, there have been
    numerous challenges to collecting such retail data:

       The immense volume of SNAP retail data--in FY 2011, over $71
            billion in SNAP benefits were redeemed at over 230,000
            participating stores, farmers['] markets and other venues
            authorized to accept SNAP benefits.\20\ These transactions
            represent billions of food items purchased each month via an
            estimated 250 million or more unique transactions.
    ---------------------------------------------------------------------------
        \20\ Supplemental Nutrition Assistance Program, USDA FNS Benefit
    Redemption Division 2011 Annual Report. Available from http://
    www.fns.usda.gov/snap/retailers/pdfs/2011-annual-report-revised.pdf.

       The wide variety of food products and package sizes sold by
            the over 230,000 SNAP-authorized retailers--roughly 40,000
            items in larger stores \21\--and the diverse ways retailers
            identify and track these items.
    ---------------------------------------------------------------------------
        \21\ http://www.fmi.org/facts_figs/?fuseaction=superfact.

       Industry reluctance to share detailed sales data, a key
    ---------------------------------------------------------------------------
            competitive tool for food marketers.

       Equipment and system changes needed to capture item-level
            data at SNAP-approved stores. The numerous cash register
            technologies currently in use vary in their sophistication and
            their ability to collect item-level data. Data transmission and
            storage are also important issues.

       Distinguishing between SNAP and non-SNAP transactions and
            purchases, given that SNAP households at times combine SNAP
            benefits and their own funds when making purchases.

        The current study provides a snapshot of food purchasing patterns
    using POS data from a set of retailers to compare expenditures on SNAP-
    eligible food items made by SNAP and non-SNAP households.
    Chapter 2. Methodology
    2.1  Data Overview
        POS transaction data from January 1, 2011 through December 31, 2011
    from a leading grocery retailer were examined in this study.\22\ The
    majority of stores from which the data came would be classified as
    grocery stores, supermarkets, and combination food and drug stores per
    FNS Retailer Policy and Management Division food retailer
    definitions.\23\ On average, each of the 12 monthly data files
    contained over one billion records of food items purchased by 26.5
    million households, reflecting 127 million unique transactions. Each
    monthly data file included an average of 3.2 million SNAP households,
    identified using the methodology described below. Total expenditures on
    all SNAP-eligible food items in the dataset by SNAP and non-SNAP
    households over the 12 months were $39.0 billion, or approximately $3.3
    billion per month. SNAP households expended approximately $555 million
    on SNAP-eligible food items each month in this dataset, using both SNAP
    benefits and other resources such as cash or credit cards.\24\
    ---------------------------------------------------------------------------
        \22\ Per the data sharing agreement between the data provider and
    IMPAQ, a description of the source of these data must be limited to the
    following: ``From a leading U.S. grocery retailer data examining POS
    transactions from January 1, 2011 through December 31, 2011 across
    approximately 11 million SNAP households. The majority of stores would
    be classified as grocery stores, supermarkets, and combination food and
    drug stores per USDA/FNS food retailer definitions.''
        \23\ Stores that opened or closed during 2011 were not included in
    these analyses.
        \24\ By way of comparison, in FY 2011, 21.1 million households
    participated in SNAP in an average month (http://www.fns.usda.gov/ora/
    MENU/Published/snap/FILES/Participation/2011Characteristics.pdf) and
    redeemed $6.0 billion in benefits in an average month (http://
    www.fns.usda.gov/snap/retailers/pdfs/2011-annual-report-revised.pdf).
    ---------------------------------------------------------------------------
    2.2  Identification of SNAP Households and Creation of Analysis
            Categories
        SNAP households were identified in the data for each month. This
    identification was performed monthly because, in any given month, some
    households enter or leave the program. The analysis identified SNAP
    households each month by first identifying any transaction in which
    SNAP EBT was used to pay for at least \1/2\ of the value of the
    purchase and designating the household that made that transaction as a
    SNAP household.\25\ It then linked all other transactions made by that
    household during that month to estimate total monthly spending by SNAP
    households. All other transactions in these stores were designated as
    non-SNAP household purchases.\26\ Exhibit 2 illustrates the
    identification of SNAP households.
    ---------------------------------------------------------------------------
        \25\ SNAP transactions in which SNAP EBT was not the majority
    tender were not identifiable in the data.
        \26\ Some of these transactions may, in fact, have included SNAP
    purchases. Some SNAP households may never have presented EBT as the
    majority tender in any transaction, for example.
    ---------------------------------------------------------------------------
    Exhibit 2: Conceptual Map for Identification of SNAP Households in the
            POS Data

        IMPAQ analyzed SNAP-eligible food items given the focus of the
    study. Per the Food and Nutrition Act of 2008 (the Act), eligible food
    include any food or food product for home consumption, as well as seeds
    and plants which produce food for consumption. The Act precludes
    alcoholic beverages, tobacco products, hot food and any food sold for
    on-premises consumption from being purchased with SNAP benefits.\27\
    The unit of analysis for the study was a food-related subcommodity,
    with subcommodities and commodities defined by the data provider. Each
    subcommodity typically consisted of multiple food items, often
    distinguished by brand or package size, identified by a Universal
    Product Code (UPC) or a Price Look Up (PLU) code. Each commodity was an
    aggregation of similar subcommodities. The ``apples'' commodity group,
    for example, combined different varieties (Gala, Fuji, Honeycrisp) and
    forms (bagged, bulk) that were presented separately as subcommodities.
    The decision to rely on subcommodity groupings follows procedures
    established in published studies.\28\ These studies prefer
    subcommodity-level analyses over item-level analyses because UPCs and
    PLUs assigned by manufacturers and retailers can change over time.
    Additionally, the same food item may be sold in multiple forms with
    different brands and labels, each with its own unique UPC.\29\
    ---------------------------------------------------------------------------
        \27\ See http://www.fns.usda.gov/snap/retailers/eligible.htm for
    more details.
        \28\ For examples, see Hamilton, S., et al. (2007). ``Food and
    nutrient availability in New Zealand: An analysis of supermarket sales
    data.'' Public Health Nutrition, 10(12): 1448-1455; Van Wave, T.W., &
    Decker, M. (2003). ``Secondary analysis of a marketing research
    database reveals patterns in dairy product purchases over time.''
    Journal of American Dietetic Association, 103(4), 445-453.
        \29\ Baxter, J., et al. (1996). Experiences in using computerized
    sales data to evaluate a nutrition intervention program. Journal of
    Nutrition Education, 28, 443-445.
    ---------------------------------------------------------------------------
        Exhibit 3 details expenditures on SNAP-eligible food items in the
    dataset. As can be seen, expenditures on all 1,792 subcommodities in
    the dataset sum up to $6.7 billion and $32.3 billion for SNAP and non-
    SNAP households, respectively. Notably, expenditures on the top 1,000
    subcommodities account for 99% of expenditures for SNAP households and
    98% for non-SNAP households. For this reason, all subsequent analyses
    and tables in the report are generated using the top 1,000
    subcommodities.

     Exhibit 3: Summary of SNAP and Non-SNAP Household Food Expenditures in
                           the Dataset by Subcommodity
    ------------------------------------------------------------------------
                                                                Non-SNAP
                  Finding                SNAP Households       Households
    ------------------------------------------------------------------------
    Total annual expenditures on SNAP-       $6.7 billion      $32.3 billion
     eligible foods in dataset
    Percentage of all transactions by                 12%                88%
     all households
    Percentage of total annual                        17%                83%
     expenditures by all households
    Top 1,000 (of 1,792) subcommodity                 99%                98%
     expenditures as a percentage of
     all expenditures
    Top 100 (of 1,792) subcommodity                   51%                46%
     expenditures as a percentage of
     all expenditures
    Top 25 (of 1,792) subcommodity                    25%                21%
     expenditures as a percentage of
     all expenditures
    Top 25 commodity (of 238)                         45%                41%
     expenditures as a percentage of
     all expenditures
                                       -------------------------------------
      Total annual expenditures on top    $6.5805 billion   $31.5138 billion
       1,000 subcommodities
    ------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ
      International, LLC, 2016.

        The data provider aggregated the subcommodities to commodities. The
    top 1,000 subcommodities represented 238 commodities. Although
    subcommodities and commodities provide adequate comparison reference
    points, these groupings were designed to help retailers classify
    purchases for their own needs (e.g., marketing purposes). Therefore,
    this study analyzed purchases at two higher levels of aggregation.
    Thirty summary categories were created--for example, meat/poultry/
    seafood, fruits, vegetables, cereal, candy, and frozen prepared foods--
    to be roughly analogous to the major sections or departments in a
    typical grocery store. These categories were constructed to enhance
    discussion of similarities and differences between the purchasing
    patterns of SNAP and non-SNAP households. Appendix B provides a
    crosswalk of subcommodities to summary categories.
        IMPAQ also mapped food subcommodities to USDA Food Pattern
    categories (dairy, fruits, grains, oils, protein foods, solid fats and
    added sugars (SoFAS), and vegetables).\30\ A crosswalk of
    subcommodities to USDA Food Pattern categories can be found in Appendix
    C. Relative to the 30 summary categories, there are only seven USDA
    Food Pattern categories. As a result, more subcommodities were included
    in each Food Pattern category, on average, relative to the summary
    categories which at times lead to differing results for categories with
    the same name. For example, for the USDA Food Patterns analysis, 100%
    pure orange juice was classified as a fruit. Juice, however, is a
    specific category among the summary categories. Therefore, expenditures
    on 100% orange juice were not included as fruit expenditures for the
    summary categories analysis as they were for the Food Patterns
    analysis. Readers should keep this in mind when comparing results for
    categories such as fruits or vegetables across analyses.
    ---------------------------------------------------------------------------
        \30\ USDA Center for Nutrition Policy and Promotion Food Patterns
    (http://www.cnpp.usda.gov/USDAFoodPatterns.htm).
    ---------------------------------------------------------------------------
        Not all subcommodities could be classified into single Food Pattern
    categories. Subcommodities incorporating multiple food categories, such
    as foods packaged as complete meals, were classified as composite
    foods. In addition, some subcommodities did not fit any Food Pattern
    categories, or the labels were not descriptive enough to permit
    categorization even with the addition of the composite category. A
    ninth category, other, was created to capture such subcommodities.
    ``Other'' captured all items that could not be classified using USDA
    Food Patterns, such as water, isotonic drinks, and baby food. Exhibit 4
    describes the aggregations of food items used for these analyses, using
    fluid milk products as an example.
    Exhibit 4: Aggregating Food Items

              Note: The vast majority of commodities included
            subcommodities that could be mapped to a single summary
            category as shown above. However, a small number of commodities
            included subcommodities that did not map to the same summary
            category. For example, the commodity group Authentic Hispanic
            Foods and Products included authentic vegetables and foods,
            Hispanic carbonated beverages, and authentic pasta/rice/beans
            subcommodities which mapped to the vegetables, sweetened
            beverages, and rice summary categories, respectively. The top
            1,000 subcommodities accounted for 99% of all expenditures on
            SNAP-eligible food items in the dataset for SNAP households and
            98% of all expenditures on SNAP-eligible food items by non-SNAP
            households.
    2.3  Data Caveats and Limitations
        Although POS data provide a wealth of information on the food
    purchase patterns of SNAP households, some limitations existed in the
    data analyzed for this study. The data used for this study captured
    only transactions completed at a specific set of retail outlets. As
    stated before, the majority of stores from which the data came would be
    classified as grocery stores, supermarkets, and combination food and
    drug stores per FNS Retailer Policy and Management Division food
    retailer definitions.\31\ Purchases made at other SNAP-authorized
    retailers or other venues (e.g., farmers['] markets) were not included
    in these data. On average, SNAP households in the data spent
    approximately $229 per month on SNAP-eligible foods using a combination
    of SNAP benefits, cash and other forms of payment.\32\ In contrast, the
    national average monthly SNAP benefit per household was $284 in FY
    2011.\33\ Therefore, although these data account for a significant
    proportion of SNAP-eligible food expenditures by SNAP households, they
    do not include all SNAP benefit expenditures.
    ---------------------------------------------------------------------------
        \31\ Stores that opened or closed during 2011 were not included in
    these analyses.
        \32\ On average, SNAP households in the data made 8.5 transactions
    per month. The average total expenditure on SNAP-eligible foods per
    transaction was $26.99.
        \33\ http://www.fns.usda.gov/pd/19SNAPavg$HH.htm.
    ---------------------------------------------------------------------------
        SNAP transactions were identified as those for which a SNAP EBT
    card was the majority tender. Because some transactions included both
    SNAP and cash or credit tenders, these data could not differentiate
    between items purchased with SNAP benefits and those purchased with
    other funds. These data, therefore, represent food purchases made by
    SNAP households rather than the foods purchased with SNAP EBT.
        Rankings of expenditure categories depend in part on the level of
    food item aggregation (whether at the Food Pattern category, summary
    category, commodity or subcommodity levels). As discussed above, the
    data provider aggregated food items into subcommodities and commodities
    considering other factors outside of the needs of this particular
    analysis. These classifications at times presented analytic challenges
    that may have affected the rank ordering of expenditures. For example,
    subcommodity groups categorized as ``composite'' or ``other'' for these
    analyses likely included food items that would more appropriately be
    included in one of the Food Pattern categories had more information
    been available. Similarly, some distinctions of potential nutritional
    importance were not available in these data. For example, it was not
    possible to distinguish between fat-free or low-fat varieties of some
    dairy products, such as fluid milk or yogurt, from whole milk
    varieties.
    Chapter 3. Findings: Top Expenditures by SNAP and Non-SNAP Households

    ------------------------------------------------------------------------

    -------------------------------------------------------------------------
    Key Findings

         There were no major differences in the expenditure patterns
         of SNAP and non-SNAP households, no matter how the data were
         categorized. Similar to most American households:

             About 40 of every dollar of food expenditures by SNAP
             households was spent on basic items such as meat, fruits,
             vegetables, milk, eggs, and bread.

             Another 20 out of every dollar was spent on sweetened
             beverages, desserts, salty snacks, candy and sugar.

             The remaining 40 were spent on a variety of items such as
             cereal, prepared foods, dairy products, rice, and beans.

         The top ten summary categories and the top seven
         commodities by expenditure were the same for SNAP and non-SNAP
         households, although ranked in slightly different orders.

         Less healthy food items were common purchases for both SNAP
         and non-SNAP households. Sweetened beverages, prepared desserts and
         salty snacks were among the top ten summary categories for both
         groups. Expenditures were greater for sweetened beverages compared
         to all milk for both groups, as well.

         Expenditures were concentrated in a relatively small number
         of similar food-item categories. The top five summary groups
         totaled \1/2\ (50%) of the expenditures for SNAP households and
         nearly \1/2\ (47%) for non-SNAP households. Twenty-five commodities
         accounted for nearly \1/2\ of the food expenditures in these data
         with SNAP and non-SNAP households having 20 of them in common. The
         top 25 subcommodities for SNAP households and non-SNAP households,
         respectively, accounted for over \1/5\ of food expenditures for
         each group with 16 subcommodities in common for the two groups.
    ------------------------------------------------------------------------

    3.1  Distribution of Expenditures by Summary Categories
        Exhibit 5 provides an overview of expenditures by the summary
    categories described in Chapter 2. In general, SNAP and non-SNAP
    household expenditure rankings and proportions were similar.
    Expenditures on basic or staple foods (meat/poultry/seafood, fruits,
    vegetables, milk, eggs and bread/crackers) comprised over 40 of every
    food purchase dollar for both SNAP and non-SNAP households (41 and
    44/dollar, respectively). Another 20 per dollar was spent on less
    healthy foods such as sweetened beverages, prepared desserts, salty
    snacks, candy and sugars by both household groups (SNAP households--
    23; non-SNAP households--20).
        Expenditures were generally concentrated in a small number of
    summary groups for both SNAP and non-SNAP households. The top five
    groups total \1/2\ (50%) of the expenditures for SNAP households and
    nearly \1/2\ (47%) for non-SNAP households. The top three categories by
    expenditures for SNAP households were meat/poultry/seafood, sweetened
    beverages, and vegetables. The top three categories for non-SNAP
    households were meat/poultry/seafood, vegetables, and high fat dairy/
    cheese; sweetened beverages ranked fifth. Both SNAP and non-SNAP
    households spent a greater proportion of total expenditures on meat,
    poultry and seafood than any other category. Both household groups
    spent more on fruits and vegetables than on prepared foods, and more on
    sweetened beverages than on milk.

                                      Exhibit 5: Summary Categories by Expenditure
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
              Summary Category                         $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Meat, Poultry and Seafood                    1    $1,262.9          19.19%         1    $5,016.3          15.92%
    Sweetened Beverages                          2      $608.7           9.25%         5    $2,238.8           7.10%
    Vegetables                                   3      $473.4           7.19%         2    $2,873.9           9.12%
    Frozen Prepared Foods                        4      $455.2           6.92%         8    $1,592.3           5.05%
    Prepared Desserts                            5      $453.8           6.90%         6    $2,021.2           6.41%
    High Fat Dairy/Cheese                        6      $427.8           6.50%         3    $2,483.2           7.88%
    Bread and Crackers                           7      $354.9           5.39%         7    $1,978.2           6.28%
    Fruits                                       8      $308.2           4.68%         4    $2,271.2           7.21%
    Milk                                         9      $232.7           3.54%         9    $1,211.0           3.84%
    Salty Snacks                                10      $225.6           3.43%        10      $969.7           3.08%
    Prepared Foods                              11      $202.2           3.07%        14      $707.0           2.24%
    Cereal                                      12      $186.9           2.84%        11      $933.9           2.96%
    Condiments and Seasoning                    13      $174.6           2.65%        12      $878.9           2.79%
    Fats and Oils                               14      $155.1           2.36%        13      $766.9           2.43%
    Candy                                       15      $138.2           2.10%        15      $701.4           2.23%
    Baby Food                                   16      $126.8           1.93%        27      $198.2           0.63%
    Juices                                      17      $110.4           1.68%        16      $605.4           1.92%
    Coffee and Tea                              18       $83.4           1.27%        17      $568.8           1.80%
    Bottled Water                               19       $78.1           1.19%        22      $377.4           1.20%
    Eggs                                        20       $73.8           1.12%        21      $388.2           1.23%
    Other Dairy Products                        21       $69.8           1.06%        18      $549.5           1.74%
    Pasta, Cornmeal, Other Cereal               22       $66.4           1.01%        23      $281.5           0.89%
     Products
    Soups                                       23       $62.7           0.95%        20      $414.1           1.31%
    Sugars                                      24       $60.9           0.93%        24      $260.3           0.83%
    Nuts and Seeds                              25       $53.2           0.81%        19      $445.9           1.41%
    Beans                                       26       $38.3           0.58%        25      $234.5           0.74%
    Rice                                        27       $30.1           0.46%        28      $131.0           0.42%
    Jams, Jellies, Preserves and Other          28       $29.1           0.44%        29      $117.5           0.37%
     Sweets
    Flour and Prepared Flour Mixes              29       $18.7           0.28%        30       $94.9           0.30%
    Miscellaneous                               30       $18.6           0.28%        26      $202.6           0.64%
                                                   ----------------------------          ---------------------------
      Total Summary Category                          $6,580.5            100%             $31,513.8            100%
       Expenditures (Top 1,000
       subcommodities)
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.

    3.2  Distribution of Expenditures by Commodities
        Exhibit 6 examines expenditures at the commodity level, listing the
    top 100 commodities by expenditure for SNAP households while providing
    corresponding rankings of these commodities for non-SNAP households.
    The top 100 commodities accounted for nearly all expenditures for both
    SNAP (87%) and non-SNAP (82%) households. The top 25 SNAP household
    commodities accounted for nearly \1/2\ (46%) of the food expenditures
    for SNAP households; the top 25 commodities for non-SNAP households
    accounted for 42%. Among the top 25 commodities, the two households
    groups had 20 in common.
        The top two commodities were the same for SNAP and non-SNAP
    households, namely soft drinks and fluid milk products, although the
    order was reversed with soft drinks ranked first for SNAP households
    compared to fluid milk products for non-SNAP households. However, while
    expenditure proportions were similar for fluid milk products across the
    two household types (4 per dollar), expenditure proportions on soft
    drinks were slightly higher for SNAP households compared to non-SNAP
    households (5 versus 4 per dollar). Overall, the expenditure rankings
    and patterns should be assessed with caution as a small difference in
    the expenditure share of a commodity can lead to a major difference in
    the ranking of the commodity. For example, among SNAP households, the
    difference in expenditure shares between lunchmeat, ranked tenth, and
    aseptic juice, ranked sixty-ninth, is approximately 1 per dollar.

                            Exhibit 6: Top 100 Commodities for SNAP Households by Expenditure
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
                  Commodity                            $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Soft drinks                                  1      $357.7           5.44%         2    $1,263.3           4.01%
    Fluid milk products                          2      $253.7           3.85%         1    $1,270.3           4.03%
    Beef grinds                                  3      $201.0           3.05%         6      $621.1           1.97%
    Bag snacks                                   4      $199.3           3.03%         5      $793.9           2.52%
    Cheese                                       5      $186.4           2.83%         3      $948.9           3.01%
    Baked breads                                 6      $163.7           2.49%         4      $874.8           2.78%
    Cold cereal                                  7      $139.2           2.12%         7      $583.9           1.85%
    Chicken fresh                                8      $121.4           1.85%        11      $477.8           1.52%
    Frozen handhelds and snacks                  9      $101.5           1.54%        47      $214.6           0.68%
    Lunchmeat                                   10       $99.4           1.51%        17      $386.1           1.23%
    Candy--packaged                             11       $96.2           1.46%         8      $527.7           1.67%
    Infant formula                              12       $95.7           1.45%        80      $124.8           0.40%
    Frozen pizza                                13       $90.2           1.37%        23      $305.7           0.97%
    Refrigerated juices/drinks                  14       $88.5           1.35%        14      $412.8           1.31%
    Ice cream, ice milk, sherbets               15       $86.0           1.31%        10      $481.8           1.53%
    Coffee and creamers                         16       $82.3           1.25%         9      $519.4           1.65%
    Cookies                                     17       $78.2           1.19%        16      $408.3           1.30%
    Water--(sparkling and still)                18       $77.0           1.17%        18      $379.2           1.20%
    Shelf stable juice                          19       $73.1           1.11%        28      $282.2           0.90%
    Eggs/muffins/potatoes                       20       $72.0           1.09%        20      $358.7           1.14%
    Frozen single serving premium meals         21       $68.6           1.04%        12      $447.1           1.42%
    Cakes                                       22       $68.2           1.04%        38      $240.9           0.76%
    Bacon                                       23       $66.1           1.00%        27      $283.2           0.90%
    Traditional Mexican foods                   24       $62.6           0.95%        25      $286.9           0.91%
    Yogurt                                      25       $59.9           0.91%        13      $442.3           1.40%
    Salad dressing and sandwich spreads         26       $59.7           0.91%        30      $280.9           0.89%
    Dinner sausage                              27       $59.3           0.90%        46      $222.6           0.71%
    Frozen prepared chicken                     28       $58.6           0.89%        74      $136.4           0.43%
    Baked sweet goods                           29       $57.5           0.87%        62      $159.6           0.51%
    Beef loins                                  30       $56.3           0.86%        31      $280.3           0.89%
    Chicken frozen                              31       $54.8           0.83%        85      $123.0           0.39%
    Deli meat: bulk                             32       $54.6           0.83%        15      $411.0           1.30%
    Frozen multi-serve meals                    33       $53.0           0.81%        54      $183.5           0.58%
    Dinner mixes-dry                            34       $51.8           0.79%        72      $140.3           0.45%
    Frozen breakfast foods                      35       $51.3           0.78%        55      $180.9           0.57%
    Crackers and misc baked food                36       $50.9           0.77%        21      $323.7           1.03%
    Frozen novelties-water ice                  37       $50.7           0.77%        43      $229.7           0.73%
    Margarines                                  38       $50.3           0.76%        24      $303.0           0.96%
    Condiments and sauces                       39       $49.8           0.76%        52      $187.2           0.59%
    Potatoes                                    40       $48.8           0.74%        34      $265.2           0.84%
    Frozen vegetable and veg dish               41       $48.2           0.73%        33      $266.9           0.85%
    Hot dogs                                    42       $45.5           0.69%        63      $158.4           0.50%
    Can vegetables--shelf stable                43       $45.3           0.69%        50      $191.7           0.61%
    Shortening and oil                          44       $44.6           0.68%        57      $174.2           0.55%
    Sugars and sweeteners                       45       $43.3           0.66%        60      $162.4           0.52%
    Isotonic drinks                             46       $42.8           0.65%        53      $185.3           0.59%
    Salad mix                                   47       $42.8           0.65%        22      $319.4           1.01%
    Milk by-products                            48       $42.5           0.65%        32      $268.9           0.85%
    Pork boneless loin/rib                      49       $41.5           0.63%        58      $168.0           0.53%
    Convenience breakfasts and wholesome        50       $41.1           0.62%        45      $226.1           0.72%
     snacks
    Frozen single serve economy meals           51       $40.9           0.62%       109       $80.7           0.26%
    Refrigerated dough products                 52       $40.5           0.62%        56      $176.6           0.56%
    Beef round                                  53       $40.4           0.61%        75      $134.2           0.43%
    Dry bean vegetables and rice                54       $39.9           0.61%        59      $166.1           0.53%
    Convenient meals                            55       $38.7           0.59%       108       $81.0           0.26%
    Tomatoes                                    56       $38.3           0.58%        35      $261.7           0.83%
    Candy--checklane                            57       $37.9           0.58%        64      $154.0           0.49%
    Berries                                     58       $37.4           0.57%        19      $373.5           1.19%
    Grapes                                      59       $36.1           0.55%        39      $235.7           0.75%
    Bananas                                     60       $36.1           0.55%        36      $261.4           0.83%
    Peanut                                      61       $36.0           0.55%        42      $231.0           0.73%
    Pork thin meats                             62       $35.0           0.53%        93      $106.8           0.34%
    Citrus                                      63       $34.3           0.52%        37      $251.7           0.80%
    Breakfast sausage                           64       $34.2           0.52%        79      $126.7           0.40%
    Dry sauce, gravy, potatoes, stuffing        65       $34.0           0.52%        87      $119.2           0.38%
    Salad and dips                              66       $33.9           0.52%        40      $235.3           0.75%
    Apples                                      67       $33.7           0.51%        29      $281.7           0.89%
    Meat--shelf stable                          68       $33.3           0.51%        91      $109.2           0.35%
    Aseptic juice                               69       $33.1           0.50%       112       $78.9           0.25%
    Sweet goods                                 70       $32.5           0.49%        66      $152.9           0.49%
    Frozen potatoes                             71       $32.2           0.49%        95      $104.5           0.33%
    Meat frozen                                 72       $31.9           0.48%       120       $69.9           0.22%
    Baby foods                                  73       $30.6           0.46%       121       $67.8           0.22%
    Vegetables salad                            74       $30.0           0.46%        44      $228.6           0.73%
    Beef: thin meats                            75       $30.0           0.46%        78      $127.7           0.41%
    Seafood--shrimp                             76       $29.8           0.45%        84      $123.1           0.39%
    Canned soups                                77       $29.7           0.45%        65      $153.6           0.49%
    Baking mixes                                78       $28.3           0.43%        69      $148.1           0.47%
    Pasta and pizza sauce                       79       $27.6           0.42%        99       $96.7           0.31%
    Dry noodles and pasta                       80       $27.5           0.42%        71      $141.5           0.45%
    Can seafood--shelf stable                   81       $26.5           0.40%        77      $132.3           0.42%
    Rts/micro soup/broth                        82       $26.0           0.40%        48      $200.8           0.64%
    Canned pasta and microwave food             83       $25.9           0.39%       135       $56.7           0.18%
    Smoked hams                                 84       $25.7           0.39%        92      $108.8           0.35%
    Nuts                                        85       $25.6           0.39%        41      $234.2           0.74%
    Value-added fruit                           86       $25.3           0.38%        70      $146.6           0.47%
    Can beans                                   87       $24.0           0.36%        82      $123.3           0.39%
    Dry/ramen bouillon                          88       $21.7           0.33%       133       $61.0           0.19%
    Powder and crystal drink mix                89       $21.6           0.33%       119       $75.2           0.24%
    Rtd tea/new age juice                       90       $21.5           0.33%       103       $93.8           0.30%
    Baking needs                                91       $21.3           0.32%        51      $188.9           0.60%
    Can fruit/jar applesauce                    92       $20.9           0.32%        96      $104.0           0.33%
    Spices and extracts                         93       $20.4           0.31%        86      $121.9           0.39%
    Energy drinks                               94       $20.1           0.30%       102       $94.1           0.30%
    Onions                                      95       $20.0           0.30%        81      $123.5           0.39%
    Tropical fruit                              96       $19.8           0.30%        61      $160.1           0.51%
    Bagels and cream cheese                     97       $19.8           0.30%        83      $123.2           0.39%
    Frozen bread/dough                          98       $19.7           0.30%       114       $77.7           0.25%
    Rolls                                       99       $18.9           0.29%        88      $113.9           0.36%
    Hot cereal                                 100       $18.9           0.29%       100       $96.1           0.30%
                                                   ----------------------------          ---------------------------
      Expenditures on Listed Commodities              $5,700.3          86.62%             $25,800.4          81.93%
                                                   ============================          ===========================
        Expenditures on Top 1,000                     $6,580.5            100%             $31,513.8            100%
         Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 100 commodities for SNAP households and the corresponding rankings of these
      commodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    3.3  Distribution of Expenditures by Subcommodities
        Exhibit 7 presents the top 100 subcommodities purchased by SNAP
    households, along with corresponding expenditures and ranks of these
    subcommodities for non-SNAP households.\34\ These 100 subcommodities
    accounted for over \1/2\ (51%) of the food expenditures in these data
    for SNAP households. Comparatively, the food purchases of non-SNAP
    households on these 100 subcommodities represented only 43% of their
    total expenditures. As expected, the level of detail provided by the
    subcommodity classifications resulted in relatively small proportions
    of total expenditures being spent on any single subcommodity.
    Individually, only six subcommodities represented more than 1% of the
    expenditures of SNAP households. As with the commodity rankings, a
    small difference in the expenditure share of a subcommodity translated
    into a substantial difference in its ranking. For example, among SNAP
    households, the difference in shares of expenditures between potato
    chips, ranked seventh, and bananas, ranked thirty-fifth, is less than
    \1/2\ of one percentage point.
    ---------------------------------------------------------------------------
        \34\ See Appendix A for the commodity that corresponds to each
    subcommodity for the top 1,000 subcommodities.
    ---------------------------------------------------------------------------
        The top two subcommodities purchased by SNAP households, fluid
    milk/white only and carbonated soft drinks in 12-18 can packages, were
    the top subcommodities for non-SNAP households as well. An interesting
    difference in rankings of subcommodities between SNAP households and
    non-SNAP households was for infant formula/starter solution. This
    subcommodity ranked tenth among SNAP households. The majority of these
    formula purchases were made when SNAP EBT was not the majority tender
    (results not presented here), perhaps because WIC (Special Supplemental
    Nutrition Program for Women, Infants, and Children) benefits were used.
    Infant formula/starter solution purchases ranked well out of the top
    100 for non-SNAP households, at 190.

                          Exhibit 7: Top 100 Subcommodities for SNAP Households by Expenditure
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
                Subcommodity                           $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/White Only                        1      $191.1           2.90%         1      $853.8           2.71%
    Soft Drinks 12/18 &15pk Can Car              2      $164.6           2.50%         2      $601.2           1.91%
    Lean [Beef]                                  3      $112.4           1.71%         7      $257.9           0.82%
    Kids' Cereal                                 4       $78.1           1.19%        20      $186.4           0.59%
    Shredded Cheese                              5       $74.7           1.14%         3      $342.0           1.09%
    Soft Drink 2 Liter Btl Carb Incl             6       $70.9           1.08%        12      $230.1           0.73%
    Potato Chips                                 7       $64.4           0.98%         8      $253.2           0.80%
    Primal [Beef]                                8       $62.4           0.95%        14      $219.8           0.70%
    Lunchmeat--Deli Fresh                        9       $55.8           0.85%        11      $242.6           0.77%
    Infant Formula Starter/Solution             10       $54.2           0.82%       190       $45.3           0.14%
    Eggs--Large                                 11       $52.1           0.79%         9      $251.6           0.80%
    Chicken Breast Boneless                     12       $49.6           0.75%         4      $292.9           0.93%
    Still Water Drinking/Mineral Water          13       $48.8           0.74%        19      $187.7           0.60%
    Mainstream White Bread                      14       $48.0           0.73%        39      $136.8           0.43%
    Tortilla/Nacho Chips                        15       $47.4           0.72%        17      $209.0           0.66%
    Snacks/Appetizers                           16       $44.6           0.68%        65      $100.5           0.32%
    American Single Cheese                      17       $44.1           0.67%        41      $136.6           0.43%
    Frozen Single Serve Premium                 18       $43.8           0.67%        24      $175.4           0.56%
     Traditional Meals
    Dairy Case 100% Pure Juice--Orange          19       $43.5           0.66%         6      $269.0           0.85%
    Snack Cake--Multi-Pack                      20       $41.6           0.63%        63      $101.7           0.32%
    Enhanced [Pork Boneless Loin/Rib]           21       $41.5           0.63%        27      $168.0           0.53%
    Unflavored Can Coffee                       22       $41.3           0.63%        18      $198.0           0.63%
    Frozen Single Serve Economy Meals           23       $40.9           0.62%        81       $80.7           0.26%
     All
    Bacon--Trad 16oz Or Less                    24       $40.7           0.62%        29      $157.6           0.50%
    Soft Drinks 20pk & 24pk Can Carb            25       $39.7           0.60%        60      $106.4           0.34%
    Pizza/Premium                               26       $39.7           0.60%        32      $153.3           0.49%
    Mainstream Variety Breads                   27       $38.4           0.58%        26      $173.2           0.55%
    Sugar                                       28       $36.9           0.56%        55      $112.7           0.36%
    All Family Cereal                           29       $36.2           0.55%        16      $214.9           0.68%
    Sandwiches and Handhelds                    30       $35.9           0.54%        91       $73.6           0.23%
    Potatoes Russet (Bulk & Bag)                31       $35.8           0.54%        30      $154.5           0.49%
    Natural Cheese Chunks                       32       $35.3           0.54%        15      $216.1           0.69%
    Ribs [Pork]                                 33       $35.0           0.53%        59      $106.8           0.34%
    Convenient Meals--Kids Meal                 34       $34.2           0.52%        96       $69.7           0.22%
    Bananas                                     35       $34.2           0.52%        10      $242.7           0.77%
    Soft Drink Mlt-Pk Btl Carb                  36       $34.0           0.52%        25      $173.6           0.55%
    Premium [Ice Cream & Sherbert]              37       $31.2           0.47%        13      $226.0           0.72%
    Isotonic Drinks Single Serve                38       $30.5           0.46%        47      $119.5           0.38%
    Frozen Chicken--White Meat                  39       $30.0           0.46%        66       $99.8           0.32%
    Condensed Soup                              40       $29.7           0.45%        31      $153.6           0.49%
    Pourable Salad Dressings                    41       $29.0           0.44%        37      $139.4           0.44%
    Choice Beef                                 42       $28.4           0.43%        40      $136.6           0.43%
    Select Beef                                 43       $27.9           0.42%        36      $143.7           0.46%
    Soft Drink Single Srv Btl Carb              44       $27.8           0.42%        94       $71.4           0.23%
    Frozen Family Style Entrees                 45       $27.6           0.42%        77       $83.5           0.26%
    Mayonnaise & Whipped Dressing               46       $27.3           0.41%        48      $119.1           0.38%
    Frozen Bag Vegetables--Plain                47       $25.7           0.39%        42      $131.9           0.42%
    Traditional [Ice Cream and Sherbert]        48       $25.6           0.39%        49      $118.7           0.38%
    Hot Dogs--Base Meat                         49       $25.1           0.38%       138       $56.8           0.18%
    Adult Cereal                                50       $24.9           0.38%        21      $182.6           0.58%
    Frozen Single Serve Premium                 51       $24.7           0.38%         5      $271.6           0.86%
     Nutritional Meals
    Macaroni and Cheese Dinners                 52       $24.3           0.37%       125       $59.7           0.19%
    Aseptic Pack Juice and Drinks               53       $24.2           0.37%       134       $57.1           0.18%
    Refrigerated Coffee Creamers                54       $24.1           0.37%        34      $147.2           0.47%
    Choice Beef                                 55       $24.0           0.37%        92       $72.5           0.23%
    Mexican Soft Tortillas and Wraps            56       $23.7           0.36%        54      $113.1           0.36%
    Strawberries                                57       $23.5           0.36%        22      $178.4           0.57%
    Margarine: Tubs and Bowls                   58       $23.4           0.36%        64      $100.9           0.32%
    Mainstream [Pasta & Pizza]                  59       $23.0           0.35%        80       $81.0           0.26%
    Chicken Wings                               60       $22.2           0.34%       300       $28.6           0.09%
    Can Pasta                                   61       $22.2           0.34%       179       $47.7           0.15%
    Frozen Chicken--Wings                       62       $22.2           0.34%       452       $17.4           0.06%
    Lunchmeat--Bologna/Sausage                  63       $21.8           0.33%       121       $60.9           0.19%
    Multi-Pack Bag Snacks                       64       $21.6           0.33%       199       $43.4           0.14%
    Candy Bags-Chocolate                        65       $21.5           0.33%        33      $147.5           0.47%
    Sweet Goods: Donuts                         66       $21.3           0.32%        78       $82.3           0.26%
    Tuna                                        67       $21.1           0.32%        57      $109.9           0.35%
    Vegetable Oil                               68       $20.5           0.31%       246       $35.4           0.11%
    Frozen French Fries                         69       $20.5           0.31%       163       $50.3           0.16%
    Peanut Butter                               70       $20.4           0.31%        43      $127.8           0.41%
    Pizza/Economy                               71       $19.8           0.30%       192       $45.1           0.14%
    Butter                                      72       $19.6           0.30%        23      $175.6           0.56%
    Meat: Turkey Bulk                           73       $19.3           0.29%        28      $159.6           0.51%
    Frozen Breakfast Sandwiches                 74       $19.1           0.29%       142       $55.7           0.18%
    Frozen Meat--Beef                           75       $19.0           0.29%       185       $46.3           0.15%
    Frozen Skillet Meals                        76       $18.8           0.29%        83       $79.3           0.25%
    Value Forms/18oz and Larger                 77       $18.6           0.28%       209       $42.6           0.14%
     [Chicken]
    Cakes: Birthday/Celebration                 78       $18.6           0.28%       164       $50.3           0.16%
    Sandwich Cookies                            79       $18.0           0.27%        93       $71.8           0.23%
    Pizza/Traditional                           80       $17.9           0.27%       111       $64.1           0.20%
    Fruit Snacks                                81       $17.6           0.27%       202       $43.2           0.14%
    Rts Soup: Chunky/Homestyle                  82       $17.6           0.27%        46      $119.9           0.38%
    Sour Creams                                 83       $17.5           0.27%        70       $95.2           0.30%
    Waffles/Pancakes/French Toast               84       $17.3           0.26%        90       $77.4           0.25%
    Chicken Drums                               85       $17.3           0.26%       270       $31.5           0.10%
    Cream Cheese                                86       $17.2           0.26%        51      $115.5           0.37%
    Angus [Beef]                                87       $17.1           0.26%        61      $103.8           0.33%
    Bagged Cheese Snacks                        88       $17.1           0.26%       157       $52.0           0.16%
    Salsa and Dips                              89       $17.1           0.26%       135       $57.0           0.18%
    Sandwiches--(Cold)                          90       $16.9           0.26%       106       $67.7           0.21%
    Ramen Noodles/Ramen Cups                    91       $16.7           0.25%       304       $28.1           0.09%
    Cheese Crackers                             92       $16.5           0.25%        72       $90.2           0.29%
    Dinner Sausage--Links Pork                  93       $16.4           0.25%       233       $37.6           0.12%
    Candy Bars (Singles)                        94       $16.3           0.25%       146       $54.9           0.17%
    Hamburger Buns                              95       $16.2           0.25%        95       $70.2           0.22%
    Hot Dog Buns                                96       $16.2           0.25%       117       $62.2           0.20%
    Spring Water                                97       $16.2           0.25%        69       $95.6           0.30%
    Dairy Case Juice Drink Under 10oz           98       $16.0           0.24%       177       $48.0           0.15%
    Flavored Milk                               99       $16.0           0.24%       128       $59.4           0.19%
    Sweet Goods--Full Size                     100       $15.8           0.24%       133       $57.9           0.18%
                                                   ----------------------------          ---------------------------
      Expenditures on Listed                          $3,372.2          51.01%             $13,390.0          42.14%
       Subcommodities
                                                   ============================          ===========================
        Expenditures on Top 1,000                     $6,580.5            100%             $31,513.8            100%
         subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 100 subcommodities for SNAP households and the corresponding rankings of these
      subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    3.4  Distribution of Expenditures by Household Demographics, Store
            Characteristics, Type of Resource Used, and Month of Purchase
        In addition to analyzing purchase patterns as a whole, IMPAQ also
    analyzed the POS purchase data by household demographic and store
    characteristic subgroups based on information from the data provider.
    Appendix E provides these analyses. More transactions in these data
    were made by households without children than by households with
    children. In addition, a larger proportion of transactions were made at
    retail outlets in metropolitan areas than in rural or suburban areas;
    \35\ at larger stores rather than smaller ones; \36\ and in counties
    with 10-20% poverty rates, the median of the three poverty rate
    categories into which the counties in which the stores were located
    were classified.\37\ Compared to non-SNAP household transactions, SNAP
    household transactions were more likely to be made by households headed
    by adults 19-44 years of age, in stores located in the Midwest, and in
    medium-sized grocery stores. A larger proportion of SNAP household
    transactions than of non-SNAP household transactions took place in the
    most impoverished counties (counties with poverty rates greater than
    20%). Notably, the distribution of transactions by household
    demographic and store characteristics was relatively consistent whether
    SNAP households used SNAP benefits or other resources.
    ---------------------------------------------------------------------------
        \35\ USDA Economic Research Service Urban Influence Codes (http://
    www.ers.usda.gov/data-products/urban-influence-codes.aspx).
        \36\ Following Food Marketing Institute conventions from http://
    www.fmi.org/about/ and http://www.fmi.org/facts--figs/
    ?fuseaction=superfact and FNS Retailer Policy and Management Division
    food retailer definitions from http://www.fns.usda.gov/snap/retailers/
    pdfs/2012-annual-report.pdf.
        \37\ Census Bureau data from http://www.census.gov/did/www/saipe/
    county.html.
    ---------------------------------------------------------------------------
        In addition to analyzing the POS data for the full year, analyses
    were completed at the monthly level to investigate monthly or seasonal
    patterns in purchases. There was little month-to-month variation in
    expenditure patterns for either SNAP or non-SNAP households. A notable
    exception was that for both household types expenditure shares for
    vegetables were 2-3 percentage points lower during the summer months,
    while expenditure shares for fruits were 2-3 percentage points higher
    (data not shown).
    Chapter 4. Findings: Top Expenditures by USDA Food Pattern Categories

    ------------------------------------------------------------------------

    -------------------------------------------------------------------------
    Key Findings

         Overall, there were few differences between SNAP and non-
         SNAP household expenditures by USDA Food Pattern categories.
         Expenditure shares for each of the USDA Food Pattern categories
         (dairy, fruits, grains, oils, protein foods, solid fats and added
         sugars (SoFAS), and vegetables) varied by no more than 3 per
         dollar when comparing SNAP and non-SNAP households.

         Protein foods represented the largest expenditure share for
         both household types, while proportionally more was spent on fruits
         and vegetables than on solid fats and added sugars, grains or
         dairy.
    ------------------------------------------------------------------------

    SNAP and Non-SNAP Household Expenditures by USDA Food Pattern
            Categories

            [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              SNAP Households                    Non-SNAP Households

              Source: Foods Typically Purchased by SNAP Households, IMPAQ
            International, LLC, 2016.
    4.1  Top Expenditures for Dairy
        There are few differences in dairy expenditure patterns between
    SNAP households and non-SNAP households. Shown in Exhibit 8, the top
    four dairy subcommodities for both household groups were identical--
    fluid milk/white only, shredded cheese, American single cheese, and
    natural cheese chunks. These top four accounted for 60% of all dairy
    expenditures for SNAP households and 47% for non-SNAP households. The
    biggest driver of the proportional difference was the purchase of fluid
    milk/white only. Fluid white milk was the top subcommodity representing
    33% of all dairy expenditures by SNAP households. In comparison, this
    subcommodity accounted for 26% of non-SNAP household dairy
    expenditures. Overall, 23 dairy subcommodities in the top 25 for SNAP
    households were also among the top 25 for non-SNAP households. The top
    25 dairy subcommodities for SNAP households represented almost all
    dairy expenditures, 93%, while these 25 subcommodities represented 85%
    of dairy expenditures for non-SNAP households.

                            Exhibit 8: Top 25 SNAP Household Dairy Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
             Dairy Subcommodity                        $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/White Only                        1      $191.1          33.25%         1      $853.8          25.69%
    Shredded Cheese                              2       $74.7          13.00%         2      $342.0          10.29%
    American Single Cheese                       3       $44.1           7.67%         4      $136.6           4.11%
    Natural Cheese Chunks                        4       $35.3           6.14%         3      $216.1           6.50%
    Bagged Cheese Snacks                         5       $17.1           2.98%        16       $52.0           1.56%
    Flavored Fluid Milk                          6       $16.0           2.78%        14       $59.4           1.79%
    String Cheese                                7       $15.1           2.63%         9       $99.0           2.98%
    Yogurt/Kids                                  8       $14.0           2.44%        20       $42.4           1.28%
    Cottage Cheese                               9       $13.9           2.42%         7      $108.8           3.27%
    Natural Cheese Slices                       10       $13.4           2.33%         6      $113.2           3.41%
    Yogurt/Single Serving Regular               11       $11.0           1.91%        11       $69.0           2.07%
    Loaf Cheese                                 12       $10.9           1.90%        23       $38.1           1.15%
    Yogurt/Single Serve Light                   13       $10.2           1.78%         8      $103.1           3.10%
    Yogurt/Pro Active Health                    14        $7.4           1.29%        13       $63.5           1.91%
    Yogurt/Adult Multi-Packs                    15        $7.2           1.25%        19       $42.5           1.28%
    Specialty/Lactose Free Milk                 16        $6.7           1.17%        17       $48.4           1.46%
    Grated Cheese                               17        $6.2           1.08%        25       $33.6           1.01%
    Bulk Semi-Hard (Cheese)                     18        $6.1           1.05%        18       $44.0           1.32%
    Fluid Milk                                  19        $5.9           1.02%         5      $113.3           3.41%
    Canned Milk                                 20        $5.5           0.96%        27       $27.9           0.84%
    Yogurt/Specialty Greek                      21        $5.0           0.86%        10       $77.4           2.33%
    Half & Half                                 22        $4.4           0.77%        15       $54.6           1.64%
    Yogurt/Large Size (16oz or More)            23        $4.4           0.76%        22       $40.4           1.22%
    Miscellaneous Cheese                        24        $3.8           0.67%        21       $42.1           1.27%
    Bulk Processed (Cheese)                     25        $3.4           0.59%        29       $19.8           0.60%
                                                   ----------------------------          ---------------------------
      Sum of Listed Dairy Expenditures                  $532.9          92.70%              $2,841.0          85.49%
                                                   ============================          ===========================
        Total Dairy Expenditures Among                  $571.2            100%              $3,257.4            100%
         Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 dairy subcommodities for SNAP households and the corresponding ranking of these
      subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    4.2  Top Expenditures for Fruits
        The top 25 fruit subcommodities by expenditure for SNAP households
    included whole fruits as well as 100% fruit juices, as shown in Exhibit
    9 below. The top fruit subcommodity for both SNAP and non-SNAP
    households was 100% orange juice. This top fruit subcommodity
    represented 10% of all SNAP household fruit expenditures, 9% for non-
    SNAP households. Bananas and strawberries rank second and third,
    respectively, for both household groups. Together, the top three fruit
    subcommodities account for about \1/4\ (24%) of the fruit expenditures
    for both SNAP and non-SNAP households. The top 25 SNAP household fruit
    subcommodities accounted for 71% of all SNAP household fruit
    expenditures. These 25 subcommodities accounted for 66% of fruit
    expenditures for non-SNAP households. Twenty-one of the top 25 fruit
    subcommodities for SNAP households were also in the top 25 for non-SNAP
    households.

                            Exhibit 9: Top 25 SNAP Household Fruit Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
             Fruit Subcommodity                        $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    100% Pure Juice--Orange; Dairy Case          1       $43.5          10.18%         1      $269.0           9.35%
    Bananas                                      2       $34.2           8.00%         2      $242.7           8.43%
    Strawberries                                 3       $23.5           5.48%         3      $178.4           6.20%
    Fruit Snacks                                 4       $17.6           4.13%        17       $43.2           1.50%
    Grapes Red                                   5       $15.8           3.70%         4      $121.7           4.23%
    Grapes White                                 6       $15.5           3.61%         6       $84.9           2.95%
    Apple Juice & Cider (Over 50% Pure           7       $13.3           3.11%        14       $45.8           1.59%
     Juice)
    Instore Cut Fruit                            8       $13.2           3.09%         5       $85.8           2.98%
    Oranges Navels                               9       $12.6           2.94%         8       $79.3           2.75%
    Fruit Cup                                   10       $10.6           2.47%        19       $42.7           1.49%
    Blended Juice & Combinations                11        $9.3           2.17%        29       $29.6           1.03%
    Clementines                                 12        $8.8           2.06%         9       $78.6           2.73%
    Melons Instore Cut                          13        $8.2           1.93%        18       $42.8           1.49%
    Watermelon Seedless Whole                   14        $7.9           1.84%        16       $43.9           1.53%
    Cherries Red                                15        $6.9           1.61%        11       $56.7           1.97%
    Apples Gala (Bulk & Bag)                    16        $6.6           1.54%        10       $69.3           2.41%
    Cranapple/Cran Grape Juice                  17        $6.1           1.43%        31       $27.3           0.95%
    Apples Red Delicious (Bulk & Bag)           18        $5.8           1.35%        23       $35.2           1.22%
    100% Pure Juice--Other; Dairy Case          19        $5.4           1.26%        25       $32.3           1.12%
    Cantaloupe Whole                            20        $5.3           1.24%        15       $44.4           1.54%
    Blueberries                                 21        $5.1           1.19%         7       $79.4           2.76%
    Pineapple                                   22        $4.9           1.15%        33       $24.0           0.83%
    Peaches Yellow Flesh                        23        $4.8           1.13%        22       $35.6           1.24%
    Grape Juice (Over 50% Juice)                24        $4.8           1.12%        44       $17.1           0.60%
    Lemons                                      25        $4.6           1.08%        24       $33.6           1.17%
                                                   ----------------------------          ---------------------------
      Sum of Listed Fruit Expenditures                  $294.3          68.81%              $1,843.4          64.06%
                                                   ============================          ===========================
        Total Fruit Expenditures Among                  $416.8            100%              $2,772.4            100%
         Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 fruit subcommodities for SNAP households and the corresponding rankings of
      these subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    4.3  Top Expenditures for Grains
        Exhibit 10 details the top 25 grain subcommodities purchased by
    SNAP households. Cereals are a popular purchase among grain
    subcommodities for both SNAP and non-SNAP households. The top grain
    subcommodity for SNAP households was kids cereal, representing almost
    10% of all grain expenditures. Kids cereal, ranked third for non-SNAP
    households. All family cereal was ranked first for non-SNAP households
    and fifth for SNAP households. Adult cereals were also common purchases
    ranking sixth for SNAP households and fourth for non-SNAP households.
    The top 25 grain subcommodities purchased by SNAP households made up
    67% of their grain expenditures. Comparatively, these 25 subcommodities
    comprised 57% of expenditures on grains subcommodities for non-SNAP
    households. Ninteen subcommodities in the top 25 for SNAP households
    were also among the top 25 for non-SNAP households.

                           Exhibit 10: Top 25 SNAP Household Grains Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
             Grains Subcommodity                       $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Kids Cereal                                  1       $78.1           9.88%         3      $186.4           4.51%
    Mainstream White Bread                       2       $48.0           6.07%         7      $136.8           3.31%
    Tortilla/Nacho Chips                         3       $47.4           5.99%         2      $209.0           5.05%
    Mainstream Variety Breads                    4       $38.4           4.86%         5      $173.2           4.19%
    All Family Cereal                            5       $36.2           4.58%         1      $214.9           5.20%
    Adult Cereal                                 6       $24.9           3.15%         4      $182.6           4.42%
    Mexican Soft Tortillas and Wraps             7       $23.7           3.00%         8      $113.1           2.74%
    Waffles/Pancakes/French Toast                8       $17.3           2.19%        13       $77.4           1.87%
    Ramen Noodles/Ramen Cups                     9       $16.7           2.12%        43       $28.1           0.68%
    Cheese Crackers                             10       $16.5           2.08%        10       $90.2           2.18%
    Hamburger Buns                              11       $16.2           2.05%        14       $70.2           1.70%
    Hot Dog Buns                                12       $16.2           2.05%        18       $62.2           1.50%
    Refrigerated Biscuits                       13       $14.7           1.86%        30       $45.2           1.09%
    Butter Spray Crackers                       14       $14.6           1.85%        15       $68.7           1.66%
    Toaster Pastries                            15       $14.0           1.77%        27       $47.6           1.15%
    Rice Side Dish Mixes Dry                    16       $14.0           1.76%        28       $46.7           1.13%
    Popcorn--Microwave                          17       $13.1           1.65%        17       $63.4           1.53%
    Long Cut Pasta                              18       $13.0           1.64%        19       $60.4           1.46%
    Granola Bars                                19       $12.8           1.61%        11       $88.9            .15%
    Premium Bread                               20       $12.3           1.55%         6      $144.7           3.50%
    Cereal Bars                                 21       $10.9           1.38%        12       $78.4           1.90%
    Short Cut Pasta                             22        $9.9           1.25%        21       $56.2           1.36%
    Rolls: Dinner                               23        $9.5           1.21%        23       $50.5           1.22%
    Frozen Garlic Toast                         24        $9.1           1.16%        44       $27.8           0.67%
    Corn Chips                                  25        $9.1           1.15%        29       $45.6           1.10%
                                                   ----------------------------          ---------------------------
      Sum of Listed Grain Expenditures                  $536.6          67.86%              $2,368.4          57.27%
                                                   ============================          ===========================
        Total Grain Expenditures Among                  $783.8            100%              $4,049.9            100%
         Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 grain subcommodities for SNAP households and the corresponding ranking of these
      subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    4.4  Top Expenditures for Oils
        The top oils subcommodity expenditures are shown in Exhibit 11.
    Pourable salad dressings was the top oils subcommodity by expenditure
    for both SNAP and non-SNAP households, accounting for nearly \1/4\ of
    their total expenditures on oils. The second and third ranked oils
    subcommodities, mayonnaise/whipped dressing and margarine in tubs and
    bowls, were the same for both household groups, as well.

                                       Exhibit 11: Oils Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
              Oils Subcommodity                        $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Pourable Salad Dressings                     1       $29.0          22.71%         1      $139.4          24.28%
    Mayonnaise and Whipped Dressing              2       $27.3          21.34%         2      $119.1          20.73%
    Margarine: Tubs and Bowls                    3       $23.4          18.37%         3      $100.9          17.56%
    Vegetable Oils                               4       $20.5          16.07%         5       $35.4           6.16%
    Canola Oils                                  5        $8.3           6.49%         6       $29.3           5.10%
    Olive Oils                                   6        $7.3           5.69%         4       $63.8          11.11%
    Cooking Sprays                               7        $3.2           2.49%         7       $21.0           3.65%
    Dressing Creamy                              8        $1.6           1.23%         8       $14.5           2.53%
    Sandwich/Horseradish and Tartar              9        $1.4           1.14%        10        $7.2           1.26%
     Sauce
    Corn Oils                                   10        $1.3           1.01%        14        $4.1           0.71%
    Cooking Oils: Peanut/Safflower              11        $1.1           0.89%        11        $6.7           1.17%
    Dressing Blue Cheese                        12        $0.9           0.71%         9        $9.5           1.65%
    Margarine: Squeeze                          13        $0.6           0.44%        13        $4.2           0.74%
                                                   ----------------------------          ---------------------------
      Sum of Listed Oils Expenditures                   $125.9          98.58%                $555.0          96.65%
                                                   ============================          ===========================
        Total Oils Expenditures Among                   $125.9            100%                $555.0            100%
         the Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The data included only 13 oils subcommodities in the top 1,000 subcommodities. Columns may not sum to
      total shown due to rounding.

    4.5  Top Expenditures for Protein Foods
        The top 25 protein foods subcommodities based on expenditures of
    SNAP households are shown in Exhibit 12. For SNAP households, the top
    25 represented over \1/2\ (54%) of all protein foods expenditures.
    These same 25 subcommodities comprised 48% of the protein foods
    expenditures for non-SNAP households. The top five subcommodities were
    the same for both household groups, although in slightly different
    order and accounted for \1/5\ of all protein expenditures for both
    households. The protein foods included in the top five were beef,
    lunchmeat, eggs and chicken. Lean ground beef was the top protein foods
    subcommodity by expenditure for SNAP households, totaling just over 7%
    of all protein foods expenditures. The top protein foods subcommodity
    for non-SNAP households was boneless chicken breasts at 5% of their
    expenditures. Eighteen of the SNAP household top 25 subcommodities were
    also ranked in the top 25 for non-SNAP households.

                        Exhibit 12: Top 25 SNAP Household Protein Foods Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
         Protein Foods Subcommodity                    $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Lean Ground Beef                             1      $112.4           7.38%         2      $257.9           4.03%
    Primal Ground Beef                           2       $62.4           4.10%         5      $219.8           3.43%
    Lunchmeat--Deli Fresh                        3       $55.8           3.67%         4      $242.6           3.79%
    Eggs--Large                                  4       $52.1           3.43%         3      $251.6            .93%
    Chicken Breast Boneless                      5       $49.6           3.26%         1      $292.9           4.57%
    Enhanced Pork Boneless Loin/Rib              6       $41.5           2.73%         6      $168.0           2.62%
    Bacon--Trad 16oz Or Less                     7       $40.7           2.68%         8      $157.6           2.46%
    Ribs (Pork)                                  8       $35.0           2.30%        15      $106.8           1.67%
    Frozen Chicken--White Meat                   9       $30.0           1.97%        17       $99.8           1.56%
    Choice Beef (Loins)                         10       $28.4           1.87%        11      $136.6           2.13%
    Select Beef                                 11       $27.9           1.83%         9      $143.7           2.24%
    Hot Dogs--Base Meat                         12       $25.1           1.65%        27       $56.8           0.89%
    Choice Beef (Rounds)                        13       $24.0           1.58%        20       $72.5           1.13%
    Chicken Wings                               14       $22.2           1.46%        58       $28.6           0.45%
    Frozen Chicken--Wings                       15       $22.2           1.46%        97       $17.4           0.27%
    Lunchmeat--Bologna/Sausage                  16       $21.8           1.43%        24       $60.9           0.95%
    Tuna                                        17       $21.1           1.39%        14      $109.9           1.72%
    Peanut Butter                               18       $20.4           1.34%        12      $127.8           1.99%
    Meat: Turkey Bulk                           19       $19.3           1.27%         7      $159.6           2.49%
    Frozen Meat--Beef                           20       $19.0           1.25%        34       $46.3           0.72%
    Value Forms/18oz & Larger                   21       $18.6           1.22%        41       $42.6           0.67%
    Chicken Drumsticks                          22       $17.3           1.14%        49       $31.5           0.49%
    Angus Beef                                  23       $17.1           1.13%        16      $103.8           1.62%
    Dinner Sausage--Links Pork Ckd              24       $16.4           1.08%        45       $37.6           0.59%
    Meat: Ham Bulk                              25       $15.3           1.00%        13      $115.9           1.81%
                                                   ----------------------------          ---------------------------
      Sum of Listed Protein Foods                       $815.7          53.62%              $3,088.3          48.22%
       Expenditures
                                                   ============================          ===========================
        Total Protein Foods Expenditures              $1,512.2            100%              $6,288.8            100%
         Among Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 protein foods subcommodities for SNAP households and the corresponding ranking
      of these subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    4.6  Top Expenditures for Solid Fats and Added Sugars (SoFAS)
        The top 25 SoFAS subcommodities by expenditure for SNAP households
    are shown in Exhibit 13. Twenty two subcommodities in the top 25 for
    SNAP households were also among the top 25 for non-SNAP households. In
    addition, the top two subcommodities were the same. They were
    carbonated soft drinks packaged as 12-18 pack cans and 2-liter bottles.
    These two subcommodities represented approximately \1/4\ of the SoFAS
    expenditures for both types of households. Sugar, ranked fourth, was
    the highest ranked non-beverage SoFAS subcommodity for SNAP households.
    It was eighth ranked for non-SNAP households. Butter ranked higher
    (third) for non-SNAP households compared to tenth for SNAP households.
    Overall, the top 25 SNAP household SoFAS subcommodities in Exhibit 13
    totaled 75% of SNAP household SoFAS expenditures. These 25
    subcommodities totaled 71% of the SoFAS expenditures for non-SNAP
    households.

             Exhibit 13: Top 25 SNAP Household Solid Fats and Added Sugars (SoFAS) Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
     Solid Fats and Added Sugars (SoFAS) ---------------------------------------------------------------------------
                Subcommodity                           $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Soft Drinks 12/18 & 15pk Can Car             1      $164.6          18.86%         1      $601.2          16.11%
    Soft Drinks 2 Liter Btl Carb Incl            2       $70.9           8.12%         2      $230.1           6.17%
    Soft Drinks 20pk & 24pk Can Carb             3       $39.7           4.55%         9      $106.4           2.85%
    Sugar                                        4       $36.9           4.23%         8      $112.7           3.02%
    Soft Drink Mlt-Pk Btl Carb                   5       $34.0           3.90%         4      $173.6           4.65%
    Soft Drink Single Serve Btl Carb             6       $27.8           3.18%        11       $71.4           1.91%
    Aseptic Pack Juice And Drinks                7       $24.2           2.78%        16       $57.1           1.53%
    Refrigerated Coffee Creamers                 8       $24.1           2.76%         6      $147.2           3.95%
    Candy Bags-Chocolate                         9       $21.5           2.46%         5      $147.5           3.95%
    Butter                                      10       $19.6           2.24%         3      $175.6           4.71%
    Sour Creams                                 11       $17.5           2.00%        10       $95.2           2.55%
    Cream Cheese                                12       $17.2           1.97%         7      $115.5           3.10%
    Candy Bars (Singles)                        13       $16.3           1.87%        18       $54.9           1.47%
    Dairy Case Juice Drink Under 10 Oz          14       $16.0           1.83%        22       $48.0           1.29%
    Candy Bars (Multi Pack)                     15       $15.6           1.79%        12       $69.6           1.86%
    Tea Sweetened                               16       $13.9           1.59%        13       $68.7           1.84%
    Chewing Gum                                 17       $13.2           1.51%        14       $68.3           1.83%
    Candy Bags-Non Chocolate                    18       $12.6           1.44%        19       $54.9           1.47%
    Molasses and Syrups                         19       $11.7           1.34%        15       $58.7           1.57%
    Dairy Case Citrus Punch/OJ Subs             20       $11.0           1.26%        27       $34.4           0.92%
    Fruit Drinks: Canned & Glass                21       $10.6           1.21%        60       $10.9           0.29%
    Non Dairy Creamer                           22       $10.5           1.20%        25       $35.4           0.95%
    Seasonal Miscellaneous                      23        $9.2           1.05%        23       $46.9           1.26%
    Dairy Case Tea With Sugar                   24        $8.4           0.96%        36       $23.1           0.62%
    Seasonal Candy Bags-Chocolate               25        $7.9           0.90%        20       $54.8           1.47%
                                                   ----------------------------          ---------------------------
      Sum of Listed SoFAS Expenditures                  $655.0          75.00%              $2,662.3          71.34%
                                                   ============================          ===========================
        Total SoFAS Expenditures Among                  $864.1            100%              $3,673.1            100%
         Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 SoFAS subcommodities for SNAP households and the corresponding ranking of these
      subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

        SoFAS were divided into three broad subcategories to inform the
    analyses: butter/cream/solid fats, candy/sweets, and sweetened
    beverages.\38\ The distribution of these subcategories for both
    household types is shown in Exhibit 14. As a share of total SoFAS
    expenditures, sweetened beverage expenditures were more than ten
    percentage points higher in SNAP households than non-SNAP households.
    In contrast, non-SNAP households spent a larger share of their SoFAS
    expenditures on the butter/cream/solid fats and candy/sweets
    subcategories.
    ---------------------------------------------------------------------------
        \38\ Fruit drinks that are over 50% juice are categorized as
    fruits. All other fruit drinks are categorized as SoFAS. In our
    discussion, fruit drinks that are less than 50% juice are grouped into
    ``sweetened beverages.''
    ---------------------------------------------------------------------------
    Exhibit 14: Solid Fats and Added Sugars (SoFAS) Expenditures by
            Subcategory

            [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              SNAP Households                    Non-SNAP Households

              Source: Foods Typically Purchased by SNAP Households, IMPAQ
            International, LLC, 2016.
    4.7  Top Expenditures for Vegetables
        As shown in Exhibit 15, russet potatoes and plain frozen bag
    vegetables were the top two vegetable subcommodities by expenditure
    purchased by SNAP and non-SNAP households. Overall, 18 of the top 25
    vegetable subcommodities for SNAP households were among the top 25 for
    non-SNAP households. The top 25 SNAP household subcommodities comprised
    56% of total vegetable expenditures for SNAP households. These same 25
    subcommodities comprised 47% of total vegetable expenditures for non-
    SNAP households. The top 25 subcommodities for both SNAP and non-SNAP
    households for this Food Pattern category included a range of
    vegetables such as potatoes, avocados, green beans, corn, lettuce and
    cucumbers to name a few.

                         Exhibit 15: Top 25 SNAP Household Vegetables Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
           Vegetables Subcommodity                     $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Potatoes Russet (Bulk & Bag)                 1       $35.8           6.74%         1      $154.5           4.60%
    Frozen Bag Vegetables--Plain                 2       $25.7           4.85%         2      $131.9           3.93%
    Mainstream Pasta & Pizza Sauce               3       $23.0           4.33%         6       $81.0           2.41%
    Frozen French Fries                          4       $20.5           3.86%        19       $50.3           1.50%
    Avocado                                      5       $13.4           2.52%         4      $112.6           3.35%
    Blends Salad Mix                             6       $13.1           2.47%         3      $124.0           3.69%
    Green Beans: Fs/Whl/Cut                      7       $12.8           2.41%        15       $53.1           1.58%
    Potatoes: Dry                                8       $12.3           2.31%        33       $32.3           0.96%
    Corn                                         9       $12.1           2.28%        22       $44.0           1.31%
    Head Lettuce                                10       $11.6           2.18%        13       $55.5           1.65%
    Frozen Steamable Vegetables                 11       $10.5           1.98%         5       $81.4           2.42%
    Mexican Sauces and Picante Sauce            12       $10.2           1.93%         9       $62.3           1.85%
    Tomatoes Diced                              13        $9.5           1.79%        11       $59.9           1.78%
    Tomatoes Hothouse On The Vine               14        $9.2           1.74%         7       $77.7           2.31%
    Onions Yellow (Bulk & Bag)                  15        $8.7           1.65%        27       $39.3           1.17%
    Cucumbers                                   16        $8.2           1.55%        12       $58.9           1.75%
    Vegetable Salads--Prepack                   17        $7.8           1.48%        29       $36.6           1.09%
    Peppers Green Bell                          18        $7.8           1.47%        25       $41.5           1.24%
    Regular Garden                              19        $7.8           1.46%        35       $31.9           0.95%
    Roma Tomatoes (Bulk/Pkg)                    20        $7.5           1.41%        26       $39.6           1.18%
    Carrots Mini Peeled                         21        $7.0           1.32%        10       $61.4           1.83%
    Onions Sweet (Bulk & Bag)                   22        $6.2           1.16%        20       $47.4           1.41%
    Celery                                      23        $5.9           1.11%        17       $51.2           1.52%
    Tomatoes Vine Ripe Bulk                     24        $5.7           1.07%        51       $22.5           0.67%
    Garden Plus Salad Mix                       25        $5.5           1.03%        36       $31.8           0.95%
                                                   ----------------------------          ---------------------------
      Sum of Listed Vegetable                           $297.7          56.10%              $1,582.6          47.10%
       Expenditures
                                                   ============================          ===========================
        Total Vegetable Expenditures                    $520.5            100%              $3,251.8            100%
         Among Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 vegetable subcommodities for SNAP households and the corresponding ranking of
      these subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

    4.8  Top Expenditures for Composite Foods
        Composite foods include those subcommodities that contain more than
    one USDA Food Pattern category. As a result, they could not be assigned
    specifically to a single category. For example, composite foods include
    both dairy and grains (macaroni and cheese), dairy and SoFAS (ice
    cream), vegetables and oils (potato chips), or protein foods,
    vegetables and grains (frozen meals). The top 25 composite foods
    subcommodities based on the expenditures of SNAP households are
    presented in Exhibit 16. Potato chips were the top composite
    subcommodity by expenditure for SNAP households, representing 5% of
    their overall expenditures on composite items. Potato chips were ranked
    second for non-SNAP households. Overall, expenditures on composite
    subcommodities were similar for SNAP and non-SNAP households with 19
    subcommodities in the top 25 for both groups. The top 25 SNAP household
    subcommodities shown in Exhibit 16 represented 58% of all SNAP
    household composite foods expenditures, while expenditures on these 25
    subcommodities by non-SNAP households accounted for 51% of their total
    composite foods expenditures.

                          Exhibit 16: Top 25 SNAP Household Composite Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
           Composite Subcommodity                      $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Potato Chips                                 1       $64.4           5.19%         2      $253.2           4.88%
    Snacks/Appetizers                            2       $44.6           3.59%        10      $100.5           1.94%
    Frozen Single Serve Premium                  3       $43.8           3.53%         4      $175.4           3.38%
     Traditional Meals
    Snack Cake--Multi Pack                       4       $41.6           3.36%         9      $101.7           1.96%
    Frozen Single Serve Economy Meals            5       $40.9           3.30%        15       $80.7           1.56%
    Pizza/Premium                                6       $39.7           3.20%         6      $153.3           2.95%
    Sandwiches and Handhelds                     7       $35.9           2.89%        17       $73.6           1.42%
    Convenient Meals--Kids Meal                  8       $34.2           2.76%        19       $69.7           1.34%
    Premium (Ice Cream & Sherbert)               9       $31.2           2.52%         3      $226.0           4.35%
    Condensed Soup                              10       $29.7           2.39%         5      $153.6           2.96%
    Frozen Family Style Entrees                 11       $27.6           2.23%        13       $83.5           1.61%
    Traditional                                 12       $25.6           2.07%         8      $118.7           2.29%
    Frozen Single Serve Premium                 13       $24.7           1.99%         1      $271.6           5.23%
     Nutritional Meals
    Macaroni and Cheese Dinners                 14       $24.3           1.96%        24       $59.7           1.15%
    Can Pasta                                   15       $22.2           1.79%        36       $47.7           0.92%
    Multi-Pack Bag Snacks                       16       $21.6           1.74%        38       $43.4           0.84%
    Sweet Goods: Donuts                         17       $21.3           1.72%        14       $82.3           1.58%
    Pizza/Economy                               18       $19.8           1.60%        37       $45.1           0.87%
    Frozen Breakfast Sandwiches                 19       $19.1           1.54%        29       $55.7           1.07%
    Frozen Skillet Meals                        20       $18.8           1.51%        16       $79.3           1.53%
    Cakes: Birthday/Celebration                 21       $18.6           1.50%        33       $50.3           0.97%
    Sandwich Cookies                            22       $18.0           1.45%        18       $71.8           1.38%
    Pizza/Traditional                           23       $17.9           1.44%        22       $64.1           1.24%
    Rts Soup: Chunky/Homestyle                  24       $17.6           1.42%         7      $119.9           2.31%
    Salsa and Dips                              25       $17.1           1.38%        28       $57.0           1.10%
                                                   ----------------------------          ---------------------------
      Sum of Listed Composite                           $720.5          58.07%              $2,637.7          50.83%
       Expenditures
                                                   ============================          ===========================
        Total Composite Expenditures                  $1,235.4            100%              $5,132.0            100%
         Among Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 composite subcommodities for SNAP households and the corresponding ranking of
      these subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

        The composite subcommodities were further categorized as snacks,
    soups, desserts, and entree/meal items to inform the analyses. Exhibit
    17 suggests some differences in SNAP and non-SNAP household expenditure
    distributions on these subgroups. SNAP households spent a larger share
    of their composite expenditures on entree/meal subcommodities, while
    non-SNAP households spent larger shares on desserts and soup.
    Expenditures on snacks were not very different across the two groups.
    Exhibit 17: Composite Expenditures by Subcategory

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              SNAP Households                    Non-SNAP Households

              Source: Foods Typically Purchased by SNAP Households, IMPAQ
            International, LLC, 2016.
    4.9  Top Expenditures for Other Subcommodities
        Some subcommodities did not contain any USDA Food Pattern
    categories, or the subcommodity labels were not descriptive enough to
    permit categorization even with the addition of the composite category.
    As a result, a ninth category, other, was created to capture such
    subcommodities. ``Other'' included subcommodities such as water,
    isotonic drinks, and baby food. The top 25 other subcommodities based
    on the expenditures of SNAP households are shown in Exhibit 18 and
    accounted for 66% of their overall other subcommodity expenditures.
    These subcommodities accounted for 54% of all other expenditures for
    non-SNAP households. Overall, expenditures on other subcommodities were
    similar for SNAP and non-SNAP households with 19 subcommodities in
    common in the top 25 for both groups. The top other subcommodity
    purchased by SNAP households was infant formula/starter solution,
    accounting for almost 10% of the total SNAP household expenditures on
    these items. Subcommodities reflecting drinking water and coffee were
    ranked second and third, respectively. Coffee subcommodities were
    ranked first and third for non-SNAP households with the same water
    subcommodity that was ranked second for SNAP households ranked second
    for non-SNAP households, as well. Interestingly, infant formula/starter
    solution that was ranked first for SNAP households was ranked 14th for
    non-SNAP households.

                            Exhibit 18: Top 25 SNAP Household Other Subcommodity Expenditures
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
             Other Subcommodity                        $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Infant Formula/Starter Solution              1       $54.2           9.60%        14       $45.3           1.70%
    Still Water Drinking/Mineral Water           2       $48.8           8.64%         2      $187.7           7.03%
    Unflavored Can Coffee                        3       $41.3           7.32%         1      $198.0           7.41%
    Isotonic Drinks Single Serve                 4       $30.5           5.40%         4      $119.5           4.47%
    Spring Water                                 5       $16.2           2.87%         5       $95.6           3.58%
    Traditional Spices                           6       $14.1           2.49%         8       $61.2           2.29%
    Bbq Sauce                                    7       $12.3           2.17%        16       $38.6           1.45%
    Baby Food--Beginner                          8       $11.7           2.07%        21       $28.1           1.05%
    Non-Carb Water Flavor--Drink/Mnr             9       $11.6           2.05%         7       $63.4           2.37%
    Catsup                                      10       $11.5           2.03%        15       $41.5           1.55%
    Sauce Mixes/Gravy Mixes Dry                 11       $11.5           2.03%        13       $46.7           1.75%
    Baby Food Junior/All Brands                 12       $11.2           1.98%        22       $27.5           1.03%
    Isotonic Drinks Multi-Pack                  13       $10.8           1.92%         9       $58.1           2.17%
    Ice--Crushed/Cubed                          14        $9.3           1.65%        11       $49.9           1.87%
    Unflavored Bag Coffee                       15        $8.5           1.50%         3      $137.3           5.14%
    Infant Formula Specialty                    16        $8.4           1.49%        71        $9.1           0.34%
    Infant Formula Starter Large                17        $8.3           1.46%        30       $22.8           0.85%
    Steak & Worchester Sauce                    18        $8.2           1.44%        25       $26.7           1.00%
    Unflavored Instant Coffee                   19        $7.6           1.34%        23       $27.3           1.02%
    Non-Dairy Milk                              20        $7.1           1.25%         6       $67.7           2.53%
    Unsweetened Envelope (Powder Drink          21        $7.0           1.25%        88        $6.2           0.23%
     Mix)
    Malted Milk/Syrup/Powders/Eggnog            22        $6.9           1.23%        28       $25.3           0.95%
    Still Water Flavored Drink/Mineral          23        $6.3           1.11%        17       $38.1           1.43%
     Water
    Infant Formula Toddler                      24        $6.0           1.06%        55       $12.4           0.46%
    Mexican Seasoning Mixes                     25        $5.9           1.05%        33       $20.6           0.77%
                                                   ----------------------------          ---------------------------
      Sum of Listed Other Expenditures                  $374.8          66.40%              $1,454.7          54.44%
                                                   ============================          ===========================
        Total Other Expenditures Among                  $550.7            100%              $2,533.2            100%
         Top 1,000 Subcommodities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: The table lists the top 25 ``other'' subcommodities for SNAP households and the corresponding ranking of
      these subcommodities for non-SNAP households. Columns may not sum to total shown due to rounding.

        All other subcommodities were divided into the following six
    subcategories for additional analysis: condiments; infant formula/baby
    food; seasoning/baking needs; supplements/meal replacements/energy
    drinks; unsweetened beverages; and miscellaneous. Exhibit 19 shows that
    SNAP households spent a notably larger share--about 15 percentage
    points more than non-SNAP households--on infant formulas and baby foods
    in these data. Non-SNAP households spent a larger share on unsweetened
    beverages.
    Exhibit 19: Other Expenditures by Subcategory

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              SNAP Households                    Non-SNAP Households

              Source: Foods Typically Purchased by SNAP Households, IMPAQ
            International, LLC, 2016.
    Chapter 5. Conclusion
        IMPAQ analyzed point-of-sale transaction data from January 1, 2011
    through December 31, 2011 from a leading grocery retailer to understand
    what food items are typically purchased by SNAP households and how
    these purchases compare to those made by non-SNAP households. The
    majority of stores from which the data came would be classified as
    grocery stores, supermarkets, and combination food and drug stores per
    FNS Retailer Policy and Management Division food retailer
    definitions.\39\ Expenditures on SNAP-eligible food items were examined
    at four levels: by USDA Food Pattern categories, summary categories,
    commodities, and subcommodities, as shown in Exhibit 20.
    ---------------------------------------------------------------------------
        \39\ Stores that opened or closed during 2011 were not included in
    these analyses.
    ---------------------------------------------------------------------------
        Overall, the findings from this study indicate that SNAP households
    and non-SNAP households purchased similar foods in the retail outlets
    in these data. The findings hold true after assessing food expenditure
    patterns of SNAP and non-SNAP households using multiple categorization
    methods. Both groups of households spent about 40 of every dollar of
    food expenditures on basic items such as meat, fruits, vegetables,
    milk, eggs, and bread. Another 20 out of every dollar was spent on
    sweetened beverages, desserts, salty snacks, candy and sugar. The
    remaining 40 were spent on a variety of items such as cereal, prepared
    foods, dairy products, rice, and beans.

        Exhibit 20: SNAP and Non-SNAP Household Food Expenditure Patterns
    ------------------------------------------------------------------------
            Finding             SNAP Households        Non-SNAP  Households
    ------------------------------------------------------------------------
    Total annual            $6.7 billion             $32.3 billion
     expenditures on SNAP-
     eligible foods in
     dataset
    Percentage of all       12%                      88%
     transactions by all
     households
    Percentage of total     17%                      83%
     annual expenditures
     by all households
    Top 1,000 (of 1,792)    99%                      98%
     subcommodity
     expenditures as a
     percentage of all
     expenditures
    Top 100 subcommodity    51%                      46%
     expenditures as a
     percentage of all
     expenditures
    Top 25 subcommodity     25%                      21%
     expenditures as a
     percentage of all
     expenditures
    Top 25 commodity (of    45%                      41%
     238) expenditures as
     a percentage of all
     expenditures
    Top 10 summary          Meat, Poultry and        Meat, Poultry and
     categories (of 30) by   Seafood                  Seafood
     expenditure
                            Sweetened Beverages      Vegetables
                            Vegetables               High-fat Dairy/Cheese
                            Frozen Prepared Foods    Fruits
                            Prepared Desserts        Sweetened Beverages
                            High-fat Dairy/Cheese    Prepared Desserts
                            Bread and Crackers       Bread and Crackers
                            Fruits                   Frozen Prepared Foods
                            Milk                     Milk
                            Salty Snacks             Salty Snacks
    Top 10 commodities (of  Soft Drinks              Fluid Milk Products
     238) by expenditure
                            Fluid Milk Products      Soft Drinks
                            Beef Grinds              Cheese
                            Bag Snacks               Baked Breads
                            Cheese                   Bag Snacks
                            Baked Breads             Beef Grinds
                            Cold Cereal              Cold Cereal
                            Chicken Fresh            Candy--Packaged
                            Frozen Handhelds and     Coffee and Creamers
                             Snacks
                            Lunchmeat                Ice Cream, Ice Milk,
                                                      and Sherbets
    Top 10 subcommodities   Fluid Milk/White Only    Fluid Milk/White Only
     (of 1,792) by
     expenditure
                            Soft Drinks 12-18 pack   Soft Drinks 12-18 pack
                            Lean Beef                Shredded Cheese
                            Kids' Cereal             Chicken Breast--
                                                      Boneless
                            Shredded Cheese          Frozen Premium
                                                      Nutritional Meals
                            2-Liter Soft Drink       Pure Orange Juice--
                                                      Dairy Case
                            Potato Chips             Lean Beef
                            Primal Beef              Potato Chips
                            Lunchmeat--Deli fresh    Large Eggs
                            Infant Formula/Starter   Bananas
                             Solution
    ------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ
      International, LLC, 2016.
    * All SNAP totals represent purchases by SNAP households in the dataset,
      not SNAP dollars.
    In summary, after assessing food expenditure patterns of SNAP households
      and non-SNAP households using multiple categorization methods, both
      household types made similar food expenditures in 2011 from the retail
      outlets included in these data.

    Appendix A: Top Purchases by Expenditure for SNAP and Non-SNAP
            Households

                                              Exhibit A-1: All Commodities
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
                  Commodity                            $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Soft drinks                                  1      $357.7           5.44%         2    $1,263.3           4.01%
    Fluid milk products                          2      $253.7           3.85%         1    $1,270.3           4.03%
    Beef: grinds                                 3      $201.0           3.05%         6      $621.1           1.97%
    Bag snacks                                   4      $199.3           3.03%         5      $793.9           2.52%
    Cheese                                       5      $186.4           2.83%         3      $948.9           3.01%
    Baked breads                                 6      $163.7           2.49%         4      $874.8           2.78%
    Cold cereal                                  7      $139.2           2.12%         7      $583.9           1.85%
    Chicken fresh                                8      $121.4           1.85%        11      $477.8           1.52%
    Frozen handhelds & snacks                    9      $101.5           1.54%        47      $214.6           0.68%
    Lunchmeat                                   10       $99.4           1.51%        17      $386.1           1.23%
    Candy--packaged                             11       $96.2           1.46%         8      $527.7           1.67%
    Infant formula                              12       $95.7           1.45%        80      $124.8           0.40%
    Frozen pizza                                13       $90.2           1.37%        23      $305.7           0.97%
    Refrigerated juices/drinks                  14       $88.5           1.35%        14      $412.8           1.31%
    Ice cream ice milk & sherbets               15       $86.0           1.31%        10      $481.8           1.53%
    Coffee & creamers                           16       $82.3           1.25%         9      $519.4           1.65%
    Cookies                                     17       $78.2           1.19%        16      $408.3           1.30%
    Water--(sparkling & still)                  18       $77.0           1.17%        18      $379.2           1.20%
    Shelf stable juice                          19       $73.1           1.11%        28      $282.2           0.90%
    Eggs/muffins/potatoes                       20       $72.0           1.09%        20      $358.7           1.14%
    Frozen ss premium meals                     21       $68.6           1.04%        12      $447.1           1.42%
    Cakes                                       22       $68.2           1.04%        38      $240.9           0.76%
    Bacon                                       23       $66.1           1.00%        27      $283.2           0.90%
    Traditional Mexican foods                   24       $62.6           0.95%        25      $286.9           0.91%
    Yogurt                                      25       $59.9           0.91%        13      $442.3           1.40%
    Salad dressing & sandwich spreads           26       $59.7           0.91%        30      $280.9           0.89%
    Dinner sausage                              27       $59.3           0.90%        46      $222.6           0.71%
    Frozen prepared chicken                     28       $58.6           0.89%        74      $136.4           0.43%
    Baked sweet goods                           29       $57.5           0.87%        62      $159.6           0.51%
    Beef loins                                  30       $56.3           0.86%        31      $280.3           0.89%
    Chicken frozen                              31       $54.8           0.83%        85      $123.0           0.39%
    Deli meat: bulk                             32       $54.6           0.83%        15      $411.0           1.30%
    Frozen multi serve                          33       $53.0           0.81%        54      $183.5           0.58%
    Dinner mixes--dry                           34       $51.8           0.79%        72      $140.3           0.45%
    Frozen breakfast foods                      35       $51.3           0.78%        55      $180.9           0.57%
    Crackers & misc baked food                  36       $50.9           0.77%        21      $323.7           1.03%
    Frozen novelties--water ice                 37       $50.7           0.77%        43      $229.7           0.73%
    Margarines                                  38       $50.3           0.76%        24      $303.0           0.96%
    Condiments & sauces                         39       $49.8           0.76%        52      $187.2           0.59%
    Potatoes                                    40       $48.8           0.74%        34      $265.2           0.84%
    Frozen vegetable & veg dish                 41       $48.2           0.73%        33      $266.9           0.85%
    Hot dogs                                    42       $45.5           0.69%        63      $158.4           0.50%
    Can vegetables--shelf stable                43       $45.3           0.69%        50      $191.7           0.61%
    Shortening & oil                            44       $44.6           0.68%        57      $174.2           0.55%
    Sugars & sweeteners                         45       $43.3           0.66%        60      $162.4           0.52%
    Isotonic drinks                             46       $42.8           0.65%        53      $185.3           0.59%
    Salad mix                                   47       $42.8           0.65%        22      $319.4           1.01%
    Milk by-products                            48       $42.5           0.65%        32      $268.9           0.85%
    Pork boneless loin/rib                      49       $41.5           0.63%        58      $168.0           0.53%
    Cnv breakfast & wholesome snacks            50       $41.1           0.62%        45      $226.1           0.72%
    Frozen ss economy meals                     51       $40.9           0.62%       109       $80.7           0.26%
    Refrigerated dough products                 52       $40.5           0.62%        56      $176.6           0.56%
    Beef: round                                 53       $40.4           0.61%        75      $134.2           0.43%
    Dry bean veg & rice                         54       $39.9           0.61%        59      $166.1           0.53%
    Convenient meals                            55       $38.7           0.59%       108       $81.0           0.26%
    Tomatoes                                    56       $38.3           0.58%        35      $261.7           0.83%
    Candy--checklane                            57       $37.9           0.58%        64      $154.0           0.49%
    Berries                                     58       $37.4           0.57%        19      $373.5           1.19%
    Grapes                                      59       $36.1           0.55%        39      $235.7           0.75%
    Bananas                                     60       $36.1           0.55%        36      $261.4           0.83%
    Peanut butter/jelly/jams & honey            61       $36.0           0.55%        42      $231.0           0.73%
    Pork thin meats                             62       $35.0           0.53%        93      $106.8           0.34%
    Citrus                                      63       $34.3           0.52%        37      $251.7           0.80%
    Breakfast sausage                           64       $34.2           0.52%        79      $126.7           0.40%
    Dry sauce/gravy/potatoes/stuffing           65       $34.0           0.52%        87      $119.2           0.38%
    Salad & dips                                66       $33.9           0.52%        40      $235.3           0.75%
    Apples                                      67       $33.7           0.51%        29      $281.7           0.89%
    Meat--shelf stable                          68       $33.3           0.51%        91      $109.2           0.35%
    Aseptic juice                               69       $33.1           0.50%       112       $78.9           0.25%
    Sweet goods                                 70       $32.5           0.49%        66      $152.9           0.49%
    Frozen potatoes                             71       $32.2           0.49%        95      $104.5           0.33%
    Meat frozen                                 72       $31.9           0.48%       120       $69.9           0.22%
    Baby foods                                  73       $30.6           0.46%       121       $67.8           0.22%
    Vegetables salad                            74       $30.0           0.46%        44      $228.6           0.73%
    Beef: thin meats                            75       $30.0           0.46%        78      $127.7           0.41%
    Seafood--shrimp                             76       $29.8           0.45%        84      $123.1           0.39%
    Canned soups                                77       $29.7           0.45%        65      $153.6           0.49%
    Baking mixes                                78       $28.3           0.43%        69      $148.1           0.47%
    Pasta & pizza sauce                         79       $27.6           0.42%        99       $96.7           0.31%
    Dry noodles & pasta                         80       $27.5           0.42%        71      $141.5           0.45%
    Can seafood--shelf stable                   81       $26.5           0.40%        77      $132.3           0.42%
    Rts/micro soup/broth                        82       $26.0           0.40%        48      $200.8           0.64%
    Canned pasta & mwv fd-shlf stbl             83       $25.9           0.39%       135       $56.7           0.18%
    Smoked hams                                 84       $25.7           0.39%        92      $108.8           0.35%
    Nuts                                        85       $25.6           0.39%        41      $234.2           0.74%
    Value-added fruit                           86       $25.3           0.38%        70      $146.6           0.47%
    Can beans                                   87       $24.0           0.36%        82      $123.3           0.39%
    Dry/ramen bouillon                          88       $21.7           0.33%       133       $61.0           0.19%
    Powder & crystal drink mix                  89       $21.6           0.33%       119       $75.2           0.24%
    Rtd tea/new age juice                       90       $21.5           0.33%       103       $93.8           0.30%
    Baking needs                                91       $21.3           0.32%        51      $188.9           0.60%
    Can fruit/jar applesauce                    92       $20.9           0.32%        96      $104.0           0.33%
    Spices & extracts                           93       $20.4           0.31%        86      $121.9           0.39%
    Energy drinks                               94       $20.1           0.30%       102       $94.1           0.30%
    Onions                                      95       $20.0           0.30%        81      $123.5           0.39%
    Tropical fruit                              96       $19.8           0.30%        61      $160.1           0.51%
    Bagels & cream cheese                       97       $19.8           0.30%        83      $123.2           0.39%
    Frozen bread/dough                          98       $19.7           0.30%       114       $77.7           0.25%
    Rolls                                       99       $18.9           0.29%        88      $113.9           0.36%
    Hot cereal                                 100       $18.9           0.29%       100       $96.1           0.30%
    Tomato products-shelf stable               101       $18.8           0.29%        90      $112.5           0.36%
    Bread                                      102       $18.7           0.28%        49      $194.7           0.62%
    Frozen desserts                            103       $18.7           0.28%       107       $82.9           0.26%
    Chicken & poultry                          104       $18.7           0.28%       140       $50.3           0.16%
    Refrigerated dairy case                    105       $18.6           0.28%        26      $284.7           0.90%
    Dry cheese                                 106       $18.5           0.28%       111       $79.1           0.25%
    Stone fruit                                107       $18.3           0.28%        73      $138.6           0.44%
    Molasses/syrups/pancake mixes              108       $17.9           0.27%       110       $80.6           0.26%
    Peppers                                    109       $17.7           0.27%        76      $133.4           0.42%
    Fruit snacks                               110       $17.6           0.27%       152       $43.2           0.14%
    Vegetables cooking bulk                    111       $17.3           0.26%        68      $150.6           0.48%
    Sandwiches                                 112       $16.9           0.26%       124       $67.7           0.21%
    Service case meat                          113       $16.8           0.26%        97      $101.4           0.32%
    Melons                                     114       $16.7           0.25%        89      $113.2           0.36%
    Popcorn                                    115       $15.3           0.23%       117       $76.6           0.24%
    Warehouse snacks                           116       $14.7           0.22%       125       $67.1           0.21%
    Dry mix desserts                           117       $14.7           0.22%       128       $65.0           0.21%
    Single serve fruit/applesauce              118       $14.6           0.22%       127       $65.4           0.21%
    Frozen seafood                             119       $13.8           0.21%       155       $41.0           0.13%
    Flour & meals                              120       $13.8           0.21%       126       $65.7           0.21%
    Pickle/relish/pckld veg & olives           121       $13.5           0.21%       106       $83.1           0.26%
    Turkey grinds                              122       $13.1           0.20%       113       $78.0           0.25%
    Bulk service case cheese                   123       $12.5           0.19%       104       $87.1           0.28%
    Pies                                       124       $12.3           0.19%       123       $67.7           0.21%
    Water                                      125       $12.3           0.19%       122       $67.8           0.22%
    Sushi                                      126       $11.8           0.18%        94      $104.6           0.33%
    Teas                                       127       $11.4           0.17%       116       $76.9           0.24%
    Authentic Hispanic foods & products        128       $11.0           0.17%       165       $31.7           0.10%
    Cookie/cracker multi-pks                   129       $10.9           0.16%       136       $52.7           0.17%
    Carrots                                    130       $10.6           0.16%        98       $97.3           0.31%
    Pork shoulder                              131       $10.5           0.16%       164       $32.1           0.10%
    Cocoa mixes                                132       $10.4           0.16%       153       $43.0           0.14%
    Juices super premium                       133       $10.3           0.16%       130       $63.2           0.20%
    Snack meat                                 134       $10.3           0.16%       147       $47.9           0.15%
    Seafood--catfish                           135        $9.8           0.15%       191       $17.6           0.06%
    Turkey frozen                              136        $9.7           0.15%       138       $51.8           0.16%
    Specialty cheese pre pack                  137        $9.6           0.15%        67      $152.4           0.48%
    Smoked pork                                138        $9.4           0.14%       156       $39.2           0.12%
    Frozen ice                                 139        $9.3           0.14%       142       $49.9           0.16%
    Seafood--crab                              140        $9.2           0.14%       182       $24.5           0.08%
    Mushrooms                                  141        $9.1           0.14%       105       $85.7           0.27%
    Value-added vegetables                     142        $9.0           0.14%       115       $77.0           0.24%
    Seafood--value-added seafood               143        $8.9           0.14%       178       $25.6           0.08%
    Sweet goods & snacks                       144        $8.6           0.13%       146       $48.3           0.15%
    Meat snacks                                145        $8.5           0.13%       170       $29.3           0.09%
    Single serve/vending--salty snacks         146        $8.4           0.13%       197       $15.8           0.05%
    Traditional Asian foods                    147        $8.3           0.13%       134       $59.8           0.19%
    Frozen juice and smoothies                 148        $7.7           0.12%       150       $44.9           0.14%
    Broccoli/cauliflower                       149        $7.4           0.11%       118       $76.5           0.24%
    Beef: rib                                  150        $7.3           0.11%       151       $43.3           0.14%
    Refrigerated desserts                      151        $7.0           0.11%       143       $49.5           0.16%
    Croutons/bread stick & salad top           152        $6.9           0.11%       171       $29.1           0.09%
    Dietary aid product/med liq nutr           153        $6.8           0.10%       132       $62.9           0.20%
    Dressings/dips                             154        $6.6           0.10%       139       $51.7           0.16%
    Party tray                                 155        $6.6           0.10%       154       $42.6           0.14%
    Corn                                       156        $6.5           0.10%       149       $45.3           0.14%
    Canned & dry milk                          157        $6.1           0.09%       163       $33.1           0.10%
    Fitness & diet                             158        $5.8           0.09%       101       $95.8           0.30%
    Juice                                      159        $5.8           0.09%       148       $46.2           0.15%
    Single serve sweet goods                   160        $5.7           0.09%       196       $16.2           0.05%
    Refrigerated hispanic grocery              161        $5.7           0.09%       177       $26.5           0.08%
    Enhancements (Pickles/Spreads)             162        $5.6           0.08%       174       $27.3           0.09%
    Convenience/snacking                       163        $5.5           0.08%       173       $28.5           0.09%
    Dried fruit                                164        $5.4           0.08%       137       $52.6           0.17%
    Seafood--salmon-farm raised                165        $5.0           0.08%       144       $48.8           0.15%
    Frozen whipped topping                     166        $5.0           0.08%       167       $30.9           0.10%
    Deli meat: presliced                       167        $4.9           0.07%       129       $63.8           0.20%
    Herbs/garlic                               168        $4.8           0.07%       141       $50.0           0.16%
    Seafood--party trays                       169        $4.8           0.07%       181       $24.8           0.08%
    Salad bar                                  170        $4.5           0.07%       188       $18.2           0.06%
    Seafood--salmon--wild caught               171        $4.5           0.07%       158       $36.7           0.12%
    Frozen fruits                              172        $4.3           0.07%       145       $48.6           0.15%
    Single serve/vending--cookie/cracker       173        $4.1           0.06%       211        $9.1           0.03%
    Chicken specialty/natural                  174        $3.8           0.06%       166       $31.5           0.10%
    Cereals                                    175        $3.8           0.06%       131       $63.0           0.20%
    Pork offal                                 176        $3.5           0.05%       232        $4.2           0.01%
    Pears                                      177        $3.5           0.05%       162       $33.6           0.11%
    Frozen meatless                            178        $3.3           0.05%       169       $30.0           0.10%
    Seafood--tilapia                           179        $3.2           0.05%       194       $16.4           0.05%
    Non-dairy/dairy aseptic                    180        $3.1           0.05%       168       $30.5           0.10%
    Refrigerated italian                       181        $2.9           0.04%       159       $36.6           0.12%
    Rice cakes                                 182        $2.8           0.04%       184       $22.4           0.07%
    Vinegar & cooking wines                    183        $2.8           0.04%       176       $27.2           0.09%
    Seafood--salad/dip/sce/cond                184        $2.8           0.04%       223        $6.2           0.02%
    Refrigerated vegetarian                    185        $2.8           0.04%       180       $24.8           0.08%
    Cake decor                                 186        $2.7           0.04%       199       $15.4           0.05%
    Frozen pasta                               187        $2.6           0.04%       193       $16.9           0.05%
    Syrups toppings & cones                    188        $2.6           0.04%       202       $14.1           0.04%
    Snacks                                     189        $2.6           0.04%       157       $37.6           0.12%
    Trail mix & snacks                         190        $2.5           0.04%       189       $18.1           0.06%
    Snack                                      191        $2.5           0.04%       160       $35.6           0.11%
    Prepared/pdgd foods                        192        $2.3           0.04%       161       $34.1           0.11%
    Turkey fresh                               193        $2.3           0.04%       192       $17.0           0.05%
    Condiments                                 194        $2.3           0.03%       175       $27.2           0.09%
    Seafood--fin fish other                    195        $2.2           0.03%       225        $5.8           0.02%
    Seafood--lobster                           196        $2.2           0.03%       204       $13.0           0.04%
    Pre-slice service case cheese              197        $2.1           0.03%       172       $28.6           0.09%
    Spices/jarred garlic                       198        $2.1           0.03%       205       $12.4           0.04%
    Vegetables cooking packaged                199        $2.0           0.03%       187       $18.3           0.06%
    Mixers                                     200        $1.9           0.03%       195       $16.4           0.05%
    Poultry other                              201        $1.8           0.03%       219        $6.7           0.02%
    Pork bone in loin/rib                      202        $1.8           0.03%       214        $7.6           0.02%
    Turkey offal                               203        $1.6           0.02%       235        $2.0           0.01%
    Organics fruit & vegetables                204        $1.6           0.02%       185       $22.2           0.07%
    Frozen ethnic                              205        $1.6           0.02%       218        $6.7           0.02%
    Lamb                                       206        $1.6           0.02%       207       $11.4           0.04%
    Seasonal                                   207        $1.5           0.02%       209       $10.3           0.03%
    Chicken offal                              208        $1.5           0.02%       230        $4.3           0.01%
    Turkey smoked                              209        $1.5           0.02%       234        $2.5           0.01%
    Seafood--cod                               210        $1.5           0.02%       206       $12.0           0.04%
    Frozen meat alternatives                   211        $1.5           0.02%       203       $13.6           0.04%
    Soup                                       212        $1.4           0.02%       179       $25.4           0.08%
    Authentic central american fds             213        $1.4           0.02%       227        $5.5           0.02%
    Cereal bars                                214        $1.4           0.02%       183       $23.6           0.07%
    Frozen entrees                             215        $1.4           0.02%       186       $21.5           0.07%
    Authentic asian foods                      216        $1.4           0.02%       208       $11.3           0.04%
    Bulk food                                  217        $1.3           0.02%       190       $18.0           0.06%
    Baking                                     218        $1.2           0.02%       201       $14.6           0.05%
    Random weight meat products                219        $1.1           0.02%       233        $4.0           0.01%
    Processed (dry mixes/squeezed fruit)       220        $1.0           0.02%       222        $6.2           0.02%
    Mediterranean bar                          221        $1.0           0.02%       198       $15.5           0.05%
    Chicken grinds                             222        $0.9           0.01%       217        $6.9           0.02%
    Chilled ready meals                        223        $0.9           0.01%       231        $4.2           0.01%
    Dry tea/coffee/coco mixes                  224        $0.9           0.01%       210        $9.2           0.03%
    Crackers                                   225        $0.8           0.01%       200       $14.6           0.05%
    Seafood--trout                             226        $0.7           0.01%       224        $6.0           0.02%
    Beverages                                  227        $0.7           0.01%       215        $7.6           0.02%
    Seafood--scallops                          228        $0.6           0.01%       221        $6.4           0.02%
    Baby food                                  229        $0.6           0.01%       226        $5.5           0.02%
    Deli specialties (retail pk)               230        $0.6           0.01%       228        $5.3           0.02%
    Buffalo                                    231        $0.5           0.01%       213        $8.3           0.03%
    Seafood--smoked seafood                    232        $0.5           0.01%       212        $8.4           0.03%
    Pork grinds                                233        $0.5           0.01%       229        $4.3           0.01%
    Authentic italian foods                    234        $0.5           0.01%       216        $7.4           0.02%
    Bakery party trays                         235        $0.4           0.01%       236        $1.9           0.01%
    Candy                                      236        $0.4           0.01%       220        $6.5           0.02%
    Authentic caribbean foods                  237        $0.4           0.01%       238        $1.1           0.00%
    Seafood--shellfish other                   238        $0.4           0.01%       237        $1.3           0.00%
                                                   ----------------------------          ---------------------------
      Totals                                          $6,580.5            100%             $31,513.8            100%
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.

                        Exhibit A-2: Top 1,000 Subcommodities by Expenditures of SNAP Households
    ----------------------------------------------------------------------------------------------------------------
                                              SNAP Household  Expenditures        Non-SNAP Household  Expenditures
                                         ---------------------------------------------------------------------------
        Commodity        Subcommodity                  $ in          % of                    $ in          % of
                                            Rank     Millions    Expenditures     Rank     Millions    Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk        Milk/White Only            1      $191.1           2.90%         1      $853.8           2.71%
     Products
    Soft Drinks       Soft Drinks 12/18          2      $164.6           2.50%         2      $601.2           1.91%
                       & 15pk Can Car
    Beef: Grinds      Lean [Beef]                3      $112.4           1.71%         7      $257.9           0.82%
    Cold Cereal       Kids Cereal                4       $78.1           1.19%        20      $186.4           0.59%
    Cheese            Shredded Cheese            5       $74.7           1.14%         3      $342.0           1.09%
    Soft Drinks       Sft Drnk 2 Liter           6       $70.9           1.08%        12      $230.1           0.73%
                       Btl Carb Incl
    Bag Snacks        Potato Chips               7       $64.4           0.98%         8      $253.2           0.80%
    Beef: Grinds      Primal [Beef]              8       $62.4           0.95%        14      $219.8           0.70%
    Lunchmeat         Lunchmeat--Deli            9       $55.8           0.85%        11      $242.6           0.77%
                       Fresh
    Infant Formula    Infant Formula            10       $54.2           0.82%       190       $45.3           0.14%
                       Starter/Solution
    Eggs/Muffins/     Eggs--Large               11       $52.1           0.79%         9      $251.6           0.80%
     Potatoes
    Chicken Fresh     Chicken Breast            12       $49.6           0.75%         4      $292.9           0.93%
                       Boneless
    Water--(Sparklin  Still Water               13       $48.8           0.74%        19      $187.7           0.60%
     g & Still)        Drnking/Mnrl
                       Water
    Baked Breads      Mainstream White          14       $48.0           0.73%        39      $136.8           0.43%
                       Bread
    Bag Snacks        Tortilla/Nacho            15       $47.4           0.72%        17      $209.0           0.66%
                       Chips
    Frozen Handhelds  Snacks/Appetizers         16       $44.6           0.68%        65      $100.5           0.32%
     & Snacks
    Cheese            American Single           17       $44.1           0.67%        41      $136.6           0.43%
                       Cheese
    Frzn Ss Premium   Fz Ss Prem                18       $43.8           0.67%        24      $175.4           0.56%
     Meals             Traditional Meals
    Refrgratd Juices/ Dairy Case 100%           19       $43.5           0.66%         6      $269.0           0.85%
     Drinks            Pure Juice--O
    Baked Sweet       Snack Cake--Multi         20       $41.6           0.63%        63      $101.7           0.32%
     Goods             Pack
    Pork Boneless     Enhanced [Pork            21       $41.5           0.63%        27      $168.0           0.53%
     Loin/Rib          Boneless Loin/
                       Rib]
    Coffee &          Unflavored Can            22       $41.3           0.63%        18      $198.0           0.63%
     Creamers          Coffee
    Frzn Ss Economy   Fz Ss Economy             23       $40.9           0.62%        81       $80.7           0.26%
     Meals             Meals All
    Bacon             Bacon--Trad 16oz          24       $40.7           0.62%        29      $157.6           0.50%
                       Or Less
    Soft Drinks       Soft Drinks 20pk &        25       $39.7           0.60%        60      $106.4           0.34%
                       24pk Can Carb
    Frozen Pizza      Pizza/Premium             26       $39.7           0.60%        32      $153.3           0.49%
    Baked Breads      Mainstream Variety        27       $38.4           0.58%        26      $173.2           0.55%
                       Breads
    Sugars &          Sugar                     28       $36.9           0.56%        55      $112.7           0.36%
     Sweeteners
    Cold Cereal       All Family Cereal         29       $36.2           0.55%        16      $214.9           0.68%
    Frozen Handhelds  Sandwiches &              30       $35.9           0.54%        91       $73.6           0.23%
     & Snacks          Handhelds
    Potatoes          Potatoes Russet           31       $35.8           0.54%        30      $154.5           0.49%
                       (Bulk & Bag)
    Cheese            Natural Cheese            32       $35.3           0.54%        15      $216.1           0.69%
                       Chunks
    Pork Thin Meats   Ribs [Pork]               33       $35.0           0.53%        59      $106.8           0.34%
    Convenient Meals  Convenient Meals--        34       $34.2           0.52%        96       $69.7           0.22%
                       Kids Meal C
    Bananas           Bananas                   35       $34.2           0.52%        10      $242.7           0.77%
    Soft Drinks       Sft Drnk Mlt-Pk           36       $34.0           0.52%        25      $173.6           0.55%
                       Btl Carb (Excp)
    Ice Cream Ice     Premium [Ice Cream        37       $31.2           0.47%        13      $226.0           0.72%
     Milk & Sherbets   & Sherbert]
    Isotonic Drinks   Isotonic Drinks           38       $30.5           0.46%        47      $119.5           0.38%
                       Single Serve
    Chicken Frozen    Frzn Chicken--Wht         39       $30.0           0.46%        66       $99.8           0.32%
                       Meat
    Canned Soups      Condensed Soup            40       $29.7           0.45%        31      $153.6           0.49%
    Salad Dresing &   Pourable Salad            41       $29.0           0.44%        37      $139.4           0.44%
     Sandwich          Dressings
     Spreads
    Beef: Loins       Choice Beef               42       $28.4           0.43%        40      $136.6           0.43%
    Beef: Loins       Select Beef               43       $27.9           0.42%        36      $143.7           0.46%
    Soft Drinks       Sft Drnk Sngl Srv         44       $27.8           0.42%        94       $71.4           0.23%
                       Btl Carb (Ex)
    Frzn Multi Serve  Fz Family Style           45       $27.6           0.42%        77       $83.5           0.26%
                       Entrees
    Salad Dresing &   Mayonnaise &              46       $27.3           0.41%        48      $119.1           0.38%
     Sandwich          Whipped Dressing
     Spreads
    Frozen Vegetable  Fz Bag Vegetables--       47       $25.7           0.39%        42      $131.9           0.42%
     & Veg Dish        Plain
    Ice Cream Ice     Traditional [Ice          48       $25.6           0.39%        49      $118.7           0.38%
     Milk & Sherbets   Cream & Sherbert]
    Hot Dogs          Hot Dogs--Base            49       $25.1           0.38%       138       $56.8           0.18%
                       Meat
    Cold Cereal       Adult Cereal              50       $24.9           0.38%        21      $182.6           0.58%
    Frzn Ss Premium   Fz Ss Prem                51       $24.7           0.38%         5      $271.6           0.86%
     Meals             Nutritional Meals
    Dinner Mixes-Dry  Macaroni & Cheese         52       $24.3           0.37%       125       $59.7           0.19%
                       Dnrs
    Aseptic Juice     Aseptic Pack Juice        53       $24.2           0.37%       134       $57.1           0.18%
                       And Drinks
    Fluid Milk        Refrigerated              54       $24.1           0.37%        34      $147.2           0.47%
     Products          Coffee Creamers
    Beef: Round       Choice Beef               55       $24.0           0.37%        92       $72.5           0.23%
    Traditional       Mexican Soft              56       $23.7           0.36%        54      $113.1           0.36%
     Mexican Foods     Tortillas And
                       Wraps
    Berries           Strawberries              57       $23.5           0.36%        22      $178.4           0.57%
    Margarines        Margarine: Tubs           58       $23.4           0.36%        64      $100.9           0.32%
                       And Bowls
    Pasta & Pizza     Mainstream [Pasta         59       $23.0           0.35%        80       $81.0           0.26%
     Sauce             & Pizza Sauce]
    Chicken Fresh     Chicken Wings             60       $22.2           0.34%       300       $28.6           0.09%
    Canned Pasta &    Can Pasta                 61       $22.2           0.34%       179       $47.7           0.15%
     Mwv Fd-Shlf
     Stbl
    Chicken Frozen    Frzn Chicken--            62       $22.2           0.34%       452       $17.4           0.06%
                       Wings
    Lunchmeat         Lunchmeat--Bologna/       63       $21.8           0.33%       121       $60.9           0.19%
                       Sausage
    Bag Snacks        Mult Pk Bag Snacks        64       $21.6           0.33%       199       $43.4           0.14%
    Candy--Packaged   Candy Bags-               65       $21.5           0.33%        33      $147.5           0.47%
                       Chocolate
    Sweet Goods       Sw Gds: Donuts            66       $21.3           0.32%        78       $82.3           0.26%
    Can Seafood--     Tuna                      67       $21.1           0.32%        57      $109.9           0.35%
     Shelf Stable
    Shortening & Oil  Vegetable Oil             68       $20.5           0.31%       246       $35.4           0.11%
    Frozen Potatoes   Frzn French Fries         69       $20.5           0.31%       163       $50.3           0.16%
    Peanut Butter/    Peanut Butter             70       $20.4           0.31%        43      $127.8           0.41%
     Jelly/Jams &
     Honey
    Frozen Pizza      Pizza/Economy             71       $19.8           0.30%       192       $45.1           0.14%
    Margarines        Butter                    72       $19.6           0.30%        23      $175.6           0.56%
    Deli Meat: Bulk   Meat: Turkey Bulk         73       $19.3           0.29%        28      $159.6           0.51%
    Frozen Breakfast  Frzn Breakfast            74       $19.1           0.29%       142       $55.7           0.18%
     Foods             Sandwiches
    Meat Frozen       Frzn Meat--Beef           75       $19.0           0.29%       185       $46.3           0.15%
    Frzn Multi Serve  Fz Skillet Meals          76       $18.8           0.29%        83       $79.3           0.25%
    Frzn Prepared     Value Forms/18oz          77       $18.6           0.28%       209       $42.6           0.14%
     Chicken           And Larger
                       [Chicken]
    Cakes             Cakes: Birthday/          78       $18.6           0.28%       164       $50.3           0.16%
                       Celebration
    Cookies           Sandwich Cookies          79       $18.0           0.27%        93       $71.8           0.23%
    Frozen Pizza      Pizza/Traditional         80       $17.9           0.27%       111       $64.1           0.20%
    Fruit Snacks      Fruit Snacks              81       $17.6           0.27%       202       $43.2           0.14%
    Rts/Micro Soup/   Soup: Chunky/             82       $17.6           0.27%        46      $119.9           0.38%
     Broth Rts         Homestyle
    Milk By-Products  Sour Creams               83       $17.5           0.27%        70       $95.2           0.30%
    Frozen Breakfast  Waffles/Pancakes/         84       $17.3           0.26%        90       $77.4           0.25%
     Foods             French Toast
    Chicken Fresh     Chicken Drums             85       $17.3           0.26%       270       $31.5           0.10%
    Bagels & Cream    Cream Cheese              86       $17.2           0.26%        51      $115.5           0.37%
     Cheese
    Beef: Grinds      Angus [Beef]              87       $17.1           0.26%        61      $103.8           0.33%
    Bag Snacks        Bagged Cheese             88       $17.1           0.26%       157       $52.0           0.16%
                       Snacks
    Bag Snacks        Salsa & Dips              89       $17.1           0.26%       135       $57.0           0.18%
    Sandwiches        Sandwiches--(Cold)        90       $16.9           0.26%       106       $67.7           0.21%
    Dry/Ramen         Ramen Noodles/            91       $16.7           0.25%       304       $28.1           0.09%
     Bouillon          Ramen Cups
    Crackers & Misc   Cheese Crackers           92       $16.5           0.25%        72       $90.2           0.29%
     Baked Food
    Dinner Sausage    Dnr Sausage--Links        93       $16.4           0.25%       233       $37.6           0.12%
                       Pork Ckd
    Candy--Checklane  Candy Bars                94       $16.3           0.25%       146       $54.9           0.17%
                       (Singles)
    Baked Breads      Hamburger Buns            95       $16.2           0.25%        95       $70.2           0.22%
    Baked Breads      Hot Dog Buns              96       $16.2           0.25%       117       $62.2           0.20%
    Water--(Sparklin  Spring Water              97       $16.2           0.25%        69       $95.6           0.30%
     g & Still)
    Refrgratd Juices/ Dairy Case Juice          98       $16.0           0.24%       177       $48.0           0.15%
     Drinks            Drnk Under 10 oz
    Fluid Milk        Flavored Milk             99       $16.0           0.24%       128       $59.4           0.19%
     Products
    Baked Sweet       Sweet Goods--Full        100       $15.8           0.24%       133       $57.9           0.18%
     Goods             Size
    Grapes            Grapes Red               101       $15.8           0.24%        45      $121.7           0.39%
    Candy--Packaged   Candy Bars (Multi        102       $15.6           0.24%        97       $69.6           0.22%
                       Pack)
    Grapes            Grapes White             103       $15.5           0.23%        76       $84.9           0.27%
    Cookies           Tray Pack/Choc           104       $15.3           0.23%       153       $53.9           0.17%
                       Chip Cookies
    Deli Meat: Bulk   Meat: Ham Bulk           105       $15.3           0.23%        50      $115.9           0.37%
    Cheese            String Cheese            106       $15.1           0.23%        67       $99.0           0.31%
    Breakfast         Bkfst Sausage--          107       $15.1           0.23%       119       $61.4           0.19%
     Sausage           Fresh Rolls
    Seafood--Shrimp   Shrimp--Raw              108       $15.0           0.23%        99       $69.0           0.22%
    Seafood--Shrimp   Shrimp--Cooked           109       $14.8           0.22%       152       $54.0           0.17%
    Refrgrated Dough  Refrigerated             110       $14.7           0.22%       191       $45.2           0.14%
     Products          Biscuits
    Crackers & Misc   Butter Spray             111       $14.6           0.22%       101       $68.7           0.22%
     Baked Food        Cracker
    Frozen            Sticks/Enrobed           112       $14.2           0.22%       126       $59.7           0.19%
     Novelties--Wate   [Frozen
     r Ice             Novelties]
    Spices &          Traditional Spices       113       $14.1           0.21%       120       $61.2           0.19%
     Extracts
    Frozen            Water Ice [Frozen        114       $14.0           0.21%       160       $50.6           0.16%
     Novelties--Wate   Novelties]
     r Ice
    Yogurt            Yogurt/Kids              115       $14.0           0.21%       212       $42.4           0.13%
    Cnv Breakfast &   Toaster Pastries         116       $14.0           0.21%       180       $47.6           0.15%
     Wholesome Snks
    Dry Bean Veg &    Rice Side Dish           117       $14.0           0.21%       184       $46.7           0.15%
     Rice              Mixes Dry
    Ice Cream Ice     Pails [Ice Cream &       118       $13.9           0.21%       250       $35.1           0.11%
     Milk & Sherbets   Sherbert]
    Milk By-Products  Cottage Cheese           119       $13.9           0.21%        58      $108.8           0.35%
    Rtd Tea/New Age   Tea Sweetened            120       $13.9           0.21%       102       $68.7           0.22%
     Juice
    Can Beans         Prepared Beans--         121       $13.4           0.20%       145       $55.3           0.18%
                       Baked W/Pork
    Cheese            Natural Cheese           122       $13.4           0.20%        53      $113.2           0.36%
                       Slices
    Tropical Fruit    Avocado                  123       $13.4           0.20%        56      $112.6           0.36%
    Meat--Shelf       Chili: Canned            124       $13.3           0.20%       206       $42.8           0.14%
     Stable
    Shelf Stable      Apple Juice &            125       $13.3           0.20%       187       $45.8           0.15%
     Juice             Cider (Over 50%)
    Value-Added       Instore Cut Fruit        126       $13.2           0.20%        74       $85.8           0.27%
     Fruit
    Candy--Checklane  Chewing Gum              127       $13.2           0.20%       103       $68.3           0.22%
    Salad Mix         Blends [Salad Mix]       128       $13.1           0.20%        44      $124.0           0.39%
    Popcorn           Popcorn--Microwave       129       $13.1           0.20%       114       $63.4           0.20%
    Turkey Grinds     Ground Turkey            130       $13.1           0.20%        87       $78.0           0.25%
    Dinner Sausage    Dnr Sausage--Links       131       $13.0           0.20%       132       $58.0           0.18%
                       Fresh
    Dinner Mixes-Dry  Skillet Dinners          132       $13.0           0.20%       332       $25.8           0.08%
    Dry Noodles &     Long Cut Pasta           133       $13.0           0.20%       122       $60.4           0.19%
     Pasta
    Chicken Fresh     Whole Chicken            134       $12.9           0.20%       136       $56.9           0.18%
                       (Roasters/Fryer)
    Frozen Pizza      Pizza/Single Serve/      135       $12.8           0.19%       203       $43.2           0.14%
                       Microwave
    Can Vegetables--  Green Beans: Fs/         136       $12.8           0.19%       155       $53.1           0.17%
     Shelf Stable      Whl/Cut
    Cnv Breakfast &   Granola Bars             137       $12.8           0.19%        73       $88.9           0.28%
     Wholesome Snks
    Candy--Packaged   Candy Bags-Non           138       $12.6           0.19%       147       $54.9           0.17%
                       Chocolate
    Citrus            Oranges Navels All       139       $12.6           0.19%        84       $79.3           0.25%
    Baked Breads      Premium Bread            140       $12.3           0.19%        35      $144.7           0.46%
    Dry Sce/Gravy/    Potatoes: Dry            141       $12.3           0.19%       262       $32.3           0.10%
     Potatoes/
     Stuffng
    Condiments &      Bbq Sauce                142       $12.3           0.19%       226       $38.6           0.12%
     Sauces
    Chicken Fresh     Chicken Thighs           143       $12.2           0.19%       165       $50.0           0.16%
    Dinner Sausage    Dnr Sausage--Pork        144       $12.1           0.18%       227       $38.2           0.12%
                       Rope Ckd
    Can Vegetables--  Corn                     145       $12.1           0.18%       197       $44.0           0.14%
     Shelf Stable
    Bacon             Bacon--Trad              146       $12.0           0.18%       193       $44.6           0.14%
                       Greater Than 16oz
    Ice Cream Ice     Super Premium            147       $11.8           0.18%        71       $91.1           0.29%
     Milk & Sherbets   Pints [Ice Cream
                       & Sherbert]
    Baby Foods        Baby Food--              148       $11.7           0.18%       303       $28.1           0.09%
                       Beginner
    Molasses/Syrups/  Molasses & Syrups        149       $11.7           0.18%       130       $58.7           0.19%
     Pancake Mixes
    Water             Non-Carb Water           150       $11.6           0.18%       115       $63.4           0.20%
                       Flvr--Drnk/Mnr
    Vegetables Salad  Head Lettuce             151       $11.6           0.18%       143       $55.5           0.18%
    Condiments &      Catsup                   152       $11.5           0.17%       216       $41.5           0.13%
     Sauces
    Dry Sce/Gravy/    Sauce Mixes/Gravy        153       $11.5           0.17%       183       $46.7           0.15%
     Potatoes/         Mixes Dry
     Stuffng
    Beef: Thin Meats  Soup/Stew                154       $11.2           0.17%       195       $44.1           0.14%
    Baby Foods        Baby Food Junior/        155       $11.2           0.17%       311       $27.5           0.09%
                       All Brands
    Frzn Prepared     Whole Muscle             156       $11.1           0.17%       285       $29.9           0.09%
     Chicken           Breaded/18oz
    Cakes             Cakes: Cupcakes          157       $11.1           0.17%       247       $35.3           0.11%
    Refrgratd Juices/ Dairy Case Citrus        158       $11.0           0.17%       254       $34.4           0.11%
     Drinks            Pnch/Oj Subs
    Yogurt            Yogurt/Ss Regular        159       $11.0           0.17%       100       $69.0           0.22%
    Dry Cheese        Loaf Cheese              160       $10.9           0.17%       229       $38.1           0.12%
    Frozen Handhelds  Corn Dogs                161       $10.9           0.17%       401       $20.6           0.07%
     & Snacks
    Cnv Breakfast &   Cereal Bars              162       $10.9           0.17%        86       $78.4           0.25%
     Wholesome Snks
    Isotonic Drinks   Isotonic Drinks          163       $10.8           0.16%       131       $58.1           0.18%
                       Multi-Pack
    Cookies           Cookies: Regular         164       $10.8           0.16%       127       $59.6           0.19%
    Shelf Stable      Fruit Drinks:            165       $10.6           0.16%       617       $10.9           0.03%
     Juice             Canned & Glass
    Single Serve      Fruit Cup                166       $10.6           0.16%       207       $42.7           0.14%
     Fruit/
     Applesauce
    Can Beans         Variety Beans--          167       $10.5           0.16%       104       $68.0           0.22%
                       Kidney/Pinto
    Frozen Vegetable  Frzn Steamable           168       $10.5           0.16%        79       $81.4           0.26%
     & Veg Dish        Vegetables
    Coffee &          Non Dairy Creamer        169       $10.5           0.16%       244       $35.4           0.11%
     Creamers
    Beef: Thin Meats  Cubed Meats [Beef]       170       $10.5           0.16%       286       $29.8           0.09%
    Hot Dogs          Hot Dogs--Base           171       $10.3           0.16%       171       $49.4           0.16%
                       Beef
    Yogurt            Yogurt/Ss Light          172       $10.2           0.16%        62      $103.1           0.33%
    Traditional       Mexican Sauces And       173       $10.2           0.16%       116       $62.3           0.20%
     Mexican Foods     Picante Sauce
    Frozen Handhelds  Burritos                 174       $10.2           0.15%       406       $20.0           0.06%
     & Snacks
    Eggs/Muffins/     Eggs--Medium             175       $10.1           0.15%       394       $21.0           0.07%
     Potatoes
    Dry Noodles &     Short Cut Pasta          176        $9.9           0.15%       140       $56.2           0.18%
     Pasta
    Dinner Mixes-Dry  Microwave Dinners        177        $9.8           0.15%       220       $39.9           0.13%
    Cakes             Cakes: Layers            178        $9.8           0.15%       228       $38.2           0.12%
    Pork Shoulder     Butts [Pork              179        $9.7           0.15%       292       $29.2           0.09%
                       Shoulder]
    Frzn Prepared     Boneless Snack/          180        $9.6           0.15%       384       $21.5           0.07%
     Chicken           18oz And Larger
    Rolls             Rolls: Dinner            181        $9.5           0.14%       161       $50.5           0.16%
    Chicken &         Chix: Value-Added        182        $9.5           0.14%       323       $26.7           0.08%
     Poultry           (Cold)
    Tomato Products-  Tomatoes Diced           183        $9.5           0.14%       123       $59.9           0.19%
     Shelf Stable
    Frozen Ice        Ice--Crushed/Cubed       184        $9.3           0.14%       166       $49.9           0.16%
    Beef: Round       Angus [Beef]             185        $9.3           0.14%       271       $31.4           0.10%
    Shelf Stable      Blended Juice &          186        $9.3           0.14%       287       $29.6           0.09%
     Juice             Combinations
    Sushi             Sushi--In Store          187        $9.2           0.14%        75       $85.4           0.27%
                       Prepared
    Tomatoes          Tomatoes Hothouse        188        $9.2           0.14%        88       $77.7           0.25%
                       On The Vine
    Candy--Packaged   Seasonal                 189        $9.2           0.14%       182       $46.9           0.15%
                       Miscellaneous
                       [Candy]
    Frozen Bread/     Frzn Garlic Toast        190        $9.1           0.14%       307       $27.8           0.09%
     Dough
    Warehouse Snacks  Canister Snacks          191        $9.1           0.14%       241       $36.4           0.12%
    Beef: Grinds      Patties [Beef]           192        $9.1           0.14%       221       $39.7           0.13%
    Bag Snacks        Corn Chips               193        $9.1           0.14%       188       $45.6           0.14%
    Hot Cereal        Instant Oatmeal          194        $8.9           0.14%       218       $41.1           0.13%
    Breakfast         Bkfst Sausage--          195        $8.9           0.14%       325       $26.3           0.08%
     Sausage           Fresh Links
    Crackers & Misc   Snack Crackers           196        $8.9           0.14%        68       $98.6           0.31%
     Baked Food
    Citrus            Clementines              197        $8.8           0.13%        85       $78.6           0.25%
    Frzn Prepared     Bone-In Wings            198        $8.8           0.13%       586       $12.0           0.04%
     Chicken
    Onions            Onions Yellow            199        $8.7           0.13%       225       $39.3           0.12%
                       (Bulk & Bag)
    Dry Mix Desserts  Pudding & Gelatin        200        $8.7           0.13%       310       $27.6           0.09%
                       Cups/Cans
    Coffee &          Unflavored Bag           201        $8.5           0.13%        38      $137.3           0.44%
     Creamers          Coffee
    Refrgratd Juices/ Dairy Case Tea           202        $8.4           0.13%       364       $23.1           0.07%
     Drinks            With Sugar
    Infant Formula    Infant Formula           203        $8.4           0.13%       687        $9.1           0.03%
                       Specialty
    Ss/Vending--      Salty Snacks             204        $8.4           0.13%       480       $15.8           0.05%
     Salty Snacks      Vending
    Shortening & Oil  Canola Oils              205        $8.3           0.13%       291       $29.3           0.09%
    Infant Formula    Infant Formula           206        $8.3           0.13%       368       $22.8           0.07%
                       Starter Large
    Value-Added       Melons Instore Cut       207        $8.2           0.13%       205       $42.8           0.14%
     Fruit
    Vegetables Salad  Cucumbers                208        $8.2           0.13%       129       $58.9           0.19%
    Smoked Hams       Hams--Half/Port          209        $8.2           0.12%       282       $30.0           0.10%
                       Bone-In
    Crackers & Misc   Saltine/Oyster           210        $8.2           0.12%       204       $43.1           0.14%
     Baked Food
    Condiments &      Steak & Worchester       211        $8.2           0.12%       321       $26.7           0.08%
     Sauces            Sauce
    Cookie/Cracker    Multi-Pack               212        $8.0           0.12%       217       $41.3           0.13%
     Multi-Pks         Crackers
    Frozen            Cones [Frozen            213        $7.9           0.12%       273       $31.2           0.10%
     Novelties--Wate   Novelties]
     r Ice
    Deli Meat: Bulk   Meat: Beef Bulk          214        $7.9           0.12%       154       $53.4           0.17%
    Melons            Watermelon               215        $7.9           0.12%       198       $43.9           0.14%
                       Seedless Whole
    Candy--Packaged   Seasonal Candy           216        $7.9           0.12%       148       $54.8           0.17%
                       Bags--Chocolate
    Salad & Dips      Vegetable Salads--       217        $7.8           0.12%       238       $36.6           0.12%
                       Prepack
    Baked Breads      Bagels                   218        $7.8           0.12%       108       $66.9           0.21%
    Peppers           Peppers Green Bell       219        $7.8           0.12%       215       $41.5           0.13%
    Salad Mix         Regular Garden           220        $7.8           0.12%       265       $31.9           0.10%
                       Salad
    Energy Drinks     Energy Drink--           221        $7.7           0.12%       327       $26.3           0.08%
                       Single Serve
    Smoked Hams       Hams--Spiral             222        $7.6           0.12%       240       $36.5           0.12%
    Coffee &          Unflavored Instant       223        $7.6           0.12%       316       $27.3           0.09%
     Creamers          Coffee
    Tomatoes          Roma Tomatoes            224        $7.5           0.11%       222       $39.6           0.13%
                       (Bulk/Pkg)
    Cookies           Vanilla Wafer/Kids       225        $7.5           0.11%       236       $36.7           0.12%
                       Cookies
    Frozen            Ice Cream                226        $7.4           0.11%       354       $24.2           0.08%
     Novelties--Wate   Sandwiches
     r Ice
    Hot Dogs          Hot Dogs--Premium        227        $7.4           0.11%       208       $42.7           0.14%
    Yogurt            Yogurt/Pro Active        228        $7.4           0.11%       113       $63.5           0.20%
                       Health
    Snack Meat        Snack Meat--             229        $7.4           0.11%       263       $32.1           0.10%
                       Pepperoni
    Cakes             Cakes: Creme/            230        $7.4           0.11%       333       $25.8           0.08%
                       Pudding
    Meat Frozen       Frzn Meat--              231        $7.3           0.11%       602       $11.3           0.04%
                       Breakfast Sausage
    Beef: Rib         Angus [Beef]             232        $7.3           0.11%       200       $43.3           0.14%
    Shortening & Oil  Olive Oil                233        $7.3           0.11%       112       $63.8           0.20%
    Dry Bean Veg &    Noodle Side Dish         234        $7.3           0.11%       390       $21.1           0.07%
     Rice              Mixes
    Yogurt            Yogurt/Adult Multi-      235        $7.2           0.11%       210       $42.5           0.14%
                       Packs
    Dry Bean Veg &    Rice--Dry Bag And        236        $7.1           0.11%       255       $33.9           0.11%
     Rice              Box
    Energy Drinks     Energy Drink--           237        $7.1           0.11%       224       $39.5           0.13%
                       Single Serve
    Baked Breads      Sandwich Buns            238        $7.1           0.11%       137       $56.8           0.18%
    Refrigerated      Non-Dairy Milks          239        $7.1           0.11%       105       $67.7           0.21%
     Dairy Case
    Beef: Round       Select Beef              240        $7.1           0.11%       278       $30.4           0.10%
    Powder & Crystal  Unsweetened              241        $7.0           0.11%       802        $6.2           0.02%
     Drink Mix         Envelope [Powder
                       Drink Mix]
    Refrigerated      Refrigerated             242        $7.0           0.11%       170       $49.5           0.16%
     Desserts          Pudding
    Carrots           Carrots Mini             243        $7.0           0.11%       118       $61.4           0.19%
                       Peeled
    Baking Mixes      Layer Cake Mix           244        $7.0           0.11%       251       $35.1           0.11%
    Cocoa Mixes       Malted Mlk/Syrup/        245        $6.9           0.11%       339       $25.3           0.08%
                       Pwdrs (Eggnog)
    Stone Fruit       Cherries Red             246        $6.9           0.10%       139       $56.7           0.18%
    Frzn Seafood      Frz Coated Fish          247        $6.9           0.10%       389       $21.1           0.07%
                       Fillets
    Meat Snacks       Jerky/Nuggets/           248        $6.8           0.10%       334       $25.8           0.08%
                       Tenders
    Dry Bean Veg &    Rice--Instant &          249        $6.8           0.10%       231       $38.0           0.12%
     Rice              Microwave
    Seafood--Catfish  Catfish--Fillet          250        $6.8           0.10%       544       $13.1           0.04%
    Refrgrated Dough  Refrigerated             251        $6.8           0.10%       296       $28.8           0.09%
     Products          Cookies-Brand
    Fluid Milk        Specialty/Lactose        252        $6.7           0.10%       175       $48.4           0.15%
     Products          Free Milk
    Peanut Butter/    Preserves/Jam/           253        $6.7           0.10%       141       $56.2           0.18%
     Jelly/Jams &      Marmalade
     Honey
    Margarines        Margarine Stick          254        $6.7           0.10%       376       $22.3           0.07%
    Rts/Micro Soup/   Broth                    255        $6.7           0.10%       109       $65.6           0.21%
     Broth
    Rtd Tea/New Age   Juice (Under 10%         256        $6.7           0.10%       374       $22.4           0.07%
     Juice             Juice)
    Apples            Apples Gala (Bulk        257        $6.6           0.10%        98       $69.3           0.22%
                       & Bag)
    Chicken Fresh     Chicken Legs/            258        $6.6           0.10%       536       $13.5           0.04%
                       Quarters
    Frozen Breakfast  Frzn Breakfast           259        $6.5           0.10%       420       $19.0           0.06%
     Foods             Pastry
    Flour & Meals     Flour: White &           260        $6.4           0.10%       297       $28.8           0.09%
                       Self Rising
    Seafood--Value-   Seafood Value-           261        $6.4           0.10%       459       $16.9           0.05%
     Added             Added Breaded
                       Shrimp
    Sugars &          Sweeteners               262        $6.4           0.10%       168       $49.8           0.16%
     Sweeteners
    Baking Mixes      Frosting                 263        $6.3           0.10%       318       $27.0           0.09%
    Pies              Pies: Fruit/Nut          264        $6.3           0.10%       223       $39.6           0.13%
    Molasses/Syrups/  Pancake Mixes            265        $6.3           0.10%       379       $21.9           0.07%
     Pancake Mixes
    Water--(Sparklin  Still Water Flvrd        266        $6.3           0.10%       230       $38.1           0.12%
     g & Still)        Drnk/Mnrl Wtr
    Bag Snacks        Pretzels                 267        $6.2           0.09%       144       $55.4           0.18%
    Dry Cheese        Grated Cheese            268        $6.2           0.09%       256       $33.6           0.11%
    Onions            Onions Sweet (Bulk       269        $6.2           0.09%       181       $47.4           0.15%
                       & Bag)
    Shelf Stable      Cranapple/Cran           270        $6.1           0.09%       315       $27.3           0.09%
     Juice             Grape Juice
    Frzn Seafood      Frz Fishsticks/          271        $6.1           0.09%       506       $14.7           0.05%
                       Tenders/Nuggets
    Seafood--Crab     Crab--Snow               272        $6.1           0.09%       598       $11.4           0.04%
    Bread             Bread:Italian/           273        $6.1           0.09%       172       $49.0           0.16%
                       French
    Bulk Service      Bulk Semi-Hard           274        $6.1           0.09%       196       $44.0           0.14%
     Case Cheese       Cheese
    Baking Mixes      Muffin & Corn            275        $6.0           0.09%       295       $28.9           0.09%
                       Bread Mix
    Chicken &         Chix: Frd 8pc/Cut        276        $6.0           0.09%       558       $12.7           0.04%
     Poultry           Up (Cold)
    Infant Formula    Infant Formula           277        $6.0           0.09%       570       $12.4           0.04%
                       Toddler
    Vegetables        Celery                   278        $5.9           0.09%       158       $51.2           0.16%
     Cooking Bulk
    Traditional       Mexican Seasoning        279        $5.9           0.09%       402       $20.6           0.07%
     Mexican Foods     Mixes
    Refrigerated      Fluid Milk               280        $5.9           0.09%        52      $113.3           0.36%
     Dairy Case
    Soft Drinks       Soft Drinks Can          281        $5.9           0.09%       592       $11.5           0.04%
                       Non-Carb
    Condiments &      Hot Sauce                282        $5.8           0.09%       466       $16.4           0.05%
     Sauces
    Apples            Apples Red               283        $5.8           0.09%       248       $35.2           0.11%
                       Delicious (Bulk &
                       Bag)
    Single Serve      Snack Cake--Single       284        $5.7           0.09%       470       $16.2           0.05%
     Sweet Goods       Serve
    Milk By-Products  Refrig Dips              285        $5.7           0.09%       350       $24.7           0.08%
    Tomatoes          Tomatoes Vine Ripe       286        $5.7           0.09%       373       $22.5           0.07%
                       Bulk
    Bag Snacks        Brand Snacks             287        $5.6           0.09%       176       $48.1           0.15%
    Refrgrated Dough  Refrigerated             288        $5.5           0.08%       312       $27.5           0.09%
     Products          Specialty Rolls
    Canned & Dry      Canned Milk              289        $5.5           0.08%       305       $27.9           0.09%
     Milk
    Coffee &          Ready To Drink           290        $5.5           0.08%       403       $20.5           0.06%
     Creamers          Coffee
    Salad Mix         Garden Plus [Salad       291        $5.5           0.08%       267       $31.8           0.10%
                       Mix]
    Cookies           Cookies: Holiday/        292        $5.5           0.08%       320       $26.8           0.08%
                       Special Occas
    Bag Snacks        Misc Bag Snacks          293        $5.5           0.08%       591       $11.5           0.04%
    Refrgratd Juices/ 100% Pure Juice          294        $5.4           0.08%       261       $32.3           0.10%
     Drinks Dairy      Other
     Case
    Refrgrated Dough  Refrigerated             295        $5.4           0.08%       274       $31.2           0.10%
     Products          Crescent Rolls
    Teas              Tea Bags & Bulk          296        $5.4           0.08%       317       $27.2           0.09%
                       Tea
    Aseptic Juice     Aseptic Pack Juice       297        $5.3           0.08%       449       $17.5           0.06%
                       And Drinks
    Infant Formula    Infant Formula           298        $5.3           0.08%       497       $15.2           0.05%
                       Solutions Large
    Vegetables        Cabbage                  299        $5.3           0.08%       340       $25.1           0.08%
     Cooking Bulk
    Melons            Cantaloupe Whole         300        $5.3           0.08%       194       $44.4           0.14%
    Dry Sce/Gravy/    Stuffing Mixes           301        $5.3           0.08%       378       $22.1           0.07%
     Potatoes/
     Stuffng
    Frozen Desserts   Frozen Fruit Pies        302        $5.3           0.08%       359       $23.7           0.08%
                       & Cobblers
    Frozen Potatoes   Frzn Tater Tots/         303        $5.2           0.08%       424       $18.8           0.06%
                       Other Extruded
    Traditional       Mexican Taco/            304        $5.2           0.08%       417       $19.1           0.06%
     Mexican Foods     Tostado/Shells
    Broccoli/         Broccoli Whole &         305        $5.2           0.08%       156       $52.0           0.16%
     Cauliflower       Crowns
    Tomato Products-  Tomato Sauce             306        $5.1           0.08%       353       $24.2           0.08%
     Shelf Stable
    Candy--Checklane  Candy Bars               307        $5.1           0.08%       476       $15.9           0.05%
                       (Singles)
    Lunchmeat         Lunchmeat--Chop/         308        $5.1           0.08%       583       $12.1           0.04%
                       Form Pltry
    Vegetables Salad  Variety Lettuce          309        $5.1           0.08%       110       $65.2           0.21%
    Berries           Blueberries              310        $5.1           0.08%        82       $79.4           0.25%
    Shelf Stable      Cranberry Juice          311        $5.0           0.08%       371       $22.6           0.07%
     Juice             (50% And Under)
    Seafood--Salmon-  Salmon Fr--              312        $5.0           0.08%       173       $48.8           0.15%
     Farm Raised       Atlantic
    Tomatoes          Tomatoes Hot House       313        $5.0           0.08%       280       $30.3           0.10%
                       Bulk
    Yogurt            Yogurt/Specialty         314        $5.0           0.08%        89       $77.4           0.25%
                       Greek
    Frozen Whipped    Frzn Whipped             315        $5.0           0.08%       276       $30.9           0.10%
     Topping           Topping
    Can Fruit/Jar     Pineapple                316        $4.9           0.07%       357       $24.0           0.08%
     Applesauce
    Frozen Desserts   Frozen Cream Pies        317        $4.9           0.07%       423       $18.9           0.06%
    Infant Formula    Infant Formula           318        $4.9           0.07%       954        $3.9           0.01%
                       Concentrate
    Stone Fruit       Peaches Yellow           319        $4.8           0.07%       243       $35.6           0.11%
                       Flesh
    Sweet Goods       Sw Gds: Sw Rolls/        320        $4.8           0.07%       319       $26.9           0.09%
                       Dan
    Potatoes          Potatoes Sweet &         321        $4.8           0.07%       234       $37.1           0.12%
                       Yams
    Seafood--Party    Party Tray--Shrimp       322        $4.8           0.07%       347       $24.8           0.08%
     Trays
    Shelf Stable      Blended Juice &          323        $4.8           0.07%       365       $22.9           0.07%
     Juice             Combinations
    Baking Mixes      Brownie Mix              324        $4.8           0.07%       313       $27.5           0.09%
    Shelf Stable      Grape Juice (Over        325        $4.8           0.07%       455       $17.1           0.05%
     Juice             50% Juice)
    Frzn Prepared     Fz Meal Kits/            326        $4.8           0.07%       578       $12.2           0.04%
     Chicken           Stuffed/Other
    Peanut Butter/    Jelly                    327        $4.7           0.07%       439       $18.1           0.06%
     Jelly/Jams &
     Honey
    Smoked Pork       Ham Steaks/Cubes/        328        $4.7           0.07%       324       $26.3           0.08%
                       Slices
    Tomatoes          Tomatoes Grape           329        $4.7           0.07%       150       $54.6           0.17%
    Traditional       Mexican Beans/           330        $4.7           0.07%       393       $21.0           0.07%
     Mexican Foods     Refried
    Citrus            Lemons                   331        $4.6           0.07%       257       $33.6           0.11%
    Can Fruit/Jar     Peaches                  332        $4.6           0.07%       387       $21.3           0.07%
     Applesauce
    Frozen Potatoes   Frzn Hashbrown           333        $4.6           0.07%       348       $24.8           0.08%
                       Potatoes
    Dry Noodles &     Noodles Dry              334        $4.5           0.07%       344       $24.9           0.08%
     Pasta
    Salad Bar         Salad Bar Other          335        $4.5           0.07%       438       $18.2           0.06%
    Corn              Corn Bulk                336        $4.5           0.07%       260       $32.5           0.10%
    Sweet Goods       Sw Gds: Muffins          337        $4.5           0.07%       266       $31.8           0.10%
    Frozen Breakfast  Frzn Breakfast           338        $4.5           0.07%       473       $16.2           0.05%
     Foods             Entrees
    Eggs/Muffins/     Eggs--X-Large            339        $4.5           0.07%       232       $37.9           0.12%
     Potatoes
    Convenient Meals  Convenient Meals--       340        $4.5           0.07%       603       $11.2           0.04%
                       Adult Meal
    Bacon             Bacon--Poultry           341        $4.5           0.07%       435       $18.4           0.06%
    Smoked Hams       Hams--Whole              342        $4.5           0.07%       510       $14.6           0.05%
                       Boneless
    Fluid Milk        Half & Half              343        $4.4           0.07%       149       $54.6           0.17%
     Products
    Deli Meat: Bulk   Meat Bulk:               344        $4.4           0.07%       302       $28.3           0.09%
                       Specialty Dry
                       Meats
    Frozen Vegetable  Fz Box Vegetables--      345        $4.4           0.07%       349       $24.7           0.08%
     & Veg Dish        Value-Added
    Apples            Apples Granny            346        $4.4           0.07%       277       $30.9           0.10%
                       Smith (Bulk &
                       Bag)
    Baking Needs      Bits & Morsels           347        $4.4           0.07%       162       $50.3           0.16%
                       [Baking Needs]
    Meat--Shelf       Chunk Meats--Chix/       348        $4.4           0.07%       338       $25.3           0.08%
     Stable            Ham/Etc.
    Yogurt            Yogurt/Large Size        349        $4.4           0.07%       219       $40.4           0.13%
                       (16oz Or Larger)
    Energy Drinks     Energy Drink--           350        $4.3           0.07%       421       $19.0           0.06%
                       Multi-Pack
    Frozen Fruits     Frozen Fruit             351        $4.3           0.07%       174       $48.6           0.15%
    Turkey Frozen     Whole Toms (Over         352        $4.3           0.06%       407       $20.0           0.06%
                       16lbs) [Turkey]
    Lunchmeat         Lunchmeat--Whole         353        $4.2           0.06%       413       $19.7           0.06%
                       Muscle Pltry
    Dry Bean Veg &    Dry Beans/Peas/          354        $4.2           0.06%       425       $18.8           0.06%
     Rice              Barley: Bag &
                       Bulk
    Frozen            Adult Premium            355        $4.2           0.06%       151       $54.5           0.17%
     Novelties--Wate   [Frozen
     r Ice             Novelties]
    Traditional       Mexican Dinners          356        $4.2           0.06%       597       $11.4           0.04%
     Mexican Foods     And Foods
    Salad Mix         Kits [Salad Mix]         357        $4.2           0.06%       258       $33.5           0.11%
    Cookies           Premium Cookies          358        $4.2           0.06%       269       $31.5           0.10%
    Peanut Butter/    Honey                    359        $4.1           0.06%       294       $28.9           0.09%
     Jelly/Jams &
     Honey
    Pickle/Relish/    Ripe Olives              360        $4.1           0.06%       337       $25.3           0.08%
     Pckld Veg &
     Olives
    Bacon             Bacon--Pre-Cooked        361        $4.1           0.06%       346       $24.8           0.08%
    Rolls             Rolls: Sandwich          362        $4.1           0.06%       322       $26.7           0.08%
    Potatoes          Potatoes Red (Bulk       363        $4.1           0.06%       264       $32.0           0.10%
                       & Bag)
    Croutons/Bread    Salad Toppers            364        $4.1           0.06%       500       $15.1           0.05%
     Stick & Salad
     Top
    Candy--Packaged   Gum (Packaged)           365        $4.1           0.06%       331       $25.9           0.08%
    Baking Needs      Baking Nuts              366        $4.1           0.06%       201       $43.2           0.14%
    Soft Drinks       Soft Drinks 6pk          367        $4.1           0.06%       308       $27.8           0.09%
                       Can Carb
    Single Serve      Applesauce Cup           368        $4.1           0.06%       370       $22.6           0.07%
     Fruit/
     Applesauce
    Dry Sce/Gravy/    Gravy Can/Glass          369        $4.0           0.06%       485       $15.7           0.05%
     Potatoes/
     Stuffng
    Cookies           Graham Crackers          370        $4.0           0.06%       342       $24.9           0.08%
    Candy--Packaged   Miscellaneous            371        $4.0           0.06%       418       $19.0           0.06%
                       Candy
    Frozen Vegetable  Frzn Corn On The         372        $4.0           0.06%       708        $8.4           0.03%
     & Veg Dish        Cob
    Cookies           Chocolate Covered        373        $4.0           0.06%       432       $18.5           0.06%
                       Cookies
    Value-Added       Vegetable Party          374        $4.0           0.06%       341       $25.1           0.08%
     Vegetables        Tray
    Value-Added       Cut Vegetables All       375        $4.0           0.06%       213       $42.2           0.13%
     Vegetables        Other
    Deli Meat: Bulk   Bologna/Loaves/          376        $4.0           0.06%       415       $19.2           0.06%
                       Franks
    Condiments &      Marinades                377        $3.9           0.06%       434       $18.4           0.06%
     Sauces
    Nuts              Pistachios               378        $3.9           0.06%       293       $29.1           0.09%
    Service Case      Seasoned Poultry         379        $3.9           0.06%       463       $16.5           0.05%
     Meat
    Salad & Dips      Protein Salads--         380        $3.9           0.06%       326       $26.3           0.08%
                       Bulk
    Hot Cereal        Standard Oatmeal         381        $3.9           0.06%       284       $29.9           0.09%
    Cheese            Miscellaneous            382        $3.8           0.06%       214       $42.1           0.13%
                       Cheese
    Salad & Dips      Vegetable Salads--       383        $3.8           0.06%       275       $31.0           0.10%
                       Bulk
    Shelf Stable      Veg Juice (Except        384        $3.8           0.06%       279       $30.4           0.10%
     Juice             Tomato)
    Juices Super      Juices Superfoods/       385        $3.8           0.06%       367       $22.8           0.07%
     Premium           Enhanced
    Breakfast         Bkfst Sausage--          386        $3.8           0.06%       651        $9.8           0.03%
     Sausage           Fresh Patties
    Vegetables        Asparagus                387        $3.8           0.06%       159       $50.7           0.16%
     Cooking Bulk
    Baby Foods        Baby Food Cereals        388        $3.8           0.06%       756        $7.1           0.02%
    Baked Breads      English Muffins/         389        $3.8           0.06%       169       $49.5           0.16%
                       Waffles
    Baked Breads      Main Meal Bread          390        $3.8           0.06%       252       $34.9           0.11%
    Juice             Non-Carb Jce (Over       391        $3.8           0.06%       268       $31.7           0.10%
                       50% Juice)
    Deli Meat: Bulk   Meat: Chicken Bulk       392        $3.7           0.06%       253       $34.6           0.11%
    Breakfast         Bkfst Sausage--          393        $3.7           0.06%       385       $21.4           0.07%
     Sausage           Precooked
    Dietary Aid       Diet Cntrl Liqs          394        $3.7           0.06%       281       $30.3           0.10%
     Prdct/Med Liq     Nutritional
     Nutr
    Refrgratd Juices/ Fruit Drinks             395        $3.7           0.06%     1,041        $2.8           0.01%
     Drinks Dairy
     Case
    Dinner Sausage    Dnr Sausage--Beef        396        $3.7           0.06%       577       $12.2           0.04%
                       Rope Ckd
    Canned Pasta &    Microwavable Cups        397        $3.7           0.06%       690        $9.0           0.03%
     Mwv Fd-Shlf
     Stbl
    Turkey Frozen     Whole Hens (Under        398        $3.6           0.06%       419       $19.0           0.06%
                       16lbs) [Turkey]
    Cakes             Cakes: Cheesecake        399        $3.6           0.06%       507       $14.7           0.05%
    Enhancements      Enhancements--Pick       400        $3.6           0.06%       410       $19.8           0.06%
     (Pickles/         les/Kraut
     Spreads)
    Tomatoes          Tomatoes Vine Ripe       401        $3.6           0.06%       743        $7.3           0.02%
                       Pkg
    Peppers           Peppers Red Bell         402        $3.6           0.05%       211       $42.5           0.13%
    Dinner Sausage    Dnr Sausage--Other       403        $3.6           0.05%       381       $21.6           0.07%
                       Forms
    Pork Offal        External Fresh           404        $3.5           0.05%       937        $4.2           0.01%
    Pasta & Pizza     Value [Pasta &           405        $3.5           0.05%       657        $9.7           0.03%
     Sauce             Pizza Sauce]
    Aseptic Juice     Aseptic Pack Juice       406        $3.5           0.05%       934        $4.2           0.01%
                       And Drinks
    Berries           Raspberries              407        $3.5           0.05%       186       $45.8           0.15%
    Beef: Thin Meats  Corned Beef              408        $3.5           0.05%       461       $16.9           0.05%
    Party Tray        Deli Tray: Meat          409        $3.5           0.05%       383       $21.5           0.07%
                       And Cheese
    Can Vegetables--  Peas/Green               410        $3.5           0.05%       504       $14.7           0.05%
     Shelf Stable
    Dry/Ramen         Dry Soup                 411        $3.5           0.05%       362       $23.3           0.07%
     Bouillon
    Can Vegetables--  Spinach & Greens         412        $3.5           0.05%       765        $7.0           0.02%
     Shelf Stable
    Frzn Multi Serve  Fz Meatballs             413        $3.5           0.05%       447       $17.7           0.06%
    Milk By-Products  Aerosol Toppings         414        $3.5           0.05%       351       $24.5           0.08%
                       [Milk By-
                       Products]
    Baked Breads      Dinner Rolls             415        $3.5           0.05%       513       $14.5           0.05%
    Cocoa Mixes       Hot Chocolate/           416        $3.5           0.05%       445       $17.8           0.06%
                       Cocoa Mix
    Infant Formula    Infant Formula           417        $3.5           0.05%       768        $6.9           0.02%
                       Ready To Use
    Powder & Crystal  Sugar Free               418        $3.5           0.05%       391       $21.1           0.07%
     Drink Mix         Canister [Powder
                       Drink Mix]
    Cnv Breakfast &   Treats [Breakfast]       419        $3.5           0.05%       605       $11.2           0.04%
     Wholesome Snks
    Smoked Hams       Hams--Half/Port          420        $3.4           0.05%       392       $21.0           0.07%
                       Boneless
    Fitness & Diet    Fitness & Diet--         421        $3.4           0.05%       124       $59.8           0.19%
                       Bars W/Flour
    Refrgrated Dough  Refrigerated             422        $3.4           0.05%       551       $12.9           0.04%
     Products          Cookie Dough
    Grapes            Grapes Black/Blue        423        $3.4           0.05%       380       $21.8           0.07%
    Bulk Service      Bulk Processed           424        $3.4           0.05%       411       $19.8           0.06%
     Case Cheese       [Cheese]
    Candy--Packaged   Seasonal Candy           425        $3.4           0.05%       462       $16.6           0.05%
                       Box--Chocolate
    Coffee &          Coffee Pods/             426        $3.4           0.05%       167       $49.8           0.16%
     Creamers          Singles/Filter
                       Pack
    Can Fruit/Jar     Fruit Cocktail/          427        $3.4           0.05%       569       $12.5           0.04%
     Applesauce        Fruit Salad
    Peppers           Peppers Other Bell       428        $3.4           0.05%       301       $28.4           0.09%
    Mushrooms         Mushrooms White          429        $3.3           0.05%       306       $27.8           0.09%
                       Sliced Pkg
    Lunchmeat         Lunchmeat--Chip          430        $3.3           0.05%       653        $9.7           0.03%
                       Meat
    Soft Drinks       Sft Drnk 1 Liter         431        $3.3           0.05%       716        $8.2           0.03%
                       Btl Carb
    Cakes             Cakes: Fancy/            432        $3.3           0.05%       451       $17.4           0.06%
                       Service Case
    Salad Mix         Shredded Lettuce         433        $3.3           0.05%       616       $10.9           0.03%
    Powder & Crystal  Sugar Free Sticks        434        $3.3           0.05%       426       $18.8           0.06%
     Drink Mix         [Powder Drink
                       Mix]
    Dinner Mixes-Dry  Package Dinners/         435        $3.3           0.05%       664        $9.5           0.03%
                       Pasta Salads
    Cakes             Cakes: Layers/           436        $3.3           0.05%       565       $12.5           0.04%
                       Sheets Novelties
    Flour & Meals     Breadings/Coatings/      437        $3.2           0.05%       474       $16.0           0.05%
                       Crumbs
    Pies              Pies: Pumpkin/           438        $3.2           0.05%       545       $13.1           0.04%
                       Custard
    Refrigerated      Yogurt                   439        $3.2           0.05%       107       $67.0           0.21%
     Dairy Case
    Apples            Mixed Fruit Bags         440        $3.2           0.05%       829        $5.7           0.02%
    Shelf Stable      Fruit Drinks:            441        $3.2           0.05%       870        $5.0           0.02%
     Juice             Canned & Glass
    Dry Mix Desserts  Puddings Dry             442        $3.2           0.05%       400       $20.8           0.07%
    Can Seafood--     Salmon                   443        $3.2           0.05%       534       $13.6           0.04%
     Shelf Stable
    Shortening & Oil  Cooking Sprays           444        $3.2           0.05%       396       $21.0           0.07%
    Meat--Shelf       Sandwich Sauce           445        $3.2           0.05%       733        $7.7           0.02%
     Stable            (Manwich)
    Bread             Bread: Specialty         446        $3.2           0.05%       366       $22.9           0.07%
    Seafood--Tilapia  Tilapia--Fillet          447        $3.2           0.05%       465       $16.4           0.05%
    Frzn Multi Serve  Frzn Burgers             448        $3.2           0.05%     1,010        $3.1           0.01%
    Convenience/      Jarred Fruit             449        $3.1           0.05%       511       $14.6           0.05%
     Snacking          Single Serve
    Powder & Crystal  Soft Drink               450        $3.1           0.05%       723        $7.9           0.03%
     Drink Mix         Canisters
    Frozen Breakfast  Frzn Breakfast           451        $3.1           0.05%       647        $9.8           0.03%
     Foods             Sausage
    Ss/Vending--      Vendor Size/Single       452        $3.1           0.05%       770        $6.8           0.02%
     Cookie/Cracker    Serve Cookie
    Water--(Sparklin  Sparkling Water--        453        $3.1           0.05%       355       $24.1           0.08%
     g & Still)        Flvrd Sweet
    Service Case      Stuffed/Mixed Beef       454        $3.1           0.05%       416       $19.2           0.06%
     Meat
    Meat--Shelf       Vienna Sausage           455        $3.1           0.05%       867        $5.1           0.02%
     Stable
    Mushrooms         Mushrooms White          456        $3.1           0.05%       288       $29.6           0.09%
                       Whole Pkg
    Teas              Tea Bags/Herbal          457        $3.1           0.05%       272       $31.2           0.10%
    Meat Frozen       Frzn Meat--Offals        458        $3.0           0.05%     1,053        $2.6           0.01%
    Bulk Service      Bulk Semi-Soft           459        $3.0           0.05%       363       $23.3           0.07%
     Case Cheese
    Bag Snacks        Bagged Popped            460        $3.0           0.05%       566       $12.5           0.04%
                       Popcorn
    Condiments &      Yellow Mustard           461        $3.0           0.05%       571       $12.4           0.04%
     Sauces
    Vegetables Salad  Green Onions             462        $3.0           0.05%       361       $23.5           0.07%
    Frozen Bread/     Frzn Dinner Rolls        463        $3.0           0.05%       398       $20.9           0.07%
     Dough
    Baking Needs      Marshmallows             464        $3.0           0.05%       467       $16.4           0.05%
    Warehouse Snacks  Snack Mix                465        $3.0           0.05%       450       $17.5           0.06%
    Fluid Milk        Whipping Cream           466        $3.0           0.04%       249       $35.2           0.11%
     Products
    Dried Fruit       Raisins                  467        $2.9           0.04%       330       $26.0           0.08%
    Dinner Sausage    Dnr Sausage--Links       468        $2.9           0.04%       722        $8.0           0.03%
                       Beef Ckd
    Rolls             Rolls: Croissants/       469        $2.9           0.04%       464       $16.5           0.05%
                       Breadsticks
    Lunchmeat         Lunchmeat--Brauns/       470        $2.9           0.04%       632       $10.3           0.03%
                       Liver/Loave
    Cookie/Cracker    Multi-Pack Cookies       471        $2.9           0.04%       596       $11.4           0.04%
     Multi-Pks
    Snack Meat        Snack Meat--Salami/      472        $2.9           0.04%       481       $15.8           0.05%
                       Smr Sausage
    Shortening & Oil  Solid Shortening         473        $2.9           0.04%       525       $14.0           0.04%
    Salad Mix         Salad Bowls              474        $2.9           0.04%       572       $12.3           0.04%
    Hot Cereal        Grits                    475        $2.8           0.04%       774        $6.7           0.02%
    Cereals           Cereal--Cold             476        $2.8           0.04%       178       $47.8           0.15%
    Frozen Vegetable  Fz Bag Vegetables--      477        $2.8           0.04%       505       $14.7           0.05%
     & Veg Dish        Value-Added
    Traditional       Asian Other Sauces/      478        $2.8           0.04%       422       $18.9           0.06%
     Asian Foods       Marinade
    Frozen            Cups/Push Ups/           479        $2.8           0.04%       661        $9.6           0.03%
     Novelties--Wate   Other [Frozen
     r Ice             Novelties]
    Refrigerated      Refrigerated             480        $2.8           0.04%       669        $9.4           0.03%
     Hispanic          Tortillas
     Grocery
    Frzn Prepared     Whole Muscle             481        $2.8           0.04%       555       $12.8           0.04%
     Chicken           Unbreaded Chicken
    Meat--Shelf       Luncheon Meat            482        $2.8           0.04%       693        $8.9           0.03%
     Stable            (Spam)
    Frzn Prepared     Boneless Snack/          483        $2.8           0.04%       836        $5.5           0.02%
     Chicken           Value/Small
    Croutons/Bread    Croutons                 484        $2.8           0.04%       526       $14.0           0.04%
     Stick & Salad
     Top
    Apples            Apples Other (Bulk       485        $2.8           0.04%       314       $27.4           0.09%
                       & Bag)
    Apples            Apples Fuji (Bulk        486        $2.8           0.04%       242       $36.2           0.11%
                       & Bag)
    Apples            Apples Gold              487        $2.8           0.04%       443       $17.9           0.06%
                       Delicious (Bulk &
                       Bag)
    Salad & Dips      Sal: Hommus              488        $2.8           0.04%       189       $45.4           0.14%
    Dinner Sausage    Dnr Sausage--            489        $2.7           0.04%       562       $12.7           0.04%
                       Cocktails
    Can Vegetables--  Mushrooms Cnd &          490        $2.7           0.04%       521       $14.3           0.05%
     Shelf Stable      Glass
    Frozen Desserts   Frzn Pie Shells/         491        $2.7           0.04%       475       $16.0           0.05%
                       Pastry Shell
    Lunchmeat         Lunchmeat--Variety       492        $2.7           0.04%       677        $9.3           0.03%
                       Pack
    Frozen Desserts   Frozen Cakes/            493        $2.7           0.04%       611       $11.0           0.03%
                       Desserts
    Pickle/Relish/    Peppers                  494        $2.7           0.04%       537       $13.5           0.04%
     Pckld Veg &
     Olives
    Cakes             Cakes: Angel Fds/        495        $2.7           0.04%       440       $18.1           0.06%
                       Cke Rolls
    Berries           Blackberries             496        $2.7           0.04%       283       $29.9           0.09%
    Frozen Bread/     Frzn Garlic Bread        497        $2.7           0.04%       608       $11.1           0.04%
     Dough
    Traditional       Mexican Enchilada        498        $2.7           0.04%       532       $13.7           0.04%
     Mexican Foods     Sauce
    Fluid Milk        Egg Nog/Boiled           499        $2.7           0.04%       539       $13.3           0.04%
     Products          Custard
    Hot Dogs          Hot Dogs--Base           500        $2.7           0.04%       667        $9.4           0.03%
                       Poultry
    Beef: Thin Meats  Brisket [Beef]           501        $2.7           0.04%       446       $17.8           0.06%
    Cookies           Wellness/Portion         502        $2.7           0.04%       358       $23.8           0.08%
                       Control [Cookies]
    Baking Needs      Pie Filling/             503        $2.7           0.04%       345       $24.8           0.08%
                       Mincemeat/Glazes
    Soft Drinks       Tea Can With             504        $2.7           0.04%       807        $6.1           0.02%
                       Sweetener/Sugar
    Citrus            Limes                    505        $2.7           0.04%       369       $22.7           0.07%
    Warehouse Snacks  Misc Snacks              506        $2.6           0.04%       541       $13.2           0.04%
    Traditional       Mexican Taco Sauce       507        $2.6           0.04%       761        $7.0           0.02%
     Mexican Foods
    Soft Drinks       Soft Drink Bottle        508        $2.6           0.04%       887        $4.7           0.02%
                       Non-Carb
    Seafood--Salmon-  Salmon Wc--Pink          509        $2.6           0.04%       612       $11.0           0.03%
     Wild Caught
    Frozen Bread/     Frzn Biscuits            510        $2.6           0.04%       550       $12.9           0.04%
     Dough
    Frzn Pasta        Frozen Pasta             511        $2.6           0.04%       458       $16.9           0.05%
    Chicken Frozen    Frzn Chicken--Drk        512        $2.6           0.04%       818        $5.9           0.02%
                       Meat
    Syrups Toppings   Ice Cream Toppings       513        $2.6           0.04%       524       $14.1           0.04%
     & Cones
    Candy--Packaged   Seasonal Candy           514        $2.6           0.04%       502       $14.9           0.05%
                       Bags Non-
                       Chocolate
    Salad & Dips      Pasta/Grain              515        $2.6           0.04%       631       $10.3           0.03%
                       Salads--Prepack
    Cakes             Cakes: Ice Cream         516        $2.6           0.04%       700        $8.6           0.03%
    Nuts              Mixed Nuts               517        $2.6           0.04%       309       $27.6           0.09%
    Sushi             Sushi--Prepackaged       518        $2.6           0.04%       414       $19.2           0.06%
    Pickle/Relish/    Green Olives             519        $2.6           0.04%       483       $15.8           0.05%
     Pckld Veg &
     Olives
    Candy--Packaged   Candy Bars Multi         520        $2.6           0.04%       695        $8.8           0.03%
                       Pack W/Flour
    Stone Fruit       Nectarines Yellow        521        $2.5           0.04%       430       $18.6           0.06%
                       Flesh
    Onions            Onions Red (Bulk &       522        $2.5           0.04%       397       $20.9           0.07%
                       Bag)
    Flour & Meals     Cornmeal                 523        $2.5           0.04%       746        $7.3           0.02%
    Tropical Fruit    Pineapple Whole &        524        $2.5           0.04%       377       $22.1           0.07%
                       Peel/Cored
    Bagels & Cream    Refrigerated             525        $2.5           0.04%       731        $7.7           0.02%
     Cheese            Bagels
    Onions            Onions White (Bulk       526        $2.5           0.04%       482       $15.8           0.05%
                       & Bag)
    Meat Frozen       Frzn Meat--Turkey        527        $2.5           0.04%       652        $9.7           0.03%
    Pickle/Relish/    Relishes                 528        $2.5           0.04%       590       $11.6           0.04%
     Pckld Veg &
     Olives
    Candy--Packaged   Candy Bags--             529        $2.5           0.04%       496       $15.2           0.05%
                       Chocolate W/Flour
    Nuts              Cashews                  530        $2.5           0.04%       437       $18.3           0.06%
    Cakes             Cakes:Birthday/          531        $2.5           0.04%       684        $9.1           0.03%
                       Celebration Lay
    Smoked Pork       Smoked Offal             532        $2.4           0.04%       940        $4.1           0.01%
                       [Pork]
    Apples            Apples Honeycrisp        533        $2.4           0.04%       235       $36.9           0.12%
    Sweet Goods &     Sw Gds: Swt/Flvrd        534        $2.4           0.04%       528       $13.9           0.04%
     Snacks            Loaves
    Fluid Milk        Buttermilk               535        $2.4           0.04%       478       $15.9           0.05%
     Products
    Cakes             Cakes: Sheet             536        $2.4           0.04%       750        $7.2           0.02%
    Cookies           Cookies: Gourmet         537        $2.4           0.04%       399       $20.8           0.07%
    Citrus            Grapefruit               538        $2.4           0.04%       388       $21.2           0.07%
    Coffee &          Flavored Bag             539        $2.4           0.04%       328       $26.2           0.08%
     Creamers          Coffee
    Stone Fruit       Plums                    540        $2.4           0.04%       543       $13.1           0.04%
    Refrigerated      Refrigerated Pasta       541        $2.4           0.04%       290       $29.3           0.09%
     Italian
    Spices &          Gourmet Spices           542        $2.4           0.04%       259       $33.2           0.11%
     Extracts
    Baked Breads      Diet/Light Bread         543        $2.4           0.04%       356       $24.0           0.08%
    Bacon             Bacon--Trad Center       544        $2.3           0.04%       395       $21.0           0.07%
                       Cut
    Salad & Dips      Pasta/Grain              545        $2.3           0.04%       460       $16.9           0.05%
                       Salads--Bulk
    Rice Cakes        Mini-Cakes               546        $2.3           0.04%       454       $17.2           0.05%
    Authentic         Authentic Sauces/        547        $2.3           0.03%       678        $9.2           0.03%
     Hispanic Fds &    Salsa/Picante
     Product
    Ice Cream Ice     Premium Pints [Ice       548        $2.3           0.03%       787        $6.5           0.02%
     Milk & Sherbets   Cream & Sherbert]
    Can Fruit/Jar     Mandarin Oranges/        549        $2.3           0.03%       564       $12.6           0.04%
     Applesauce        Citrus Sect
    Baby Foods        Baby Juices              550        $2.3           0.03%      1013        $3.1           0.01%
    Salad Mix         Salad Mix Blends         551        $2.3           0.03%       239       $36.5           0.12%
                       Organic
    Salad & Dips      Salad: Lettuce           552        $2.2           0.03%       576       $12.2           0.04%
    Baked Breads      Fruit/Breakfast          553        $2.2           0.03%       427       $18.7           0.06%
                       Bread
    Seafood--Salad/   Breading [Seafood]       554        $2.2           0.03%       966        $3.7           0.01%
     Dip/Sce/Cond
    Seafood--Finfish  Finfish--Other           555        $2.2           0.03%       826        $5.8           0.02%
     Other
    Frozen Bread/     Frzn Breadsticks         556        $2.2           0.03%       871        $5.0           0.02%
     Dough
    Bag Snacks        Pork Skins/              557        $2.2           0.03%       804        $6.2           0.02%
                       Cracklins
    Frozen Juice And  Frzn Conc Allieds        558        $2.2           0.03%       638       $10.1           0.03%
     Smoothies         Over 50% Juice
    Broccoli/         Cauliflower Whole        559        $2.2           0.03%       352       $24.5           0.08%
     Cauliflower
    Mushrooms         Mushrooms                560        $2.2           0.03%       372       $22.6           0.07%
                       Portabella
    Tropical Fruit    Mango                    561        $2.2           0.03%       522       $14.1           0.04%
    Seafood--Lobster  Lobster--Tails           562        $2.2           0.03%       546       $13.0           0.04%
    Can Fruit/Jar     Apple Sauce              563        $2.2           0.03%       530       $13.8           0.04%
     Applesauce        (Excludes Cup)
    Traditional       Mexican Peppers          564        $2.2           0.03%       487       $15.7           0.05%
     Mexican Foods     Chilies
    Candy--Checklane  Mints/Candy &            565        $2.1           0.03%       582       $12.1           0.04%
                       Breath
    Citrus            Tangerines &             566        $2.1           0.03%       600       $11.3           0.04%
                       Tangelos
    Juices Super      Juices Smoothies/        567        $2.1           0.03%       613       $11.0           0.03%
     Premium           Blended
    Can Vegetables--  Fried Onions             568        $2.1           0.03%       574       $12.3           0.04%
     Shelf Stable
    Carrots           Carrots Bagged           569        $2.0           0.03%       453       $17.2           0.05%
    Eggs/Muffins/     Eggs--Jumbo              570        $2.0           0.03%       548       $13.0           0.04%
     Potatoes
    Potatoes          Potatoes Gourmet         571        $2.0           0.03%       405       $20.3           0.06%
    Can Vegetables--  Sweet Potatoes           572        $2.0           0.03%       777        $6.7           0.02%
     Shelf Stable
    Seafood--Value-   Value-Added Shrimp       573        $2.0           0.03%       840        $5.4           0.02%
     Added Seafood
    Baked Breads      Rye Breads               574        $2.0           0.03%       375       $22.3           0.07%
    Salad Dresing &   Dry Salad Dressing       575        $2.0           0.03%       498       $15.1           0.05%
     Sandwich          & Dip Mixes
     Spreads
    Condiments &      Mustard--All Other       576        $2.0           0.03%       436       $18.3           0.06%
     Sauces
    Fluid Milk        Organic Milk             577        $2.0           0.03%       245       $35.4           0.11%
     Products
    Dry Mix Desserts  Gelatin                  578        $2.0           0.03%       517       $14.3           0.05%
    Nuts              Sunflower/Other          579        $1.9           0.03%       656        $9.7           0.03%
                       Seeds
    Vinegar &         Vinegar/White &          580        $1.9           0.03%       515       $14.4           0.05%
     Cooking Wines     Cider
    Dinner Sausage    Dnr Sausage--            581        $1.9           0.03%       618       $10.9           0.03%
                       Poultry Rope Ckd
    Corn              Corn Is Packaged         582        $1.9           0.03%       556       $12.8           0.04%
    Candy--Packaged   Miscellaneous            583        $1.9           0.03%       607       $11.2           0.04%
                       Candy
    Milk By-Products  Ricotta Cheese           584        $1.9           0.03%       490       $15.6           0.05%
    Hot Cereal        Other Hot Cereal         585        $1.9           0.03%       628       $10.3           0.03%
    Frozen Juice And  Frzn Oj&Oj               586        $1.9           0.03%       472       $16.2           0.05%
     Smoothies         Substitutes (Over
                       50%)
    Sweet Goods &     Sw Gds: Brownie/         587        $1.9           0.03%       606       $11.2           0.04%
     Snacks            Bar Cookie
    Rolls             Rolls: Bagels            588        $1.9           0.03%       494       $15.4           0.05%
    Melons            Watermelon               589        $1.9           0.03%       477       $15.9           0.05%
                       Personal
    Nuts              Pecans Shelled           590        $1.9           0.03%       448       $17.6           0.06%
    Infant Formula    Baby Isotonic            591        $1.9           0.03%       878        $4.9           0.02%
                       Drinks
    Mixers            Cocktail Mixes-          592        $1.9           0.03%       468       $16.4           0.05%
                       Fluid: Add Liq
    Bananas           Bananas Organic          593        $1.9           0.03%       428       $18.7           0.06%
    Seafood--Crab     Crab--King               594        $1.9           0.03%       725        $7.9           0.02%
    Bacon             Bacon--Other             595        $1.9           0.03%       655        $9.7           0.03%
    Can Fruit/Jar     Pears                    596        $1.9           0.03%       646       $10.0           0.03%
     Applesauce
    Baking Mixes      Biscuit Flour &          597        $1.9           0.03%       529       $13.8           0.04%
                       Mixes
    Chicken           Chicken Breast           598        $1.9           0.03%       343       $24.9           0.08%
     Specialty/        Boneless
     Natural
    Sweet Goods       Sw Gds: Coffee           599        $1.8           0.03%       588       $11.9           0.04%
                       Cakes
    Refrigerated      Eggs                     600        $1.8           0.03%       289       $29.5           0.09%
     Dairy Case
    Condiments &      Wing Sauce               601        $1.8           0.03%       872        $5.0           0.02%
     Sauces
    Seafood--Salmon-  Salmon Wc--Sockeye       602        $1.8           0.03%       335       $25.7           0.08%
     Wild Caught
    Baking Needs      Pie Crust Mixes &        603        $1.8           0.03%       676        $9.3           0.03%
                       Shells
    Salad Mix         Salad Spinach            604        $1.8           0.03%       442       $17.9           0.06%
    Eggs/Muffins/     Eggs Substitute          605        $1.8           0.03%       329       $26.2           0.08%
     Potatoes
    Crackers & Misc   Aerosol Cheese           606        $1.8           0.03%       857        $5.2           0.02%
     Baked Food
    Poultry Other     Cornish Hen              607        $1.8           0.03%       773        $6.7           0.02%
    Tomato Products-  Tomato Paste             608        $1.8           0.03%       633       $10.2           0.03%
     Shelf Stable
    Turkey Frozen     Turkey Breast Bone       609        $1.8           0.03%       553       $12.8           0.04%
                       In
    Sweet Goods &     Sw Gds: Puff             610        $1.8           0.03%       573       $12.3           0.04%
     Snacks            Pastry
    Seafood--Catfish  Catfish--Whole           611        $1.8           0.03%     1,055        $2.6           0.01%
    Cake Decor        Cake Decors &            612        $1.8           0.03%       645       $10.0           0.03%
                       Icing
    Convenience/      Convenience/             613        $1.8           0.03%       670        $9.4           0.03%
     Snacking          Snacking Fruit
    Salad & Dips      Sal: Salsa/Dips          614        $1.8           0.03%       730        $7.7           0.02%
                       Bulk
    Pork Bone In      Dry [Pork Bone In        615        $1.8           0.03%       734        $7.6           0.02%
     Loin/Rib          Loin/Rib]
    Authentic         Authentic Pasta/         616        $1.7           0.03%       884        $4.8           0.02%
     Hispanic Fds &    Rice/Beans
     Product
    Spices &          Pure Extracts            617        $1.7           0.03%       493       $15.4           0.05%
     Extracts
    Powder & Crystal  Enhanced Stick           618        $1.7           0.03%       621       $10.7           0.03%
     Drink Mix         [Powder Drink
                       Mix]
    Bread             Bread: Artisan           619        $1.7           0.03%       237       $36.7           0.12%
    Infant Formula    Infant Formula Soy       620        $1.7           0.03%     1,270        $1.1           0.00%
                       Base
    Juices Super      Juices Proteins          621        $1.7           0.03%       640       $10.1           0.03%
     Premium
    Salad & Dips      Sal: Dip Prepack         622        $1.7           0.03%       584       $12.1           0.04%
                       [Salad & Dips]
    Dietary Aid       Diet Energy Drinks       623        $1.7           0.03%       554       $12.8           0.04%
     Prdct/Med Liq
     Nutr
    Nuts              Peanuts All              624        $1.7           0.03%       594       $11.5           0.04%
    Rts/Micro Soup/   Microwavable Soups       625        $1.7           0.03%       495       $15.3           0.05%
     Broth
    Service Case      Marinated Pork           626        $1.7           0.03%       519       $14.3           0.05%
     Meat
    Chicken &         Chix: Baked 8pc          627        $1.7           0.03%       837        $5.5           0.02%
     Poultry           Cut Up (Cold)
    Vegetables        Beans                    628        $1.7           0.03%       457       $16.9           0.05%
     Cooking Bulk
    Baby Foods        Baby Spring Waters       629        $1.7           0.03%     1,128        $2.0           0.01%
    Shelf Stable      Tomato Juice (Over       630        $1.7           0.03%       662        $9.6           0.03%
     Juice             50% Jce)
    Authentic         Authentic                631        $1.7           0.03%       998        $3.2           0.01%
     Hispanic Fds &    Vegetables And
     Product           Foods
    Meat Snacks       Meat Sticks/Bites        632        $1.7           0.03%       972        $3.6           0.01%
    Refrigerated      Hispanic Cheese          633        $1.7           0.03%       769        $6.9           0.02%
     Hispanic
     Grocery
    Can Fruit/Jar     Cranberry Sauce          634        $1.7           0.03%       642       $10.0           0.03%
     Applesauce
    Fitness & Diet    Fitness & Diet--         635        $1.7           0.03%       298       $28.7           0.09%
                       Bars W/O Flour
    Pies              Pies: Cream/             636        $1.6           0.02%       728        $7.8           0.02%
                       Meringue
    Berries           Strawberries             637        $1.6           0.02%       386       $21.4           0.07%
                       Organic
    Candy--Packaged   Novelty Candy            638        $1.6           0.02%       827        $5.7           0.02%
    Party Tray        Deli Tray:               639        $1.6           0.02%       636       $10.2           0.03%
                       Sandwiches
    Value-Added       Cut Fruit All            640        $1.6           0.02%       704        $8.5           0.03%
     Fruit             Other Prepack
    Nuts              Walnuts Shelled          641        $1.6           0.02%       431       $18.5           0.06%
    Turkey Offal      External [Turkey]        642        $1.6           0.02%     1,133        $2.0           0.01%
    Flour & Meals     Flour: Misc/             643        $1.6           0.02%       533       $13.6           0.04%
                       Specialty/Blend
    Frozen Ethnic     Frozen                   644        $1.6           0.02%       771        $6.7           0.02%
                       Internaional
                       [Ethnic Foods]
    Deli Meat:        Deli Meat:               645        $1.6           0.02%       336       $25.5           0.08%
     Presliced         Specialty Dry
                       Meats
    Dressings/Dips    Dressing Creamy          646        $1.6           0.02%       512       $14.5           0.05%
    Spices &          Table Salt/Popcorn       647        $1.6           0.02%       698        $8.6           0.03%
     Extracts          Salt
    Meat--Shelf       Hash: Canned             648        $1.6           0.02%       863        $5.1           0.02%
     Stable            [Meat]
    Water--(Sparklin  Distilled Water          649        $1.6           0.02%       579       $12.2           0.04%
     g & Still)
    Frozen Desserts   Frzn Pastry &            650        $1.6           0.02%       694        $8.8           0.03%
                       Cookies
    Potatoes          Potatoes Gold            651        $1.6           0.02%       503       $14.8           0.05%
                       (Bulk & Bag)
    Herbs/Garlic      Garlic Whole             652        $1.6           0.02%       557       $12.7           0.04%
                       Cloves
    Salad Mix         Coleslaw                 653        $1.6           0.02%       589       $11.9           0.04%
    Apples            Caramel/Candy            654        $1.6           0.02%       985        $3.4           0.01%
                       Apples
    Nuts              Almonds Shelled          655        $1.5           0.02%       412       $19.8           0.06%
    Service Case      Marinated Poultry        656        $1.5           0.02%       702        $8.5           0.03%
     Meat
    Carrots           Carrots Bagged           657        $1.5           0.02%       429       $18.6           0.06%
                       Organic
    Frozen Desserts   Single Serv/             658        $1.5           0.02%       898        $4.6           0.01%
                       Portion Control
    Seasonal          Pumpkins                 659        $1.5           0.02%       626       $10.3           0.03%
    Chicken Offal     Internal [Chicken        660        $1.5           0.02%       929        $4.3           0.01%
                       Offal]
    Specialty Cheese  Specialty Ppk            661        $1.5           0.02%       299       $28.7           0.09%
     Pre Pack          Cheese Hard/
                       Grated
    Pears             Pears Bartlett           662        $1.5           0.02%       486       $15.7           0.05%
    Meat--Shelf       Beef Stew                663        $1.5           0.02%       897        $4.6           0.01%
     Stable
    Bread             Bread: Pita/Pocket/      664        $1.5           0.02%       523       $14.1           0.04%
                       Flatbrd
    Chicken &         Chix: Rotisserie         665        $1.5           0.02%       848        $5.4           0.02%
     Poultry           Cold
    Dry/Ramen         Bouillon                 666        $1.5           0.02%       663        $9.6           0.03%
     Bouillon
    Nuts              Trail Mix                667        $1.5           0.02%       610       $11.0           0.03%
    Enhancements      Enhancements--Sala       668        $1.5           0.02%       858        $5.2           0.02%
     (Pickles/         ds/Spreads
     Spreads)
    Smoked Pork       Bacon--Belly/Jowl        669        $1.5           0.02%       783        $6.6           0.02%
    Seafood--Cod      Cod--Fillet              670        $1.5           0.02%       587       $12.0           0.04%
    Refrgrated Dough  Refrigerated             671        $1.5           0.02%       834        $5.5           0.02%
     Products          Cookies--Seasonal
    Traditional       Asian Soy Sauce          672        $1.5           0.02%       630       $10.3           0.03%
     Asian Foods
    Salad Dresing &   Sand/Horseradish &       673        $1.4           0.02%       749        $7.2           0.02%
     Sandwich          Tartar Sauce
     Spreads
    Refrgrated Dough  Refrigerated Pie         674        $1.4           0.02%       538       $13.5           0.04%
     Products          Crust
    Frozen Juice And  Frzn Fruit Drinks        675        $1.4           0.02%       685        $9.1           0.03%
     Smoothies         (Under 10% Juice)
    Sweet Goods &     Sw Gds: Specialty        676        $1.4           0.02%       784        $6.6           0.02%
     Snacks            Desserts
    Dinner Mixes-Dry  Pizza Mix Dry            677        $1.4           0.02%       845        $5.4           0.02%
    Authentic         Central American         678        $1.4           0.02%       838        $5.5           0.02%
     Central           Foods
     American Fds
    Cereal Bars       Breakfast Bars/          679        $1.4           0.02%       360       $23.6           0.07%
                       Tarts/Scones
    Service Case      Seasoned Beef            680        $1.4           0.02%       724        $7.9           0.03%
     Meat
    Herbs/Garlic      Herbs Cilanto            681        $1.4           0.02%       637       $10.1           0.03%
    Value-Added       Fruit Party Tray         682        $1.4           0.02%       785        $6.5           0.02%
     Fruit             Prepack
    Dried Fruit       Dried Fruit--Other       683        $1.4           0.02%       491       $15.6           0.05%
    Non-Dairy/Dairy   Aseptic Milk             684        $1.4           0.02%       535       $13.6           0.04%
     Aseptic
    Eggs/Muffins/     Misc Dairy               685        $1.4           0.02%       686        $9.1           0.03%
     Potatoes          Refigerated
    Shelf Stable      Pineapple Juice          686        $1.4           0.02%       788        $6.4           0.02%
     Juice             (Over 50% Juice)
    Frozen Entrees    Meatless/                687        $1.4           0.02%       382       $21.5           0.07%
                       Vegetarian
    Powder & Crystal  Sugar Sweetened          688        $1.4           0.02%     1,071        $2.5           0.01%
     Drink Mix         Sticks
    Lunchmeat         Lunchmeat--Other         689        $1.4           0.02%       951        $3.9           0.01%
    Dietary Aid       Diet Cntrl Bars          690        $1.4           0.02%       409       $19.9           0.06%
     Prdct/Med Liq     Nutritional
     Nutr
    Popcorn           Popcorn--Other           691        $1.4           0.02%       641       $10.0           0.03%
    Salad & Dips      Sal: Desserts-           692        $1.4           0.02%       906        $4.5           0.01%
                       Prepack
    Dry Cheese        Misc Dry Cheese          693        $1.4           0.02%       739        $7.3           0.02%
    Shelf Stable      Cranberry Juice          694        $1.4           0.02%       706        $8.4           0.03%
     Juice             (Over 50% Juice)
    Baking Mixes      Cookies Mix              695        $1.4           0.02%       699        $8.6           0.03%
    Frozen Potatoes   Frzn Baked/Stuffed/      696        $1.3           0.02%       689        $9.0           0.03%
                       Mashed
    Turkey Fresh      Whole Hen (Under         697        $1.3           0.02%       658        $9.7           0.03%
                       16lbs) [Turkey]
    Vegetables        Broccoli/                698        $1.3           0.02%       567       $12.5           0.04%
     Cooking           Cauliflower
     Packaged          Processed
    Dressings/Dips    Dips Caramel/Fruit       699        $1.3           0.02%       819        $5.9           0.02%
                       Glazes
    Dressings/Dips    Dips Guacamole/          700        $1.3           0.02%       563       $12.6           0.04%
                       Salsa/Queso
    Meat--Shelf       Hot Dog Chili            701        $1.3           0.02%     1,063        $2.6           0.01%
     Stable            Sauce
    Breakfast         Bkfst Sausage--          702        $1.3           0.02%       986        $3.4           0.01%
     Sausage           Bkfast Side
    Traditional       Asian Noodles/Rice       703        $1.3           0.02%       623       $10.5           0.03%
     Asian Foods
    Deli Meat:        Deli Meat: Semi-         704        $1.3           0.02%       674        $9.3           0.03%
     Presliced         Dry Sausage
    Breakfast         Bkfst Sausage--          705        $1.3           0.02%       916        $4.4           0.01%
     Sausage           Other Forms
    Shortening & Oil  Corn Oil                 706        $1.3           0.02%       943        $4.1           0.01%
    Nuts              Almonds                  707        $1.3           0.02%       404       $20.5           0.06%
    Hot Cereal        Instant Breakfast        708        $1.3           0.02%       718        $8.1           0.03%
    Traditional       Asian Foods And          709        $1.3           0.02%       793        $6.3           0.02%
     Asian Foods       Meals
    Can Vegetables--  Mixed Vegetables         710        $1.3           0.02%       905        $4.5           0.01%
     Shelf Stable
    Authentic         Authentic Peppers        711        $1.3           0.02%       910        $4.5           0.01%
     Hispanic Fds &
     Product
    Dinner Sausage    Dnr Sausage--Links       712        $1.3           0.02%       766        $7.0           0.02%
                       Poultry Ck
    Snack             Tortilla Chips           713        $1.3           0.02%       408       $19.9           0.06%
    Salad & Dips      Sal: Salsa Prepack       714        $1.3           0.02%       531       $13.7           0.04%
    Fluid Milk        Soy Milk                 715        $1.3           0.02%       753        $7.1           0.02%
     Products
    Bread             Bread: Sweet/            716        $1.3           0.02%       707        $8.4           0.03%
                       Breakfast
    Bulk Food         Trail Mix/Nuts           717        $1.3           0.02%       441       $18.0           0.06%
                       Bulk
    Service Case      Seasoned Pork            718        $1.3           0.02%       744        $7.3           0.02%
     Meat
    Refrigerated      Vegetarian Meats         719        $1.3           0.02%       625       $10.4           0.03%
     Vegetarian
    Candy--Packaged   Seasonal                 720        $1.2           0.02%       754        $7.1           0.02%
                       Miscellaneous W/
                       Flour [Candy]
    Teas              Tea Bags/Green           721        $1.2           0.02%       604       $11.2           0.04%
    Chicken           Chicken Wings            722        $1.2           0.02%     1,111        $2.1           0.01%
     Specialty/
     Natural
    Refrgrated Dough  Refrigerated             723        $1.2           0.02%       634       $10.2           0.03%
     Products          Breads
    Shelf Stable      Lemon Juice & Lime       724        $1.2           0.02%       727        $7.8           0.02%
     Juice             Juice
    Specialty Cheese  Specialty Ppk            725        $1.2           0.02%       469       $16.2           0.05%
     Pre Pack          Cheese Spreads
    Baking            Flours/Grains/           726        $1.2           0.02%       509       $14.6           0.05%
                       Sugar
    Smoked Hams       Hams--Dry Cured/         727        $1.2           0.02%       917        $4.4           0.01%
                       Country
    Coffee &          Specialty Instant        728        $1.2           0.02%       732        $7.7           0.02%
     Creamers          Coffee W/Swe
    Cookies           Fruit Filled             729        $1.2           0.02%       601       $11.3           0.04%
                       Cookies
    Traditional       Mexican Con Queso        730        $1.2           0.02%     1,009        $3.1           0.01%
     Mexican Foods
    Nuts              Dry Roast Peanuts        731        $1.2           0.02%       479       $15.9           0.05%
    Can Seafood--     Sardines                 732        $1.2           0.02%       822        $5.8           0.02%
     Shelf Stable
    Service Case      Stuffed/Mixed            733        $1.2           0.02%       717        $8.2           0.03%
     Meat              Poultry
    Citrus            Oranges Non Navel        734        $1.2           0.02%       868        $5.0           0.02%
                       All
    Seafood--Catfish  Catfish--Nuggets         735        $1.2           0.02%     1,151        $1.8           0.01%
    Snack             Soy/Rice Snacks          736        $1.2           0.02%       488       $15.7           0.05%
    Bread             Bread: Sourdough         737        $1.2           0.02%       456       $17.1           0.05%
    Refrigerated      Misc Hispanic            738        $1.2           0.02%       635       $10.2           0.03%
     Hispanic          Grocery
     Grocery
    Prepared/Pdgd     Boxed Prepared/          739        $1.2           0.02%       489       $15.6           0.05%
     Foods             Entree/Dry Prep
    Shelf Stable      Prune Juice (Over        740        $1.2           0.02%       711        $8.3           0.03%
     Juice             50% Juice)
    Specialty Cheese  Specialty Ppk            741        $1.2           0.02%       433       $18.5           0.06%
     Pre Pack          Cheese Feta
    Teas              Instant Tea & Tea        742        $1.1           0.02%       914        $4.4           0.01%
                       Mix (W/Sugar)
    Pre-Slice         Pre-Sliced Semi-         743        $1.1           0.02%       514       $14.4           0.05%
     Service Case      Soft Cheese
     Cheese
    Shortening & Oil  Cooking Oil:             744        $1.1           0.02%       775        $6.7           0.02%
                       Peanut/Safflower
    Authentic         Hispanic Cookies         745        $1.1           0.02%     1,152        $1.8           0.01%
     Hispanic Fds &    Crackers
     Product
    Can Vegetables--  Carrots                  746        $1.1           0.02%       900        $4.5           0.01%
     Shelf Stable
    Juice Drinks--    Juice (Over 50%          747        $1.1           0.02%       659        $9.7           0.03%
     Carb              juice)
    Juices Super      Juice Single Blend       748        $1.1           0.02%       673        $9.4           0.03%
     Premium
    Nuts              Oil Roast Peanuts        749        $1.1           0.02%       615       $10.9           0.03%
    Beef: Thin Meats  Skirt [Beef]             750        $1.1           0.02%       798        $6.3           0.02%
    Nuts              Nuts Other               751        $1.1           0.02%       593       $11.5           0.04%
    Peppers           Peppers Yellow           752        $1.1           0.02%       599       $11.4           0.04%
                       Bell
    Baking Needs      Baking Powder &          753        $1.1           0.02%       715        $8.2           0.03%
                       Soda
    Frzn Meatless     Meatless Burgers         754        $1.1           0.02%       639       $10.1           0.03%
    Candy--Checklane  Misc Checklane           755        $1.1           0.02%     1,052        $2.6           0.01%
                       Candy
    Pears             Pears Anjou              756        $1.1           0.02%       649        $9.8           0.03%
    Powder & Crystal  Fluid Pouch              757        $1.1           0.02%       781        $6.6           0.02%
     Drink Mix         [Powder Drink
                       Mix]
    Pasta & Pizza     Pizza Sauce              758        $1.1           0.02%       810        $6.1           0.02%
     Sauce
    Spices/Jarred     Garlic Jar               759        $1.1           0.02%       729        $7.7           0.02%
     Garlic
    Sweet Goods &     Sweet Goods: Candy       760        $1.1           0.02%       920        $4.4           0.01%
     Snacks
    Soft Drinks       Tea Bottles With         761        $1.1           0.02%     1,148        $1.9           0.01%
                       Sweetener/Sugar
    Random Weight     Lunch Meats              762        $1.1           0.02%       947        $4.0           0.01%
     Meat Products
    Authentic         Hispanic                 763        $1.1           0.02%       979        $3.5           0.01%
     Hispanic Fds &    Carbonated
     Product           Beverages
    Isotonic Drinks   Isotonic Drinks          764        $1.1           0.02%       889        $4.7           0.01%
                       Multi-Serve
    Juices Super      Juices Antioxidant/      765        $1.0           0.02%       719        $8.1           0.03%
     Premium           Wellness
    Spices/Jarred     Spices &                 766        $1.0           0.02%       892        $4.6           0.01%
     Garlic            Seasonings
    Trail Mix &       Trail Mixes/Snack        767        $1.0           0.02%       650        $9.8           0.03%
     Snacks
    Lunchmeat         Lunchmeat--Natural/      768        $1.0           0.02%       559       $12.7           0.04%
                       Organic
    Lunchmeat         Lunchmeat--Peggabl       769        $1.0           0.02%       877        $4.9           0.02%
                       e Deli Fresh
    Bread             Bread: Tortillas/        770        $1.0           0.02%       648        $9.8           0.03%
                       Wraps
    Ice Cream Ice     Quarts [Ice Cream        771        $1.0           0.02%       924        $4.3           0.01%
     Milk & Sherbets   & Sherbert]
    Infant Formula    Infant Formula Up        772        $1.0           0.02%     1,015        $3.0           0.01%
                       Age
    Tropical Fruit    Kiwi Fruit               773        $1.0           0.02%       764        $7.0           0.02%
    Peppers           Peppers Jalapeno         774        $1.0           0.02%       911        $4.4           0.01%
    Tomatoes          Tomatoes Cherry          775        $1.0           0.02%       580       $12.1           0.04%
    Trail Mix &       Candy W/O Flour          776        $1.0           0.02%       844        $5.4           0.02%
     Snacks
    Condiments        Oils/Vinegar             777        $1.0           0.02%       643       $10.0           0.03%
    Value-Added       Instore Cut              778        $1.0           0.02%       654        $9.7           0.03%
     Vegetables        Vegetables
    Candy--Packaged   Candy Boxed              779        $1.0           0.02%       852        $5.3           0.02%
                       Chocolates W/
                       Flour
    Dried Fruit       Dried Plums              780        $1.0           0.02%       609       $11.0           0.03%
    Shelf Stable      Apple Juice &            781        $1.0           0.02%     1,024        $3.0           0.01%
     Juice             Cider (50% And
                       Under)
    Pre-Slice         Pre-Sliced Semi-         782        $1.0           0.02%       520       $14.3           0.05%
     Service Case      Hard [Cheese]
     Cheese
    Tomato Products-  Tomato Stewed            783        $1.0           0.02%       790        $6.4           0.02%
     Shelf Stable
    Nuts              Misc Snack Nuts          784        $1.0           0.02%       726        $7.8           0.02%
    Beef: Thin Meats  Flank [Beef]             785        $1.0           0.02%       547       $13.0           0.04%
    Cookies           Cookies: Message         786        $1.0           0.02%       876        $4.9           0.02%
    Baking Mixes      Miscellaneous            787        $1.0           0.02%       752        $7.2           0.02%
                       Package Mixes
    Mediterranean     Sal: Olives/             788        $1.0           0.02%       492       $15.5           0.05%
     Bar               Pickles--Bulk
    Dry Sce/Gravy/    Cooking Bags With        789        $1.0           0.01%     1,078        $2.4           0.01%
     Potatoes/         Spices/Season
     Stuffng
    Stone Fruit       Cherries Ranier          790        $1.0           0.01%       691        $9.0           0.03%
    Energy Drinks     Energy Drink--           791        $1.0           0.01%       671        $9.4           0.03%
                       Multi-Pack
    Meat--Shelf       Beef/Pork--Dried         792        $1.0           0.01%       990        $3.3           0.01%
     Stable            Sliced
    Cookies           Cookies/Sweet            793        $1.0           0.01%       542       $13.1           0.04%
                       Goods
    Turkey Fresh      Whole Tom (Over          794        $1.0           0.01%       747        $7.3           0.02%
                       16lbs) [Turkey]
    Ss/Vending--      Vending Size/Sngl        795        $1.0           0.01%     1,090        $2.3           0.01%
     Cookie/Cracker    Serve Cracker
    Can Vegetables--  White Potatoes           796        $1.0           0.01%       927        $4.3           0.01%
     Shelf Stable
    Can Seafood--     Oysters                  797        $0.9           0.01%     1,025        $3.0           0.01%
     Shelf Stable
    Dressings/Dips    Dips Veggie              798        $0.9           0.01%       740        $7.3           0.02%
    Snacks            Snacks: Pita Chips       799        $0.9           0.01%       484       $15.7           0.05%
    Candy--Packaged   Candy Boxed              800        $0.9           0.01%       772        $6.7           0.02%
                       Chocolates
    Chicken Grinds    Ground Chicken           801        $0.9           0.01%       767        $6.9           0.02%
    Candy--Packaged   Seasonal Candy Box       802        $0.9           0.01%       949        $4.0           0.01%
                       Non-Chocola
    Frozen Meat       Alternatives Soy/        803        $0.9           0.01%       688        $9.0           0.03%
                       Tofu
    Can Vegetables--  Kraut & Cabbage          804        $0.9           0.01%       814        $6.0           0.02%
     Shelf Stable
    Cereals           Granola                  805        $0.9           0.01%       501       $15.1           0.05%
    Baking Needs      Cooking Chocolate        806        $0.9           0.01%       627       $10.3           0.03%
                       (Ex Smi-Swt)
    Candy--Packaged   Candy Box Non-           807        $0.9           0.01%       953        $3.9           0.01%
                       Chocolate
    Dinner Sausage    Dnr Sausage--            808        $0.9           0.01%       585       $12.1           0.04%
                       Natural/Organic
    Dressings/Dips    Dressing Blue            809        $0.9           0.01%       666        $9.5           0.03%
                       Cheese
    Herbs/Garlic      Herbs Fresh Other        810        $0.9           0.01%       518       $14.3           0.05%
                       Organic
    Shelf Stable      Tomato Juice (50%        811        $0.9           0.01%       975        $3.5           0.01%
     Juice             And Under)
    Popcorn           Caramel Coated           812        $0.9           0.01%     1,006        $3.1           0.01%
                       Snacks
    Deli Meat:        Deli Meat: Turkey        813        $0.9           0.01%       516       $14.3           0.05%
     Presliced
    Cake Decor        Cake Decors--            814        $0.9           0.01%       841        $5.4           0.02%
                       Candies
    Specialty Cheese  Specialty Ppk            815        $0.9           0.01%       471       $16.2           0.05%
     Pre Pack          Cheese Mozzarell
    Shelf Stable      Cranapple/Cran           816        $0.9           0.01%       797        $6.3           0.02%
     Juice             Grape Juice
    Rtd Tea/New Age   Juice (Over 50%          817        $0.9           0.01%     1,047        $2.7           0.01%
     Juice             Juice)
    Crackers & Misc   Specialty Crackers       818        $0.9           0.01%       444       $17.8           0.06%
     Baked Food
    Salad & Dips      Salad Bar                819        $0.9           0.01%       644       $10.0           0.03%
    Service Case      Marinated Beef           820        $0.9           0.01%       782        $6.6           0.02%
     Meat
    Juice             Non-Carb Jce             821        $0.9           0.01%       880        $4.8           0.02%
                       (Under 50% Juice)
    Organics Fruit &  Organic Salad Mix        822        $0.9           0.01%       499       $15.1           0.05%
     Vegetables
    Chilled Ready     Store Brand              823        $0.9           0.01%       932        $4.2           0.01%
     Meals
    Frzn Meatless     Meatless Breakfast       824        $0.9           0.01%       697        $8.6           0.03%
    Dry Tea/Coffee/   Tea Bags                 825        $0.9           0.01%       681        $9.2           0.03%
     Coco Mixes        (Supplement)
    Melons            Watermelon W/Seeds       826        $0.9           0.01%     1,019        $3.0           0.01%
                       Whole
    Dry Mix Desserts  Misc: Cheesecake/        827        $0.9           0.01%     1,087        $2.3           0.01%
                       Mousse Mixes
    Value-Added       Parfait Cups             828        $0.8           0.01%     1,032        $2.9           0.01%
     Fruit             Instore
    Vinegar &         Specialty Vinegar        829        $0.8           0.01%       552       $12.9           0.04%
     Cooking Wines
    Pork Shoulder     Fresh Hams               830        $0.8           0.01%     1,030        $2.9           0.01%
    Specialty Cheese  Specialty Ppk            831        $0.8           0.01%       815        $6.0           0.02%
     Pre Pack          Cheese Processed
    Turkey Smoked     Turkey Wings             832        $0.8           0.01%     1,228        $1.3           0.00%
    Frzn Seafood      Frz Non-Coated           833        $0.8           0.01%       860        $5.2           0.02%
                       Fish Fillets
    Vegetables Salad  Radish                   834        $0.8           0.01%       713        $8.3           0.03%
    Cookies           Specialty Cookies        835        $0.8           0.01%       622       $10.7           0.03%
    Traditional       Traditional Thai         836        $0.8           0.01%       710        $8.3           0.03%
     Asian Foods       Foods
    Yogurt            Yogurt/Adult             837        $0.8           0.01%       958        $3.8           0.01%
                       Drinks
    Specialty Cheese  Specialty Ppk            838        $0.8           0.01%       527       $13.9           0.04%
     Pre Pack          Cheese Cheddar
    Peppers           Peppers All Other        839        $0.8           0.01%       864        $5.1           0.02%
    Pickle/Relish/    Pickld Veg/Peppers/      840        $0.8           0.01%       820        $5.9           0.02%
     Pckld Veg &       Etc.
     Olives
    Candy--Packaged   Candy Bags-Non           841        $0.8           0.01%       965        $3.7           0.01%
                       Chocolate W/Flour
    Frozen Juice And  Frzn Conc Under          842        $0.8           0.01%       983        $3.4           0.01%
     Smoothies         50% Juice
    Pickle/Relish/    Specialty Olives         843        $0.8           0.01%       614       $11.0           0.03%
     Pckld Veg &
     Olives
    Salad & Dips      Sal: Desserts--          844        $0.8           0.01%       890        $4.7           0.01%
                       Bulk
    Authentic Asian   Authentic Japanese       845        $0.8           0.01%       755        $7.1           0.02%
     Foods             Foods
    Crackers          Crackers                 846        $0.8           0.01%       508       $14.6           0.05%
    Smoked Pork       Smoked Picnics           847        $0.8           0.01%     1,105        $2.2           0.01%
                       [Pork]
    Condiments        Nut Butters/Peanut       848        $0.8           0.01%       549       $12.9           0.04%
                       Butter
    Tomato Products-  Tomatoes/Whole           849        $0.8           0.01%       865        $5.1           0.02%
     Shelf Stable
    Party Tray Deli   Tray: Appetizers &       850        $0.8           0.01%       957        $3.9           0.01%
                       Hors D'oe
    Soup              Cans Soup/Chili          851        $0.8           0.01%       561       $12.7           0.04%
    Service Case      Kabobs Beef              852        $0.8           0.01%       843        $5.4           0.02%
     Meat
    Vegetables Salad  Variety Lettuce          853        $0.8           0.01%       568       $12.5           0.04%
                       Organic
    Melons            Honeydew Whole           854        $0.8           0.01%       817        $5.9           0.02%
    Grapes            Grapes Red Globe         855        $0.8           0.01%       980        $3.5           0.01%
    Condiments &      Chili Sauce/             856        $0.7           0.01%       813        $6.0           0.02%
     Sauces            Cocktail Sauce
    Tropical Fruit    Pomegranates             857        $0.7           0.01%       926        $4.3           0.01%
    Organics Fruit &  Organic Value-           858        $0.7           0.01%       762        $7.0           0.02%
     Vegetables        Added Vegetables
    Grapes            Grapes Other             859        $0.7           0.01%       960        $3.8           0.01%
    Chicken Fresh     Mixed Packs              860        $0.7           0.01%       923        $4.3           0.01%
                       [Chicken]
    Nuts              Nuts Inshell             861        $0.7           0.01%       894        $4.6           0.01%
    Authentic         Hispanic Juice           862        $0.7           0.01%     1,123        $2.0           0.01%
     Hispanic Fds &    Under 50% Juice
     Product
    Coffee &          Flavored Can             863        $0.7           0.01%       823        $5.8           0.02%
     Creamers          Coffee
    Prepared/Pdgd     Vegetables/Dry           864        $0.7           0.01%       575       $12.2           0.04%
     Foods             Beans
    Bread             Bread: Rye/              865        $0.7           0.01%       720        $8.1           0.03%
                       Cocktail
    Baking Needs      Maraschino               866        $0.7           0.01%       944        $4.1           0.01%
                       Cherries
    Seafood--Crab     Crab--Dungy              867        $0.7           0.01%       952        $3.9           0.01%
    Bread             Whole Grain Bread        868        $0.7           0.01%       680        $9.2           0.03%
    Smoked Hams       Hams--Whole Bone-        869        $0.7           0.01%     1,092        $2.3           0.01%
                       In
    Apples            Apples Braeburn          870        $0.7           0.01%       668        $9.4           0.03%
                       (Bulk & Bag)
    Shelf Stable      Grapefruit Juice         871        $0.7           0.01%       939        $4.1           0.01%
     Juice             (Over 50% Juice)
    Water             Fortified/Water          872        $0.7           0.01%       913        $4.4           0.01%
    Meat--Shelf       Potted Meats And         873        $0.7           0.01%     1,103        $2.2           0.01%
     Stable            Spreads
    Water--(Sparklin  Sparkling Water--        874        $0.7           0.01%       581       $12.1           0.04%
     g & Still)        Unflavored
    Seafood--Trout    Steelhead Fr             875        $0.7           0.01%       812        $6.0           0.02%
                       [Trout]
    Can Vegetables--  Beets                    876        $0.7           0.01%       825        $5.8           0.02%
     Shelf Stable
    Frozen Juice And  Smoothies-Frozen         877        $0.7           0.01%       950        $4.0           0.01%
     Smoothies
    Frozen Breakfast  Frzn Bagels              878        $0.7           0.01%     1,035        $2.9           0.01%
     Foods
    Party Tray Deli   Tray: Fruit And          879        $0.7           0.01%       758        $7.1           0.02%
                       Vegetable
    Chicken           Whole Chicken            880        $0.7           0.01%       902        $4.5           0.01%
     Specialty/        (Roasters/Fryer)
     Natural
    Bread             Bread: Wheat/Whl         881        $0.7           0.01%       629       $10.3           0.03%
                       Grain
    Non-Dairy/Dairy   Soy Beverage             882        $0.7           0.01%       849        $5.3           0.02%
     Aseptic
    Fitness & Diet    Fitness & Diet-          883        $0.7           0.01%       741        $7.3           0.02%
                       Powder Ntrtnl
    Frzn Meatless     Meatless Poultry         884        $0.7           0.01%       799        $6.2           0.02%
    Pies              Pies: Sugar Free         885        $0.7           0.01%       904        $4.5           0.01%
    Dinner Sausage    Dnr Sausage--Fresh       886        $0.7           0.01%       918        $4.4           0.01%
                       Poultry
    Spices &          Imitation Extracts       887        $0.7           0.01%       973        $3.5           0.01%
     Extracts
    Beverages         Can/Btl Carb Beve        888        $0.7           0.01%       736        $7.6           0.02%
                       50% And Under
    Vegetables        Vegetables Cooking       889        $0.7           0.01%       821        $5.9           0.02%
     Cooking           Packaged
     Packaged
    Frozen Vegetable  Fz Box Vegetables--      890        $0.7           0.01%       824        $5.8           0.02%
     & Veg Dish        Plain
    Soup              Broths                   891        $0.7           0.01%       560       $12.7           0.04%
    Bread             Bread: Brand             892        $0.7           0.01%       679        $9.2           0.03%
    Can Vegetables--  Peas Fresh Pack/         893        $0.7           0.01%       978        $3.5           0.01%
     Shelf Stable      Crowder
    Snacks            Snacks: Salty            894        $0.7           0.01%       703        $8.5           0.03%
    Salad & Dips      Protein Salads--         895        $0.6           0.01%       946        $4.0           0.01%
                       Prepack
    Turkey Smoked     Turkey Drums             896        $0.6           0.01%     1,250        $1.2           0.00%
    Apples            Apples Gala (Bulk        897        $0.6           0.01%       672        $9.4           0.03%
                       & Bag) Organic
    Stone Fruit       Peaches White            898        $0.6           0.01%       833        $5.5           0.02%
                       Flesh
    Tomatoes          Tomatoes--Other          899        $0.6           0.01%     1,003        $3.2           0.01%
    Service Case      Kabobs Poultry           900        $0.6           0.01%       879        $4.9           0.02%
     Meat
    Frzn Meatless     Meatless                 901        $0.6           0.01%       869        $5.0           0.02%
                       Miscellaneous
    Seafood--Scallop  Scallops--Sea            902        $0.6           0.01%       791        $6.4           0.02%
     s
    Convenience/      Jarred Fruit Multi       903        $0.6           0.01%       901        $4.5           0.01%
     Snacking          Serve
    Traditional       Asian Vegetables         904        $0.6           0.01%       847        $5.4           0.02%
     Asian Foods
    Shelf Stable      Cranapple/Cran           905        $0.6           0.01%       760        $7.0           0.02%
     Juice             Grape Juice
    Frozen Juice And  Cocktail Mixes-Frz       906        $0.6           0.01%     1,107        $2.2           0.01%
     Smoothies
    Shelf Stable      Grapefruit Juice         907        $0.6           0.01%     1,007        $3.1           0.01%
     Juice             (50% And Under)
    Tomato Products-  Tomato Crushed           908        $0.6           0.01%       780        $6.6           0.02%
     Shelf Stable
    Condiments &      Misc Meat Sauces         909        $0.6           0.01%       962        $3.7           0.01%
     Sauces
    Shelf Stable      Blended Juice &          910        $0.6           0.01%     1,022        $3.0           0.01%
     Juice             Combinations
    Coffee &          Bulk Coffee              911        $0.6           0.01%       701        $8.6           0.03%
     Creamers
    Specialty Cheese  Specialty Ppk            912        $0.6           0.01%       595       $11.4           0.04%
     Pre Pack          Cheese Semi Soft
    Non-Dairy/Dairy   Nut Milk                 913        $0.6           0.01%       763        $7.0           0.02%
     Aseptic
    Specialty Cheese  Specialty Ppk            914        $0.6           0.01%       620       $10.8           0.03%
     Pre Pack          Cheese Soft &
                       Ripe
    Authentic         Authentic Soups/         915        $0.6           0.01%     1,200        $1.5           0.00%
     Hispanic Fds &    Bouillons
     Product
    Authentic Asian   Authentic Chinese        916        $0.6           0.01%       931        $4.2           0.01%
     Foods             Foods
    Baby Food         Baby Food                917        $0.6           0.01%       835        $5.5           0.02%
    Deli Meat:        Deli Meat: Ham           918        $0.6           0.01%       665        $9.5           0.03%
     Presliced
    Bacon             Bacon--Natural/          919        $0.6           0.01%       759        $7.1           0.02%
                       Organic
    Frozen Potatoes   Frzn Onion Rings         920        $0.6           0.01%     1,177        $1.6           0.01%
    Margarines        Margarine: Squeeze       921        $0.6           0.01%       930        $4.2           0.01%
    Deli Specialties  Dl Spec: Dry/            922        $0.6           0.01%       850        $5.3           0.02%
     (Retail Pk)       Refrig Pastas
    Seafood--Crab     Crab--Other              923        $0.6           0.01%     1,213        $1.4           0.00%
    Specialty Cheese  Specialty Ppk            924        $0.6           0.01%       619       $10.8           0.03%
     Pre Pack          Cheese Blue/Gorg
    Tomatoes          Tomatoes Others          925        $0.6           0.01%       808        $6.1           0.02%
                       Organic
    Teas              Instant Tea & Tea        926        $0.6           0.01%     1,038        $2.9           0.01%
                       Mix
    Refrigerated      Vegetarian Misc          927        $0.6           0.01%       963        $3.7           0.01%
     Vegetarian
    Canned & Dry      Non Fat Dry Milk         928        $0.6           0.01%       859        $5.2           0.02%
     Milk
    Refrigerated      Kefir                    929        $0.6           0.01%       751        $7.2           0.02%
     Dairy Case
    Coffee &          Specialty Instant        930        $0.6           0.01%     1,043        $2.8           0.01%
     Creamers          Coffee
    Can Vegetables--  Artichokes               931        $0.6           0.01%       682        $9.1           0.03%
     Shelf Stable
    Soft Drinks       Mixers (Tonic            932        $0.5           0.01%       540       $13.2           0.04%
                       Water/Gngr Ale)
    Refrigerated      Refrigerated Pasta       933        $0.5           0.01%       742        $7.3           0.02%
     Italian           Sauce
    Baking Needs      Baking Cocoa             934        $0.5           0.01%       851        $5.3           0.02%
    Vegetables Salad  Spinach Bulk             935        $0.5           0.01%       883        $4.8           0.02%
    Infant Formula    Infant Formula           936        $0.5           0.01%     1,455        $0.3           0.00%
                       Milk Base
    Seafood--Salad/   Dips/Spreads             937        $0.5           0.01%     1,069        $2.5           0.01%
     Dip/Sce/Cond
    Authentic         Hispanic Baking          938        $0.5           0.01%     1,233        $1.3           0.00%
     Hispanic Fds &    Needs
     Product
    Baking Needs      Marshmallow Creme        939        $0.5           0.01%       977        $3.5           0.01%
    Buffalo           Grinds [Buffalo]         940        $0.5           0.01%       712        $8.3           0.03%
    Baking Needs      Yeast: Dry               941        $0.5           0.01%       816        $5.9           0.02%
    Lamb              Round/Leg [Lamb]         942        $0.5           0.01%       936        $4.2           0.01%
    Seafood--Smoked   Seafood Smoked           943        $0.5           0.01%       709        $8.4           0.03%
                       Salmon
    Processed         Packaged Dry Mixes       944        $0.5           0.01%     1,039        $2.9           0.01%
    Frozen Meat       Micro Protein            945        $0.5           0.01%       899        $4.6           0.01%
     Alternatives      [Meats]
    Refrgrated Dough  Misc Refrig Dough        946        $0.5           0.01%     1,162        $1.7           0.01%
     Products          Products
    Deli Meat:        Deli Meat: Beef          947        $0.5           0.01%       862        $5.2           0.02%
     Presliced
    Vegetables        Celery Organic           948        $0.5           0.01%       779        $6.6           0.02%
     Cooking Bulk
    Cakes             Cakes: Creme/            949        $0.5           0.01%     1,171        $1.7           0.01%
                       Pudding Novelties
    Lamb              Loin [Lamb]              950        $0.5           0.01%       882        $4.8           0.02%
    Refrgratd Juices/ Dairy Case Tea No        951        $0.5           0.01%     1,002        $3.2           0.01%
     Drinks            Sugar Or Sweetner
    Baking Needs      Coconut [Baking          952        $0.5           0.01%       873        $4.9           0.02%
                       Needs]
    Salad Mix         Salad Spinach            953        $0.5           0.01%       696        $8.7           0.03%
                       Organic
    Pork Grinds       Ground Pork              954        $0.5           0.01%       928        $4.3           0.01%
    Processed         Squeeze Lemons/          955        $0.5           0.01%       988        $3.3           0.01%
                       Limes
    Lamb              Chuck/Shoulder           956        $0.5           0.01%     1,083        $2.4           0.01%
                       [Lamb]
    Berries           Raspberries              957        $0.5           0.01%       683        $9.1           0.03%
                       Organic
    Rolls             Rolls: Biscuits/         958        $0.5           0.01%       886        $4.7           0.02%
                       Eng Muffins
    Snacks            Snacks: Tortilla         959        $0.5           0.01%       874        $4.9           0.02%
                       Chips
    Condiments        Honey/Syrup              960        $0.5           0.01%       921        $4.3           0.01%
    Rice Cakes        Large Cakes              961        $0.5           0.01%       855        $5.2           0.02%
    Authentic         Italian Vegetables       962        $0.5           0.01%       738        $7.4           0.02%
     Italian Foods
    Dressings/Dips    Dips Fruit And           963        $0.5           0.01%     1,149        $1.9           0.01%
                       Chocolate
    Potatoes          Potatoes Other           964        $0.5           0.01%       789        $6.4           0.02%
                       Organic
    Juices Super      Juices (50% And          965        $0.5           0.01%     1,141        $1.9           0.01%
     Premium           Under Juice)
    Specialty Cheese  Specialty Ppk            966        $0.5           0.01%     1,192        $1.5           0.00%
     Pre Pack          Cheese Hispanic
    Seafood--Value-   Seafood Value-           967        $0.5           0.01%       997        $3.2           0.01%
     Added             Added Crab
    Service Case      Stuffed/Mixed Pork       968        $0.5           0.01%     1,051        $2.7           0.01%
     Meat
    Herbs/Garlic      Sprouts                  969        $0.5           0.01%       955        $3.9           0.01%
    Pears             Pears Bosc               970        $0.5           0.01%       922        $4.3           0.01%
    Meat--Shelf       Corn Beef                971        $0.5           0.01%     1,169        $1.7           0.01%
     Stable
    Refrigerated      Non-Dairy Cheese         972        $0.5           0.01%       893        $4.6           0.01%
     Vegetarian
    Isotonic Drinks   Sports Drink N/          973        $0.5           0.01%     1,017        $3.0           0.01%
                       Supplmnt Milk
    Soft Drinks       Seltzer Unflavored       974        $0.5           0.01%       757        $7.1           0.02%
    Refrigerated      Tofu                     975        $0.5           0.01%       809        $6.1           0.02%
     Vegetarian
    Berries           Blueberries              976        $0.5           0.01%       660        $9.6           0.03%
                       Organic
    Trail Mix &       Candy W/Flour            977        $0.5           0.01%     1,027        $2.9           0.01%
     Snacks
    Cakes             Cakes: Cheesecake        978        $0.5           0.01%     1,115        $2.1           0.01%
                       Novelties
    Water--(Sparklin  Sparkling Water--        979        $0.5           0.01%       675        $9.3           0.03%
     g & Still)        Flvrd Unsweetened
    Powder & Crystal  Breakfast Crystals       980        $0.5           0.01%     1,209        $1.4           0.00%
     Drink Mix
    Non-Dairy/Dairy   Rice Beverage            981        $0.5           0.01%       891        $4.6           0.01%
     Aseptic
    Pies              Pies: Tarts/Minis/       982        $0.5           0.01%     1,045        $2.7           0.01%
                       Crstdas
    Specialty Cheese  Specialty Ppk            983        $0.5           0.01%       721        $8.0           0.03%
     Pre Pack          Cheese Gouda &
                       Eda
    Enhancements      Enhancements--Spic       984        $0.5           0.01%     1,082        $2.4           0.01%
     (Pickles/         es/Sauces
     Spreads)
    Snacks            Snacks: Crackers/        985        $0.5           0.01%       705        $8.4           0.03%
                       Cookies
    Baking Needs      Corn Starch              986        $0.5           0.01%     1,062        $2.6           0.01%
    Candy--Packaged   Bulk Candy               987        $0.5           0.01%     1,031        $2.9           0.01%
    Prepared/Pdgd     Pasta/Ramen              988        $0.5           0.01%       801        $6.2           0.02%
     Foods
    Specialty Cheese  Specialty Ppk            989        $0.5           0.01%       624       $10.4           0.03%
     Pre Pack          Cheese Goat Milk
    Herbs/Garlic      Herbs Basil              990        $0.4           0.01%       692        $9.0           0.03%
                       Organic
    Bakery Party      Party Trays: Cakes       991        $0.4           0.01%     1,147        $1.9           0.01%
     Trays
    Mushrooms         Mushrooms White          992        $0.4           0.01%       830        $5.7           0.02%
                       Bulk
    Candy             Candy/Chocolate          993        $0.4           0.01%       786        $6.5           0.02%
    Candy--Packaged   Seasonal Candy           994        $0.4           0.01%       999        $3.2           0.01%
                       Bags-Chocolate
    Tomatoes          Tomatoes Cocktail        995        $0.4           0.01%       714        $8.3           0.03%
    Pears             Pears Asian              996        $0.4           0.01%       961        $3.8           0.01%
    Authentic         Caribbean Foods          997        $0.4           0.01%     1,273        $1.1           0.00%
     Caribbean Foods
    Dry Bean Veg &    Misc Grain Mixes         998        $0.4           0.01%       735        $7.6           0.02%
     Rice
    Can Vegetables--  Peas & Onions/Peas       999        $0.4           0.01%     1,136        $1.9           0.01%
     Shelf Stable      & Carrot
    Seafood--Shellfi  Other Shellfish--      1,000        $0.4           0.01%     1,225        $1.3           0.00%
     sh                Other
                                                   -----------------------------------------------------------------
      Top 1,000                                       $6,580.5            100%             $31,513.8            100%
       Totals
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.

    EAppendix B. Crosswalk of Top 1,000 Subcommodities to Summary Categories
    ------------------------------------------------------------------------
           Commodity               Subcommodity           Summary Category
    ------------------------------------------------------------------------
    Baby Food               Baby Food                  Baby food
    Baby Foods              Baby Food--Beginner        Baby food
    Baby Foods              Baby Food                  Junior/All Brands
                                                        Baby food
    Baby Foods              Baby Food                  Cereals Baby food
    Baby Foods              Baby Juices                Baby food
    Baby Foods              Baby Spring Waters         Baby food
    Infant Formula          Infant Formula             Starter/Solutio Baby
                                                        food
    Infant Formula          Infant Formula             Specialty Baby food
    Infant Formula          Infant Formula             Starter Large P Baby
                                                        food
    Infant Formula          Infant Formula             Toddler Baby food
    Infant Formula          Infant Formula             Solutions Large Baby
                                                        food
    Infant Formula          Infant Formula             Concentrate Baby food
    Infant Formula          Infant Formula             Ready To Use Baby
                                                        food
    Infant Formula          Baby Isotonic Drinks       Baby food
    Infant Formula          Infant Formula Soy Base    Baby food
    Infant Formula          Infant Formula Up Age      Baby food
    Infant Formula          Infant Formula Milk Base   Baby food
    Can Beans               Prepared Beans--Baked W/   Beans
                             Pork
    Can Beans               Variety Beans--Kidney/     Beans
                             Pinto/E
    Dry Bean Veg & Rice     Dry Beans/Peas/Barley:     Beans
                             Bag & B
    Frozen Meat             Soy/Tofu                   Beans
     Alternatives
    Salad & Dips            Sal: Hommus                Beans
    Traditional Mexican     Mexican Beans/Refried      Beans
     Foods
    Vegetables Cooking      Beans                      Beans
     Bulk
    Frozen Ice              Ice--Crushed/Cubed         Bottled water
    Water                   Fortified/Water            Bottled water
    Water--(Sparkling &     Still Water Drnking/Mnrl   Bottled water
     Still)                  Water
    Water--(Sparkling &     Spring Water               Bottled water
     Still)
    Water--(Sparkling &     Distilled Water            Bottled water
     Still)
    Water--(Sparkling &     Sparkling Water--          Bottled water
     Still)                  Unflavored
    Water--(Sparkling &     Sparkling Water--Flvrd     Bottled water
     Still)                  Unswee
    Bagels & Cream Cheese   Refrigerated Bagels        Bread and Crackers
    Baked Breads            Mainstream White Bread     Bread and Crackers
    Baked Breads            Mainstream Variety Breads  Bread and Crackers
    Baked Breads            Hamburger Buns             Bread and Crackers
    Baked Breads            Hot Dog Buns               Bread and Crackers
    Baked Breads            Premium Bread              Bread and Crackers
    Baked Breads            Bagels                     Bread and Crackers
    Baked Breads            Sandwich Buns              Bread and Crackers
    Baked Breads            English Muffins/Waffles    Bread and Crackers
    Baked Breads            Main Meal Bread            Bread and Crackers
    Baked Breads            Dinner Rolls               Bread and Crackers
    Baked Breads            Diet/Light Bread           Bread and Crackers
    Baked Breads            Fruit/Breakfast Bread      Bread and Crackers
    Baked Breads            Rye Breads                 Bread and Crackers
    Baking Mixes            Biscuit Flour & Mixes      Bread and Crackers
    Bread                   Bread: Italian/French      Bread and Crackers
    Bread                   Bread: Specialty           Bread and Crackers
    Bread                   Bread: Artisan             Bread and Crackers
    Bread                   Bread: Pita/Pocket/        Bread and Crackers
                             Flatbrd
    Bread                   Bread: Sweet/Breakfast     Bread and Crackers
    Bread                   Bread: Sourdough           Bread and Crackers
    Bread                   Bread: Tortillas/Wraps     Bread and Crackers
    Bread                   Bread: Rye/Cocktail        Bread and Crackers
    Bread                   Whole Grain Bread          Bread and Crackers
    Bread                   Bread: Wheat/Whl Grain     Bread and Crackers
    Bread                   Bread: Brand               Bread and Crackers
    Cookie/Cracker Multi-   Multi-Pack Crackers        Bread and Crackers
     Pks
    Crackers                Crackers                   Bread and Crackers
    Crackers & Misc Baked   Cheese Crackers            Bread and Crackers
     Food
    Crackers & Misc Baked   Butter Spray Cracker       Bread and Crackers
     Food
    Crackers & Misc Baked   Snack Crackers             Bread and Crackers
     Food
    Crackers & Misc Baked   Saltine/Oyster             Bread and Crackers
     Food
    Crackers & Misc Baked   Specialty Crackers         Bread and Crackers
     Food
    Croutons/Bread          Croutons                   Bread and Crackers
     Stick&Salad Top
    Dry Sce/Gravy/Potatoes/ Stuffing Mixes             Bread and Crackers
     Stuffng
    Frozen Bread/Dough      Frzn Garlic Toast          Bread and Crackers
    Frozen Bread/Dough      Frzn Dinner Rolls          Bread and Crackers
    Frozen Bread/Dough      Frzn Garlic Bread          Bread and Crackers
    Frozen Bread/Dough      Frzn Biscuits              Bread and Crackers
    Frozen Bread/Dough      Frzn Breadsticks           Bread and Crackers
    Frozen Breakfast Foods  Frzn Bagels                Bread and Crackers
    Refrgrated Dough        Refrigerated Biscuits      Bread and Crackers
     Products
    Refrgrated Dough        Refrigerated Specialty     Bread and Crackers
     Products                Rolls
    Refrgrated Dough        Refrigerated Crescent      Bread and Crackers
     Products                Rolls
    Refrgrated Dough        Refrigerated Breads        Bread and Crackers
     Products
    Refrgrated Dough        Misc Refrig Dough          Bread and Crackers
     Products                Products
    Refrigerated Hispanic   Refrigerated Tortillas     Bread and Crackers
     Grocery
    Rice Cakes              Mini-Cakes                 Bread and Crackers
    Rice Cakes              Large Cakes                Bread and Crackers
    Rolls                   Rolls: Dinner              Bread and Crackers
    Rolls                   Rolls: Sandwich            Bread and Crackers
    Rolls                   Rolls: Croissants/         Bread and Crackers
                             Breadsticks
    Rolls                   Rolls: Bagels              Bread and Crackers
    Rolls                   Rolls: Biscuits/Eng        Bread and Crackers
                             Muffins
    Ss/Vending--Cookie/     Vending Size/Sngl Serve    Bread and Crackers
     Cracker                 Cracke
    Traditional Mexican     Mexican Soft Tortillas     Bread and Crackers
     Foods                   And Wra
    Traditional Mexican     Mexican Taco/Tostado/      Bread and Crackers
     Foods                   Shells
    Apples                  Caramel/Candy Apples       Candy
    Candy                   Candy/Chocolate            Candy
    Candy--Checklane        Candy Bars (Singles)       Candy
                             (Including)
    Candy--Checklane        Chewing Gum                Candy
    Candy--Checklane        Candy Bars (Singles)       Candy
                             (Including)
    Candy--Checklane        Mints/Candy & Breath (Not  Candy
                             Life)
    Candy--Checklane        Misc Checklane Candy       Candy
    Candy--Checklane        Mints/Candy & Breath (Not  Candy
                             Life)
    Candy--Packaged         Candy Bags-Chocolate       Candy
    Candy--Packaged         Candy Bars (Multi Pack)    Candy
    Candy--Packaged         Candy Bags-Non Chocolate   Candy
    Candy--Packaged         Seasonal Miscellaneous     Candy
                             [Candy]
    Candy--Packaged         Seasonal Candy Bags-       Candy
                             Chocolate
    Candy--Packaged         Gum (Packaged)             Candy
    Candy--Packaged         Miscellaneous Candy        Candy
                             (Including)
    Candy--Packaged         Seasonal Candy Box-        Candy
                             Chocolate
    Candy--Packaged         Seasonal Candy Bags Non-   Candy
                             Chocol
    Candy--Packaged         Candy Bars Multi Pack W/   Candy
                             Flour
    Candy--Packaged         Candy Bags-Chocolate W/    Candy
                             Flour
    Candy--Packaged         Miscellaneous Candy        Candy
                             (Including)
    Candy--Packaged         Novelty Candy              Candy
    Candy--Packaged         Seasonal Miscellaneous W/  Candy
                             Flour
    Candy--Packaged         Candy Boxed Chocolates W/  Candy
                             Flour
    Candy--Packaged         Candy Boxed Chocolates     Candy
    Candy--Packaged         Seasonal Candy Box Non-    Candy
                             Chocola
    Candy--Packaged         Candy Box Non-Chocolate    Candy
    Candy--Packaged         Candy Bags-Non Chocolate   Candy
                             W/Flo
    Candy--Packaged         Bulk Candy                 Candy
    Candy--Packaged         Seasonal Candy Bags-       Candy
                             Chocolate
    Candy--Packaged         Seasonal Candy Bags Non-   Candy
                             Chocol
    Candy--Packaged         Seasonal Candy Box Non-    Candy
                             Chocola
    Sweet Goods & Snacks    Sweet Goods: Candy         Candy
    Trail Mix & Snacks      Candy W/O Flour            Candy
    Trail Mix & Snacks      Candy W/Flour              Candy
    Cereal Bars             Breakfast Bars/Tarts/      Cereal
                             Scones
    Cereals                 Cereal--Cold               Cereal
    Cereals                 Granola                    Cereal
    Cnv Breakfast &         Granola Bars               Cereal
     Wholesome Snks
    Cnv Breakfast &         Cereal Bars                Cereal
     Wholesome Snks
    Cold Cereal             Kids Cereal                Cereal
    Cold Cereal             All Family Cereal          Cereal
    Cold Cereal             Adult Cereal               Cereal
    Hot Cereal              Instant Oatmeal            Cereal
    Hot Cereal              Standard Oatmeal           Cereal
    Hot Cereal              Grits                      Cereal
    Hot Cereal              Other Hot Cereal           Cereal
    Hot Cereal              Instant Breakfast          Cereal
    Coffee & Creamers       Unflavored Can Coffee      Coffee and tea
    Coffee & Creamers       Unflavored Bag Coffee      Coffee and tea
    Coffee & Creamers       Unflavored Instant Coffee  Coffee and tea
    Coffee & Creamers       Ready To Drink Coffee      Coffee and tea
    Coffee & Creamers       Coffee Pods/Singles/       Coffee and tea
                             Filter Pac
    Coffee & Creamers       Flavored Bag Coffee        Coffee and tea
    Coffee & Creamers       Specialty Instant Coffee   Coffee and tea
                             W/Swe
    Coffee & Creamers       Flavored Can Coffee        Coffee and tea
    Coffee & Creamers       Bulk Coffee                Coffee and tea
    Coffee & Creamers       Specialty Instant Coffee   Coffee and tea
                             W/O S
    Dry Tea/Coffee/Coco     Tea Bags (Supplement)      Coffee and tea
     Mixes
    Refrgratd Juices/       Tea No Sugar Or Swe        Coffee and tea
     Drinks Dairy Case
    Teas                    Tea Bags & Bulk Tea        Coffee and tea
    Teas                    Tea Bags/Herbal            Coffee and tea
    Teas                    Tea Bags/Green             Coffee and tea
    Teas                    Instant Tea & Tea Mix      Coffee and tea
    Authentic Hispanic Fds  Authentic Sauces/Salsa/    Condiments and
     & Product               Picante                    seasoning
    Bag Snacks              Salsa & Dips               Condiments and
                                                        seasoning
    Can Vegetables--Shelf   Fried Onions               Condiments and
     Stable                                             seasoning
    Condiments              Oils/Vinegar               Condiments and
                                                        seasoning
    Condiments & Sauces     Bbq Sauce                  Condiments and
                                                        seasoning
    Condiments & Sauces     Catsup                     Condiments and
                                                        seasoning
    Condiments & Sauces     Steak & Worchester Sauce   Condiments and
                                                        seasoning
    Condiments & Sauces     Hot Sauce                  Condiments and
                                                        seasoning
    Condiments & Sauces     Marinades                  Condiments and
                                                        seasoning
    Condiments & Sauces     Yellow Mustard             Condiments and
                                                        seasoning
    Condiments & Sauces     Mustard--All Other         Condiments and
                                                        seasoning
    Condiments & Sauces     Wing Sauce                 Condiments and
                                                        seasoning
    Condiments & Sauces     Chili Sauce/Cocktail       Condiments and
                             Sauce                      seasoning
    Condiments & Sauces     Misc Meat Sauces           Condiments and
                                                        seasoning
    Croutons/Bread Stick &  Salad Toppers              Condiments and
     Salad Top                                          seasoning
    Dressings/Dips          Dips Guacamole/Salsa/      Condiments and
                             Queso                      seasoning
    Dressings/Dips          Dips Veggie                Condiments and
                                                        seasoning
    Dressings/Dips          Dips Fruit And Chocolate   Condiments and
                                                        seasoning
    Dry Sce/Gravy/Potatoes/ Sauce Mixes/Gravy Mixes    Condiments and
     Stuffng                 Dry                        seasoning
    Dry Sce/Gravy/Potatoes/ Gravy Can/Glass            Condiments and
     Stuffng                                            seasoning
    Dry Sce/Gravy/Potatoes/ Cooking Bags With Spices/  Condiments and
     Stuffng                 Seaso                      seasoning
    Enhancements            Enhancements--Pickles/     Condiments and
                             Kraut                      seasoning
    Enhancements            Enhancements--Salads/      Condiments and
                             Spreads                    seasoning
    Enhancements            Enhancements--Spices/      Condiments and
                             Sauces                     seasoning
    Herbs/Garlic            Herbs Cilanto              Condiments and
                                                        seasoning
    Herbs/Garlic            Herbs Fresh Other Organic  Condiments and
                                                        seasoning
    Herbs/Garlic            Herbs Basil Organic        Condiments and
                                                        seasoning
    Mediterranean Bar       Sal: Olives/Pickles--Bulk  Condiments and
                                                        seasoning
    Mediterranean Bar       Sal: Olives/Pickles--Bulk  Condiments and
                                                        seasoning
    Pickle/Relish/Pckld     Ripe Olives                Condiments and
     Veg & Olives                                       seasoning
    Pickle/Relish/Pckld     Peppers                    Condiments and
     Veg & Olives                                       seasoning
    Pickle/Relish/Pckld     Green Olives               Condiments and
     Veg & Olives                                       seasoning
    Pickle/Relish/Pckld     Relishes                   Condiments and
     Veg & Olives                                       seasoning
    Pickle/Relish/Pckld     Pickld Veg/Peppers/Etc.    Condiments and
     Veg & Olives                                       seasoning
    Pickle/Relish/Pckld     Specialty Olives           Condiments and
     Veg & Olives                                       seasoning
    Refrigerated Italian    Refrigerated Pasta Sauce   Condiments and
                                                        seasoning
    Salad & Dips            Sal: Salsa/Dips Bulk       Condiments and
                                                        seasoning
    Salad & Dips            Sal: Dip Prepack           Condiments and
                                                        seasoning
    Salad & Dips            Sal: Salsa Prepack         Condiments and
                                                        seasoning
    Salad Dresing &         Dry Salad Dressing & Dip   Condiments and
     Sandwich Spreads        Mixes                      seasoning
    Seafood--Salad/Dip/Sce/ Dips/Spreads               Condiments and
     Cond                                               seasoning
    Spices & Extracts       Traditional Spices         Condiments and
                                                        seasoning
    Spices & Extracts       Gourmet Spices             Condiments and
                                                        seasoning
    Spices & Extracts       Pure Extracts              Condiments and
                                                        seasoning
    Spices & Extracts       Table Salt/Popcorn Salt/   Condiments and
                             Ice Cr                     seasoning
    Spices & Extracts       Imitation Extracts         Condiments and
                                                        seasoning
    Spices/Jarred Garlic    Spices & Seasonings        Condiments and
                                                        seasoning
    Traditional Asian       Asian Other Sauces/        Condiments and
     Foods                   Marinad                    seasoning
    Traditional Asian       Asian Soy Sauce            Condiments and
     Foods                                              seasoning
    Traditional Mexican     Mexican Sauces And         Condiments and
     Foods                   Picante Sau                seasoning
    Traditional Mexican     Mexican Seasoning Mixes    Condiments and
     Foods                                              seasoning
    Traditional Mexican     Mexican Taco Sauce         Condiments and
     Foods                                              seasoning
    Vinegar & Cooking       Vinegar/White & Cider      Condiments and
     Wines                                              seasoning
    Vinegar & Cooking       Specialty Vinegar          Condiments and
     Wines                                              seasoning
    Eggs/Muffins/Potatoes   Eggs--Large                Eggs
    Eggs/Muffins/Potatoes   Eggs--Medium               Eggs
    Eggs/Muffins/Potatoes   Eggs--X-Large              Eggs
    Eggs/Muffins/Potatoes   Eggs--Jumbo                Eggs
    Eggs/Muffins/Potatoes   Eggs Substitute            Eggs
    Eggs/Muffins/Potatoes   Misc Dairy Refigerated     Eggs
    Refrigerated Dairy      Eggs                       Eggs
     Case
    Dressings/Dips          Creamy                     Fats and oils
     Dressing
    Dressings/Dips          Blue Cheese                Fats and oils
     Dressing
    Margarines              Margarine: Tubs And Bowls  Fats and oils
    Margarines              Butter                     Fats and oils
    Margarines              Margarine Stick            Fats and oils
    Margarines              Margarine: Squeeze         Fats and oils
    Salad Dresing &         Pourable Salad Dressings   Fats and oils
     Sandwich Spreads
    Salad Dresing &         Mayonnaise & Whipped       Fats and oils
     Sandwich Spreads        Dressing
    Salad Dresing &         Sand/Horseradish & Tartar  Fats and oils
     Sandwich Spreads        Sauce
    Shortening & Oil        Vegetable Oil              Fats and oils
    Shortening & Oil        Canola Oils                Fats and oils
    Shortening & Oil        Olive Oil                  Fats and oils
    Shortening & Oil        Cooking Sprays             Fats and oils
    Shortening & Oil        Solid Shortening           Fats and oils
    Shortening & Oil        Corn Oil                   Fats and oils
    Shortening & Oil        Cooking Oil: Peanut/       Fats and oils
                             Safflower/
    Baking                  Flours/Grains/Sugar        Flour and prepared
                                                        flour mixes
    Flour & Meals           Flour: White & Self        Flour and prepared
                             Rising                     flour mixes
    Flour & Meals           Breadings/Coatings/Crumbs  Flour and prepared
                                                        flour mixes
    Flour & Meals           Flour: Misc/Specialty/     Flour and prepared
                             Blend Et                   flour mixes
    Molasses/Syrups/        Pancake Mixes              Flour and prepared
     Pancake Mixes                                      flour mixes
    Frozen Breakfast Foods  Frzn Breakfast Sandwiches  Frozen prepared foods
    Frozen Breakfast Foods  Waffles/Pancakes/French    Frozen prepared foods
                             Toast
    Frozen Breakfast Foods  Frzn Breakfast Entrees     Frozen prepared foods
    Frozen Entrees          Meatless/Vegetarian        Frozen prepared foods
    Frozen Ethnic           Frozen International       Frozen prepared foods
                             [Ethnic Food]
    Frozen Handhelds &      Snacks/Appetizers          Frozen prepared foods
     Snacks
    Frozen Handhelds &      Sandwiches & Handhelds     Frozen prepared foods
     Snacks
    Frozen Handhelds &      Corn Dogs                  Frozen prepared foods
     Snacks
    Frozen Handhelds &      Burritos                   Frozen prepared foods
     Snacks
    Frozen Meat             Micro Protein [Meat]       Frozen prepared foods
     Alternatives
    Frozen Pizza            Pizza/Premium              Frozen prepared foods
    Frozen Pizza            Pizza/Economy              Frozen prepared foods
    Frozen Pizza            Pizza/Traditional          Frozen prepared foods
    Frozen Pizza            Pizza/Single Serve/        Frozen prepared foods
                             Microwave
    Frzn Meatless           Meatless Burgers           Frozen prepared foods
    Frzn Meatless           Meatless Breakfast         Frozen prepared foods
    Frzn Meatless           Meatless Poultry           Frozen prepared foods
    Frzn Meatless           Meatless Miscellaneous     Frozen prepared foods
    Frzn Multi Serve        Fz Family Style Entrees    Frozen prepared foods
    Frzn Multi Serve        Fz Skillet Meals           Frozen prepared foods
    Frzn Multi Serve        Fz Meatballs               Frozen prepared foods
    Frzn Pasta              Frozen Pasta               Frozen prepared foods
    Frzn Prepared Chicken   Whole Muscle Breaded/18oz  Frozen prepared foods
                             And
    Frzn Prepared Chicken   Boneless Snack/18oz And    Frozen prepared foods
                             Larger
    Frzn Prepared Chicken   Bone-In Wings              Frozen prepared foods
    Frzn Prepared Chicken   Fz Meal Kits/Stuffed/      Frozen prepared foods
                             Other
    Frzn Prepared Chicken   Whole Muscle Unbreaded     Frozen prepared foods
    Frzn Prepared Chicken   Boneless Snack/Value/      Frozen prepared foods
                             Small
    Frzn Seafood            Frz Coated Fish Fillets    Frozen prepared foods
    Frzn Seafood            Frz Fishsticks/Tenders/    Frozen prepared foods
                             Nuggets
    Frzn Seafood            Frz Non-Coated Fish        Frozen prepared foods
                             Fillets
    Frzn Ss Economy Meals   Fz Ss Economy Meals All    Frozen prepared foods
    Frzn Ss Premium Meals   Fz Ss Prem Traditional     Frozen prepared foods
                             Meals
    Frzn Ss Premium Meals   Fz Ss Prem Nutritional     Frozen prepared foods
                             Meals
    Apples                  Apples Gala (Bulk & Bag)   Fruits
    Apples                  Apples Red Delicious       Fruits
                             (Bulk & Bag)
    Apples                  Apples Granny Smith (Bulk  Fruits
                             & Bag)
    Apples                  Mixed Fruit Bags           Fruits
    Apples                  Apples Other (Bulk & Bag)  Fruits
    Apples                  Apples Fuji (Bulk & Bag)   Fruits
    Apples                  Apples Gold Delicious      Fruits
                             (Bulk & Bag)
    Apples                  Apples Honeycrisp          Fruits
    Apples                  Apples Braeburn (Bulk &    Fruits
                             Bag)
    Apples                  Apples Gala (Bulk & Bag)   Fruits
                             Organic
    Apples                  Apples Red Delicious       Fruits
                             (Bulk & Bag)
    Apples                  Apples Granny Smith (Bulk  Fruits
                             & Bag)
    Apples                  Apples Gold Delicious      Fruits
                             (Bulk & Bag)
    Bananas                 Bananas                    Fruits
    Bananas                 Bananas Organic            Fruits
    Berries                 Strawberries               Fruits
    Berries                 Blueberries                Fruits
    Berries                 Raspberries                Fruits
    Berries                 Blackberries               Fruits
    Berries                 Strawberries Organic       Fruits
    Berries                 Raspberries Organic        Fruits
    Berries                 Blueberries Organic        Fruits
    Can Fruit/Jar           Pineapple                  Fruits
     Applesauce
    Can Fruit/Jar           Peaches                    Fruits
     Applesauce
    Can Fruit/Jar           Fruit Cocktail/Fruit       Fruits
     Applesauce              Salad
    Can Fruit/Jar           Mandarin Oranges/Citrus    Fruits
     Applesauce              Sect
    Can Fruit/Jar           Apple Sauce (Excludes      Fruits
     Applesauce              Cup)
    Can Fruit/Jar           Pears                      Fruits
     Applesauce
    Can Fruit/Jar           Cranberry Sauce            Fruits
     Applesauce
    Citrus                  Oranges Navels All         Fruits
    Citrus                  Clementines                Fruits
    Citrus                  Lemons                     Fruits
    Citrus                  Limes                      Fruits
    Citrus                  Grapefruit                 Fruits
    Citrus                  Tangerines & Tangelos      Fruits
    Citrus                  Oranges Non Navel All      Fruits
    Convenience/Snacking    Jarred Fruit Single Serve  Fruits
    Convenience/Snacking    Convenience/Snacking       Fruits
                             Fruit Pro
    Convenience/Snacking    Jarred Fruit Multi Serve   Fruits
    Dried Fruit             Raisins                    Fruits
    Dried Fruit             Dried Fruit--Other         Fruits
    Dried Fruit             Dried Plums                Fruits
    Frozen Fruits           Frozen Fruit               Fruits
    Grapes                  Grapes Red                 Fruits
    Grapes                  Grapes White               Fruits
    Grapes                  Grapes Black/Blue          Fruits
    Grapes                  Grapes Red Globe           Fruits
    Grapes                  Grapes Other               Fruits
    Melons                  Watermelon Seedless Whole  Fruits
    Melons                  Cantaloupe Whole           Fruits
    Melons                  Watermelon Personal        Fruits
    Melons                  Watermelon W/Seeds Whole   Fruits
    Melons                  Honeydew Whole             Fruits
    Pears                   Pears Bartlett             Fruits
    Pears                   Pears Anjou                Fruits
    Pears                   Pears Bosc                 Fruits
    Single Serve Fruit/     Fruit Cup                  Fruits
     Applesauce
    Single Serve Fruit/     Applesauce Cup             Fruits
     Applesauce
    Stone Fruit             Cherries Red               Fruits
    Stone Fruit             Peaches Yellow Flesh       Fruits
    Stone Fruit             Nectarines Yellow Flesh    Fruits
    Stone Fruit             Plums                      Fruits
    Stone Fruit             Cherries Ranier            Fruits
    Stone Fruit             Peaches White Flesh        Fruits
    Tropical Fruit          Avocado                    Fruits
    Tropical Fruit          Pineapple Whole&Peel/      Fruits
                             Cored
    Tropical Fruit          Mango                      Fruits
    Tropical Fruit          Kiwi Fruit                 Fruits
    Tropical Fruit          Pomegranates               Fruits
    Value-Added Fruit       Instore Cut Fruit          Fruits
    Value-Added Fruit       Melons Instore Cut         Fruits
    Value-Added Fruit       Cut Fruit All Other        Fruits
                             Prepack
    Value-Added Fruit       Fruit Party Tray Prepack   Fruits
    Bagels & Cream Cheese   Cream Cheese               High fat dairy/cheese
    Bulk Service Case       Bulk Semi-Hard [Cheese]    High fat dairy/cheese
     Cheese
    Bulk Service Case       Bulk Processed [Cheese]    High fat dairy/cheese
     Cheese
    Bulk Service Case       Bulk Semi-Soft [Cheese]    High fat dairy/cheese
     Cheese
    Cheese                  Shredded Cheese            High fat dairy/cheese
    Cheese                  American Single Cheese     High fat dairy/cheese
    Cheese                  Natural Cheese Chunks      High fat dairy/cheese
    Cheese                  String Cheese              High fat dairy/cheese
    Cheese                  Natural Cheese Slices      High fat dairy/cheese
    Cheese                  Miscellaneous Cheese       High fat dairy/cheese
    Coffee & Creamers       Non Dairy Creamer          High fat dairy/cheese
    Crackers & Misc Baked   Aerosol Cheese             High fat dairy/cheese
     Food
    Dry Cheese              Loaf Cheese                High fat dairy/cheese
    Dry Cheese              Grated Cheese              High fat dairy/cheese
    Dry Cheese              Misc Dry Cheese            High fat dairy/cheese
    Fluid Milk Products     Refrigerated Coffee        High fat dairy/cheese
                             Creamers
    Fluid Milk              Products Half & Half       High fat dairy/cheese
    Fluid Milk Products     Whipping Cream             High fat dairy/cheese
    Fluid Milk Products     Egg Nog/Boiled Custard     High fat dairy/cheese
    Fluid Milk Products     Buttermilk                 High fat dairy/cheese
    Ice Cream Ice Milk &    Premium [Ice Cream &       High fat dairy/cheese
     Sherbets                Sherbert]
    Ice Cream Ice Milk &    Traditional [Ice Cream &   High fat dairy/cheese
     Sherbets                Sherbert]
    Ice Cream Ice Milk &    Pails [Ice Cream &         High fat dairy/cheese
     Sherbets                Sherbert]
    Ice Cream Ice Milk &    Super Premium Pints [Ice   High fat dairy/cheese
     Sherbets                Cream & Sherbert]
    Ice Cream Ice Milk &    Premium Pints [Ice Cream   High fat dairy/cheese
     Sherbets                & Sherbert]
    Ice Cream Ice Milk &    Quarts [Ice Cream &        High fat dairy/cheese
     Sherbets                Sherbert]
    Milk By-Products        Sour Creams                High fat dairy/cheese
    Milk By-Products        Cottage Cheese             High fat dairy/cheese
    Milk By-Products        Refrig Dips                High fat dairy/cheese
    Milk By-Products        Aerosol Toppings [Milk By- High fat dairy/cheese
                             Products]
    Milk By-Products        Ricotta Cheese             High fat dairy/cheese
    Pre-Slice Service Case  Pre-Sliced Semi-Soft       High fat dairy/cheese
     Cheese                  [Cheese]
    Pre-Slice Service Case  Pre-Sliced Semi-Hard       High fat dairy/cheese
     Cheese                  [Cheese]
    Refrigerated Hispanic   Hispanic Cheese            High fat dairy/cheese
     Grocery
    Specialty Cheese Pre    Specialty Ppk Cheese Hard/ High fat dairy/cheese
     Pack                    Grat
    Specialty Cheese Pre    Specialty Ppk Cheese       High fat dairy/cheese
     Pack                    Spreads
    Specialty Cheese Pre    Specialty Ppk Cheese Feta  High fat dairy/cheese
     Pack
    Specialty Cheese Pre    Specialty Ppk Cheese       High fat dairy/cheese
     Pack                    Mozzarell
    Specialty Cheese Pre    Specialty Ppk Cheese       High fat dairy/cheese
     Pack                    Processed
    Specialty Cheese Pre    Specialty Ppk Cheese       High fat dairy/cheese
     Pack                    Cheddar & C
    Specialty Cheese Pre    Specialty Ppk Cheese Semi  High fat dairy/cheese
     Pack                    Soft
    Specialty Cheese Pre    Specialty Ppk Cheese Soft  High fat dairy/cheese
     Pack                    & Ripe
    Specialty Cheese Pre    Specialty Ppk Cheese Blue/ High fat dairy/cheese
     Pack                    Gorg
    Specialty Cheese Pre    Specialty Ppk Cheese       High fat dairy/cheese
     Pack                    Hispanic
    Specialty Cheese Pre    Specialty Ppk Cheese       High fat dairy/cheese
     Pack                    Gouda & Eda
    Specialty Cheese Pre    Specialty Ppk Cheese Goat  High fat dairy/cheese
     Pack                    Milk
    Traditional Mexican     Mexican Con Queso          High fat dairy/cheese
     Foods
    Fruit Snacks            Fruit Snacks               Jams, jellies,
                                                        preserves and other
                                                        sweets
    Peanut Butter/Jelly/    Preserves/Jam/Marmalade    Jams, jellies,
     Jams & Honey                                       preserves and other
                                                        sweets
    Peanut Butter/Jelly/    Jelly                      Jams, jellies,
     Jams & Honey                                       preserves and other
                                                        sweets
    Aseptic Juice           Aseptic Pack Juice And     Juices
                             Drinks
    Frozen Juice And        Frzn Conc Allieds Over     Juices
     Smoothies               50% Jui
    Frozen Juice And        Frzn Oj & Oj Substitutes   Juices
     Smoothies               (Over 5
    Juice                   Non-Carb Jce(Over 50%      Juices
                             Jce)
    Juice                   Drinks--Carb Juice (Over   Juices
                             50%)
    Juices Super Premium    Juices Superfoods/         Juices
                             Enhanced
    Juices Super Premium    Juices Proteins            Juices
    Juices Super Premium    Juice Single Blend         Juices
    Processed               Squeeze Lemons/Limes       Juices
    Refrgratd Juices/       Dairy Case 100% Pure       Juices
     Drinks                  Juice--O
    Refrgratd Juices/       Dairy Case 100% Pure       Juices
     Drinks                  Juice Oth
    Rtd Tea/New Age Juice   Juice (Over 50% Juice)     Juices
    Shelf Stable Juice      Apple Juice & Cider (Over  Juices
                             50%)
    Shelf Stable Juice      Blended Juice &            Juices
                             Combinations (Ov)
    Shelf Stable Juice      Grape Juice (Over 50%      Juices
                             Juice)
    Shelf Stable Juice      Veg Juice (Except Tomato)  Juices
                             (Ove)
    Shelf Stable Juice      Tomato Juice (Over 50%     Juices
                             Jce)
    Shelf Stable Juice      Pineapple Juice (Over 50%  Juices
                             Juic)
    Shelf Stable Juice      Cranberry Juice (Over 50%  Juices
                             Jce)
    Shelf Stable Juice      Lemon Juice & Lime Juice   Juices
                             (Over)
    Shelf Stable Juice      Prune Juice (Over 50%      Juices
                             Juice)
    Shelf Stable Juice      Cranapple/Cran Grape       Juices
                             Juice (Ov)
    Shelf Stable Juice      Grapefruit Juice (Over     Juices
                             50% Jui)
    Shelf Stable Juice      Cranapple/Cran Grape       Juices
                             Juice (Un)
    Shelf Stable Juice      Grapefruit Juice (50% And  Juices
                             Unde)
    Bacon                   Bacon--Trad 16oz Or Less   Meat/Poultry/Seafood
    Bacon                   Bacon--Trad Greater Than   Meat/Poultry/Seafood
                             16oz
    Bacon                   Bacon--Poultry             Meat/Poultry/Seafood
    Bacon                   Bacon--Pre-Cooked          Meat/Poultry/Seafood
    Bacon                   Bacon--Trad Center Cut     Meat/Poultry/Seafood
    Bacon                   Bacon--Other               Meat/Poultry/Seafood
    Bacon                   Bacon--Natural/Organic     Meat/Poultry/Seafood
    Beef: Grinds            Lean [Beef]                Meat/Poultry/Seafood
    Beef: Grinds            Primal [Beef]              Meat/Poultry/Seafood
    Beef: Grinds            Angus [Beef]               Meat/Poultry/Seafood
    Beef: Grinds            Patties [Beef]             Meat/Poultry/Seafood
    Beef: Loins             Choice Beef                Meat/Poultry/Seafood
    Beef: Loins Select      Beef                       Meat/Poultry/Seafood
    Beef: Rib               Angus [Beef]               Meat/Poultry/Seafood
    Beef: Round             Choice Beef                Meat/Poultry/Seafood
    Beef: Round             Angus Beef                 Meat/Poultry/Seafood
    Beef: Round             Select Beef                Meat/Poultry/Seafood
    Beef: Thin Meats        Soup/Stew                  Meat/Poultry/Seafood
    Beef: Thin Meats        Cubed Meats [Beef]         Meat/Poultry/Seafood
    Beef: Thin Meats        Corned Beef                Meat/Poultry/Seafood
    Beef: Thin Meats        Brisket [Beef]             Meat/Poultry/Seafood
    Beef: Thin Meats        Skirt [Beef]               Meat/Poultry/Seafood
    Beef: Thin Meats        Flank [Beef]               Meat/Poultry/Seafood
    Breakfast Sausage       Bkfst Sausage--Fresh       Meat/Poultry/Seafood
                             Rolls
    Breakfast Sausage       Bkfst Sausage--Fresh       Meat/Poultry/Seafood
                             Links
    Breakfast Sausage       Bkfst Sausage--Fresh       Meat/Poultry/Seafood
                             Patties
    Breakfast Sausage       Bkfst Sausage--Precooked   Meat/Poultry/Seafood
    Breakfast Sausage       Bkfst Sausage--Bkfast      Meat/Poultry/Seafood
                             Side Di
    Breakfast Sausage       Bkfst Sausage--Other       Meat/Poultry/Seafood
                             Forms
    Buffalo                 Grinds [Buffalo]           Meat/Poultry/Seafood
    Can Seafood--Shelf      Tuna                       Meat/Poultry/Seafood
     Stable
    Can Seafood--Shelf      Salmon                     Meat/Poultry/Seafood
     Stable
    Can Seafood--Shelf      Sardines                   Meat/Poultry/Seafood
     Stable
    Can Seafood--Shelf      Oysters                    Meat/Poultry/Seafood
     Stable
    Chicken & Poultry       Chix: Value-Added (Cold)   Meat/Poultry/Seafood
    Chicken & Poultry       Chix: Frd 8pc/Cut Up       Meat/Poultry/Seafood
                             (Cold)
    Chicken & Poultry       Chix: Baked 8pc Cut Up     Meat/Poultry/Seafood
                             (Cold)
    Chicken & Poultry       Chix: Rotisserie Cold      Meat/Poultry/Seafood
    Chicken Fresh           Chicken Breast Boneless    Meat/Poultry/Seafood
    Chicken Fresh           Chicken Wings              Meat/Poultry/Seafood
    Chicken Fresh           Chicken Drums              Meat/Poultry/Seafood
    Chicken Fresh           Whole Chicken (Roasters/   Meat/Poultry/Seafood
                             Fryer)
    Chicken Fresh           Chicken Thighs             Meat/Poultry/Seafood
    Chicken Fresh           Chicken Legs/Quarters      Meat/Poultry/Seafood
    Chicken Fresh           Mixed Packs [Chicken]      Meat/Poultry/Seafood
    Chicken Frozen          Frzn Chicken--Wht Meat     Meat/Poultry/Seafood
    Chicken Frozen          Frzn Chicken--Wings        Meat/Poultry/Seafood
    Chicken Frozen          Frzn Chicken--Drk Meat     Meat/Poultry/Seafood
    Chicken Grinds          Ground Chicken             Meat/Poultry/Seafood
    Chicken Offal           Internal Chicken Offal     Meat/Poultry/Seafood
    Chicken Specialty/      Chicken Breast Boneless    Meat/Poultry/Seafood
     Natural
    Chicken Specialty/      Chicken Wings              Meat/Poultry/Seafood
     Natural
    Chicken Specialty/      Whole Chicken (Roasters/   Meat/Poultry/Seafood
     Natural                 Fryer)
    Deli Meat: Bulk         Meat: Turkey Bulk          Meat/Poultry/Seafood
    Deli Meat: Bulk         Meat: Ham Bulk             Meat/Poultry/Seafood
    Deli Meat: Bulk         Meat: Beef Bulk            Meat/Poultry/Seafood
    Deli Meat: Bulk         Meat Bulk: Specialty Dry   Meat/Poultry/Seafood
                             Meats
    Deli Meat: Bulk         Bologna/Loaves/Franks      Meat/Poultry/Seafood
    Deli Meat: Bulk         Meat: Chicken Bulk         Meat/Poultry/Seafood
    Deli Meat: Presliced    Deli Meat: Specialty Dry   Meat/Poultry/Seafood
                             Meats
    Deli Meat: Presliced    Deli Meat: Semi-Dry        Meat/Poultry/Seafood
                             Sausage
    Deli Meat: Presliced    Deli Meat: Turkey          Meat/Poultry/Seafood
    Deli Meat: Presliced    Deli Meat: Ham             Meat/Poultry/Seafood
    Deli Meat: Presliced    Deli Meat: Beef            Meat/Poultry/Seafood
    Dinner Sausage          Dnr Sausage--Links Pork    Meat/Poultry/Seafood
                             Ckd/S
    Dinner Sausage          Dnr Sausage--Links Fresh   Meat/Poultry/Seafood
    Dinner Sausage          Dnr Sausage--Pork Rope     Meat/Poultry/Seafood
                             Ckd/Sm
    Dinner Sausage          Dnr Sausage--Beef Rope     Meat/Poultry/Seafood
                             Ckd/Sm
    Dinner Sausage          Dnr Sausage--Other Forms   Meat/Poultry/Seafood
    Dinner Sausage          Dnr Sausage--Links Beef    Meat/Poultry/Seafood
                             Ckd/S
    Dinner Sausage          Dnr Sausage--Poultry Rope  Meat/Poultry/Seafood
                             Ckd
    Dinner Sausage          Dnr Sausage--Links         Meat/Poultry/Seafood
                             Poultry Ck
    Dinner Sausage          Dnr Sausage--Natural/      Meat/Poultry/Seafood
                             Organic
    Dinner Sausage          Dnr Sausage--Fresh         Meat/Poultry/Seafood
                             Poultry
    Frozen Breakfast Foods  Frzn Breakfast Sausage     Meat/Poultry/Seafood
    Frzn Multi Serve        Frzn Burgers               Meat/Poultry/Seafood
    Frzn Prepared Chicken   Value Forms/18oz And       Meat/Poultry/Seafood
                             Larger [Chicken]
    Hot Dogs                Hot Dogs--Base Meat        Meat/Poultry/Seafood
    Hot Dogs                Hot Dogs--Base Beef        Meat/Poultry/Seafood
    Hot Dogs                Hot Dogs--Premium          Meat/Poultry/Seafood
    Hot Dogs                Hot Dogs--Base Poultry     Meat/Poultry/Seafood
    Lamb                    Round/Leg [Lamb]           Meat/Poultry/Seafood
    Lamb                    Loin [Lamb]                Meat/Poultry/Seafood
    Lamb                    Chuck/Shoulder [Lamb]      Meat/Poultry/Seafood
    Lunchmeat               Lunchment--Deli Fresh      Meat/Poultry/Seafood
    Lunchmeat               Lunchment--Bologna/        Meat/Poultry/Seafood
                             Sausage
    Lunchmeat               Lunchmeat--Chop/Form       Meat/Poultry/Seafood
                             Pltry & Ha
    Lunchmeat               Lunchmeat--Whole Muscle    Meat/Poultry/Seafood
                             Pltry
    Lunchmeat               Lunchmeat--Chip Meat       Meat/Poultry/Seafood
    Lunchmeat               Lunchmeat--Brauns/Liver/   Meat/Poultry/Seafood
                             Loave
    Lunchmeat               Lunchmeat--Variety Pack    Meat/Poultry/Seafood
    Lunchmeat               Lunchmeat--Other           Meat/Poultry/Seafood
    Lunchmeat               Lunchment--Natural/        Meat/Poultry/Seafood
                             Organic
    Lunchmeat               Lunchmeat--Peggable Deli   Meat/Poultry/Seafood
                             Fres
    Meat Frozen             Frzn Meat--Beef            Meat/Poultry/Seafood
    Meat Frozen             Frzn Meat--Breakfast       Meat/Poultry/Seafood
                             Sausage
    Meat Frozen             Frzn Meat--Offals          Meat/Poultry/Seafood
    Meat Frozen             Frzn Meat--Turkey          Meat/Poultry/Seafood
    Meat Snacks             Jerky/Nuggets/Tenders      Meat/Poultry/Seafood
    Meat Snacks             Meat Sticks/Bites          Meat/Poultry/Seafood
    Party Tray Deli         Tray: Meat And Cheese      Meat/Poultry/Seafood
    Pork Bone In Loin/Rib   Dry [Pork Bone In Loin/    Meat/Poultry/Seafood
                             Rib]
    Pork Boneless Loin/Rib  Enhanced [Pork Boneless    Meat/Poultry/Seafood
                             Loin/Rib]
    Pork Grinds             Ground Pork                Meat/Poultry/Seafood
    Pork Offal              External Fresh [Pork       Meat/Poultry/Seafood
                             Offal]
    Pork Shoulder           Butts [Pork Shoulder]      Meat/Poultry/Seafood
    Pork Shoulder           Fresh Hams                 Meat/Poultry/Seafood
    Pork Thin Meats         Ribs [Pork]                Meat/Poultry/Seafood
    Poultry                 Other Cornish Hen          Meat/Poultry/Seafood
    Random Weight Meat      Lunch Meats                Meat/Poultry/Seafood
     Products
    Seafood--Catfish        Catfish--Fillet            Meat/Poultry/Seafood
    Seafood--Catfish        Catfish--Whole             Meat/Poultry/Seafood
    Seafood--Catfish        Catfish--Nuggets           Meat/Poultry/Seafood
    Seafood--Cod            Cod--Fillet                Meat/Poultry/Seafood
    Seafood--Crab           Crab--Snow                 Meat/Poultry/Seafood
    Seafood--Crab           Crab--King                 Meat/Poultry/Seafood
    Seafood--Crab           Crab--Dungy                Meat/Poultry/Seafood
    Seafood--Crab           Crab--Other                Meat/Poultry/Seafood
    Seafood--Finfish        Other Finfish--Other       Meat/Poultry/Seafood
    Seafood--Finfish        Other Finfish--Other       Meat/Poultry/Seafood
    Seafood--Lobster        Lobster--Tails             Meat/Poultry/Seafood
    Seafood--Party Trays    Party Tray--Shrimp         Meat/Poultry/Seafood
    Seafood--Salmon-Farm    Salmon Fr--Altantic        Meat/Poultry/Seafood
     Raised
    Seafood--Salmon-Wild    Salmon Wc--Pink            Meat/Poultry/Seafood
     Caught
    Seafood--Salmon-Wild    Salmon Wc--Sockeye         Meat/Poultry/Seafood
     Caught
    Seafood--Scallops       Scallops--Sea              Meat/Poultry/Seafood
    Seafood--Shrimp         Shrimp--Raw                Meat/Poultry/Seafood
    Seafood--Shrimp         Shrimp--Cooked             Meat/Poultry/Seafood
    Seafood--Smoked         Smoked Salmon              Meat/Poultry/Seafood
     Seafood
    Seafood--Tilapia        Tilapia--Fillet            Meat/Poultry/Seafood
    Seafood--Trout          Steelhead Fr [Trout]       Meat/Poultry/Seafood
    Seafood--Value-Added    Value-Added Breaded        Meat/Poultry/Seafood
     Seafood                 Shrimp
    Seafood--Value-Added    Value-Added Shrimp         Meat/Poultry/Seafood
     Seafood
    Seafood--Value-Added    Value-Added Crab           Meat/Poultry/Seafood
     Seafood
    Service Case Meat       Seasoned Poultry           Meat/Poultry/Seafood
    Service Case Meat       Stuffed/Mixed Beef         Meat/Poultry/Seafood
    Service Case Meat       Marinated Pork             Meat/Poultry/Seafood
    Service Case Meat       Marinated Poultry          Meat/Poultry/Seafood
    Service Case Meat       Seasoned Beef              Meat/Poultry/Seafood
    Service Case Meat       Seasoned Pork              Meat/Poultry/Seafood
    Service Case Meat       Stuffed/Mixed Poultry      Meat/Poultry/Seafood
    Service Case Meat       Marinated Beef             Meat/Poultry/Seafood
    Service Case Meat       Kabobs Beef                Meat/Poultry/Seafood
    Service Case Meat       Kabobs Poultry             Meat/Poultry/Seafood
    Service Case Meat       Stuffed/Mixed Pork         Meat/Poultry/Seafood
    Smoked Hams             Hams--Half/Port Bone-In    Meat/Poultry/Seafood
    Smoked Hams             Hams--Spiral               Meat/Poultry/Seafood
    Smoked Hams             Hams--Whole Boneless       Meat/Poultry/Seafood
    Smoked Hams             Hams--Half/Port Boneless   Meat/Poultry/Seafood
    Smoked Hams             Hams--Dry Cured/Country    Meat/Poultry/Seafood
    Smoked Hams             Hams--Whole Bone-In        Meat/Poultry/Seafood
    Smoked Pork             Ham Steaks/Cubes/Slices    Meat/Poultry/Seafood
    Smoked Pork             Smoked Offal [Pork]        Meat/Poultry/Seafood
    Smoked Pork             Bacon--Belly/Jowl          Meat/Poultry/Seafood
    Smoked Pork             Smoked Picnics [Pork]      Meat/Poultry/Seafood
    Snack Meat              Snack Meat--Pepperoni      Meat/Poultry/Seafood
    Snack Meat              Snack Meat--Salami/Smr     Meat/Poultry/Seafood
                             Sausag
    Turkey Fresh            Whole Hen (Under 16lbs)    Meat/Poultry/Seafood
                             [Turkey]
    Turkey Fresh            Whole Tom (Over 16lbs)     Meat/Poultry/Seafood
                             [Turkey]
    Turkey Frozen           Whole Toms (Over 16lbs)    Meat/Poultry/Seafood
                             [Turkey]
    Turkey Frozen           Whole Hens (Under 16lbs)   Meat/Poultry/Seafood
                             [Turkey]
    Turkey Frozen           Turkey Breast Bone In      Meat/Poultry/Seafood
    Turkey Grinds           Ground Turkey              Meat/Poultry/Seafood
    Turkey Offal            External [Turkey Offal]    Meat/Poultry/Seafood
    Turkey Smoked           Turkey Wings               Meat/Poultry/Seafood
    Turkey Smoked           Turkey Drums               Meat/Poultry/Seafood
    Fluid Milk Products     Fluid Milk/White Only      Milk
    Fluid Milk Products     Flavored Milk              Milk
    Fluid Milk Products     Specialty/Lactose Free     Milk
                             Milk
    Fluid Milk Products     Organic Milk               Milk
    Fluid Milk Products     Soy Milk                   Milk
    Non-Dairy/Dairy         Aseptic Milk               Milk
     Aseptic
    Non-Dairy/Dairy         Soy Beverage               Milk
     Aseptic
    Non-Dairy/Dairy         Nut Milk                   Milk
     Aseptic
    Non-Dairy/Dairy         Rice Beverage              Milk
     Aseptic
    Refrigerated Dairy      Non-Dairy Milks            Milk
     Case
    Refrigerated Dairy      Fluid Milk                 Milk
     Case
    Authentic Asian Foods   Authentic Japanese Foods   Miscellaneous
    Authentic Asian Foods   Authentic Chinese Foods    Miscellaneous
    Authentic Central       Central American Foods     Miscellaneous
     American Fds
    Authentic Hispanic Fds  Hispanic Baking Needs      Miscellaneous
     & Product
    Baking Needs            Baking Powder & Soda       Miscellaneous
    Baking Needs            Yeast: Dry                 Miscellaneous
    Baking Needs            Corn Starch                Miscellaneous
    Dietary Aid Prdct/Med   Diet Cntrl Liqs            Miscellaneous
     Liq Nutr                Nutritional
    Dietary Aid Prdct/Med   Diet Energy Drinks         Miscellaneous
     Liq Nutr
    Dietary Aid Prdct/Med   Diet Cntrl Bars            Miscellaneous
     Liq Nutr                Nutritional
    Fitness & Diet          Fitness & Diet--Bars W/    Miscellaneous
                             Flour
    Fitness & Diet          Fitness & Diet--Bars W/O   Miscellaneous
                             Flour
    Fitness & Diet          Fitness & Diet--Powder     Miscellaneous
                             Ntrtnl
    Refrigerated Hispanic   Misc Hispanic Grocery      Miscellaneous
     Grocery
    Baking Needs            Baking Nuts                Nuts and seeds
    Bulk Food               Trail Mix/Nuts Bulk        Nuts and seeds
    Condiments              Nut Butters/Peanut Butter  Nuts and seeds
    Nuts                    Pistachios                 Nuts and seeds
    Nuts                    Mixed Nuts                 Nuts and seeds
    Nuts                    Cashews                    Nuts and seeds
    Nuts                    Sunflower/Other Seeds      Nuts and seeds
    Nuts                    Pecans Shelled             Nuts and seeds
    Nuts                    Peanuts All                Nuts and seeds
    Nuts                    Walnuts Shelled            Nuts and seeds
    Nuts                    Almonds Shelled            Nuts and seeds
    Nuts                    Trail Mix                  Nuts and seeds
    Nuts                    Almonds                    Nuts and seeds
    Nuts                    Dry Roast Peanuts          Nuts and seeds
    Nuts                    Oil Roast Peanuts          Nuts and seeds
    Nuts                    Nuts Other                 Nuts and seeds
    Nuts                    Misc Snack Nuts            Nuts and seeds
    Nuts                    Nuts Inshell               Nuts and seeds
    Peanut Butter/Jelly/    Peanut Butter              Nuts and seeds
     Jams & Honey
    Trail Mix & Snacks      Trail Mixes/Snack          Nuts and seeds
    Canned & Dry Milk       Canned Milk                Other dairy products
    Canned & Dry Milk       Non Fat Dry Milk           Other dairy products
    Refrigerated Dairy      Yogurt                     Other dairy products
     Case
    Refrigerated Dairy      Kefir                      Other dairy products
     Case
    Yogurt                  Yogurt/Kids                Other dairy products
    Yogurt                  Yogurt/Ss Regular          Other dairy products
    Yogurt                  Yogurt/Ss Light            Other dairy products
    Yogurt                  Yogurt/Pro Active Health   Other dairy products
    Yogurt                  Yogurt/Adult Multi-Packs   Other dairy products
    Yogurt                  Yogurt/Specialty Greek     Other dairy products
    Yogurt                  Yogurt/Large Size (16oz    Other dairy products
                             Or Lar)
    Yogurt                  Yogurt/Adult Drinks        Other dairy products
    Deli Specialties        Dl Spec: Dry/Refrig        Pasta, cornmeal,
     (Retail Pk)             Pastas                     other cereal
                                                        products
    Dry Bean Veg & Rice     Noodle Side Dish Mixes     Pasta, cornmeal,
                                                        other cereal
                                                        products
    Dry Noodles & Pasta     Long Cut Pasta             Pasta, cornmeal,
                                                        other cereal
                                                        products
    Dry Noodles & Pasta     Short Cut Pasta            Pasta, cornmeal,
                                                        other cereal
                                                        products
    Dry Noodles & Pasta     Noodles Dry                Pasta, cornmeal,
                                                        other cereal
                                                        products
    Dry/Ramen Bouillon      Ramen Noodles/Ramen Cups   Pasta, cornmeal,
                                                        other cereal
                                                        products
    Flour & Meals           Cornmeal                   Pasta, cornmeal,
                                                        other cereal
                                                        products
    Prepared/Pdgd Foods     Pasta/Ramen                Pasta, cornmeal,
                                                        other cereal
                                                        products
    Refrigerated Italian    Refrigerated Pasta         Pasta, cornmeal,
                                                        other cereal
                                                        products
    Salad & Dips            Pasta/Grain Salads--       Pasta, cornmeal,
                             Prepack                    other cereal
                                                        products
    Salad & Dips            Pasta/Grain Salads--Bulk   Pasta, cornmeal,
                                                        other cereal
                                                        products
    Seafood--Salad/Dip/Sce/ Breading                   Pasta, cornmeal,
     Cond                                               other cereal
                                                        products
    Traditional Asian       Asian Noodles/Rice         Pasta, cornmeal,
     Foods                                              other cereal
                                                        products
    Authentic Hispanic Fds  Hispanic Cookies/Crackers  Prepared Desserts
     & Product
    Baked Sweet Goods       Snack Cake--Multi Pack     Prepared Desserts
    Baked Sweet Goods       Sweet Goods--Full Size     Prepared Desserts
    Bakery Party Trays      Party Trays: Cakes         Prepared Desserts
    Baking Mixes            Layer Cake Mix             Prepared Desserts
    Baking Mixes            Frosting                   Prepared Desserts
    Baking Mixes            Muffin & Corn Bread Mix    Prepared Desserts
    Baking Mixes            Brownie Mix                Prepared Desserts
    Baking Mixes            Cookies Mix                Prepared Desserts
    Baking Mixes            Miscellaneous Package      Prepared Desserts
                             Mixes
    Baking Needs            Bits & Morsels [Baking     Prepared Desserts
                             Needs]
    Baking Needs            Marshmallows               Prepared Desserts
    Baking Needs            Pie Filling/Mincemeat/     Prepared Desserts
                             Glazes
    Baking Needs            Pie Crust Mixes & Shells   Prepared Desserts
    Baking Needs            Cooking Chocolate (Ex:     Prepared Desserts
                             Smi-Swt)
    Baking Needs            Maraschino Cherries        Prepared Desserts
    Baking Needs            Baking Cocoa               Prepared Desserts
    Baking Needs            Marshmallow Creme          Prepared Desserts
    Baking Needs            Coconut [Baking Needs]     Prepared Desserts
    Cake Decor              Cake Decors & Icing        Prepared Desserts
    Cake Decor              Cake Decors--Candies       Prepared Desserts
    Cakes                   Cakes: Birthday/           Prepared Desserts
                             Celebration Sh
    Cakes                   Cakes: Cupcakes            Prepared Desserts
    Cakes                   Cakes: Layers              Prepared Desserts
    Cakes                   Cakes: Creme/Pudding       Prepared Desserts
    Cakes                   Cakes: Cheesecake          Prepared Desserts
    Cakes                   Cakes: Fancy/Service Case  Prepared Desserts
    Cakes                   Cakes: Layers/Sheets       Prepared Desserts
                             Novelties
    Cakes                   Cakes: Angel Fds/Cke       Prepared Desserts
                             Rolls
    Cakes                   Cakes: Ice Cream           Prepared Desserts
    Cakes                   Cakes: Birthday/           Prepared Desserts
                             Celebration Lay
    Cakes                   Cakes: Sheet               Prepared Desserts
    Cakes                   Cakes: Creme/Pudding       Prepared Desserts
                             Novelties
    Cakes                   Cakes: Cheesecake          Prepared Desserts
                             Novelties
    Cnv Breakfast &         Toaster Pastries           Prepared Desserts
     Wholesome Snks
    Cnv Breakfast &         Treats                     Prepared Desserts
     Wholesome Snks
    Cookie/Cracker Multi-   Multi-Pack Cookies         Prepared Desserts
     Pks
    Cookies                 Sandwich Cookies           Prepared Desserts
    Cookies                 Tray Pack/Choc Chip        Prepared Desserts
                             Cookies
    Cookies                 Cookies: Regular           Prepared Desserts
    Cookies                 Vanilla Wafer/Kids         Prepared Desserts
                             Cookies
    Cookies                 Cookies: Holiday/Special   Prepared Desserts
                             Occas
    Cookies                 Premium Cookies (Ex:       Prepared Desserts
                             Pepperidg)
    Cookies                 Graham Crackers            Prepared Desserts
    Cookies                 Chocolate Covered Cookies  Prepared Desserts
    Cookies                 Wellness/Portion Control   Prepared Desserts
                             [Cookies]
    Cookies                 Cookies: Gourmet           Prepared Desserts
    Cookies                 Fruit Filled Cookies       Prepared Desserts
    Cookies                 Cookies: Message           Prepared Desserts
    Cookies                 Cookies/Sweet Goods        Prepared Desserts
    Cookies                 Specialty Cookies          Prepared Desserts
    Dry Mix Desserts        Pudding & Gelatin Cups/    Prepared Desserts
                             Cans
    Dry Mix Desserts        Puddings Dry               Prepared Desserts
    Dry Mix Desserts        Gelatin                    Prepared Desserts
    Dry Mix Desserts        Misc: Cheesecake/Mousse    Prepared Desserts
                             Mixes
    Frozen Breakfast Foods  Frzn Breakfast Pastry      Prepared Desserts
    Frozen Desserts         Frozen Fruit Pies &        Prepared Desserts
                             Cobblers
    Frozen Desserts         Frozen Cream Pies          Prepared Desserts
    Frozen Desserts         Frzn Pie Shells/Pastry     Prepared Desserts
                             Shell/F
    Frozen Desserts         Frozen Cakes/Desserts      Prepared Desserts
    Frozen Desserts         Frzn Pastry & Cookies      Prepared Desserts
    Frozen Desserts         Single Serv/Portion        Prepared Desserts
                             Control
    Frozen Novelties--      Sticks/Enrobed [Frozen     Prepared Desserts
     Water Ice               Novelties]
    Frozen Novelties--      Water Ice [Frozen          Prepared Desserts
     Water Ice               Novelties]
    Frozen Novelties--      Cones [Frozen Novelties]   Prepared Desserts
     Water Ice
    Frozen Novelties--      Ice Cream Sandwiches       Prepared Desserts
     Water Ice
    Frozen Novelties--      Adult Premium [Frozen      Prepared Desserts
     Water Ice               Novelties]
    Frozen Novelties--      Cups/Push Ups/Other        Prepared Desserts
     Water Ice               [Frozen Novelties]
    Frozen Whipped Topping  Frzn Whipped Topping       Prepared Desserts
    Pies                    Pies: Fruit/Nut            Prepared Desserts
    Pies                    Pies: Pumpkin/Custard      Prepared Desserts
    Pies                    Pies: Cream/Meringue       Prepared Desserts
    Pies                    Pies: Sugar Free           Prepared Desserts
    Pies                    Pies: Tarts/Minis/Crstdas  Prepared Desserts
    Refrgrated Dough        Refrigerated Cookies--     Prepared Desserts
     Products                Break N B
    Refrgrated Dough        Refrigerated Cookie Dough  Prepared Desserts
     Products
    Refrgrated Dough        Refrigerated Cookies--     Prepared Desserts
     Products                Seasonal
    Refrgrated Dough        Refrigerated Pie Crust     Prepared Desserts
     Products
    Refrigerated Desserts   Refrigerated Pudding       Prepared Desserts
    Salad & Dips            Sal: Desserts--Prepack     Prepared Desserts
    Salad & Dips            Sal: Desserts--Bulk        Prepared Desserts
    Single Serve Sweet      Snack Cake--Single Serve   Prepared Desserts
     Goods
    Ss/Vending--Cookie/     Vendor Size/Single Serve   Prepared Desserts
     Cracker                 Cooki
    Sweet Goods             Sw Gds: Donuts             Prepared Desserts
    Sweet Goods             Sw Gds: Sw Rolls/Dan       Prepared Desserts
    Sweet Goods             Sw Gds: Muffins            Prepared Desserts
    Sweet Goods             Sw Gds: Coffee Cakes       Prepared Desserts
    Sweet Goods & Snacks    Sw Gds: Swt/Flvrd Loaves   Prepared Desserts
    Sweet Goods & Snacks    Sw Gds: Brownie/Bar        Prepared Desserts
                             Cookie
    Sweet Goods & Snacks    Sw Gds: Puff Pastry        Prepared Desserts
    Sweet Goods & Snacks    Sw Gds: Specialty          Prepared Desserts
                             Desserts
    Syrups Toppings &       Ice Cream Toppings         Prepared Desserts
     Cones
    Value-Added Fruit       Parfait Cups Instore       Prepared Desserts
    Canned Pasta & Mwv Fd-  Can Pasta                  Prepared Foods
     Shlf Stbl
    Canned Pasta & Mwv Fd-  Microwavable Cups [Pasta]  Prepared Foods
     Shlf Stbl
    Chilled Ready Meals     Store Brand                Prepared Foods
    Convenient Meals        Convenient Meals--Kids     Prepared Foods
                             Meal C
    Convenient Meals        Convenient Meals--Adult    Prepared Foods
                             Meal
    Dinner Mixes--Dry       Macaroni & Cheese Dnrs     Prepared Foods
    Dinner Mixes--Dry       Skillet Dinners            Prepared Foods
    Dinner Mixes--Dry       Microwave Dinners          Prepared Foods
    Dinner Mixes--Dry       Package Dinners/Pasta      Prepared Foods
                             Salads
    Dinner Mixes--Dry       Pizza Mix Dry              Prepared Foods
    Dinner Sausage          Dnr Sausage--Cocktails     Prepared Foods
    Meat--Shelf Stable      Chili: Canned              Prepared Foods
    Meat--Shelf Stable      Chunk Meats--Chix/Ham/     Prepared Foods
                             Etc.
    Meat--Shelf Stable      Sandwich Sauce (Manwich)   Prepared Foods
    Meat--Shelf Stable      Vienna Sausage             Prepared Foods
    Meat--Shelf Stable      Luncheon Meat (Spam)       Prepared Foods
    Meat--Shelf Stable      Hash: Canned               Prepared Foods
    Meat--Shelf Stable      Beef Stew                  Prepared Foods
    Meat--Shelf Stable      Hot Dog Chili Sauce        Prepared Foods
    Meat--Shelf Stable      Beef/Pork--Dried Sliced W/ Prepared Foods
                             Gra
    Meat--Shelf Stable      Potted Meats And Spreads   Prepared Foods
    Meat--Shelf Stable      Corn Beef                  Prepared Foods
    Party Tray              Deli Tray: Sandwiches      Prepared Foods
    Party Tray              Deli Tray:                 Prepared Foods
                             Appetizers&Hors D'oe
    Prepared/Pdgd Foods     Boxed Prepared/Entree/Dry  Prepared Foods
                             Prep
    Prepared/Pdgd Foods     Vegetables/Dry Beans       Prepared Foods
    Refrigerated            Vegetarian Meats           Prepared Foods
     Vegetarian
    Refrigerated            Vegetarian Misc            Prepared Foods
     Vegetarian
    Refrigerated            Non-Dairy Cheese           Prepared Foods
     Vegetarian
    Refrigerated            Tofu                       Prepared Foods
     Vegetarian
    Salad & Dips            Protein Salads--Bulk       Prepared Foods
    Salad & Dips            Protein Salads--Prepack    Prepared Foods
    Sandwiches              Sandwiches--(Cold)         Prepared Foods
    Sushi                   Sushi--In Store Prepared   Prepared Foods
    Sushi                   Sushi--Prepackaged         Prepared Foods
    Traditional Asian       Asian Foods And Meals      Prepared Foods
     Foods
    Traditional Asian       Traditional Thai Foods     Prepared Foods
     Foods
    Traditional Mexican     Mexican Dinners And Foods  Prepared Foods
     Foods
    Traditional Mexican     Mexican Enchilada Sauce    Prepared Foods
     Foods
    Authentic Hispanic Fds  Authentic Pasta/Rice/      Rice
     & Product               Beans
    Dry Bean Veg & Rice     Rice Side Dish Mixes Dry   Rice
    Dry Bean Veg & Rice     Rice--Dry Bag And Box      Rice
    Dry Bean Veg & Rice     Rice--Instant & Microwave  Rice
    Bag Snacks              Potato Chips               Salty snacks
    Bag Snacks              Tortilla/Nacho Chips       Salty snacks
    Bag Snacks              Mult Pk Bag Snacks         Salty snacks
    Bag Snacks              Bagged Cheese Snacks       Salty snacks
    Bag Snacks              Corn Chips                 Salty snacks
    Bag Snacks              Pretzels                   Salty snacks
    Bag Snacks              Store Brand                Salty snacks
    Bag Snacks              Misc Bag Snacks            Salty snacks
    Bag Snacks              Bagged Popped Popcorn      Salty snacks
    Bag Snacks              Pork Skins/Cracklins       Salty snacks
    Popcorn                 Popcorn--Microwave         Salty snacks
    Popcorn                 Popcorn--Other             Salty snacks
    Popcorn                 Caramel Coated Snacks      Salty snacks
    Snack                   Tortilla Chips             Salty snacks
    Snack                   Soy/Rice Snacks            Salty snacks
    Snacks                  Snacks: Pita Chips         Salty snacks
    Snacks                  Snacks: Salty              Salty snacks
    Snacks                  Snacks: Tortilla Chips     Salty snacks
    Snacks                  Snacks: Crackers/Cookies   Salty snacks
    Ss/Vending--Salty       Salty Snacks Vending       Salty snacks
     Snacks
    Warehouse Snacks        Canister Snacks            Salty snacks
    Warehouse Snacks        Snack Mix                  Salty snacks
    Warehouse Snacks        Misc Snacks                Salty snacks
    Authentic Hispanic Fds  Authentic Soups/Bouillons  Soup
     & Product
    Canned Soups            Condensed Soup             Soup
    Dry/Ramen Bouillon      Dry Soup                   Soup
    Dry/Ramen Bouillon      Bouillon                   Soup
    Rts/Micro Soup/Broth    Rts Soup: Chunky/          Soup
                             Homestyle/Et
    Rts/Micro Soup/Broth    Broth                      Soup
    Rts/Micro Soup/Broth    Microwavable Soups         Soup
    Soup                    Cans Soup/Chili            Soup
    Soup                    Broths                     Soup
    Condiments              Honey/Syrup                Sugars
    Dressings/Dips          Dips Caramel/Fruit Glazes  Sugars
    Molasses/Syrups/        Molasses & Syrups          Sugars
     Pancake Mixes
    Peanut Butter/Jelly/    Honey                      Sugars
     Jams & Honey
    Sugars & Sweeteners     Sugar                      Sugars
    Sugars & Sweeteners     Sweeteners                 Sugars
    Aseptic Juice           Aseptic Pack Juice And     Sweetened Beverages
                             Drinks
    Aseptic Juice           Aseptic Pack Juice And     Sweetened Beverages
                             Drinks
    Authentic Hispanic Fds  Hispanic Carbonated        Sweetened Beverages
     & Product               Beverages
    Authentic Hispanic Fds  Hispanic Juice Under 50%   Sweetened Beverages
     & Product               Juice
    Beverages               Can/Btl Carb Beve 50% And  Sweetened Beverages
                             Unde
    Cocoa Mixes             Malted Mlk/Syrup/Pwdrs     Sweetened Beverages
                             (Eggnog)
    Cocoa Mixes             Hot Chocolate/Cocoa Mix    Sweetened Beverages
    Energy Drinks           Energy Drink--Single       Sweetened Beverages
                             Serve
    Energy Drinks           Energy Drink--Single       Sweetened Beverages
                             Serve (N)
    Energy Drinks           Energy Drink--Multi-Pack   Sweetened Beverages
    Energy Drinks           Energy Drink--Multi-Pack   Sweetened Beverages
                             (Non)
    Frozen Juice And        Frzn Fruit Drinks (Under   Sweetened Beverages
     Smoothies               10% J)
    Frozen Juice And        Frzn Conc Under 50% Juice  Sweetened Beverages
     Smoothies
    Frozen Juice And        Smoothies-Frz              Sweetened Beverages
     Smoothies
    Frozen Juice And        Cocktail Mixes-Frz         Sweetened Beverages
     Smoothies
    Isotonic Drinks         Isotonic Drinks Single     Sweetened Beverages
                             Serve
    Isotonic Drinks         Isotonic Drinks Multi-     Sweetened Beverages
                             Pack
    Isotonic Drinks         Isotonic Drinks Multi-     Sweetened Beverages
                             Serve
    Isotonic Drinks         Sports Drink N/Supplmnt    Sweetened Beverages
                             Milk/M
    Juice                   Non-Carb Jce (Under 50%    Sweetened Beverages
                             Jce)
    Juices Super Premium    Juices Smoothies/Blended   Sweetened Beverages
    Juices Super Premium    Juices Antioxidant/        Sweetened Beverages
                             Wellness
    Juices Super Premium    Juices (50% And Under      Sweetened Beverages
                             Juice)
    Mixers Cocktail         Mixes--Fluid: Add Liq      Sweetened Beverages
    Powder & Crystal Drink  Unsweetened Envelope       Sweetened Beverages
     Mix                     [Powder Drink Mix]
    Powder & Crystal Drink  Sugar Free Canister        Sweetened Beverages
     Mix                     [Powder Drink Mix]
    Powder & Crystal Drink  Sugar Free Sticks [Powder  Sweetened Beverages
     Mix                     Drink Mix]
    Powder & Crystal Drink  Soft Drink Canisters       Sweetened Beverages
     Mix
    Powder & Crystal Drink  Enhanced Stick [Powder     Sweetened Beverages
     Mix                     Drink Mix]
    Powder & Crystal Drink  Sugar Sweetened Sticks     Sweetened Beverages
     Mix
    Powder & Crystal Drink  Fluid Pouch [Powder Drink  Sweetened Beverages
     Mix                     Mix]
    Powder & Crystal Drink  Breakfast Crystals         Sweetened Beverages
     Mix
    Processed               Packaged Dry Mixes         Sweetened Beverages
    Refrgratd Juices/       Dairy Case Juice Drnk      Sweetened Beverages
     Drinks                  Under 10
    Refrgratd Juices/       Dairy Case Citrus Pnch/Oj  Sweetened Beverages
     Drinks                  Subs
    Refrgratd Juices/       Dairy Case Tea With Sugar  Sweetened Beverages
     Drinks                  Or S
    Refrgratd Juices/       Dairy Case Fruit Drinks    Sweetened Beverages
     Drinks                  (No Ju)
    Rtd Tea/New Age Juice   Tea Sweetened              Sweetened Beverages
    Rtd Tea/New Age Juice   Juice (Under 10% Juice)    Sweetened Beverages
    Shelf Stable Juice      Fruit Drinks: Canned &     Sweetened Beverages
                             Glass
    Shelf Stable Juice      Cranapple/Cran Grape       Sweetened Beverages
                             Juice (50)
    Shelf Stable Juice      Cranberry Juice (50% And   Sweetened Beverages
                             Under)
    Shelf Stable Juice      Blended Juice &            Sweetened Beverages
                             Combinations (50)
    Shelf Stable Juice      Fruit Drinks: Canned &     Sweetened Beverages
                             Glass
    Shelf Stable Juice      Apple Juice & Cider (50%   Sweetened Beverages
                             And U)
    Shelf Stable Juice      Tomato Juice (50% And      Sweetened Beverages
                             Under)
    Shelf Stable Juice      Blended Juice &            Sweetened Beverages
                             Combinations (Un)
    Shelf Stable Juice      Fruit Drinks: Canned &     Sweetened Beverages
                             Glass
    Soft Drinks             Soft Drinks 12/18 & 15pk   Sweetened Beverages
                             Can Car
    Soft Drinks             Sft Drnk 2 Liter Btl Carb  Sweetened Beverages
                             Incl
    Soft Drinks             Soft Drinks 20pk & 24pk    Sweetened Beverages
                             Can Carb
    Soft Drinks             Sft Drnk Mlt-Pk Btl Carb   Sweetened Beverages
                             (Excp)
    Soft Drinks             Sft Drnk Sngl Srv Btl      Sweetened Beverages
                             Carb (Ex)
    Soft Drinks             Soft Drinks Can Non-Carb   Sweetened Beverages
                             (Exce)
    Soft Drinks             Soft Drinks 6pk Can Carb   Sweetened Beverages
                             (Exp)
    Soft Drinks             Sft Drnk 1 Liter Btl Carb  Sweetened Beverages
                             (Exc)
    Soft Drinks             Tea Can With Sweetener/    Sweetened Beverages
                             Sugar
    Soft Drinks             Soft Drink Bottle Non-     Sweetened Beverages
                             Carb (Ex)
    Soft Drinks             Tea Bottles With           Sweetened Beverages
                             Sweetener/Sug
    Soft Drinks             Mixers (Tonic Water/Gngr   Sweetened Beverages
                             Ale)
    Soft Drinks             Seltzer Unflavored         Sweetened Beverages
    Teas                    Instant Tea & Tea Mix (W/  Sweetened Beverages
                             Sugar)
    Water                   Non-Carb Water Flvr--Drnk/ Sweetened Beverages
                             Mnr
    Water--(Sparkling &     Still Water Flvrd Drnk/    Sweetened Beverages
     Still)                  Mnrl Wt
    Water--(Sparkling &     Sparkling Water--Flvrd     Sweetened Beverages
     Still)                  Sweet
    Authentic Hispanic Fds  Authentic Vegetables And   Vegetables
     & Product               Foods
    Authentic Hispanic Fds  Authentic Peppers          Vegetables
     & Product
    Authentic Italian       Italian Vegetables         Vegetables
     Foods
    Broccoli/Cauliflower    Broccoli Whole & Crowns    Vegetables
    Broccoli/Cauliflower    Cauliflower Whole          Vegetables
    Can Vegetables--Shelf   Green Beans: Fs/Whl/Cut    Vegetables
     Stable
    Can Vegetables--Shelf   Corn                       Vegetables
     Stable
    Can Vegetables--Shelf   Peas/Green                 Vegetables
     Stable
    Can Vegetables--Shelf   Spinach & Greens           Vegetables
     Stable
    Can Vegetables--Shelf   Mushrooms Cnd & Glass      Vegetables
     Stable
    Can Vegetables--Shelf   Sweet Potatoes             Vegetables
     Stable
    Can Vegetables--Shelf   Mixed Vegetables           Vegetables
     Stable
    Can Vegetables--Shelf   Carrots                    Vegetables
     Stable
    Can Vegetables--Shelf   White Potatoes             Vegetables
     Stable
    Can Vegetables--Shelf   Kraut & Cabbage            Vegetables
     Stable
    Can Vegetables--Shelf   Beets                      Vegetables
     Stable
    Can Vegetables--Shelf   Peas Fresh Pack/Crowder    Vegetables
     Stable
    Can Vegetables--Shelf   Artichokes                 Vegetables
     Stable
    Carrots                 Carrots Mini Peeled        Vegetables
    Carrots                 Carrots Bagged             Vegetables
    Carrots                 Carrots Bagged Organic     Vegetables
    Corn                    Corn Bulk                  Vegetables
    Corn                    Corn Is Packaged           Vegetables
    Dry Sce/Gravy/Potatoes/ Potatoes: Dry              Vegetables
     Stuffng
    Frozen Potatoes         Frzn French Fries          Vegetables
    Frozen Potatoes         Frzn Tater Tots/Other      Vegetables
                             Extruded
    Frozen Potatoes         Frzn Hashbrown Potatoes    Vegetables
    Frozen Potatoes         Frzn Baked/Stuffed/Mashed  Vegetables
                             & Spec
    Frozen Potatoes         Frzn Onion Rings           Vegetables
    Frozen Vegetable & Veg  Fz Bag Vegetables--Plain   Vegetables
     Dish
    Frozen Vegetable & Veg  Frzn Steamable Vegetables  Vegetables
     Dish
    Frozen Vegetable & Veg  Fz Box Vegetables--Value-  Vegetables
     Dish                    Added
    Frozen Vegetable & Veg  Frzn Corn On The Cob       Vegetables
     Dish
    Frozen Vegetable & Veg  Fz Bag Vegetables--Value-  Vegetables
     Dish                    Added
    Frozen Vegetable & Veg  Fz Box Vegetables--Plain   Vegetables
     Dish
    Herbs/Garlic            Garlic Whole Cloves        Vegetables
    Herbs/Garlic            Sprouts                    Vegetables
    Mushrooms               Mushrooms White Sliced     Vegetables
                             Pkg
    Mushrooms               Mushrooms White Whole Pkg  Vegetables
    Mushrooms               Mushrooms Portabella       Vegetables
    Mushrooms               Mushrooms White Bulk       Vegetables
    Onions                  Onions Yellow (Bulk &      Vegetables
                             Bag)
    Onions                  Onions Sweet (Bulk & Bag)  Vegetables
    Onions                  Onions Red (Bulk & Bag)    Vegetables
    Onions                  Onions White (Bulk & Bag)  Vegetables
    Organics Fruit &        Organic Salad Mix          Vegetables
     Vegetables
    Organics Fruit &        Organic Value-Added        Vegetables
     Vegetables              Vegetables
    Party Tray              Deli Tray: Fruit And       Vegetables
                             Vegetable
    Pasta & Pizza Sauce     Mainstream [Pasta & Pizza  Vegetables
                             Sauce]
    Pasta & Pizza Sauce     Value [Pasta & Pizza       Vegetables
                             Sauce]
    Pasta & Pizza Sauce     Pizza Sauce                Vegetables
    Peppers                 Peppers Green Bell         Vegetables
    Peppers                 Peppers Red Bell           Vegetables
    Peppers                 Peppers Other Bell         Vegetables
    Peppers                 Peppers Yellow Bell        Vegetables
    Peppers                 Peppers Jalapeno           Vegetables
    Peppers                 Peppers All Other          Vegetables
    Potatoes                Potatoes Russet (Bulk &    Vegetables
                             Bag)
    Potatoes                Potatoes Sweet & Yams      Vegetables
    Potatoes                Potatoes Red (Bulk & Bag)  Vegetables
    Potatoes                Potatoes Gourmet           Vegetables
    Potatoes                Potatoes Gold (Bulk &      Vegetables
                             Bag)
    Potatoes                Potatoes Other Organic     Vegetables
    Salad & Dips            Vegetable Salads--Prepack  Vegetables
    Salad & Dips            Vegetable Salads--Bulk     Vegetables
    Salad & Dips            Salad: Lettuce             Vegetables
    Salad & Dips            Salad Bar                  Vegetables
    Salad Bar               Salad Bar Other            Vegetables
    Salad Mix               Blends [Salad Mix]         Vegetables
    Salad Mix               Regular Garden             Vegetables
    Salad Mix               Garden Plus [Salad Mix]    Vegetables
    Salad Mix               Kits [Salad Mix]           Vegetables
    Salad Mix               Shredded Lettuce           Vegetables
    Salad Mix               Salad Bowls                Vegetables
    Salad Mix               Salad Mix Blends Organic   Vegetables
    Salad Mix               Salad Spinach              Vegetables
    Salad Mix               Coleslaw                   Vegetables
    Salad Mix               Salad Spinach Organic      Vegetables
    Seasonal                Pumpkins                   Vegetables
    Spices/Jarred Garlic    Garlic Jar                 Vegetables
    Tomato Products--Shelf  Tomatoes Diced             Vegetables
     Stable
    Tomato Products--Shelf  Tomato Sauce               Vegetables
     Stable
    Tomato Products--Shelf  Tomato Paste               Vegetables
     Stable
    Tomato Products--Shelf  Tomato Stewed              Vegetables
     Stable
    Tomato Products--Shelf  Tomatoes/Whole             Vegetables
     Stable
    Tomato Products--Shelf  Tomato Crushed             Vegetables
     Stable
    Tomatoes                Tomatoes Hothouse On The   Vegetables
                             Vine
    Tomatoes                Roma Tomatoes (Bulk/Pkg)   Vegetables
    Tomatoes                Tomatoes Vine Ripe Bulk    Vegetables
    Tomatoes                Tomatoes Hot House Bulk    Vegetables
    Tomatoes                Tomatoes Grape             Vegetables
    Tomatoes                Tomatoes Vine Ripe Pkg     Vegetables
    Tomatoes                Tomatoes Cherry            Vegetables
    Tomatoes                Tomatoes--Other            Vegetables
    Tomatoes                Tomatoes Others Organic    Vegetables
    Tomatoes                Tomatoes Cocktail          Vegetables
    Traditional Asian       Asian Vegetables           Vegetables
     Foods
    Traditional Mexican     Mexican Peppers Chilies    Vegetables
     Foods
    Value-Added Vegetables  Vegetable Party Tray       Vegetables
    Value-Added Vegetables  Cut Vegetables All Other   Vegetables
    Value-Added Vegetables  Instore Cut Vegetables     Vegetables
    Vegetables Cooking      Celery                     Vegetables
     Bulk
    Vegetables Cooking      Cabbage                    Vegetables
     Bulk
    Vegetables Cooking      Asparagus                  Vegetables
     Bulk
    Vegetables Cooking      Celery Organic             Vegetables
     Bulk
    Vegetables Cooking      Broccoli/Cauliflower       Vegetables
     Packaged                Processed
    Vegetables Cooking      Vegetables Cooking         Vegetables
     Packaged                Packaged
    Vegetables Salad        Head Lettuce               Vegetables
    Vegetables Salad        Cucumbers                  Vegetables
    Vegetables Salad        Variety Lettuce            Vegetables
    Vegetables Salad        Green Onions               Vegetables
    Vegetables Salad        Radish                     Vegetables
    Vegetables Salad        Variety Lettuce Organic    Vegetables
    Vegetables Salad        Spinach Bulk               Vegetables
    ------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ
      International, LLC, 2016.

                         Appendix C. Crosswalk of Subcommodities to USDA Food Pattern Categories
    ----------------------------------------------------------------------------------------------------------------
                                           USDA Food           SoFAS              Composite              Other
       Commodity        Subcommodity        Pattern        Subcategories        Subcategories        Subcategories
    ----------------------------------------------------------------------------------------------------------------
    Aseptic Juice    Kids Milk Drinks--  Dairy
                      Aseptic
    Bag Snacks       Bagged Cheese       Dairy
                      Snacks
    Bulk Service     Bulk Processed      Dairy
     Case Cheese      [Cheese]
    Bulk Service     Bulk Semi-Hard      Dairy
     Case Cheese      [Cheese]
    Bulk Service     Bulk Semi-Soft      Dairy
     Case Cheese      [Cheese]
    Bulk Service     Cheese:             Dairy
     Case Cheese      Cheeseballs/
                      Spreads
    Bulk Service     Cheese: Specialty   Dairy
     Case Cheese      Bulk
    Bulk Service     Cheese: Specialty   Dairy
     Case Cheese      Prepack
    Bulk Service     Service Case        Dairy
     Case Cheese      Natural [Cheese]
    Bulk Service     Service Case        Dairy
     Case Cheese      Natural
                      Prepackage
                      [Cheese]
    Bulk Service     Service Case        Dairy
     Case Cheese      Processed Prepack
                      [Cheese]
    Canned & Dry     Aseptic Milk &      Dairy
     Milk             Milk Drinks
    Canned & Dry     Canned Milk         Dairy
     Milk
    Canned & Dry     Non Fat Dry Milk    Dairy
     Milk
    Cheese           American Single     Dairy
                      Cheese
    Cheese           Miscellaneous       Dairy
                      Cheese
    Cheese           Natural Cheese      Dairy
                      Chunks
    Cheese           Natural Cheese      Dairy
                      Random Wt
    Cheese           Natural Cheese      Dairy
                      Slices
    Cheese           Shredded Cheese     Dairy
    Cheese           String Cheese       Dairy
    Crackers & Misc  Aerosol Cheese      Dairy
     Baked Food
    Cubes/           Cubes Cheese        Dairy
     Prepackage
     Cheese
    Cubes/           Prepackage Cheese   Dairy
     Prepackage
     Cheese
    Dry Cheese       Grated Cheese       Dairy
    Dry Cheese       Loaf Cheese         Dairy
    Dry Cheese       Misc Dry Cheese     Dairy
    Fluid Milk       Buttermilk          Dairy
     Products
    Fluid Milk       Egg Nog/Boiled      Dairy
     Products         Custard
    Fluid Milk       Flavored Milk       Dairy
     Products
    Fluid Milk       Fluid Milk/White    Dairy
     Products         Only
    Fluid Milk       Half & Half         Dairy
     Products
    Fluid Milk       Organic Milk        Dairy
     Products
    Fluid Milk       Soy Milk            Dairy
     Products
    Fluid Milk       Specialty/Lactose   Dairy
     Products         Free Milk
    Milk By-         Cottage Cheese      Dairy
     Products
    Milk By-         Ricotta Cheese      Dairy
     Products
    Non-Dairy/Dairy  Aseptic Milk        Dairy
     Aseptic
    Non-Dairy/Dairy  Soy Beverage        Dairy
     Aseptic
    Pre-Slice        Pre-Sliced          Dairy
     Service Case     Processed
     Cheese           [Cheese]
    Pre-Slice        Pre-Sliced Semi-    Dairy
     Service Case     Hard [Cheese]
     Cheese
    Pre-Slice        Pre-Sliced Semi-    Dairy
     Service Case     Soft [Cheese]
     Cheese
    Refrigerated     Cheese Spreads      Dairy
     Dairy Case
    Refrigerated     Dairy Cheese        Dairy
     Dairy Case
    Refrigerated     Fluid Milk          Dairy
     Dairy Case
    Refrigerated     Kefir               Dairy
     Dairy Case
    Refrigerated     Yogurt              Dairy
     Dairy Case
    Refrigerated     Hispanic Cheese     Dairy
     Hispanic
     Grocery
    Service          Sv Bev: Milk/Milk   Dairy
     Beverage         Products
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Blue
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Cheddar
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Cheeseba
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Feta
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Fresh
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Gift Pac
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Goat
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Gouda &
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Hard
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Hispanic
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Mozzarel
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Semi-Sof
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Smallwar
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Soft Rip
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Spreads
    Specialty Bulk   Specialty Bulk      Dairy
     Cheese           Cheese Swiss
    Specialty        Ppk Cheese Shoppe   Dairy
     Cheese Pre
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Blue/Gorg
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Cheddar &
     Pack             C
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Feta
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Fresh
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Gift Pack
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Goat Milk
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Gouda &
     Pack             Eda
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Hard/Grat
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Hispanic
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Mozzarell
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Processed
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Semi Soft
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Soft &
     Pack             Ripe
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Spreads
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese Swiss
     Pack
    Specialty        Specialty Ppk       Dairy
     Cheese Pre       Cheese: Smallwar
     Pack
    Traditional      Mexican Con Queso   Dairy
     Mexican Foods
    Yogurt           Yogurt/Adult        Dairy
                      Drinks
    Yogurt           Yogurt/Adult Multi- Dairy
                      Packs
    Yogurt           Yogurt/Kids         Dairy
    Yogurt           Yogurt/Large Size   Dairy
                      (16oz Or Lar)
    Yogurt           Yogurt/Pro Active   Dairy
                      Health
    Yogurt           Yogurt/Specialty    Dairy
                      Greek
    Yogurt           Yogurt/Ss Light     Dairy
    Yogurt           Yogurt/Ss Regular   Dairy
    Apples           Apples Braeburn     Fruit
                      (Bulk & Bag)
    Apples           Apples Braeburn     Fruit
                      (Bulk & Bag) Org
    Apples           Apples Fuji (Bulk   Fruit
                      & Bag)
    Apples           Apples Fuji (Bulk   Fruit
                      & Bag) Organic
    Apples           Apples Gala (Bulk   Fruit
                      & Bag)
    Apples           Apples Gala (Bulk   Fruit
                      & Bag) Organic
    Apples           Apples Gold         Fruit
                      Delicious (Bulk &
                      Bag)
    Apples           Apples Gold         Fruit
                      Delicious (Bulk &
                      Bag)
    Apples           Apples Granny       Fruit
                      Smith (Bulk &
                      Bag)
    Apples           Apples Granny       Fruit
                      Smith (Bulk &
                      Bag)
    Apples           Apples Honeycrisp   Fruit
    Apples           Apples Honeycrisp   Fruit
                      Organic
    Apples           Apples Other (Bulk  Fruit
                      & Bag)
    Apples           Apples Other (Bulk  Fruit
                      & Bag) Organic
    Apples           Apples Red          Fruit
                      Delicious (Bulk &
                      Bag)
    Apples           Apples Red          Fruit
                      Delicious (Bulk &
                      Bag)
    Apples           Caramel/Candy       Fruit
                      Apples
    Apples           Mixed Fruit Bags    Fruit
    Authentic        Hispanic Juices     Fruit
     Hispanic Foods   Over 50% Juice
     & Products
    Baking Needs     Maraschino          Fruit
                      Cherries
    Bananas          Bananas             Fruit
    Bananas          Bananas Organic     Fruit
    Bananas          Bananas: Variety    Fruit
    Berries          Berries Other       Fruit
    Berries          Berries Other       Fruit
                      Organic
    Berries          Blackberries        Fruit
    Berries          Blackberries        Fruit
                      Organic
    Berries          Blueberries         Fruit
    Berries          Blueberries         Fruit
                      Organic
    Berries          Cranberries         Fruit
    Berries          Cranberries         Fruit
                      Organic
    Berries          Raspberries         Fruit
    Berries          Raspberries         Fruit
                      Organic
    Berries          Strawberries        Fruit
    Berries          Strawberries        Fruit
                      Organic
    Beverages        Can/Btl Beverage    Fruit
                      Over 50% Juice
    Bulk Food        Fruit Bulk          Fruit
    Bulk Food        Fruit W/Sweetener   Fruit
    Can Fruit/Jar    Apple Sauce         Fruit
     Applesauce       (Excludes Cup)
    Can Fruit/Jar    Apples/Crabapples   Fruit
     Applesauce
    Can Fruit/Jar    Berries/Cnd (Blu/   Fruit
     Applesauce       Blk/Rasp)
    Can Fruit/Jar    Cherries (Except    Fruit
     Applesauce       Maraschino)
    Can Fruit/Jar    Cranberry Sauce     Fruit
     Applesauce
    Can Fruit/Jar    Fruit Cocktail/     Fruit
     Applesauce       Fruit Salad
    Can Fruit/Jar    Mandarin Oranges/   Fruit
     Applesauce       Citrus Sect
    Can Fruit/Jar    Misc. Cnd Fruit     Fruit
     Applesauce       (Grapes/Figs)
    Can Fruit/Jar    Peaches             Fruit
     Applesauce
    Can Fruit/Jar    Pears               Fruit
     Applesauce
    Can Fruit/Jar    Pineapple           Fruit
     Applesauce
    Citrus           Citrus--Other       Fruit
    Citrus           Citrus Other        Fruit
                      Organic
    Citrus           Clementines         Fruit
    Citrus           Clementines         Fruit
                      Organic
    Citrus           Grapefruit          Fruit
    Citrus           Grapefruit Organic  Fruit
    Citrus           Lemons              Fruit
    Citrus           Lemons Organic      Fruit
    Citrus           Limes               Fruit
    Citrus           Limes Organic       Fruit
    Citrus           Oranges Navels All  Fruit
    Citrus           Oranges Navels All  Fruit
                      Organic
    Citrus           Oranges Non Navel   Fruit
                      All
    Citrus           Oranges Non Navel   Fruit
                      All Organic
    Citrus           Tangerines &        Fruit
                      Tangelos
    Citrus           Tangerines &        Fruit
                      Tangelos Organic
    Coffee Shop      Sv Bev: Bev/Juice   Fruit
                      50-100% Jce
    Coffee Shop      Sv Bev: Bev/Juice   Fruit
                      50-100% Jce
    Convenience/     Convenience/        Fruit
     Snacking         Snacking Fruit
                      Pro
    Convenience/     Jarred Fruit Multi  Fruit
     Snacking         Serve
    Convenience/     Jarred Fruit        Fruit
     Snacking         Single Serve
    Convenience/     Squeeze Fruits      Fruit
     Snacking
    Dried Fruit      Dates Fruit
    Dried Fruit      Dried Fruit--Other  Fruit
    Dried Fruit      Dried Fruit         Fruit
                      Cranberries
    Dried Fruit      Dried Fruit Other   Fruit
                      Organic
    Dried Fruit      Dried Fruit W/      Fruit
                      Sweetener
    Dried Fruit      Dried Plums         Fruit
    Dried Fruit      Glace Fruit         Fruit
    Dried Fruit      Raisins             Fruit
    Frozen           Juice Over 50%      Fruit
     Breakfast        Juice
    Frozen Fruits    Frozen Fruit        Fruit
    Frozen Juice     Frzn Conc Allieds   Fruit
     And Smoothies    Over 50% Juice
    Frozen Juice     Frozen Oj & Oj      Fruit
     And Smoothies    Substitutes
    Fruit Snacks     Fruit Snacks        Fruit
    Gift & Fruit     Fruit Baskets       Fruit
     Baskets
    Gift & Fruit     In Store Made       Fruit
     Baskets          Fruit Baskets
    Gift & Fruit     Ready To Sell       Fruit
     Baskets          Fruit Baskets
    Grapes           Grapes Black/Blue   Fruit
    Grapes           Grapes Black/Blue   Fruit
                      Organic
    Grapes           Grapes Other        Fruit
    Grapes           Grapes Other        Fruit
                      Organic
    Grapes           Grapes Red          Fruit
    Grapes           Grapes Red Globe    Fruit
    Grapes           Grapes Red Globe    Fruit
                      Organic
    Grapes           Grapes Red Organic  Fruit
    Grapes           Grapes White        Fruit
    Grapes           Grapes White        Fruit
                      Organic
    Grapes           Grapes Wine         Fruit
    Juice            Drinks--Carb Juice  Fruit
                      (Over 50% Juice)
    Juice            Non-Carb Jce(Over   Fruit
                      50% Juice)
    Juices Super     Cider               Fruit
     Premium
    Juices Super     Juice Single Blend  Fruit
     Premium
    Juices Super     Juices Organic      Fruit
     Premium          (Over 50% Juice)
    Melons           Cantaloupe Whole    Fruit
    Melons           Cantaloupe Whole    Fruit
                      Organic
    Melons           Honeydew Whole      Fruit
    Melons           Honeydew Whole      Fruit
                      Organic
    Melons           Melons Whole Other  Fruit
    Melons           Melons Whole Other  Fruit
                      Organic
    Melons           Watermelon          Fruit
                      Personal
    Melons           Watermelon          Fruit
                      Personal Organic
    Melons           Watermelon          Fruit
                      Seedless Whole
    Melons           Watermelon          Fruit
                      Seedless Whole
                      Organic
    Melons           Watermelon W/Seeds  Fruit
                      Whole
    Packaged         Dried Fruit         Fruit
     Natural Snacks
    Packaged         Dried Fruit W/      Fruit
     Natural Snacks   Sweetener
    Peanut Butter/   Apple Butter/Fruit  Fruit
     Jelly/Jams &     Butter
     Honey
    Pears            Pears Anjou         Fruit
    Pears            Pears Anjou         Fruit
                      Organic
    Pears            Pears Asian         Fruit
    Pears            Pears Asian         Fruit
                      Organic
    Pears            Pears Bartlett      Fruit
    Pears            Pears Bartlett      Fruit
                      Organic
    Pears            Pears Bosc          Fruit
    Pears            Pears Bosc Organic  Fruit
    Pears            Pears Other         Fruit
    Pears            Pears Other         Fruit
                      Organic
    Pears            Pears Red           Fruit
    Prepared/Pdgd    Apple Sauce/        Fruit
     Foods            Pudding
    Prepared/Pdgd    Canned Fruit        Fruit
     Foods
    Processed        Jarred Fruit        Fruit
    Processed        Juice               Fruit
    Processed        Squeeze Lemons/     Fruit
                      Limes
    Refrgratd        Dairy Case 100%     Fruit
     Juices/Drinks    Pure Juice--
                      Orange
    Refrgratd        Dairy Case 100%     Fruit
     Juices/Drinks    Pure Juice Other
    Refrigerated     Nut Refrig Juice    Fruit
     Dairy Case       Over 50%
    Rtd Tea/New Age  Juice (100% Juice)  Fruit
     Juice
    Rtd Tea/New Age  Juice (Over 50%     Fruit
     Juice            Juice)
    Salad Bar        Salad Bar Fresh     Fruit
                      Fruit
    Seasonal Fruit   Baskets             Fruit
    Service          Sv Bev: Bev/Juice   Fruit
     Beverage         50-100% Juice
    Shelf Stable     Apple Juice &       Fruit
     Juice            Cider (Over 50%
                      Juice)
    Shelf Stable     Blended Juice &     Fruit
     Juice            Combinations
    Shelf Stable     Cranapple/Cran      Fruit
     Juice            Grape Juice
    Shelf Stable     Cranapple/Cran      Fruit
     Juice            Grape Juice
    Shelf Stable     Cranberry Juice     Fruit
     Juice            (Over 50% Juice)
    Shelf Stable     Grape Juice (Over   Fruit
     Juice            50% Juice)
    Shelf Stable     Grapefruit Juice    Fruit
     Juice            (Over 50% Juice)
    Shelf Stable     Lemon Juice & Lime  Fruit
     Juice            Juice (Over 50%
                      Juice)
    Shelf Stable     Nectars (Over 50%   Fruit
     Juice            Juice)
    Shelf Stable     Orange Juice (Over  Fruit
     Juice            50% Juice)
    Shelf Stable     Other Citrus        Fruit
     Juice            Juices (50% And
                      Under Juice)
    Shelf Stable     Other Citrus        Fruit
     Juice            Juices (Over 50%
                      Juice)
    Shelf Stable     Pineapple Juice     Fruit
     Juice            (Over 50% Juice)
    Shelf Stable     Prune Juice (Over   Fruit
     Juice            50% Juice)
    Single Serve     Applesauce Cup      Fruit
     Fruit/
     Applesauce
    Single Serve     Applesauce Pouch    Fruit
     Fruit/
     Applesauce
    Single Serve     Fruit Cup           Fruit
     Fruit/
     Applesauce
    Stone Fruit      Apricots            Fruit
    Stone Fruit      Cherries Ranier     Fruit
    Stone Fruit      Cherries Red        Fruit
    Stone Fruit      Cherries Red        Fruit
                      Organic
    Stone Fruit      Nectarines White    Fruit
                      Flesh
    Stone Fruit      Nectarines Yellow   Fruit
                      Flesh
    Stone Fruit      Nectarines Yellow   Fruit
                      Flesh Organic
    Stone Fruit      Peaches White       Fruit
                      Flesh
    Stone Fruit      Peaches White       Fruit
                      Flesh Organic
    Stone Fruit      Peaches Yellow      Fruit
                      Flesh
    Stone Fruit      Peaches Yellow      Fruit
                      Flesh Organic
    Stone Fruit      Plums               Fruit
    Stone Fruit      Plums Organic       Fruit
    Stone Fruit      Pluots              Fruit
    Stone Fruit      Stone Fruit Other   Fruit
                      Organic
    Tropical Fruit   Kiwi Fruit          Fruit
    Tropical Fruit   Kiwi Fruit Organic  Fruit
    Tropical Fruit   Mango               Fruit
    Tropical Fruit   Mango Organic       Fruit
    Tropical Fruit   Papaya              Fruit
    Tropical Fruit   Pineapple Whole &   Fruit
                      Peel/Cored
    Tropical Fruit   Pineapple Whole &   Fruit
                      Peel/Cored
                      Organic
    Tropical Fruit   Pomegranates        Fruit
    Tropical Fruit   Pomegranates        Fruit
                      Organic
    Tropical Fruit   Tropical Fruit--    Fruit
                      Other
    Tropical Fruit   Tropical Fruit      Fruit
                      Other Organic
    Unknown          Frozen Fruit        Fruit
    Value-Added      Cut Fruit All       Fruit
     Fruit            Other Prepack
    Value-Added      Fruit Party Tray    Fruit
     Fruit            Prepack
    Value-Added      Instore Cut Fruit   Fruit
     Fruit
    Value-Added      Melon Halves/       Fruit
     Fruit            Quarters Prepack
    Value-Added      Melons Instore Cut  Fruit
     Fruit
    Value-Added      Pineapple Wedge/    Fruit
     Fruit            Sliced/Chunks
    Value-Added      Value-Added Fruit   Fruit
     Fruit            Organic
    Authentic        Hispanic Tostados   Grains
     Hispanic Fds &   & Tortillas
     Product
    Bag Snacks       Bagged Popped       Grains
                      Popcorn
    Bag Snacks       Bagged Popped       Grains
                      Popcorn W/
                      Sweetener
    Bag Snacks       Corn Chips          Grains
    Bag Snacks       Pretzel W/Sweetner  Grains
    Bag Snacks       Pretzels            Grains
    Bag Snacks       Tortilla/Nacho      Grains
                      Chips
    Bagels & Cream   Refrigerated        Grains
     Cheese           Bagels
    Baked Breads     Bagels              Grains
    Baked Breads     Diet/Light Bread    Grains
    Baked Breads     Dinner Rolls        Grains
    Baked Breads     English Muffins/    Grains
                      Waffles
    Baked Breads     Fruit/Breakfast     Grains
                      Bread
    Baked Breads     Hamburger Buns      Grains
    Baked Breads     Hot Dog Buns        Grains
    Baked Breads     Main Meal Bread     Grains
    Baked Breads     Mainstream Variety  Grains
                      Breads
    Baked Breads     Mainstream White    Grains
                      Bread
    Baked Breads     Pita/Tortillas      Grains
    Baked Breads     Premium Bread       Grains
    Baked Breads     Rye Breads          Grains
    Baked Breads     Sandwich Buns       Grains
    Bakery Party     Trays Party Trays:  Grains
                      Rolls
    Baking Mixes     Biscuit Flour &     Grains
                      Mixes
    Baking Mixes     Muffin & Corn       Grains
                      Bread Mix
    Baking Needs     Corn Starch         Grains
    Bread            All Other Bread     Grains
    Bread            Bread--Ingredients  Grains
    Bread            Bread Snacks        Grains
    Bread            Bread: Diet/        Grains
                      Organic
    Bread            Bread: Kosher       Grains
    Bread            Bread: Artisan      Grains
    Bread            Bread: Italian/     Grains
                      French
    Bread            Bread: Pita/Pocket/ Grains
                      Flatbrd
    Bread            Bread: Retail       Grains
                      Seasonings
    Bread            Bread: Rye/         Grains
                      Cocktail
    Bread            Bread: Sourdough    Grains
    Bread            Bread: Specialty    Grains
    Bread            Bread: Sweet/       Grains
                      Breakfast
    Bread            Bread: Brand        Grains
    Bread            Bread: Tortillas/   Grains
                      Wraps
    Bread            Bread: Wheat/Whl    Grains
                      Grain
    Bread            Bread: White Loaf   Grains
    Bread            Gluten Free         Grains
    Bread            Whole Grain Bread   Grains
    Bulk Food        Cereal Bulk         Grains
    Cereal Bars      Breakfast Bars/     Grains
                      Tarts/Scones
    Cereals          Cereal--Cold        Grains
    Cereals          Cereal--Hot         Grains
    Cereals          Grains              Grains
    Cereals          Granola             Grains
    Cnv Breakfast &  Cereal Bars         Grains
     Wholesome Snks
    Cnv Breakfast &  Granola Bars        Grains
     Wholesome Snks
    Cnv Breakfast &  Toaster Pastries    Grains
     Wholesome Snks
    Coffee Shop      Coffee Shop:        Grains
     Sweet Goods &    Bagged Snacks
     Rtl
    Cold Cereal      Adult Cereal        Grains
    Cold Cereal      All Family Cereal   Grains
    Cold Cereal      Kids Cereal         Grains
    Cold Cereal      Misc. Cereal        Grains
    Cookie/Cracker   Multi-Pack          Grains
     Multi-Pks        Crackers
    Cookies          Graham Crackers     Grains
    Crackers         Crackers            Grains
    Crackers & Misc  Butter Spray        Grains
     Baked Food       Cracker
    Crackers & Misc  Cheese Crackers     Grains
     Baked Food
    Crackers & Misc  Saltine/Oyster      Grains
     Baked Food
    Crackers & Misc  Snack Crackers      Grains
     Baked Food
    Crackers & Misc  Specialty Crackers  Grains
     Baked Food
    Croutons/Bread   Bread Sticks        Grains
     Stick & Salad
     Toppings
    Croutons/Bread   Croutons            Grains
     Stick & Salad
     Toppings
    Croutons/Bread   Salad Toppers       Grains
     Stick & Salad
     Toppings
    Deli             Dl Spec: Dry/       Grains
     Specialties      Refrig Pastas
     (Retail Pk)
    Dietary Aid      Diabetic Dry        Grains
     Prdct/Med Liq    Cereal
     Nutr
    Dinner Mixes--   Pizza Mix Dry       Grains
     Dry
    Dry Bean Veg &   Misc Grain Mixes    Grains
     Rice
    Dry Bean Veg &   Noodle Side Dish    Grains
     Rice             Mixes
    Dry Bean Veg &   Rice--Dry Bag And   Grains
     Rice             Box
    Dry Bean Veg &   Rice--Instant &     Grains
     Rice             Microwave
    Dry Bean Veg &   Rice Side Dish      Grains
     Rice             Mixes Dry
    Dry Noodles &    Long Cut Pasta      Grains
     Pasta
    Dry Noodles &    Noodles Dry         Grains
     Pasta
    Dry Noodles &    Short Cut Pasta     Grains
     Pasta
    Dry Noodles &    Specialty Pasta     Grains
     Pasta
    Dry Sauce/Gravy/ Stuffing Mixes      Grains
     Potatoes/
     Stuffing
    Dry/Ramen        Ramen Noodles/      Grains
     Bouillon         Ramen Cups
    Eggs/Muffins/    Refrigerated        Grains
     Potatoes         English Muffins
    Flour & Meals    Breadings/Coatings/ Grains
                      Crumbs
    Flour & Meals    Cornmeal            Grains
    Flour & Meals    Flour: Misc/        Grains
                      Specialty/Blend
                      Et
    Flour & Meals    Flour: White &      Grains
                      Self Rising
    Frozen Bread     Allergen Free       Grains
     And Desserts     [Frozen Bread]
    Frozen Bread     Breads              Grains
     And Desserts
    Frozen Bread     Muffins/Bagels      Grains
     And Desserts
    Frozen Bread     Rolls               Grains
     And Desserts
    Frozen Bread     Sprouted Breads     Grains
     And Desserts
    Frozen Bread/    Frzn Biscuits       Grains
     Dough
    Frozen Bread/    Frzn Bread Dough    Grains
     Dough
    Frozen Bread/    Frzn Breadsticks    Grains
     Dough
    Frozen Bread/    Frzn Dinner Rolls   Grains
     Dough
    Frozen Bread/    Frzn Garlic Bread   Grains
     Dough
    Frozen Bread/    Frzn Garlic Toast   Grains
     Dough
    Frozen Bread/    Frzn Sweet Rolls &  Grains
     Dough            Muffins
    Frozen           Pancakes/French     Grains
     Breakfast        Toast
    Frozen           Waffles             Grains
     Breakfast
    Frozen           Frzn Bagels         Grains
     Breakfast
     Foods
    Frozen           Frzn Breakfast      Grains
     Breakfast        Pastry
     Foods
    Frozen           Waffles/Pancakes/   Grains
     Breakfast        French Toast
     Foods
    Frzn Pasta       Frozen Pasta        Grains
    Hot Cereal       Grits               Grains
    Hot Cereal       Instant Breakfast   Grains
    Hot Cereal       Instant Oatmeal     Grains
    Hot Cereal       Other Hot Cereal    Grains
    Hot Cereal       Standard Oatmeal    Grains
    Kosher Foods     Kosher Matzas       Grains
     And Products
    Kosher Foods     Kosher Noodles And  Grains
     And Products     Rice
    Meat--Shelf      Tamales             Grains
     Stable
    Molasses/Syrups/ Pancake Mixes       Grains
     Pancake Mixes
    Multicultural    Rice Bulk/Bag       Grains
     Products
    Non-Dairy/Dairy  Rice Beverage       Grains
     Aseptic
    Pies             Pies: Sugar Free    Grains
    Popcorn          Caramel Coated      Grains
                      Snacks
    Popcorn          Popcorn--Microwave  Grains
    Popcorn          Popcorn--Other      Grains
    Prepared/Pdgd    Grains              Grains
     Foods
    Prepared/Pdgd    Pasta/Ramen         Grains
     Foods
    Refrgrated       Misc Refrig Dough   Grains
     Dough Products   Products
    Refrgrated       Refrigerated        Grains
     Dough Products   Biscuits
    Refrgrated       Refrigerated        Grains
     Dough Products   Breads
    Refrgrated       Refrigerated        Grains
     Dough Products   Crescent Rolls
    Refrgrated       Refrigerated        Grains
     Dough Products   Specialty Rolls
    Refrigerated     Refrigerated        Grains
     Hispanic         Tortillas
     Grocery
    Refrigerated     Refrigerated Pasta  Grains
     Italian
    Rice Cakes       Large--Rice Cakes   Grains
    Rice Cakes       Large Cakes         Grains
    Rice Cakes       Mini--Rice Cakes    Grains
    Rice Cakes       Mini-Cakes          Grains
    Rice Cakes       Other--Rice Cakes   Grains
    Rolls            Rolls: Bagels       Grains
    Rolls            Rolls: Bagels--     Grains
                      Less Than 6
    Rolls            Rolls: Biscuits/    Grains
                      Eng Muffins
    Rolls            Rolls: Croissants/  Grains
                      Breadsticks
    Rolls            Rolls: Diet/        Grains
                      Organic
    Rolls            Rolls: Dinner       Grains
    Rolls            Rolls: Kosher       Grains
    Rolls            Rolls: Sandwich     Grains
    Salad & Dips     Salads--Bulk        Grains
     Pasta/Grain
    Salad & Dips     Salads--Prepack     Grains
     Pasta/Grain
    Salad Toppings   Croutons Organic    Grains
    Seafood--Salad/  Breading            Grains
     Dip/Sce/Cond
    Snack            Popcorn             Grains
    Snack            Popcorn W/          Grains
                      Sweetener
    Snack            Tortilla Chips      Grains
    Snacks           Snacks: Crackers/   Grains
                      Cookies
    Snacks           Snacks: Bagel       Grains
                      Chips
    Snacks           Snacks: Pita Chips  Grains
    Snacks           Snacks: Tortilla    Grains
                      Chips
    Specialty        Gourmet Crackers    Grains
     Cheese Pre
     Pack
    Ss/Vending--     Vending Size/Sngl   Grains
     Cookie/Cracker   Serve Cracke
    Syrups Toppings  Cones [Frozen       Grains
     & Cones          Novelties]
    Traditional      Asian Noodles/Rice  Grains
     Asian Foods
    Traditional      Mexican Soft        Grains
     Mexican Foods    Tortillas And Wra
    Traditional      Mexican Taco/       Grains
     Mexican Foods    Tostado/Shells
    Unknown          Frozen Bread        Grains
    Unknown          Frozen Convenience/ Grains
                      Pockets
    Bacon            Bacon--Natural/     Protein Foods
                      Organic
    Bacon            Bacon--Other        Protein Foods
    Bacon            Bacon--Poultry      Protein Foods
    Bacon            Bacon--Pre-Cooked   Protein Foods
    Bacon            Bacon--Trad 16oz    Protein Foods
                      Or Less
    Bacon            Bacon--Trad Center  Protein Foods
                      Cut
    Bacon            Bacon--Trad         Protein Foods
                      Greater Than 16oz
    Baking Needs     Baking Nuts         Protein Foods
    Beef: Chuck/     Choice Beef         Protein Foods
     Shoulder
    Beef: Chuck/     Natural Beef        Protein Foods
     Shoulder
    Beef: Chuck/     Organic Beef        Protein Foods
     Shoulder
    Beef: Grinds     Angus [Beef]        Protein Foods
    Beef: Grinds     Lean [Beef]         Protein Foods
    Beef: Grinds     Natural [Beef]      Protein Foods
    Beef: Grinds     Organic [Beef]      Protein Foods
    Beef: Grinds     Patties [Beef]      Protein Foods
    Beef: Grinds     Primal [Beef]       Protein Foods
    Beef: Grinds     Sausage [Beef]      Protein Foods
    Beef: Loins      Choice Beef         Protein Foods
    Beef: Loins      Select Beef         Protein Foods
    Beef: Offal      External [Beef      Protein Foods
                      Offal]
    Beef: Rib        Angus Beef          Protein Foods
    Beef: Rib        Prime Beef          Protein Foods
    Beef: Round      Angus Beef          Protein Foods
    Beef: Round      Choice Beef         Protein Foods
    Beef: Round      Natural Beef        Protein Foods
    Beef: Round      Organic Beef        Protein Foods
    Beef: Round      Prime Beef          Protein Foods
    Beef: Round      Select Beef         Protein Foods
    Beef: Thin       Brisket             Protein Foods
     Meats
    Beef: Thin       Corned Beef         Protein Foods
     Meats
    Beef: Thin       Cubed Meats [Beef]  Protein Foods
     Meats
    Beef: Thin       Flank [Beef]        Protein Foods
     Meats
    Beef: Thin       Lifter Meat [Beef]  Protein Foods
     Meats
    Beef: Thin       Skirt [Beef]        Protein Foods
     Meats
    Beef: Thin       Soup/Stew           Protein Foods
     Meats
    Breakfast        Bkfst Sausage--     Protein Foods
     Sausage          Bkfast Side Di
    Breakfast        Bkfst Sausage--     Protein Foods
     Sausage          Fresh Links
    Breakfast        Bkfst Sausage--     Protein Foods
     Sausage          Fresh Patties
    Breakfast        Bkfst Sausage--     Protein Foods
     Sausage          Fresh Rolls
    Breakfast        Bkfst Sausage--     Protein Foods
     Sausage          Other Forms
    Breakfast        Bkfst Sausage--     Protein Foods
     Sausage          Precooked
    Buffalo          Chuck/Shoulder      Protein Foods
                      [Buffalo]
    Buffalo          Grinds [Buffalo]    Protein Foods
    Buffalo          Loin [Buffalo]      Protein Foods
    Buffalo          Natural [Buffalo]   Protein Foods
    Buffalo          Rib [Buffalo]       Protein Foods
    Buffalo          Round/Leg           Protein Foods
                      [Buffalo]
    Buffalo          Thin Meats          Protein Foods
                      [Buffalo]
    Bulk Food        Nuts Bulk W/        Protein Foods
                      Sweetener
    Bulk Food        Trail Mix/Nuts      Protein Foods
                      Bulk
    Can Beans        Prepared Beans--    Protein Foods
                      Baked W/Pork
    Can Beans        Variety Beans--     Protein Foods
                      Kidney/Pinto/E
    Can Seafood--    Anchovies           Protein Foods
     Shelf Stable
    Can Seafood--    Caviar              Protein Foods
     Shelf Stable
    Can Seafood--    Clam Juice          Protein Foods
     Shelf Stable
    Can Seafood--    Clams               Protein Foods
     Shelf Stable
    Can Seafood--    Crabmeat            Protein Foods
     Shelf Stable
    Can Seafood--    Kipper Snack        Protein Foods
     Shelf Stable
    Can Seafood--    Mackerel            Protein Foods
     Shelf Stable
    Can Seafood--    Misc. Cnd Seafoods  Protein Foods
     Shelf Stable     (Crab/Etc.)
    Can Seafood--    Oysters             Protein Foods
     Shelf Stable
    Can Seafood--    Salmon              Protein Foods
     Shelf Stable
    Can Seafood--    Sardines            Protein Foods
     Shelf Stable
    Can Seafood--    Shrimp              Protein Foods
     Shelf Stable
    Can Seafood--    Tuna                Protein Foods
     Shelf Stable
    Chicken &        Chix/Poultry        Protein Foods
     Poultry          Ingredients
    Chicken &        Chix: Baked 8pc     Protein Foods
     Poultry          Cut Up (Cold)
    Chicken &        Chix: Chicken       Protein Foods
     Poultry          Dinners/Snacks C
    Chicken &        Chix: Chicken       Protein Foods
     Poultry          Dinners/Snacks H
    Chicken &        Chix: Kosher        Protein Foods
     Poultry          (Cold)
    Chicken &        Chix: Rotisserie    Protein Foods
     Poultry          Cold
    Chicken &        Chix: Frd 8pc/Cut   Protein Foods
     Poultry          Up (Cold)
    Chicken &        Chix: Value-Added   Protein Foods
     Poultry          (Cold)
    Chicken Fresh    Chicken Breast      Protein Foods
                      Boneless
    Chicken Fresh    Chicken Drums       Protein Foods
    Chicken Fresh    Chicken Legs/       Protein Foods
                      Quarters
    Chicken Fresh    Chicken Thighs      Protein Foods
    Chicken Fresh    Chicken Wings       Protein Foods
    Chicken Fresh    Mixed Packs         Protein Foods
    Chicken Fresh    Whole Chicken       Protein Foods
                      (Roasters/Fryer)
    Chicken Frozen   Chicken--Frz Iqf--  Protein Foods
                      Raw
    Chicken Frozen   Frzn Chicken--Drk   Protein Foods
                      Meat
    Chicken Frozen   Frzn Chicken--Wht   Protein Foods
                      Meat
    Chicken Frozen   Frzn Chicken--      Protein Foods
                      Wings
    Chicken Frozen   Whole/Cutup         Protein Foods
                      [Chicken]
    Chicken Frozen   Chicken Breast      Protein Foods
     (Rw)             Bone In
    Chicken Frozen   Chicken Breast      Protein Foods
     (Rw)             Boneless
    Chicken Frozen   Chicken Drums       Protein Foods
     (Rw)
    Chicken Frozen   Chicken Legs/       Protein Foods
     (Rw)             Quarters
    Chicken Frozen   Chicken Thighs      Protein Foods
     (Rw)
    Chicken Frozen   Chicken Wings       Protein Foods
     (Rw)
    Chicken Frozen   Whole Chicken       Protein Foods
     (Rw)             (Roasters/Fryer)
    Chicken Grinds   Ground Chicken      Protein Foods
    Chicken Offal    External [Chicken   Protein Foods
                      Offal]
    Chicken Offal    Internal [Chicken   Protein Foods
                      Offal]
    Chicken Organic  Chicken Breast      Protein Foods
                      Bone In
    Chicken Smoked   Chicken Breast      Protein Foods
                      Bone In
    Chicken          Chicken Breast      Protein Foods
     Specialty/       Bone In
     Natural
    Chicken          Chicken Breast      Protein Foods
     Specialty/       Boneless
     Natural
    Chicken          Chicken Drums       Protein Foods
     Specialty/
     Natural
    Chicken          Chicken Legs/       Protein Foods
     Specialty/       Quarters
     Natural
    Chicken          Chicken Thighs      Protein Foods
     Specialty/
     Natural
    Chicken          Chicken Wings       Protein Foods
     Specialty/
     Natural
    Chicken          Mixed Packs         Protein Foods
     Specialty/       [Chicken]
     Natural
    Chicken          Whole Chicken       Protein Foods
     Specialty/       (Roasters/Fryer)
     Natural
    Condiments       Nut Butters/Peanut  Protein Foods
                      Butter
    Deli Meat: Bulk  Bologna/Loaves/     Protein Foods
                      Franks
    Deli Meat: Bulk  Meat Bulk:          Protein Foods
                      Specialty Dry
                      Meats
    Deli Meat: Bulk  Meat: Bacon         Protein Foods
    Deli Meat: Bulk  Meat: Beef Bulk     Protein Foods
    Deli Meat: Bulk  Meat: Chicken Bulk  Protein Foods
    Deli Meat: Bulk  Meat: Gift Pack     Protein Foods
    Deli Meat: Bulk  Meat: Ham Ppk/      Protein Foods
                      Prslc
    Deli Meat: Bulk  Meat: Pates/Mousse  Protein Foods
    Deli Meat: Bulk  Meat: Saus Dry Ppk/ Protein Foods
                      Prslc
    Deli Meat: Bulk  Meat: Turkey Bulk   Protein Foods
    Deli Meat: Bulk  Meat:Ham Bulk       Protein Foods
    Deli Meat: Bulk  Meat: Lnchmt Ppk/   Protein Foods
                      Prslc
    Deli Meat:       Deli Meat: Bacon    Protein Foods
     Other
    Deli Meat:       Deli Meat: Kosher   Protein Foods
     Other
    Deli Meat:       Deli Meat: Pates/   Protein Foods
     Other            Mousse
    Deli Meat:       Deli Meat:          Protein Foods
     Other            Shippers/Gift
                      Packs
    Deli Meat:       Deli Meat: Beef     Protein Foods
     Presliced
    Deli Meat:       Deli Meat: Bologna/ Protein Foods
     Presliced        Loaves/Fran
    Deli Meat:       Deli Meat: Chicken  Protein Foods
     Presliced
    Deli Meat:       Deli Meat: Ham      Protein Foods
     Presliced
    Deli Meat:       Deli Meat: Semi-    Protein Foods
     Presliced        Dry Sausage
    Deli Meat:       Deli Meat:          Protein Foods
     Presliced        Specialty Dry
                      Meats
    Deli Meat:       Deli Meat: Turkey   Protein Foods
     Presliced
    Dinner Sausage   Dnr Sausage--Beef   Protein Foods
                      Rope Ckd/Sm
    Dinner Sausage   Dnr Sausage--       Protein Foods
                      Cocktails
    Dinner Sausage   Dnr Sausage--Fresh  Protein Foods
                      Poultry
    Dinner Sausage   Dnr Sausage--Links  Protein Foods
                      Beef Ckd
    Dinner Sausage   Dnr Sausage--Links  Protein Foods
                      Fresh
    Dinner Sausage   Dnr Sausage--Links  Protein Foods
                      Pork Ckd
    Dinner Sausage   Dnr Sausage--Links  Protein Foods
                      Poultry Ck
    Dinner Sausage   Dnr Sausage--       Protein Foods
                      Natural/Organic
    Dinner Sausage   Dnr Sausage--Other  Protein Foods
                      Forms
    Dinner Sausage   Dnr Sausage--Pork   Protein Foods
                      Rope Ckd/Sm
    Dinner Sausage   Dnr Sausage--       Protein Foods
                      Poultry Rope Ckd
    Dinner Sausage   Dnr Saus-Rope/Link- Protein Foods
                      Smkd/Preckd
    Eggs/Muffins/    Eggs--Jumbo         Protein Foods
     Potatoes
    Eggs/Muffins/    Eggs--Large         Protein Foods
     Potatoes
    Eggs/Muffins/    Eggs--Medium        Protein Foods
     Potatoes
    Eggs/Muffins/    Eggs--Small         Protein Foods
     Potatoes
    Eggs/Muffins/    Eggs--X-Large       Protein Foods
     Potatoes
    Eggs/Muffins/    Eggs Substitute     Protein Foods
     Potatoes
    Eggs/Muffins/    Specialty Eggs      Protein Foods
     Potatoes
    Exotic           Goat                Protein Food
    Exotic           Rabbit              Protein Foods
    Frozen           Frzn Breakfast      Protein Foods
     Breakfast        Sausage
     Foods
    Frozen           Frzn Egg            Protein Foods
     Breakfast        Substitutes
     Foods
    Frozen Entrees   Meat Protein        Protein Foods
    Frozen Meat      Frozen Meat         Protein Foods
    Frozen Meat      Alternatives Meat   Protein Foods
    Frozen Meat      Alternatives Soy/   Protein Foods
                      Tofu
    Frzn Multi       Frzn Burgers        Protein Foods
     Serve
    Frzn Multi       Fz Bbq              Protein Foods
     Serve
    Frzn Multi       Fz Meatballs        Protein Foods
     Serve
    Frzn Prepared    Bone-In Wings       Protein Foods
     Chicken
    Frzn Prepared    Boneless Snack/     Protein Foods
     Chicken          18oz And Larger
    Frzn Prepared    Boneless Snack/     Protein Foods
     Chicken          Value/Small
    Frzn Prepared    Value Forms/18oz    Protein Foods
     Chicken          And Larger
                      [Chicken]
    Frzn Prepared    Whole Muscle        Protein Foods
     Chicken          Breaded/18oz And
    Frzn Prepared    Whole Muscle        Protein Foods
     Chicken          Unbreaded
    Frzn Seafood     Frz Coated Fish     Protein Foods
                      Fillets
    Frzn Seafood     Frz Fishsticks/     Protein Foods
                      Tenders/Nuggets
    Frzn Seafood     Frz Non-Coated      Protein Foods
                      Fish Fillets
    Frzn Seafood     Frz Seafood         Protein Foods
                      Entrees
    Frzn Seafood     Frzn Misc Seafood   Protein Foods
    Hot Dogs         Hot Dogs--Base      Protein Foods
                      Beef
    Hot Dogs         Hot Dogs--Base      Protein Foods
                      Meat
    Hot Dogs         Hot Dogs--Base      Protein Foods
                      Poultry
    Hot Dogs         Hot Dogs--Premium   Protein Foods
    Hot Dogs         Hot Dogs-Rw-All     Protein Foods
    Kosher           Beef                Protein Foods
    Kosher           Chicken             Protein Foods
    Kosher           Lamb                Protein Foods
    Kosher           Turkey              Protein Foods
    Kosher           Veal                Protein Foods
    Kosher Foods     Kosher Seafood      Protein Foods
     And Products
    Lamb             Chuck/Shoulder      Protein Foods
                      [Lamb]
    Lamb             Grinds [Lamb]       Protein Foods
    Lamb             Loin [Lamb]         Protein Foods
    Lamb             Offals [Lamb]       Protein Foods
    Lamb             Rib [Lamb]          Protein Foods
    Lamb             Round/Leg [Lamb]    Protein Foods
    Lamb             Thin Meats [Lamb]   Protein Foods
    Lunchmeat        Lunchmeat--Brauns/  Protein Foods
                      Liver/Loave
    Lunchmeat        Lunchmeat--Chip     Protein Foods
                      Meat
    Lunchmeat        Lunchmeat--Chop/    Protein Foods
                      Form Pltry & Ha
    Lunchmeat        Lunchmeat--Other    Protein Foods
    Lunchmeat        Lunchmeat--Peggabl  Protein Foods
                      e Deli Fres
    Lunchmeat        Lunchmeat--Variety  Protein Foods
                      Pack
    Lunchmeat        Lunchmeat--Whole    Protein Foods
                      Muscle Pltry
    Lunchmeat        Lunchmeat--Rw-All   Protein Foods
    Lunchmeat        Lunchmeat--Bologna/ Protein Foods
                      Sausage
    Lunchmeat        Lunchmeat--Deli     Protein Foods
                      Fresh
    Lunchmeat        Lunchmeat--Natural/ Protein Foods
                      Organic
    Meat--Shelf      Beef Stew           Protein Foods
     Stable
    Meat--Shelf      Beef/Pork--Dried    Protein Foods
     Stable           Sliced W/Gra
    Meat--Shelf      Chicken &           Protein Foods
     Stable           Dumplings
    Meat--Shelf      Chili: Canned       Protein Foods
     Stable
    Meat--Shelf      Chunk Meats--Chix/  Protein Foods
     Stable           Ham/Etc.
    Meat--Shelf      Corn Beef           Protein Foods
     Stable
    Meat--Shelf      Hash: Canned        Protein Foods
     Stable
    Meat--Shelf      Hot Dog Chili       Protein Foods
     Stable           Sauce
    Meat--Shelf      Luncheon Meat       Protein Foods
     Stable           (Spam)
    Meat--Shelf      Misc Cnd Meats      Protein Foods
     Stable
    Meat--Shelf      Potted Meats And    Protein Foods
     Stable           Spreads
    Meat--Shelf      Sandwich Sauce      Protein Foods
     Stable           (Manwich)
    Meat--Shelf      Vienna Sausage      Protein Foods
     Stable
    Meat Frozen      Frzn Meat--Beef     Protein Foods
    Meat Frozen      Frzn Meat--         Protein Foods
                      Breakfast Sausage
    Meat Frozen      Frzn Meat--Exotic   Protein Foods
    Meat Frozen      Frzn Meat--Natural/ Protein Foods
                      Organic
    Meat Frozen      Frzn Meat--Offals   Protein Foods
    Meat Frozen      Frzn Meat--Pork     Protein Foods
    Meat Frozen      Frzn Meat--Turkey   Protein Foods
    Meat Frozen      Meat--Misc-Misc     Protein Foods
    Meat Snacks      Jerky/Nuggets/      Protein Foods
                      Tenders
    Meat Snacks      Meat Sticks/Bites   Protein Foods
    Nat Foods--      Ntrn Refrig Meat:   Protein Foods
     Refrigerated     Breakfast Me
     Meat
    Nat Foods--      Ntrn Refrig Meat:   Protein Foods
     Refrigerated     Hot Dogs/Sau
     Meat
    Nat Foods--      Ntrn Refrig Meat:   Protein Foods
     Refrigerated     Lunchmeat
     Meat
    Non-Dairy/Dairy  Nut Milk            Protein Foods
     Aseptic
    Nuts             Almonds             Protein Foods
    Nuts             Almonds Shelled     Protein Foods
    Nuts             Almonds W/          Protein Foods
                      Sweetener
    Nuts             Cashews             Protein Foods
    Nuts             Cashews W/          Protein Foods
                      Sweetener
    Nuts             Dry Roast Peanuts   Protein Foods
    Nuts             Dry Roast Peanuts   Protein Foods
                      W/Sweetener
    Nuts             Misc Snack Nuts     Protein Foods
    Nuts             Misc Snacks Nuts W/ Protein Foods
                      Sweetener
    Nuts             Mixed Nuts          Protein Foods
    Nuts             Mixed Nuts W/       Protein Foods
                      Sweetener
    Nuts             Nuts Inshell        Protein Foods
    Nuts             Nuts Other          Protein Foods
    Nuts             Nuts Other Organic  Protein Foods
    Nuts             Nuts Sugar Coated   Protein Foods
                      All
    Nuts             Oil Roast Peanuts   Protein Foods
    Nuts             Oil Roast Peanuts   Protein Foods
                      W/Sweetener
    Nuts             Peanuts All         Protein Foods
    Nuts             Pecans Shelled      Protein Foods
    Nuts             Pecans W/Sweetener  Protein Foods
    Nuts             Pistachios          Protein Foods
    Nuts             Sunflower/Other     Protein Foods
                      Seeds
    Nuts             Sunflower/Other     Protein Foods
                      Seeds W/Sweete
    Nuts             Trail Mix           Protein Foods
    Nuts             Walnuts Shelled     Protein Foods
    Packaged         Nuts                Protein Foods
     Natural Snacks
    Packaged         Nuts W/Sweetener    Protein Foods
     Natural Snacks
    Peanut Butter/   Peanut Butter       Protein Foods
     Jelly/Jams &
     Honey
    Pkgd Meat Corp   Only Pkgd Meat      Protein Foods
     Use              Corp Use Only
    Pork Bone In     Dry [Pork Bone In   Protein Foods
     Loin/Rib         Loin/Rib]
    Pork Boneless    Enhanced [Pork      Protein Foods
     Loin/Rib         Boneless Loin/
                      Rib]
    Pork Boneless    Natural [Pork       Protein Foods
     Loin/Rib         Boneless Loin/
                      Rib]
    Pork Grinds      Ground Pork         Protein Foods
    Pork Offal       External Fresh      Protein Foods
                      [Pork Offal]
    Pork Offal       Internal Fresh      Protein Foods
                      [Pork Offal]
    Pork Shoulder    Butts [Pork         Protein Foods
                      Shoulder]
    Pork Shoulder    Fresh Hams          Protein Foods
    Pork Thin Meats  Kabobs [Pork]       Protein Foods
    Pork Thin Meats  Organics [Pork]     Protein Foods
    Pork Thin Meats  Ribs [Pork]         Protein Foods
    Pork Thin Meats  Stir Fry/Strips/    Protein Foods
                      Fajitas [Pork]
    Poultry Other    Capons              Protein Foods
    Poultry Other    Cornish Hen         Protein Foods
    Poultry Other    Ducks               Protein Foods
    Poultry Other    Geese               Protein Foods
    Poultry Other    Poultry/Other       Protein Foods
    Prepared/Pdgd    Meat--Can/Pouch     Protein Foods
     Foods
    Processed        Beans Dried         Protein Foods
    Random Weight    Lunch Meats         Protein Foods
     Meat Products
    Refrigerated     Eggs                Protein Foods
     Dairy Case
    Refrigerated     Non-Dairy Cheese    Protein Foods
     Vegetarian
    Refrigerated     Tofu                Protein Foods
     Vegetarian
    Refrigerated     Vegetarian Meats    Protein Foods
     Vegetarian
    Restricted Diet  Pnut Btr/Jelly      Protein Foods
    Salad & Dips     Protein Salads--    Protein Foods
                      Bulk
    Salad & Dips     Protein Salads--    Protein Foods
                      Prepack
    Seafood--Catfis  Catfish--Fillet     Protein Foods
     h
    Seafood--Catfis  Catfish--Nuggets    Protein Foods
     h
    Seafood--Catfis  Catfish--Other      Protein Foods
     h                Form
    Seafood--Catfis  Catfish--Whole      Protein Foods
     h
    Seafood--Cod     Cod--Fillet         Protein Foods
    Seafood--Cod     Cod--Other Form     Protein Foods
    Seafood--Cod     Cod--Whole          Protein Foods
    Seafood--Crab    Crab--Dungy         Protein Foods
    Seafood--Crab    Crab--King          Protein Foods
    Seafood--Crab    Crab--Other         Protein Foods
    Seafood--Crab    Crab--Snow          Protein Foods
    Seafood--Exotic  Exotic--Mahi Mahi   Protein Foods
    Seafood--Exotic  Exotic--Other       Protein Foods
    Seafood--Exotic  Exotic--Red         Protein Foods
                      Snapper
    Seafood--Exotic  Exotic--Shark       Protein Foods
    Seafood--Exotic  Exotic--Swordfish   Protein Foods
    Seafood--Exotic  Exotic--Tuna        Protein Foods
    Seafood--Finfis  Finfish--Halibut    Protein Foods
     h Other
    Seafood--Finfis  Finfish--Other      Protein Foods
     h Other
    Seafood--Finfis  Finfish--Other      Protein Foods
     h Other
    Seafood--Finfis  Finfish--Rockfish   Protein Foods
     h Other
    Seafood--Finfis  Finfish--Sole/      Protein Foods
     h Other          Flounder
    Seafood--Finfis  Finfish--Sole/      Protein Foods
     h Other          Flounder
    Seafood--Imitat  Imitation Crab      Protein Foods
     ion Seafood
    Seafood--Imitat  Imitation Other     Protein Foods
     ion Seafood
    Seafood--Imitat  Imitation Shrimp    Protein Foods
     ion Seafood
    Seafood--Lobste  Lobster--Live       Protein Foods
     r
    Seafood--Lobste  Lobster--Meat       Protein Foods
     r
    Seafood--Lobste  Lobster--Other      Protein Foods
     r                Form
    Seafood--Lobste  Lobster--Tails      Protein Foods
     r
    Seafood--Oyster  Oyster--Bulk        Protein Foods
    Seafood--Oyster  Oyster--Cup         Protein Foods
                      (Packaged)
    Seafood--Oyster  Oyster--Cup         Protein Foods
                      (Packaged)
    Seafood--Party   Party Tray--Shrimp  Protein Foods
     Trays
    Seafood--Salmon- Salmon Fr--         Protein Foods
     Farm Raised      Altantic
    Seafood--Salmon- Salmon Fr--Other    Protein Foods
     Farm Raised      Form
    Seafood--Salmon- Salmon Fr--         Protein Foods
     Farm Raised      Atlantic
    Seafood--Salmon- Salmon Fr--Coho     Protein Foods
     Farm Raised
    Seafood--Salmon- Salmon Fr--King     Protein Foods
     Farm Raised
    Seafood--Salmon- Seafood--Fre-       Protein Foods
     Farm Raised      Catfish
    Seafood--Salmon- Seafood--Fre-Misc   Protein Foods
     Farm Raised
    Seafood--Salmon- Seafood--Fre-Raw    Protein Foods
     Farm Raised      Finfish--Other
    Seafood--Salmon- Salmon Wc--Other    Protein Foods
     Wild Caught      Form
    Seafood--Salmon- Salmon Wc--Coho     Protein Foods
     Wild Caught
    Seafood--Salmon- Salmon Wc--King     Protein Foods
     Wild Caught
    Seafood--Salmon- Salmon Wc--Pink     Protein Foods
     Wild Caught
    Seafood--Salmon- Salmon Wc--         Protein Foods
     Wild Caught      Silverbrite
    Seafood--Salmon- Salmon Wc--         Protein Foods
     Wild Caught      Silverbrite
    Seafood--Salmon- Salmon Wc--Sockeye  Protein Foods
     Wild Caught
    Seafood--Scallo  Scallops--Bay       Protein Foods
     ps
    Seafood--Scallo  Scallops--Sea       Protein Foods
     ps
    Seafood--Shellf  Shellfish--Clams    Protein Foods
     ish Other
    Seafood--Shellf  Shellfish--Clams    Protein Foods
     ish Other
    Seafood--Shellf  Shellfish--Mussles  Protein Foods
     ish Other
    Seafood--Shellf  Shellfish--Other    Protein Foods
     ish Other
    Seafood--Shrimp  Shrimp--Cooked      Protein Foods
    Seafood--Shrimp  Shrimp--Natural/    Protein Foods
                      Organic
    Seafood--Shrimp  Shrimp--Raw         Protein Foods
    Seafood--Smoked  Smoked Other        Protein Foods
     Seafood
    Seafood--Smoked  Smoked Salmon       Protein Foods
     Seafood
    Seafood--Tilapi  Tilapia--Fillet     Protein Foods
     a
    Seafood--Tilapi  Tilapia--Other      Protein Foods
     a                Form
    Seafood--Tilapi  Tilapia--Whole      Protein Foods
     a
    Seafood--Trout   Steelhead Fr        Protein Foods
    Seafood--Trout   Trout--Fillet       Protein Foods
    Seafood--Trout   Trout--Whole        Protein Foods
    Seafood--Value-  Value-Added         Protein Foods
     Added Seafood    Catfish
    Seafood--Value-  Value-Added In-     Protein Foods
     Added Seafood    Store Cooked Ho
    Seafood--Value-  Value-Added         Protein Foods
     Added Seafood    Breaded Shrimp
    Seafood--Value-  Value-Added Crab    Protein Foods
     Added Seafood
    Seafood--Value-  Value-Added         Protein Foods
     Added Seafood    Finfish
    Seafood--Value-  Value-Added In-     Protein Foods
     Added Seafood    Store Cooked Co
    Seafood--Value-  Value-Added Kabobs  Protein Foods
     Added Seafood
    Seafood--Value-  Value-Added Other   Protein Foods
     Added Seafood
    Seafood--Value-  Value-Added Salmon  Protein Foods
     Added Seafood
    Seafood--Value-  Value-Added Shrimp  Protein Foods
     Added Seafood
    Seafood--Value-  Value-Added         Protein Foods
     Added Seafood    Tilapia
    Seafood--Salad/  Herring             Protein Foods
     Dips/Sce/Cond
    Service Case     Cooked              Protein Foods
     Meat
    Service Case     Ingredients         Protein Foods
     Meat
    Service Case     Kabobs Beef         Protein Foods
     Meat
    Service Case     Kabobs Pork         Protein Foods
     Meat
    Service Case     Kabobs Poultry      Protein Foods
     Meat
    Service Case     Marinated Beef      Protein Foods
     Meat
    Service Case     Marinated Pork      Protein Foods
     Meat
    Service Case     Marinated Poultry   Protein Foods
     Meat
    Service Case     Seasoned            Protein Foods
     Meat
    Service Case     Seasoned Beef       Protein Foods
     Meat
    Service Case     Seasoned Pork       Protein Foods
     Meat
    Service Case     Seasoned Poultry    Protein Foods
     Meat
    Service Case     Stuffed/Mixed Beef  Protein Foods
     Meat
    Service Case     Stuffed/Mixed Pork  Protein Foods
     Meat
    Service Case     Stuffed/Mixed       Protein Foods
     Meat             Poultry
    Smoked Hams      Hams--Canned        Protein Foods
    Smoked Hams      Hams--Dry Cured/    Protein Foods
                      Country
    Smoked Hams      Hams--Half/Port     Protein Foods
                      Bone-In
    Smoked Hams      Hams--Half/Port     Protein Foods
                      Boneless
    Smoked Hams      Hams--Spiral        Protein Foods
    Smoked Hams      Hams--Whole Bone-   Protein Foods
                      In
    Smoked Hams      Hams--Whole         Protein Foods
                      Boneless
    Smoked Pork      Bacon--Belly/Jowl   Protein Foods
    Smoked Pork      Ham Steaks/Cubes/   Protein Foods
                      Slices
    Smoked Pork      Smoked Chops Bone-  Protein Foods
                      In [Pork]
    Smoked Pork      Smoked Chops        Protein Foods
                      Boneless [Pork]
    Smoked Pork      Smoked Offal        Protein Foods
                      [Pork]
    Smoked Pork      Smoked Picnics      Protein Foods
                      [Pork]
    Snack Meat       Grnd/Patty--Chuck   Protein Foods
    Snack Meat       Snack Meat--Other   Protein Foods
    Snack Meat       Snack Meat--        Protein Foods
                      Pepperoni
    Snack Meat       Snack Meat--Salami/ Protein Foods
                      Smr Sausag
    Snacks           Snacks: Deli Nuts   Protein Foods
    Ss/Vending--     Tube Nuts           Protein Foods
     Salty Snacks
    Ss/Vending--     Tube Nuts W/        Protein Foods
     Salty Snacks     Sweetener
    Turkey Fresh     Turkey Legs         Protein Foods
    Turkey Fresh     Whole Hen (Under    Protein Foods
                      16lbs) [Turkey]
    Turkey Fresh     Whole Tom (Over     Protein Foods
                      16lbs) [Turkey]
    Turkey Frozen    Turkey Breast Bone  Protein Foods
                      In
    Turkey Frozen    Turkey Breast       Protein Foods
                      Boneless
    Turkey Frozen    Turkey Halves/      Protein Foods
                      Quarters
    Turkey Frozen    Turkey Thighs       Protein Foods
    Turkey Frozen    Whole Hens (Under   Protein Foods
                      16lbs) [Turkey]
    Turkey Frozen    Whole Toms (Over    Protein Foods
                      16lbs) [Turkey]
    Turkey Grinds    Ground Turkey       Protein Foods
    Turkey Offal     External [Turkey    Protein Foods
                      Offal]
    Turkey Offal     Internal [Turkey    Protein Foods
                      Offal]
    Turkey Organic   Whole Hens (Under   Protein Foods
                      15lbs) [Turkey]
    Turkey Organic   Whole Toms (Over    Protein Foods
                      15lbs) [Turkey]
    Turkey Smoked    Turkey Drums        Protein Foods
    Turkey Smoked    Turkey Wings        Protein Foods
    Turkey           Whole Hens (Under   Protein Foods
     Specialty        15lbs) [Turkey]
     Natural
    Turkey           Whole Toms (Over    Protein Foods
     Specialty        15lbs) [Turkey]
     Natural
    Unknown          Beef--Boneless-     Protein Foods
                      Choice
    Unknown          Beef--Grinds        Protein Foods
    Unknown          Breast--Bone-In     Protein Foods
                      (Frz)
    Unknown          Frozen Burgers      Protein Foods
    Unknown          Frozen Meat         Protein Foods
    Unknown          Frozen Meat         Protein Foods
                      (Vegetarian)
    Unknown          Ham--Bone-In Whole  Protein Foods
    Unknown          Ham--Boneless Half/ Protein Foods
                      Port
    Unknown          Marinated           Protein Foods
    Unknown          Meal Sol--          Protein Foods
                      Precooked Meats
    Unknown          Meal Sol--Raw       Protein Foods
                      Frthr Preprd Mt
    Unknown          Meat Frz--Misc      Protein Foods
    Unknown          Seafood--Frz--Rw--  Protein Foods
                      All
    Unknown          Smkd Ham Country--  Protein Foods
                      All
    Unknown          Turkey--Grinds      Protein Foods
    Unknown          Turkey--Other       Protein Foods
                      Parts/Pieces--Fre
    Unknown          Whole--Tom (16 Lbs  Protein Foods
                      & Over Frz
    Veal             Whole/Half [Veal]   Protein Foods
    Nuts             Pecans              Protein Foods
    Authentic        Authentic Peppers   Vegetables
     Hispanic Fds &
     Product
    Authentic        Authentic Sauces/   Vegetables
     Hispanic Fds &   Salsa/Picante
     Product
    Authentic        Authentic           Vegetables
     Hispanic Fds &   Vegetables And
     Product          Foods
    Authentic        Italian Vegetables  Vegetables
     Italian Foods
    Broccoli/        Brocco--Flower      Vegetables
     Cauliflower
    Broccoli/        Broccoli Whole &    Vegetables
     Cauliflower      Crowns Organi
    Broccoli/        Broccoli            Vegetables
     Cauliflower      Whole&Crowns
    Broccoli/        Cauliflower Whole   Vegetables
     Cauliflower
    Broccoli/        Cauliflower Whole   Vegetables
     Cauliflower      Organic
    Can Vegetables-- Artichokes          Vegetables
     Shelf Stable
    Can Vegetables-- Beans/Wax/Shellies  Vegetables
     Shelf Stable
    Can Vegetables-- Beets               Vegetables
     Shelf Stable
    Can Vegetables-- Carrots             Vegetables
     Shelf Stable
    Can Vegetables-- Corn                Vegetables
     Shelf Stable
    Can Vegetables-- Fried Onions        Vegetables
     Shelf Stable
    Can Vegetables-- Green Beans: Fs/    Vegetables
     Shelf Stable     Whl/Cut
    Can Vegetables-- Hominy              Vegetables
     Shelf Stable
    Can Vegetables-- Kraut & Cabbage     Vegetables
     Shelf Stable
    Can Vegetables-- Lima Beans          Vegetables
     Shelf Stable
    Can Vegetables-- Miscellaneous       Vegetables
     Shelf Stable     Vegetables
    Can Vegetables-- Mixed Vegetables    Vegetables
     Shelf Stable
    Can Vegetables-- Mushrooms Cnd &     Vegetables
     Shelf Stable     Glass
    Can Vegetables-- Peas & Onions/Peas  Vegetables
     Shelf Stable     & Carrot
    Can Vegetables-- Peas Fresh Pack/    Vegetables
     Shelf Stable     Crowder
    Can Vegetables-- Peas/Green          Vegetables
     Shelf Stable
    Can Vegetables-- Pimentos            Vegetables
     Shelf Stable
    Can Vegetables-- Salads Cnd (Bean/   Vegetables
     Shelf Stable     Potato)
    Can Vegetables-- Spinach & Greens    Vegetables
     Shelf Stable
    Can Vegetables-- Squash              Vegetables
     Shelf Stable
    Can Vegetables-- Sweet Potatoes      Vegetables
     Shelf Stable
    Can Vegetables-- White Potatoes      Vegetables
     Shelf Stable
    Carrots          Carrots--Bulk       Vegetables
    Carrots          Carrots Bagged      Vegetables
    Carrots          Carrots Bagged      Vegetables
                      Organic
    Carrots          Carrots Bulk        Vegetables
                      Organic
    Carrots          Carrots Mini        Vegetables
                      Peeled
    Carrots          Carrots Mini        Vegetables
                      Peeled Organic
    Condiments       Salsa/Dips          Vegetables
    Convenience/     Convenience/        Vegetables
     Snacking         Snacking Organic
    Convenience/     Convenience/        Vegetables
     Snacking         Snacking
                      Vegetable
    Corn             Corn Bulk           Vegetables
    Corn             Corn Is Packaged    Vegetables
    Corn             Corn Organic        Vegetables
    Corn             Corn Packaged       Vegetables
    Corn             Corn White          Vegetables
    Dry Sauce/Gravy/ Potatoes: Dry       Vegetables
     Potatoes/
     Stuffing
    Frozen Potatoes  Frzn Baked/Stuffed/ Vegetables
                      Mashed & Spec
    Frozen Potatoes  Frzn French Fries   Vegetables
    Frozen Potatoes  Frzn Hashbrown      Vegetables
                      Potatoes
    Frozen Potatoes  Frzn Onion Rings    Vegetables
    Frozen Potatoes  Frzn Tater Tots/    Vegetables
                      Other Extruded
    Frozen           Frzn Breaded        Vegetables
     Vegetable &      Vegetables
     Veg Dish
    Frozen           Frzn Corn On The    Vegetables
     Vegetable &      Cob
     Veg Dish
    Frozen           Frzn Organic        Vegetables
     Vegetable &      Vegetables
     Veg Dish
    Frozen           Frzn Steamable      Vegetables
     Vegetable &      Vegetables
     Veg Dish
    Frozen           Fz Bag Vegetables-- Vegetables
     Vegetable &      Plain
     Veg Dish
    Frozen           Fz Bag Vegetables-- Vegetables
     Vegetable &      Value-Added
     Veg Dish
    Frozen           Fz Box Vegetables-- Vegetables
     Vegetable &      Plain
     Veg Dish
    Frozen           Fz Box Vegetables-- Vegetables
     Vegetable &      Value-Added
     Veg Dish
    Frozen           Bag Vegetables      Vegetables
     Vegetables And
     Potatoes
    Frozen           Box Vegetables      Vegetables
     Vegetables And
     Potatoes
    Frozen           Edamame             Vegetables
     Vegetables And
     Potatoes
    Frozen           Potatoes            Vegetables
     Vegetables And
     Potatoes
    Fruit & Veg      Herbs (Outdoor)     Vegetables
     Plants
     (Outdoor)
    Fruit & Veg      Vegetable           Vegetables
     Plants
     (Outdoor)
    Herbs/Garlic     Garlic Whole        Vegetables
                      Cloves
    Herbs/Garlic     Garlic Whole        Vegetables
                      Cloves Organic
    Herbs/Garlic     Herbs Basil         Vegetables
    Herbs/Garlic     Herbs Basil         Vegetables
                      Organic
    Herbs/Garlic     Herbs Cilanto       Vegetables
    Herbs/Garlic     Herbs Cilantro      Vegetables
                      Organic
    Herbs/Garlic     Herbs Fresh Other   Vegetables
    Herbs/Garlic     Herbs Fresh Other   Vegetables
                      Organic
    Herbs/Garlic     Herbs Parsley       Vegetables
    Herbs/Garlic     Herbs Parsley       Vegetables
                      Organic
    Herbs/Garlic     Sprouts             Vegetables
    Kosher Foods     Kosher Potato       Vegetables
     And Products     Vegetable
    Mushrooms        Mushrooms Dried     Vegetables
    Mushrooms        Mushrooms Other     Vegetables
    Mushrooms        Mushrooms Others    Vegetables
                      Organic
    Mushrooms        Mushrooms           Vegetables
                      Portabella
    Mushrooms        Mushrooms White     Vegetables
                      Bulk
    Mushrooms        Mushrooms White     Vegetables
                      Sliced Pkg
    Mushrooms        Mushrooms White     Vegetables
                      Whole Pkg
    Mushrooms        Mushrooms White     Vegetables
                      Whole Pkg Organic
    Onions           Onions Gourmet      Vegetables
    Onions           Onions Other        Vegetables
    Onions           Onions Other        Vegetables
                      Organic
    Onions           Onions Red (Bulk &  Vegetables
                      Bag)
    Onions           Onions Sweet (Bulk  Vegetables
                      & Bag)
    Onions           Onions White (Bulk  Vegetables
                      & Bag)
    Onions           Onions Yellow       Vegetables
                      (Bulk & Bag)
    Organics Fruit   Organic Broccoli/   Vegetables
     & Vegetables     Cauliflower
    Organics Fruit   Organic Fruit/Veg   Vegetables
     & Vegetables     Instore Proc
    Organics Fruit   Organic Other       Vegetables
     & Vegetables
    Organics Fruit   Organic Processed   Vegetables
     & Vegetables
    Organics Fruit   Organic Salad Mix   Vegetables
     & Vegetables
    Organics Fruit   Organic Value-      Vegetables
     & Vegetables     Added Vegetables
    Organics Fruit   Organic Vegetables  Vegetables
     & Vegetables     Salad
    Pasta & Pizza    Mainstream [Pasta   Vegetables
     Sauce            & Pizza Sauce]
    Pasta & Pizza    Pizza Sauce         Vegetables
     Sauce
    Pasta & Pizza    Specialty Italian   Vegetables
     Sauce            Sauce
    Pasta & Pizza    Value [Pasta &      Vegetables
     Sauce            Pizza Sauce]
    Peppers          Peppers All Other   Vegetables
    Peppers          Peppers All Others  Vegetables
                      Organic
    Peppers          Peppers Green Bell  Vegetables
    Peppers          Peppers Green Bell  Vegetables
                      Organic
    Peppers          Peppers Jalapeno    Vegetables
    Peppers          Peppers Mini Sweet  Vegetables
                      Packaged
    Peppers          Peppers Other Bell  Vegetables
    Peppers          Peppers Other Bell  Vegetables
                      Organic
    Peppers          Peppers Red Bell    Vegetables
    Peppers          Peppers Red Bell    Vegetables
                      Organic
    Peppers          Peppers Serrano     Vegetables
    Peppers          Peppers Yellow      Vegetables
                      Bell
    Peppers          Peppers Yellow      Vegetables
                      Bell Organic
    Potatoes         Potatoes Gold       Vegetables
                      (Bulk & Bag)
    Potatoes         Potatoes Gourmet    Vegetables
    Potatoes         Potatoes Other      Vegetables
    Potatoes         Potatoes Other      Vegetables
                      Organic
    Potatoes         Potatoes Red (Bulk  Vegetables
                      & Bag)
    Potatoes         Potatoes Russet     Vegetables
                      (Bulk & Bag)
    Potatoes         Potatoes            Vegetables
                      Sweet&Yams
    Potatoes         Potatoes White      Vegetables
                      (Bulk & Bag)
    Prepared/Pdgd    Vegetables/Dry      Vegetables
     Foods            Beans
    Processed        Jarred Vegetables   Vegetables
    Refrigerated     Refrigerated Pasta  Vegetables
     Italian          Sauce
    Salad & Dips     Sal: Hommus         Vegetables
    Salad & Dips     Sal: Salsa/Dips     Vegetables
                      Bulk
    Salad & Dips     Sal: Salsa Prepack  Vegetables
    Salad & Dips     Salad Bar           Vegetables
    Salad & Dips     Salad: Ingredients  Vegetables
    Salad & Dips     Salad: Lettuce      Vegetables
    Salad & Dips     Vegetable Salads--  Vegetables
                      Bulk
    Salad & Dips     Vegetable Salads--  Vegetables
                      Prepack
    Salad Bar        Processed Salad     Vegetables
    Salad Mix        Blends [Salad Mix]  Vegetables
    Salad Mix        Coleslaw            Vegetables
    Salad Mix        Garden Plus [Salad  Vegetables
                      Mix]
    Salad Mix        Kits [Salad Mix]    Vegetables
    Salad Mix        Regular Garden      Vegetables
                      [Salad Mix]
    Salad Mix        Salad Bowls         Vegetables
    Salad Mix        Salad Mix Blends    Vegetables
                      Organic
    Salad Mix        Salad Mix Kits      Vegetables
                      Organic
    Salad Mix        Salad Mix Other     Vegetables
    Salad Mix        Salad Spinach       Vegetables
    Salad Mix        Salad Spinach       Vegetables
                      Organic
    Salad Mix        Shredded Lettuce    Vegetables
    Seasonal         Pumpkins            Vegetables
    Shelf Stable     Tomato Juice (50%   Vegetables
     Juice            And Under)
    Shelf Stable     Tomato Juice (Over  Vegetables
     Juice            50% Juice)
    Shelf Stable     Veg Juice (Except   Vegetables
     Juice            Tomato) (50% And
                      Under)
    Shelf Stable     Veg Juice (Except   Vegetables
     Juice            Tomato) (Over 50%
                      Juice)
    Snack            Salsa               Vegetables
    Spices/Jarred    Garlic Jar          Vegetables
     Garlic
    Spices/Jarred    Garlic Jar Organic  Vegetables
     Garlic
    Spices/Jarred    Herbs Dried         Vegetables
     Garlic
    Spices/Jarred    Herbs Squeeze Tube  Vegetables
     Garlic           Organic
    Spices/Jarred    Peppers Dried       Vegetables
     Garlic
    Tomato           Tomato Stewed       Vegetables
     Products--Shel
     f
    Tomato           Tomato Paste        Vegetables
     Products--Shel
     f Stable
    Tomato           Tomatoes Diced      Vegetables
     Products--Shel
     f Stable
    Tomato           Tomato Crushed      Vegetables
     Products--Shel
     f Stable
    Tomato           Tomato Puree        Vegetables
     Products--Shel
     f Stable
    Tomato           Tomato Sauce        Vegetables
     Products--Shel
     f Stable
    Tomato           Tomato Sun Dried    Vegetables
     Products--Shel
     f Stable
    Tomato           Tomatoes/Whole      Vegetables
     Products--Shel
     f Stable
    Tomatoes         Roma Tomatoes       Vegetables
                      (Bulk/Pkg)
    Tomatoes         Tomatoes Cherry     Vegetables
    Tomatoes         Tomatoes Cherry     Vegetables
                      Organic
    Tomatoes         Tomatoes Cocktail   Vegetables
    Tomatoes         Tomatoes Grape      Vegetables
    Tomatoes         Tomatoes Grape      Vegetables
                      Organic
    Tomatoes         Tomatoes Hot House  Vegetables
                      Bulk
    Tomatoes         Tomatoes Hothouse   Vegetables
                      On The Vine
    Tomatoes         Tomatoes Hothouse   Vegetables
                      Pkg
    Tomatoes         Tomatoes Others     Vegetables
                      Organic
    Tomatoes         Tomatoes Snacking   Vegetables
                      Colored
    Tomatoes         Tomatoes Vine Ripe  Vegetables
                      Bulk
    Tomatoes         Tomatoes Vine Ripe  Vegetables
                      Pkg
    Tomatoes         Tomatoes--Other     Vegetables
    Traditional      Asian Vegetables    Vegetables
     Asian Foods
    Traditional      Mexican Beans/      Vegetables
     Mexican Foods    Refried
    Traditional      Mexican Enchilada   Vegetables
     Mexican Foods    Sauce
    Traditional      Mexican Peppers     Vegetables
     Mexican Foods    Chilies
    Traditional      Mexican Sauces And  Vegetables
     Mexican Foods    Picante Sau
    Tropical Fruit   Avocado             Vegetables
    Tropical Fruit   Avocado Organic     Vegetables
    Unknown          Frozen Vegetables   Vegetables
    Value-Added      Celery Chopped/     Vegetables
     Vegetables       Sticks
    Value-Added      Cut Vegetables All  Vegetables
     Vegetables       Other
    Value-Added      Instore Cut         Vegetables
     Vegetables       Vegetables
    Value-Added      Onions Processed    Vegetables
     Vegetables
    Value-Added      Vegetable Party     Vegetables
     Vegetables       Tray
    Vegetables       Asparagus           Vegetables
     Cooking Bulk
    Vegetables       Beans               Vegetables
     Cooking Bulk
    Vegetables       Beans Organic       Vegetables
     Cooking Bulk
    Vegetables       Cabbage             Vegetables
     Cooking Bulk
    Vegetables       Cabbage Organic     Vegetables
     Cooking Bulk
    Vegetables       Celery              Vegetables
     Cooking Bulk
    Vegetables       Celery Organic      Vegetables
     Cooking Bulk
    Vegetables       Greens Bulk         Vegetables
     Cooking Bulk
    Vegetables       Greens Bulk         Vegetables
     Cooking Bulk     Organic
    Vegetables       Hard Squash         Vegetables
     Cooking Bulk
    Vegetables       Organic Vegetables  Vegetables
     Cooking Bulk     All Others
    Vegetables       Squash Other        Vegetables
     Cooking Bulk
    Vegetables       Squash Other        Vegetables
     Cooking Bulk     Organic
    Vegetables       Vegetables All      Vegetables
     Cooking Bulk     Other
    Vegetables       Vegetables Cooking  Vegetables
     Cooking          Packaged Organic
     Packaged
    Vegetables       Broccoli/           Vegetables
     Cooking          Cauliflower
     Packaged         Processed
    Vegetables       Potatoes/Onions     Vegetables
     Cooking          Processed
     Packaged
    Vegetables       Vegetables Cooking  Vegetables
     Cooking          Packaged
     Packaged
    Vegetables       Cucumbers           Vegetables
     Salad
    Vegetables       Cucumbers Organic   Vegetables
     Salad
    Vegetables       Green Onions        Vegetables
     Salad
    Vegetables       Green Onions        Vegetables
     Salad            Organic
    Vegetables       Head Lettuce        Vegetables
     Salad
    Vegetables       Head Lettuce        Vegetables
     Salad            Organic
    Vegetables       Radish              Vegetables
     Salad
    Vegetables       Radishes Organic    Vegetables
     Salad
    Vegetables       Spinach Bulk        Vegetables
     Salad
    Vegetables       Spring Mix Bulk     Vegetables
     Salad
    Vegetables       Variety Lettuce     Vegetables
     Salad
    Vegetables       Variety Lettuce     Vegetables
     Salad            Organic
    Authentic        Italian Oils And    Oils
     Italian Foods    Dressings
    Deli             Dl Spec: Sauces/    Oils
     Specialties      Sld Dressings
     (Retail Pk)
    Dressings/Dips   Dressing Blue       Oils
                      Cheese
    Dressings/Dips   Dressing Cole Slaw  Oils
    Dressings/Dips   Dressing Creamy     Oils
    Dressings/Dips   Dressing Ginger     Oils
    Dressings/Dips   Dressing Organics   Oils
    Dressings/Dips   Dressing            Oils
                      Vinegarette
    Dressings/Dips   Dressing Yogurt     Oils
                      Based
    Margarines       Margarine: Squeeze  Oils
    Margarines       Margarine: Tubs     Oils
                      And Bowls
    Processed        Dressings           Oils
    Salad Dresing &  Mayonnaise &        Oils
     Sandwich         Whipped Dressing
     Spreads
    Salad Dresing &  Pourable Salad      Oils
     Sandwich         Dressings
     Spreads
    Salad Dresing &  Sand/Horseradish &  Oils
     Sandwich         Tartar Sauce
     Spreads
    Shortening &     Canola Oils         Oils
     Oil
    Shortening &     Cooking Oil:        Oils
     Oil              Peanut/Safflower
    Shortening &     Cooking Sprays      Oils
     Oil
    Shortening &     Corn Oil            Oils
     Oil
    Shortening &     Misc Oils           Oils
     Oil
    Shortening &     Olive Oil           Oils
     Oil
    Shortening &     Vegetable Oil       Oils
     Oil
    Aseptic Juice    Aseptic Pack Juice  Solid Fats &   sweetened beverage
                      And Drinks          Added Sugar
    Aseptic Juice    Aseptic Pack Juice  Solid Fats &   sweetened beverage
                      And Drinks          Added Sugar
    Aseptic Juice    Aseptic Pack Juice  Solid Fats &   sweetened beverage
                      And Drinks          Added Sugar
    Authentic        Central American    Solid Fats &   candy/sweet
     Central          Candy W/O Flour     Added Sugar
     American Fds
    Authentic        Central American    Solid Fats &   sweetened beverage
     Central          Carbonated Bev      Added Sugar
     American Fds
    Authentic        Hispanic            Solid Fats &   sweetened beverage
     Hispanic Fds &   Carbonated          Added Sugar
     Product          Beverages
    Authentic        Authentic Dry       Solid Fats &   sweetened beverage
     Hispanic Fds &   Beverages W/        Added Sugar
     Product          Sweetener
    Authentic        Hispanic Juice      Solid Fats &   sweetened beverage
     Hispanic Fds &   Under 50% Juice     Added Sugar
     Product
    Authentic South  South American      Solid Fats &   candy/sweet
     American Fds     Candy W/O Flour     Added Sugar
    Bag Snacks       Pork Skins/         Solid Fats &   butter/cream/solid
                      Cracklins           Added Sugar    fat
    Bagels & Cream   Cream Cheese        Solid Fats &   butter/cream/solid
     Cheese                               Added Sugar    fat
    Baking           Chocolate Chips &   Solid Fats &   candy/sweet
                      Bars (Sweete)       Added Sugar
    Baking Mixes     Frosting            Solid Fats &   candy/sweet
                                          Added Sugar
    Baking Needs     Coconut [Baking     Solid Fats &   butter/cream/solid
                      Needs]              Added Sugar    fat
    Baking Needs     Marshmallow Creme   Solid Fats &   candy/sweet
                                          Added Sugar
    Baking Needs     Marshmallows        Solid Fats &   candy/sweet
                                          Added Sugar
    Beverages        Can/Btl Carb Beve   Solid Fats &   sweetened beverage
                      50% And Under       Added Sugar
    Beverages        Can/Btl N/Carb      Solid Fats &   sweetened beverage
                      Beve 50% And        Added Sugar
                      Under
    Beverages        Tea (Canned/        Solid Fats &   sweetened beverage
                      Bottled) W/         Added Sugar
                      Sweetener
    Bulk Food        Candy Bulk          Solid Fats &   candy/sweet
                                          Added Sugar
    Bulk Food        Candy Bulk W/Flour  Solid Fats &   candy/sweet
                                          Added Sugar
    Cake Decor       Cake Decors--       Solid Fats &   candy/sweet
                      Candies             Added Sugar
    Cake Decor       Cake Decors &       Solid Fats &   candy/sweet
                      Icing               Added Sugar
    Candy            Candy W/Flour       Solid Fats &   candy/sweet
                                          Added Sugar
    Candy            Candy/Chocolate     Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Checklan  Candy Bars          Solid Fats &   candy/sweet
     e                (Singles)           Added Sugar
                      (Including)
    Candy--Checklan  Candy Bars          Solid Fats &   candy/sweet
     e                (Singles)           Added Sugar
                      (Including)
    Candy--Checklan  Chewing Gum         Solid Fats &   candy/sweet
     e                                    Added Sugar
    Candy--Checklan  Mints/Candy &       Solid Fats &   candy/sweet
     e                Breath (Not         Added Sugar
                      Lifesavers)
    Candy--Checklan  Mints/Candy &       Solid Fats &   candy/sweet
     e                Breath (Not         Added Sugar
                      Lifesavers)
    Candy--Checklan  Misc Checklane      Solid Fats &   candy/sweet
     e                Candy               Added Sugar
    Candy--Packaged  Bulk Candy          Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Packaged  Bulk Candy W/Flour  Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Packaged  Candy & Breath      Solid Fats &   candy/sweet
                      Mints (Pkgd)        Added Sugar
    Candy--Packaged  Candy & Breath      Solid Fats &   candy/sweet
                      Mints (Pkgd)        Added Sugar
    Candy--Packaged  Candy Bags--        Solid Fats &   candy/sweet
                      Chocolate           Added Sugar
    Candy--Packaged  Candy Bags--        Solid Fats &   candy/sweet
                      Chocolate W/Flour   Added Sugar
    Candy--Packaged  Candy Bags--Non     Solid Fats &   candy/sweet
                      Chocolate           Added Sugar
    Candy--Packaged  Candy Bags--Non     Solid Fats &   candy/sweet
                      Chocolate W/Flour   Added Sugar
    Candy--Packaged  Candy Bars (Multi   Solid Fats &   candy/sweet
                      Pack)               Added Sugar
    Candy--Packaged  Candy Bars Multi    Solid Fats &   candy/sweet
                      Pack W/Flour        Added Sugar
    Candy--Packaged  Candy Box Non-      Solid Fats &   candy/sweet
                      Chocolate           Added Sugar
    Candy--Packaged  Candy Box Non-      Solid Fats &   candy/sweet
                      Chocolate W/Flour   Added Sugar
    Candy--Packaged  Candy Boxed         Solid Fats &   candy/sweet
                      Chocolates          Added Sugar
    Candy--Packaged  Candy Boxed         Solid Fats &   candy/sweet
                      Chocolates W/       Added Sugar
                      Flour
    Candy--Packaged  Candy Refrigerated  Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Packaged  Gum (Packaged)      Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Packaged  Hispanic Candy      Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Packaged  Miscellaneous       Solid Fats &   candy/sweet
                      Candy               Added Sugar
    Candy--Packaged  Miscellaneous       Solid Fats &   candy/sweet
                      Candy               Added Sugar
    Candy--Packaged  Novelty Candy       Solid Fats &   candy/sweet
                                          Added Sugar
    Candy--Packaged  Novelty Candy W/    Solid Fats &   candy/sweet
                      Flour               Added Sugar
    Candy--Packaged  Novelty Candy--     Solid Fats &   candy/sweet
                      Taxable             Added Sugar
    Candy--Packaged  Seasonal Candy      Solid Fats &   candy/sweet
                      Bags Non-           Added Sugar
                      Chocolate
    Candy--Packaged  Seasonal Candy      Solid Fats &   candy/sweet
                      Bags Non-           Added Sugar
                      Chocolate
    Candy--Packaged  Seasonal Candy      Solid Fats &   candy/sweet
                      Bags--Chocolate     Added Sugar
    Candy--Packaged  Seasonal Candy      Solid Fats &   candy/sweet
                      Bags--Chocolate     Added Sugar
    Candy--Packaged  Seasonal Candy Box  Solid Fats &   candy/sweet
                      Non-Chocolate       Added Sugar
    Candy--Packaged  Seasonal Candy Box  Solid Fats &   candy/sweet
                      Non-Chocolate       Added Sugar
    Candy--Packaged  Seasonal Candy      Solid Fats &   candy/sweet
                      Box--Chocolate      Added Sugar
    Candy--Packaged  Seasonal Candy      Solid Fats &   candy/sweet
                      Box--Chocolate W/   Added Sugar
                      Flour
    Candy--Packaged  Seasonal            Solid Fats &   candy/sweet
                      Miscellaneous       Added Sugar
                      [Candy]
    Candy--Packaged  Seasonal            Solid Fats &   candy/sweet
                      Miscellaneous W/    Added Sugar
                      Flour
    Cocoa Mixes      Hot Chocolate/      Solid Fats &   sweetened beverage
                      Cocoa Mix           Added Sugar
    Cocoa Mixes      Malted Mlk/Syrup/   Solid Fats &   sweetened beverage
                      Pwdrs (Eggnog)      Added Sugar
    Coffee &         Coffee Sweeteners   Solid Fats &   sweetened beverage
     Creamers                             Added Sugar
    Coffee &         Non Dairy Creamer   Solid Fats &   sweetened beverage
     Creamers                             Added Sugar
    Coffee Shop      Coffee Shop: Candy  Solid Fats &   candy/sweet
     Sweet Goods &                        Added Sugar
     Rtl
    Condiments       Honey/Syrup         Solid Fats &   candy/sweet
                                          Added Sugar
    Condiments       Jellies/Preserves/  Solid Fats &   candy/sweet
                      Apple Butter        Added Sugar
    Deli             Dl Spec: Jellies/   Solid Fats &   Sugar candy/sweet
     Specialties      Toppings            Added
     (Retail Pk)
    Dressings/Dips   Dips Caramel/Fruit  Solid Fats &   candy/sweet
                      Glazes              Added Sugar
    Dressings/Dips   Dips Fruit And      Solid Fats &   candy/sweet
                      Chocolate           Added Sugar
    Dry Mix          Desserts Topping    Solid Fats &   butter/cream/solid
                      Mixes/Whip          Added Sugar    fat
                      Topping
    Dry Tea/Coffee/  Coco Mix            Solid Fats &   sweetened beverage
     Coco Mixes                           Added Sugar
    Dry Tea/Coffee/  Tea Concentrate W/  Solid Fats &   sweetened beverage
     Coco Mixes       Sweetener/Su        Added Sugar
    Dry Tea/Coffee/  Tea Rtd With        Solid Fats &   sweetened beverage
     Coco Mixes       Sweetener/Sugar     Added Sugar
    Energy Drinks    Energy Drink--      Solid Fats &   sweetened beverage
                      Multi-Pack          Added Sugar
    Energy Drinks    Energy Drink--      Solid Fats &   sweetened beverage
                      Multi-Pack (Non)    Added Sugar
    Energy Drinks    Energy Drink--      Solid Fats &   sweetened beverage
                      Single Serve        Added Sugar
    Energy Drinks    Energy Drink--      Solid Fats &   sweetened beverage
                      Single Serve        Added Sugar
    European Foods   British Carbonated  Solid Fats &   sweetened beverage
                      Beverages           Added Sugar
    European Foods   European            Solid Fats &   sweetened beverage
                      Carbonated          Added Sugar
                      Beverages
    Fluid Milk       Refrigerated        Solid Fats &   butter/cream/solid
     Products         Coffee Creamers     Added Sugar    fat
    Fluid Milk       Whipping Cream      Solid Fats &   butter/cream/solid
     Products                             Added Sugar    fat
    Frozen           Frzn Non-Dairy      Solid Fats &   butter/cream/solid
     Breakfast        Creamers            Added Sugar    fat
     Foods
    Frozen Juice     Cocktail Mixes-Frz  Solid Fats &   sweetened beverage
     And Smoothies                        Added Sugar
    Frozen Juice     Frzn Conc Under     Solid Fats &   sweetened beverage
     And Smoothies    50% Juice           Added Sugar
    Frozen Juice     Frzn Fruit Drinks   Solid Fats &   sweetened beverage
     And Smoothies    (Under 10% J)       Added Sugar
    Frozen Whipped   Frzn Whipped        Solid Fats &   butter/cream/solid
     Topping          Topping             Added Sugar    fat
    Gift & Fruit     Candy Arrangements  Solid Fats &   candy/sweet
     Baskets          Food Only           Added Sugar
    Juice            Drinks--Carb Juice  Solid Fats &   sweetened beverage
                      (Under 50%)         Added Sugar
    Juice            Non-Carb Jce        Solid Fats &   sweetened beverage
                      (Under 50% Juice)   Added Sugar
    Juices Super     Juices (50% And     Solid Fats &   sweetened beverage
     Premium          Under Juice)        Added Sugar
    Juices Super     Juices Organic      Solid Fats &   sweetened beverage
     Premium          (50% And Under)     Added Sugar
    Juices Super     Juices Smoothies/   Solid Fats &   sweetened beverages
     Premium          Blended             Added Sugar
    Juices Super     Juices Superfoods/  Solid Fats &   sweetened beverages
     Premium          Enhanced            Added Sugar
    Juices Super     Juices/Smoothies    Solid Fats &   sweetened beverages
     Premium          Instore Produ       Added Sugar
    Kosher Foods     Kosher Beverage     Solid Fats &   sweetened beverages
     And Products                         Added Sugar
    Kosher Foods     Kosher Candy        Solid Fats &   candy/sweet
     And Products                         Added Sugar
    Kosher Foods     Kosher Carbonated   Solid Fats &   sweetened beverage
     And Products     Soft Drinks         Added Sugar
    Margarines       Butter              Solid Fats &   butter/cream/solid
                                          Added Sugar    fat
    Margarines       Margarine Stick     Solid Fats &   butter/cream/solid
                                          Added Sugar    fat
    Milk By-         Aerosol Toppings    Solid Fats &   butter/cream/solid
     Products         [Milk By-           Added Sugar    fat
                      Products]
    Milk By-         Refrig Dips         Solid Fats &   butter/cream/solid
     Products                             Added Sugar    fat
    Milk By-         Sour Creams         Solid Fats &   butter/cream/solid
     Products                             Added Sugar    fat
    Mixers           Cocktail Mixes--    Solid Fats &   sweetened beverage
                      Dry                 Added Sugar
    Mixers           Cocktail Mixes--    Solid Fats &   sweetened beverage
                      Fluid: Add Liq      Added Sugar
    Molasses/Syrups/ Molasses & Syrups   Solid Fats &   candy/sweet
     Pancake Mixes                        Added Sugar
    Packaged         Candy               Solid Fats &   candy/sweet
     Natural Snacks                       Added Sugar
    Peanut Butter/   Preserves/Jam/      Solid Fats &   candy/sweet
     Jelly/Jams &     Marmalade           Added Sugar
     Honey
    Peanut Butter/   Honey               Solid Fats &   candy/sweet
     Jelly/Jams &                         Added Sugar
     Honey
    Peanut Butter/   Jelly               Solid Fats &   candy/sweet
     Jelly/Jams &                         Added Sugar
     Honey
    Powder &         Breakfast Crystals  Solid Fats &   sweetened beverage
     Crystal Drink                        Added Sugar
     Mix
    Powder &         Enhanced Stick      Solid Fats &   sweetened beverage
     Crystal Drink    [Powder Drink       Added Sugar
     Mix              Mix]
    Powder &         Fluid Pouch         Solid Fats &   sweetened beverage
     Crystal Drink    [Powder Drink       Added Sugar
     Mix              Mix]
    Powder &         Soft Drink          Solid Fats &   sweetened beverage
     Crystal Drink    Canisters [Powder   Added Sugar
     Mix              Drink Mix]
    Powder &         Sugar Sweetened     Solid Fats &   candy/sweet
     Crystal Drink    Envelopes           Added Sugar
     Mix
    Powder &         Sugar Sweetened     Solid Fats &   candy/sweet
     Crystal Drink    Sticks              Added Sugar
     Mix
    Processed        Dips                Solid Fats &   butter/cream/solid
                                          Added Sugar    fat
    Processed        Packaged Dry        Solid Fats &   sweetened beverages
                      Smoothie Mix        Added Sugar
    Refrgratd        Dairy Case Citrus   Solid Fats &   sweetened beverage
     Juices/Drinks    Pnch/Oj Subs        Added Sugar
    Refrgratd        Dairy Case Fruit    Solid Fats &   sweetened beverage
     Juices/Drinks    Drinks (No Ju)      Added Sugar
    Refrgratd        Dairy Case Juice    Solid Fats &   sweetened beverage
     Juices/Drinks    Drnk Under 10       Added Sugar
    Refrgratd        Dairy Case Tea      Solid Fats &   sweetened beverage
     Juices/Drinks    With Sugar Or S     Added Sugar
    Refrigerated     Ntrn Refrig Juice   Solid Fats &   sweetened beverage
     Dairy Case       Under 50%           Added Sugar
    Refrigerated     Sour Cream/Cottage  Solid Fats &   butter/cream/solid
     Dairy Case       Cheese              Added Sugar    fat
    Refrigerated     Tea With Sweetener/ Solid Fats &   sweetened beverage
     Dairy Case       Sugar               Added Sugar
    Rtd Tea/New Age  Juice (Under 10%    Solid Fats &   sweetened beverage
     Juice            Juice)              Added Sugar
    Rtd Tea/New Age  Juice (Under 50%    Solid Fats &   sweetened beverage
     Juice            Juice)              Added Sugar
    Rtd Tea/New Age  Tea Sweetened       Solid Fats &   sweetened beverage
     Juice                                Added Sugar
    Service          Sv Bev: Bev/Juic    Solid Fats &   sweetened beverage
     Beverage         10-50% Juice        Added Sugar
    Shelf Stable     Apple Juice &       Solid Fats &   sweetened beverage
     Juice            Cider (50% And      Added Sugar
                      Under Juice)
    Shelf Stable     Apple Juice &       Solid Fats &   sweetened beverage
     Juice            Cider (Under 10%    Added Sugar
                      Juice)
    Shelf Stable     Blended Juice &     Solid Fats &   sweetened beverage
     Juice            Combinations        Added Sugar
    Shelf Stable     Blended Juice &     Solid Fats &   sweetened beverage
     Juice            Combinations        Added Sugar
    Shelf Stable     Cranapple/Cran      Solid Fats &   sweetened beverage
     Juice            Grape Juice         Added Sugar
    Shelf Stable     Cranberry Juice     Solid Fats &   sweetened beverage
     Juice            (50% And Under      Added Sugar
                      Juice)
    Shelf Stable     Fruit Drinks:       Solid Fats &   sweetened beverage
     Juice            Canned & Glass      Added Sugar
    Shelf Stable     Fruit Drinks:       Solid Fats &   sweetened beverage
     Juice            Canned & Glass      Added Sugar
    Shelf Stable     Fruit Drinks:       Solid Fats &   sweetened beverage
     Juice            Canned & Glass      Added Sugar
    Shelf Stable     Fruit Drinks:       Solid Fats &   sweetened beverage
     Juice            Canned & Glass      Added Sugar
    Shelf Stable     Grape Juice (50%    Solid Fats &   sweetened beverage
     Juice            And Under Juice)    Added Sugar
    Shelf Stable     Grapefruit Juice    Solid Fats &   sweetened beverage
     Juice            (50% And Under      Added Sugar
                      Juice)
    Shelf Stable     Lemon Juice & Lime  Solid Fats &   sweetened beverage
     Juice            Juice (50% And      Added Sugar
                      Under Juice)
    Shelf Stable     Lemon Juice & Lime  Solid Fats &   sweetened beverage
     Juice            Juice               Added Sugar
    Shelf Stable     Nectars (50% And    Solid Fats &   sweetened beverage
     Juice            Under Juice)        Added Sugar
    Shelf Stable     Prune Juice (50%    Solid Fats &   sweetened beverage
     Juice            And Under Juice)    Added Sugar
    Shortening &     Solid Shortening    Solid Fats &   butter/cream/solid
     Oil                                  Added Sugar    fat
    Soft Drinks      Mixers (Tonic       Solid Fats &   sweetened beverage
                      Water/Gngr Ale)     Added Sugar
    Soft Drinks      Mixers (Tonic Wtr/  Solid Fats &   sweetened beverage
                      Gngr Ale)           Added Sugar
    Soft Drinks      Sft Drnk 1 Liter    Solid Fats &   sweetened beverage
                      Btl Carb            Added Sugar
    Soft Drinks      Sft Drnk 2 Liter    Solid Fats &   sweetened beverage
                      Btl Carb Incl       Added Sugar
    Soft Drinks      Sft Drnk 3 Liter    Solid Fats &   sweetened beverage
                      Btl Carb            Added Sugar
    Soft Drinks      Sft Drnk Misc Btl   Solid Fats &   sweetened beverage
                      (Any Btl)           Added Sugar
    Soft Drinks      Sft Drnk Misc Can   Solid Fats &   sweetened beverage
                      (Ex: 4/8/18pk)      Added Sugar
    Soft Drinks      Sft Drnk Mlt-Pk     Solid Fats &   sweetened beverage
                      Btl Carb            Added Sugar
    Soft Drinks      Sft Drnk Sngl Srv   Solid Fats &   sweetened beverage
                      Btl Carb            Added Sugar
    Soft Drinks      Soft Drink Bottle   Solid Fats &   sweetened beverage
                      Non-Carb            Added Sugar
    Soft Drinks      Soft Drinks 12/18   Solid Fats &   sweetened beverage
                      & 15pk Can Car      Added Sugar
    Soft Drinks      Soft Drinks 20pk &  Solid Fats &   sweetened beverage
                      24pk Can Carb       Added Sugar
    Soft Drinks      Soft Drinks 6pk     Solid Fats &   sweetened beverage
                      Can Carb            Added Sugar
    Soft Drinks      Soft Drinks Bottle  Solid Fats &   sweetened beverage
                      Returnable          Added Sugar
    Soft Drinks      Soft Drinks Can     Solid Fats &   sweetened beverage
                      Non-Carb            Added Sugar
    Soft Drinks      Soft Drinks Single  Solid Fats &   sweetened beverage
                      Cans Carb           Added Sugar
    Soft Drinks      Tea Bottles With    Solid Fats &   sweetened beverage
                      Sweetener/Sugar     Added Sugar
    Soft Drinks      Tea Can With        Solid Fats &   sweetened beverage
                      Sweetener/Sugar     Added Sugar
    Sugars &         Sugar               Solid Fats &   candy/sweet
     Sweeteners                           Added Sugar
    Sugars &         Sweeteners          Solid Fats &   candy/sweet
     Sweeteners                           Added Sugar
    Sweet Goods &    Sweet Goods: Candy  Solid Fats &   candy/sweet
     Snacks                               Added Sugar
    Sweet Goods &    Sweet Goods: Candy  Solid Fats &   candy/sweet
     Snacks           W/Flour             Added Sugar
    Syrups Toppings  Ice Cream Toppings  Solid Fats &   candy/sweet
     & Cones                              Added Sugar
    Teas             Instant Tea & Tea   Solid Fats &   sweetened beverage
                      Mix (W/Sugar)       Added Sugar
    Traditional      Mexican Candy       Solid Fats &   candy/sweet
     Mexican Foods                        Added Sugar
    Trail Mix &      Candy W/Flour       Solid Fats &   candy/sweet
     Snacks                               Added Sugar
    Trail Mix &      Candy W/O Flour     Solid Fats &   candy/sweet
     Snacks                               Added Sugar
    Trail Mix &      Candy W/O Flour     Solid Fats &   candy/sweet
     Snacks           Organic             Added Sugar
    Water            Carb Water--Flvrd   Solid Fats &   sweetened beverage
                      Sweetened           Added Sugar
    Water            Energy Drinks       Solid Fats &   sweetened beverage
                                          Added Sugar
    Authentic        Authentic Pasta/    Composite                           entree/meal
     Hispanic Fds &   Rice/Beans
     Product
    Authentic        Authentic Soups/    Composite                           soup
     Hispanic Fds &   Bouillons
     Product
    Authentic        Hispanic Cookies/   Composite                           desserts
     Hispanic Fds &   Crackers
     Product
    Authentic        Italian Pasta And   Composite                           entree/meal
     Italian Foods    Pasta Sauce
    Bag Snacks       Store Brand         Composite                           snacks
    Bag Snacks       Misc Bag Snacks     Composite                           snacks
    Bag Snacks       Mult Pk Bag Snacks  Composite                           snacks
    Bag Snacks       Potato Chips        Composite                           snacks
    Bag Snacks       Salsa & Dips        Composite                           snacks
    Baked Sweet      Snack Cake--Multi   Composite                           desserts
     Goods            Pack
    Baked Sweet      Sweet Goods--Full   Composite                           desserts
     Goods            Size
    Bakery Party                         Composite                           desserts
     Trays
    Bakery Party     Party Trays:        Composite                           desserts
     Trays            Breakfast Sweets
    Bakery Party     Party Trays: Cakes  Composite                           desserts
     Trays
    Bakery Party     Party Trays:        Composite                           desserts
     Trays            Cookies--Rolls
    Baking Mixes     Brownie Mix         Composite                           desserts
    Baking Mixes     Cookies Mix         Composite                           desserts
    Baking Mixes     Layer Cake Mix      Composite                           desserts
    Baking Mixes     Microwavable Cake   Composite                           desserts
                      Mix
    Baking Needs     Pie Crust Mixes &   Composite                           desserts
                      Shells
    Baking Needs     Pie Filling/        Composite                           desserts
                      Mincemeat/Glazes
    Bulk Food        Grain/Beans Bulk    Composite                           entree/meal
    Bulk Food        Misc Bulk Snacks    Composite                           snacks
                      Sweetened
    Bulk Food        Snacks Bulk         Composite                           snacks
    Cakes            Cakes Ingredients   Composite                           desserts
    Cakes            Cakes: Angel Fds/   Composite                           desserts
                      Cke Rolls
    Cakes            Cakes: Angl Fd/     Composite                           desserts
                      Roll Novelties
    Cakes            Cakes: Birthday/    Composite                           desserts
                      Celebration Sheet
    Cakes            Cakes: Cheesecake   Composite                           desserts
    Cakes            Cakes: Cheesecake   Composite                           desserts
                      Novelties
    Cakes            Cakes: Cndles/Retl  Composite                           desserts
                      Accss
    Cakes            Cakes: Creme/       Composite                           desserts
                      Pudding
    Cakes            Cakes: Creme/       Composite                           desserts
                      Pudding Novelties
    Cakes            Cakes: Cupcakes     Composite                           desserts
    Cakes            Cakes: Fancy/       Composite                           desserts
                      Service Case
    Cakes            Cakes: Ice Cream    Composite                           desserts
    Cakes            Cakes: Kosher       Composite                           desserts
    Cakes            Cakes: Layers       Composite                           desserts
    Cakes            Cakes: Layers/      Composite                           desserts
                      Sheets Novelties
    Cakes            Cakes: Novelties    Composite                           desserts
    Cakes            Cakes: Pound        Composite                           desserts
    Cakes            Cakes: Pound Cake   Composite                           desserts
                      Novelties
    Cakes            Cakes: Sheet        Composite                           desserts
    Cakes            Cakes: Birthday/    Composite                           desserts
                      Celebration Layer
    Cakes            Cakes: Wedding/     Composite                           desserts
                      Designer Series
    Canned Pasta &   Can Pasta           Composite                           entree/meal
     Mwv Fd--Shlf
     Stbl
    Canned Pasta &   Microwavable Cups   Composite                           entree/meal
     Mwv Fd--Shlf     [Canned Pasta]
     Stbl
    Canned Pasta &   Microwavable Trays  Composite                           entree/meal
     Mwv Fd--Shlf     [Canned Pasta]
     Stbl
    Canned Soups     Condensed Soup      Composite                           soup
    Chilled Ready    Store Brand         Composite                           entree/meal
     Meals
    Chilled Ready    Fresh Meals         Composite                           entree/meal
     Meals
    Chilled Ready    Fresh Side Dishes   Composite                           entree/meal
     Meals
    Cnv Breakfast &  Treats              Composite                           snacks
     Wholesome Snks
    Convenient       Convenient Meals--  Composite                           entree/meal
     Meals            Adult Meal
    Convenient       Convenient Meals--  Composite                           entree/meal
     Meals            Kids Meal
    Cookie/Cracker   Multi-Pack Cookies  Composite                           desserts
     Multi-Pks
    Cookies          Chocolate Covered   Composite                           desserts
                      Cookies
    Cookies          Cookies/Sweet       Composite                           desserts
                      Goods
    Cookies          Cookies: Gourmet    Composite                           desserts
    Cookies          Cookies: Holiday/   Composite                           desserts
                      Special Occas
    Cookies          Cookies: Kosher     Composite                           desserts
    Cookies          Cookies: Less Than  Composite                           desserts
                      6
    Cookies          Cookies: Message    Composite                           desserts
    Cookies          Cookies: Party      Composite                           desserts
    Cookies          Cookies: Regular    Composite                           desserts
    Cookies          Fruit Filled        Composite                           desserts
                      Cookies
    Cookies          Premium Cookies     Composite                           desserts
                      (Ex: Pepperidge)
    Cookies          Sandwich Cookies    Composite                           desserts
    Cookies          Specialty Cookies   Composite                           desserts
    Cookies          Tray Pack/Choc      Composite                           desserts
                      Chip Cookies
    Cookies          Vanilla Wafer/Kids  Composite                           desserts
                      Cookies
    Cookies          Wellness/Portion    Composite                           desserts
                      Control [Cookies]
    Dinner Mixes--   Macaroni & Cheese   Composite                           entree/meal
     Dry              Dnrs
    Dinner Mixes--   Microwave Dinners   Composite                           entree/meal
     Dry
    Dinner Mixes--   Package Dinners     Composite                           entree/meal
     Dry              Meat Included
    Dinner Mixes--   Package Dinners W/  Composite                           entree/meal
     Dry              O Meat
    Dinner Mixes--   Package Dinners/    Composite                           entree/meal
     Dry              Pasta Salads
    Dinner Mixes--   Skillet Dinners     Composite                           entree/meal
     Dry
    Dressings/Dips   Dips Guacamole/     Composite                           snacks
                      Salsa/Queso
    Dressings/Dips   Dips Organic        Composite                           snacks
    Dressings/Dips   Dips Veggie         Composite                           snacks
    Dry Bean Veg &   Dry Beans/Peas/     Composite                           entree/meal
     Rice             Barley: Bag & B
    Dry Mix          Freeze Mixes/Pwdrs/ Composite                           desserts
     Desserts         Liquids
    Dry Mix          Misc: Cheesecake/   Composite                           desserts
     Desserts         Mousse Mixes
    Dry Mix          Pudding & Gelatin   Composite                           desserts
     Desserts         Cups/Cans
    Dry Mix          Puddings Dry        Composite                           desserts
     Desserts
    Dry/Ramen        12 Pack Soup/Case   Composite                           soup
     Bouillon         Soup/Etc.
    Dry/Ramen        Bouillon            Composite                           soup
     Bouillon
    Dry/Ramen        Dry Soup            Composite                           soup
     Bouillon
    Fitness & Diet   Fitness & Diet--    Composite                           snacks
                      Bars (Supplement)
    Fitness & Diet   Fitness & Diet--    Composite                           snacks
                      Bars W/Flour
    Fitness & Diet   Fitness & Diet--    Composite                           snacks
                      Bars W/O Flour
    Frozen Bread     Desserts            Composite                           desserts
     And Desserts
    Frozen           Donuts              Composite                           desserts
     Breakfast
    Frozen           Meals/Sandwichs     Composite                           entree/meal
     Breakfast
    Frozen           Foods Frzn          Composite                           entree/meal
     Breakfast        Breakfast Entrees
    Frozen           Foods Frzn          Composite                           entree/meal
     Breakfast        Breakfast
                      Sandwiches
    Frozen Desserts  Frozen Cakes/       Composite                           desserts
                      Desserts
    Frozen Desserts  Frozen Cream Pies   Composite                           desserts
    Frozen Desserts  Frozen Fruit Pies   Composite                           desserts
                      & Cobblers
    Frozen Desserts  Frzn                Composite                           desserts
                      Pastry&Cookies
    Frozen Desserts  Frzn Pie Shells/    Composite                           desserts
                      Pastry Shell/F
    Frozen Desserts  Single Serv/        Composite                           desserts
                      Portion Control
    Frozen Entrees   Bowls               Composite                           entree/meal
    Frozen Entrees   Meatless/           Composite                           entree/meal
                      Vegetarian
    Frozen Entrees   Pasta/Skillet       Composite                           entree/meal
                      Meals
    Frozen Entrees   Soup                Composite                           soup
    Frozen           Burritos            Composite                           entree/meal
     Handhelds &
     Snacks
    Frozen           Corn Dogs           Composite                           snacks
     Handhelds &
     Snacks
    Frozen           Sandwiches &        Composite                           entree/meal
     Handhelds &      Handhelds
     Snacks
    Frozen           Snacks/Appetizers   Composite                           snacks
     Handhelds &
     Snacks
    Frozen Ice       Almond              Composite                           desserts
     Cream &
     Novelties
    Frozen Ice       Ice Cream           Composite                           desserts
     Cream &
     Novelties
    Frozen Ice       Novelties--Dairy    Composite                           desserts
     Cream &
     Novelties
    Frozen Ice       Novelties--Non      Composite                           desserts
     Cream &          Dairy
     Novelties
    Frozen Ice       Novelties--Water    Composite                           desserts
     Cream &          Base
     Novelties
    Frozen Ice       Rice                Composite                           desserts
     Cream &
     Novelties
    Frozen Ice       Soy                 Composite                           desserts
     Cream &
     Novelties
    Frozen Ice       Yogurt/Sorbet And   Composite                           desserts
     Cream &          Kefir
     Novelties
    Frozen Juice     Smoothies--Frz      Composite                           desserts
     And Smoothies
    Frozen           Adult Premium       Composite                           desserts
     Novelties--Wat   [Frozen
     er Ice           Novelties]
    Frozen           Cones [Frozen       Composite                           desserts
     Novelties--Wat   Novelties]
     er Ice
    Frozen           Cups/Push Ups/      Composite                           desserts
     Novelties--Wat   Other [Frozen
     er Ice           Novelties]
    Frozen           Ice Cream           Composite                           desserts
     Novelties--Wat   Sandwiches
     er Ice
    Frozen           Sticks/Enrobed      Composite                           desserts
     Novelties--Wat   [Frozen
     er Ice           Novelties]
    Frozen           Water Ice [Frozen   Composite                           desserts
     Novelties--Wat   Novelties]
     er Ice
    Frozen Pizza     Meatless/           Composite                           entree/meal
                      Vegetarian
    Frozen Pizza     Pizza/Economy       Composite                           entree/meal
    Frozen Pizza     Pizza/Premium       Composite                           entree/meal
    Frozen Pizza     Pizza/Single Serve/ Composite                           entree/meal
                      Microwave
    Frozen Pizza     Pizza/Traditional   Composite                           entree/meal
    Frozen Pizza     Pizza/Value         Composite                           entree/meal
    Frozen Pizza     Single Serve        Composite                           entree/meal
    Frozen Snacks    Burritos--Meatless/ Composite                           entree/meal
     And              Vegetarian
    Frozen Snacks    Appetizers          Composite                           snacks
     And Handhelds
    Frozen Snacks    Burritos--Meat      Composite                           entree/meal
     And Handhelds    Protein
    Frozen Snacks    Wraps/Handhelds--   Composite                           entree/meal
     And Handhelds    Meat
    Frozen Snacks    Wraps/Handhelds--   Composite                           entree/meal
     And Handhelds    Meatless
    Frozen           Meals               Composite                           entree/meal
     Vegetables And
     Potatoes
    Frzn Meatless    Meatless Breakfast  Composite                           entree/meal
    Frzn Meatless    Meatless Burgers    Composite                           entree/meal
    Frzn Meatless    Meatless Entrees    Composite                           entree/meal
    Frzn Meatless    Meatless Meal       Composite                           entree/meal
                      Starters
    Frzn Meatless    Meatless            Composite                           entree/meal
                      Miscellaneous
    Frzn Meatless    Meatless Poultry    Composite                           entree/meal
    Frzn Meatless    Meatless Snacks     Composite                           snacks
    Frzn Multi       Fz Crockpots/Soups  Composite                           soup
     Serve
    Frzn Multi       Fz Family Style     Composite                           entree/meal
     Serve            Entrees
    Frzn Multi       Fz Skillet Meals    Composite                           entree/meal
     Serve
    Frzn Prepared    Fz Meal Kits/       Composite                           entree/meal
     Chicken          Stuffed/Other
    Frzn Ss Economy  Fz Ss Economy       Composite                           entree/meal
     Meals            Meals All
    Frzn Ss Premium  Fz Regional/Other   Composite                           entree/meal
     Meals
    Frzn Ss Premium  Fz Ss Prem          Composite                           entree/meal
     Meals            Nutritional Meals
    Frzn Ss Premium  Fz Ss Prem          Composite                           entree/meal
     Meals            Traditional Meals
    Gift & Fruit     Snack Packs W/Soda  Composite                           snacks
     Baskets
    Ice Cream Ice    Pails [Ice Cream &  Composite                           desserts
     Milk &           Sherbert]
     Sherbets
    Ice Cream Ice    Premium [Ice Cream  Composite                           desserts
     Milk &           & Sherbert]
     Sherbets
    Ice Cream Ice    Premium Pints [Ice  Composite                           desserts
     Milk &           Cream & Sherbert]
     Sherbets
    Ice Cream Ice    Quarts [Ice Cream   Composite                           desserts
     Milk &           & Sherbert]
     Sherbets
    Ice Cream Ice    Super Premium       Composite                           desserts
     Milk &           Pints [Ice Cream
     Sherbets         & Sherbert]
    Ice Cream Ice    Traditional [Ice    Composite                           desserts
     Milk &           Cream & Sherbert]
     Sherbets
    Kosher Foods     Kosher Snacks       Composite                           snacks
     And Products
    Kosher Foods     Kosher Soups        Composite                           soup
     And Products
    Packaged         Trail Mixes         Composite                           snacks
     Natural Snacks
    Party Tray       Deli Tray--         Composite                           entree/meal
                      Includes Non-
                      Foods
    Party Tray       Deli Tray:          Composite                           entree/meal
                      Appetizers & Hors
                      D'oe
    Party Tray       Deli Tray: Chicken  Composite                           entree/meal
    Party Tray       Deli Tray: Fruit    Composite                           entree/meal
                      And Vegetable
    Party Tray       Deli Tray: Meat     Composite                           entree/meal
                      And Cheese
    Party Tray       Deli Tray:          Composite                           entree/meal
                      Sandwiches
    Party Tray       Deli Trays: Hot     Composite                           entree/meal
    Pies             Pie Ingredients     Composite                           desserts
    Pies             Pies: Cream/        Composite                           desserts
                      Meringue
    Pies             Pies: Fruit/Nut     Composite                           desserts
    Pies             Pies: Kosher        Composite                           desserts
    Pies             Pies: Pumpkin/      Composite                           desserts
                      Custard
    Pies             Pies: Tarts/Minis/  Composite                           desserts
                      Crstdas
    Prepared/Pdgd    Boxed Prepared/     Composite                           entree/meal
     Foods            Entree/Dry Prep
    Refrgrated       Refrigerated        Composite                           desserts
     Dough Products   Cookie Dough
    Refrgrated       Refrigerated        Composite                           desserts
     Dough Products   Cookies--Brand
    Refrgrated       Refrigerated        Composite                           desserts
     Dough Products   Cookies--Seasonal
    Refrgrated       Refrigerated Pie    Composite                           desserts
     Dough Products   Crust
    Refrigerated     Refrigerated        Composite                           desserts
     Desserts         Pudding
    Restricted Diet  Cookies             Composite                           desserts
    Rts/Micro Soup/  Broth               Composite                           soup
     Broth
    Rts/Micro Soup/  Microwavable Soups  Composite                           soup
     Broth
    Rts/Micro Soup/  Rts Soup: Chunky/   Composite                           soup
     Broth            Homestyle/Et
    Salad & Dips     Sal: Desserts--     Composite                           desserts
                      Bulk
    Salad & Dips     Sal: Desserts--     Composite                           desserts
                      Prepack
    Salad Bar        Soups               Composite                           soup
    Sandwiches       Sandwich            Composite                           entree/meals
                      Ingredients
    Sandwiches       Sandwiches--(Cold)  Composite                           entree/meals
    Sandwiches       Sandwiches: Kosher  Composite                           entree/meals
                      (Cold)
    Seafood--Party   Party Tray Other    Composite                           entree/meal
     Trays
    Seafood--Party   Party Tray Other    Composite                           entree/meal
     Trays
    Seafood--Salad/  Salads              Composite                           entree/meal
     Dips/Sce/Cond
    Service Case     Side Dishes         Composite                           entree/meal
     Meat
    Service Case     Stuffed/Mixed       Composite                           entree/meal
     Meat
    Single Serve     Single Serve        Composite                           desserts
     Items            Desserts
    Single Serve     Single Serve        Composite                           snacks
     Items            Snacks
    Single Serve     Snack Cake--Single  Composite                           desserts
     Sweet Goods      Serve
    Snack            Nuts/Trail Mix/     Composite                           snacks
                      Dried Fruit
    Snack            Soy/Rice Snacks     Composite                           snacks
    Snack            Specialty Chips     Composite                           snacks
    Snacks           Snacks: Dry         Composite                           snacks
    Snacks           Snacks: Gift Packs  Composite                           snacks
    Snacks           Snacks: Salty       Composite                           snacks
    Snacks           Snacks:Chippery     Composite                           snacks
    Soup             Asceptic            Composite                           soup
    Soup             Broths              Composite                           soup
    Soup             Cans Soup/Chili     Composite                           soup
    Soup             Cups                Composite                           soup
    Ss/Vending--     Vendor Size/Single  Composite                           desserts
     Cookie/Cracker   Serve Cookie
    Ss/Vending--     Salty Snacks        Composite                           snacks
     Salty Snacks     Vending
    Ss/Vending--     Salty Snacks W/     Composite                           snacks
     Salty Snacks     Sweetener Vending
    Sushi            Sushi--In Store     Composite                           entree/meal
                      Prepared
    Sushi            Sushi--Kosher       Composite                           entree/meal
    Sushi            Sushi--Prepackaged  Composite                           entree/meal
    Sushi            Sushi: In Store     Composite                           entree/meal
                      Prepared (Hot)
    Sushi            Sushi: Ingredients  Composite                           entree/meal
    Sushi            Sushi: In-Store     Composite                           entree/meal
                      Prepared (Dine)
    Sushi            Sushi: Smallwares   Composite                           entree/meal
    Sweet Goods      Sw Gds: Kosher      Composite                           desserts
                      Breakfast
    Sweet Goods      Sw Gds: Muffins     Composite                           desserts
    Sweet Goods      Sw Gds: Sw Rolls/   Composite                           desserts
                      Dan
    Sweet Goods      Sw Gds: Coffee      Composite                           desserts
                      Cakes
    Sweet Goods      Sw Gds: Donuts      Composite                           desserts
    Sweet Goods      Sw Gds: Donuts--    Composite                           desserts
                      Less Than 6
    Sweet Goods      Sw Gds: Muffins--   Composite                           desserts
                      Lss Thn 6
    Sweet Goods      Swt Gds             Composite                           desserts
                      Ingredients
    Sweet Goods &    Sw Gds: Brownie/    Composite                           desserts
     Snacks           Bar Cookie
    Sweet Goods &    Sw Gds: Kosher      Composite                           desserts
     Snacks
    Sweet Goods &    Sw Gds: Puff        Composite                           desserts
     Snacks           Pastry
    Sweet Goods &    Sw Gds: Specialty   Composite                           desserts
     Snacks           Desserts
    Sweet Goods &    Sw Gds: Swt/Flvrd   Composite                           desserts
     Snacks           Loaves
    Traditional      Asian Foods And     Composite                           entree/meal
     Asian Foods      Meals
    Traditional      Mexican Dinners     Composite                           entree/meal
     Mexican Foods    And Foods
    Trail Mix &      Trail Mixes/Snack   Composite                           snacks
     Snacks
    Trail Mix &      Trail Mixes/Snacks  Composite                           snacks
     Snacks           Organic
    Unknown          Frozen Breakfast    Composite                           entree/meal
    Unknown          Frozen Dessert      Composite                           desserts
                      (Ice Cream Cake)
    Unknown          Frozen Entrees      Composite                           entree/meal
    Unknown          Frozen Ice Cream    Composite                           desserts
    Unknown          Frozen Side Dish    Composite                           entree/meal
    Value-Added      Parfait Cups        Composite                           desserts
     Fruit            Instore
    Warehouse        Canister Snacks     Composite                           snacks
     Snacks
    Warehouse        Misc Snacks         Composite                           snacks
     Snacks
    Warehouse        Misc Snacks W/      Composite                           snacks
     Snacks           Sweetener
    Warehouse        Snack Mix           Composite                           snacks
     Snacks
    Authentic Asian  Authentic Chinese   Other                                                    misc
     Foods            Foods
    Authentic Asian  Authentic Japanese  Other                                                    misc
     Foods            Foods
    Authentic Asian  Authentic Thai      Other                                                    misc
     Foods            Foods
    Authentic Asian  Other Authentic     Other                                                    misc
     Foods            Asian Foods
    Authentic        Caribbean Foods     Other                                                    misc
     Caribbean
     Foods
    Authentic        Central American    Other                                                    misc
     Central          Foods
     American Fds
    Authentic        Hispanic Baking     Other                                                    seasoning/baking
     Hispanic Fds &   Needs                                                                        need
     Product
    Authentic        Authentic Dry       Other                                                    unsweetened
     Hispanic Fds &   Beverages W/O                                                                beverage
     Product          Sweetener
    Authentic        Hispanic            Other                                                    condiments
     Hispanic Fds &   Condiments
     Product
    Authentic        Hispanic Spices     Other                                                    seasoning/baking
     Hispanic Fds &   And Seasonings                                                               need
     Product
    Authentic        Other Italian       Other                                                    misc
     Italian Foods    Foods
    Authentic South  South American      Other                                                    misc
     American Fds     Foods
    Baby Food        Baby Cereal         Other                                                    infant formula/
                                                                                                   baby food
    Baby Food        Baby Crackers       Other                                                    infant formula/
                                                                                                   baby food
    Baby Food        Baby Food           Other                                                    infant formula/
                                                                                                   baby food
    Baby Food        Baby Formula        Other                                                    infant formula/
                                                                                                   baby food
    Baby Food        Baby Misc           Other                                                    infant formula/
                                                                                                   baby food
    Baby Foods       Baby Food--         Other                                                    infant formula/
                      Beginner                                                                     baby food
    Baby Foods       Baby Food Cereals   Other                                                    infant formula/
                                                                                                   baby food
    Baby Foods       Baby Food Junior/   Other                                                    infant formula/
                      All Brands                                                                   baby food
    Baby Foods       Baby Juices         Other                                                    infant formula/
                                                                                                   baby food
    Baby Foods       Baby Spring Waters  Other                                                    infant formula/
                                                                                                   baby food
    Baking           Flours/Grains/      Other                                                    seasoning/baking
                      Sugar                                                                        need
    Baking           Mixes               Other                                                    seasoning/baking
                                                                                                   need
    Baking           Spices              Other                                                    seasoning/baking
                                                                                                   need
    Baking Mixes     Microwave Mixes:    Other                                                    seasoning/baking
                      All Other                                                                    need
    Baking Mixes     Miscellaneous       Other                                                    seasoning/baking
                      Package Mixes                                                                need
    Baking Needs     Baking Cocoa        Other                                                    seasoning/baking
                                                                                                   need
    Baking Needs     Baking Powder &     Other                                                    seasoning/baking
                      Soda                                                                         need
    Baking Needs     Bits & Morsels      Other                                                    seasoning/baking
                      [Baking Needs]                                                               need
    Baking Needs     Cooking Chocolate   Other                                                    seasoning/baking
                      (Ex.: Smi-Swt)                                                               need
    Baking Needs     Cooking Chocolate   Other                                                    seasoning/baking
                      Unsweetened                                                                  need
    Baking Needs     Yeast: Dry          Other                                                    seasoning/baking
                                                                                                   need
    Beverages        Tea Unsweetened     Other                                                    unsweetened
                      (Can/Bottle)                                                                 beverage
    Bulk Food        Bulk Spices         Other                                                    seasoning/baking
                                                                                                   need
    Bulk Food        Coffee & Tea Bulk   Other                                                    unsweetened
                                                                                                   beverage
    Bulk Food        Misc Bulk           Other                                                    misc
    Coffee &         Bulk Coffee         Other                                                    unsweetened
     Creamers                                                                                      beverage
    Coffee &         Coffee Pods/        Other                                                    unsweetened
     Creamers         Singles/Filter                                                               beverage
                      Pac
    Coffee &         Flavored Bag        Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee &         Flavored Can        Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee &         Flavored Instant    Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee &         Ready To Drink      Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee &         Ready To Drink      Other                                                    unsweetened
     Creamers         Coffee Suppleme                                                              beverage
    Coffee &         Specialty Instant   Other                                                    unsweetened
     Creamers         Coffee W/O S                                                                 beverage
    Coffee &         Specialty Instant   Other                                                    unsweetened
     Creamers         Coffee W/Swe                                                                 beverage
    Coffee &         Unflavored Bag      Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee &         Unflavored Can      Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee &         Unflavored Instant  Other                                                    unsweetened
     Creamers         Coffee                                                                       beverage
    Coffee Shop      Sv Bev: Inged/      Other                                                    unsweetened
                      Portion Pk                                                                   beverage
    Coffee Shop      Sv Bev: Carb Wat-   Other                                                    unsweetened
                      Flv/Unflv                                                                    beverage
    Coffee Shop      Coff Shop: Instant  Other                                                    unsweetened
     Sweet Goods &    Retail Pack                                                                  beverage
     Rtl
    Coffee Shop      Coff Shop: Retail   Other                                                    unsweetened
     Sweet Goods &    Pack Beverag                                                                 beverage
     Rtl
    Coffee Shop      Coff Shop: Whole    Other                                                    unsweetened
     Sweet Goods &    Bean Retail P                                                                beverage
     Rtl
    Condiments       Ketchup/Mustard/    Other                                                    condiments
                      Bbq Sce/Marina
    Condiments       Oils/Vinegar        Other                                                    condiments
    Condiments       Pickles/Olives/     Other                                                    condiments
                      Kraut
    Condiments &     Bbq Sauce           Other                                                    condiments
     Sauces
    Condiments &     Catsup              Other                                                    condiments
     Sauces
    Condiments &     Chili Sauce/        Other                                                    condiments
     Sauces           Cocktail Sauce
    Condiments &     Hot Sauce           Other                                                    condiments
     Sauces
    Condiments &     Marinades           Other                                                    condiments
     Sauces
    Condiments &     Misc Meat Sauces    Other                                                    condiments
     Sauces
    Condiments &     Mustard--All Other  Other                                                    condiments
     Sauces
    Condiments &     Steak & Worchester  Other                                                    condiments
     Sauces           Sauce
    Condiments &     Wing Sauce          Other                                                    condiments
     Sauces
    Condiments &     Yellow Mustard      Other                                                    condiments
     Sauces
    Deli             Dl Spec: Beverages  Other                                                    unsweetened
     Specialties                                                                                   beverage
     (Retail Pk)
    Deli             Dl Spec: Must/Oils/ Other                                                    condiments
     Specialties      Vinegars
     (Retail Pk)
    Deli/Bakery      Deli/Bakery         Other                                                    misc
     Discontnued      Discontinued
     Items            Items
    Dietary Aid      Diet Cntrl Liqs     Other                                                    supplements/meal
     Prdct/Med Liq    Supplement                                                                   replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Cntrl Powders  Other                                                    supplements/meal
     Prdct/Med Liq    Nutritional                                                                  replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Control Water  Other                                                    supplements/meal
     Prdct/Med Liq                                                                                 replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Cntrl Bars     Other                                                    supplements/meal
     Prdct/Med Liq    (Supplement)                                                                 replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Cntrl Bars     Other                                                    supplements/meal
     Prdct/Med Liq    Nutritional                                                                  replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Cntrl Bars     Other                                                    supplements/meal
     Prdct/Med Liq    Nutritional W/                                                               replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Cntrl Liqs     Other                                                    supplements/meal
     Prdct/Med Liq    Nutritional                                                                  replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Diet Energy Drinks  Other                                                    supplements/meal
     Prdct/Med Liq                                                                                 replacements/
     Nutr                                                                                          energy drinks
    Dietary Aid      Powder Nutrition    Other                                                    supplements/meal
     Prdct/Med Liq    Products                                                                     replacements/
     Nutr                                                                                          energy drinks
    Dry Mix          Desserts Gelatin    Other                                                    seasoning/baking
                                                                                                   need
    Dry Tea/Coffee/  Coffee Ground       Other                                                    unsweetened
     Coco Mixes                                                                                    beverage
    Dry Tea/Coffee/  Coffee Whole Bean   Other                                                    unsweetened
     Coco Mixes                                                                                    beverage
    Dry Tea/Coffee/  Tea Bags            Other                                                    unsweetened
     Coco Mixes       (Supplement)                                                                 beverage
    Dry Tea/Coffee/  Tea Dry             Other                                                    unsweetened
     Coco Mixes                                                                                    beverage
    Dry Sauce/Gravy/ Cooking Bags With   Other                                                    seasoning/baking
     Potatoes/        Spices/Seaso                                                                 need
     Stuffing
    Dry Sauce/Gravy/ Gravy Can/Glass     Other                                                    seasoning/baking
     Potatoes/                                                                                     need
     Stuffing
    Dry Sauce/Gravy/ Sauce Mixes/Gravy   Other                                                    seasoning/baking
     Potatoes/        Mixes Dry                                                                    need
     Stuffing
    Eggs/Muffins/    Misc Dairy          Other                                                    misc
     Potatoes         Refigerated
    Enhancements     Enhancements--Othe  Other                                                    supplements/meal
                      r                                                                            replacements/
                                                                                                   energy drinks
    Enhancements     Enhancements--Pick  Other                                                    condiments
                      led Items
    Enhancements     Enhancements--Pick  Other                                                    condiments
                      les/Kraut
    Enhancements     Enhancements--Sala  Other                                                    condiments
                      ds/Spreads
    Enhancements     Enhancements--Spic  Other                                                    seasoning/baking
                      es/Sauces                                                                    need
    European Foods   British Foods       Other                                                    misc
    European Foods   French Foods        Other                                                    misc
    European Foods   German Foods        Other                                                    misc
    European Foods   Mediterranean/      Other                                                    misc
                      Greek Foods
    European Foods   Other Ethnic Foods  Other                                                    misc
    European Foods   Polish Foods        Other                                                    misc
    European Foods   Scandinavian Foods  Other                                                    misc
    Fitness & Diet   Fitness & Diet      Other                                                    supplements/meal
                      Energy Drinks F/S                                                            replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness & Diet      Other                                                    supplements/meal
                      Energy Drinks Non                                                            replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness & Diet      Other                                                    supplements/meal
                      Isotonic Drinks                                                              replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness & Diet      Other                                                    supplements/meal
                      Isotonic Drinks                                                              replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness & Diet--    Other                                                    supplements/meal
                      Liq (Supplement)                                                             replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness & Diet--    Other                                                    supplements/meal
                      Liq Ntrtnl                                                                   replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness & Diet--    Other                                                    supplements/meal
                      Powder                                                                       replacements/
                      (Supplement)                                                                 energy drinks
    Fitness & Diet   Fitness & Diet--    Other                                                    supplements/meal
                      Powder Ntrtnl                                                                replacements/
                                                                                                   energy drinks
    Fitness & Diet   Fitness/Diet--Meal  Other                                                    supplements/meal
                      Replacement                                                                  replacements/
                                                                                                   energy drinks
    Frozen Ethnic    Frozen              Other                                                    misc
                      Internaional
    Frozen Ethnic    Frozen Kosher       Other                                                    misc
    Frozen Meat      Alternatives Micro  Other                                                    supplements/meal
                      Protein                                                                      replacements/
                                                                                                   energy drinks
    Frzn Multi       Frozen Other        Other                                                    misc
     Serve
    Gift & Fruit     Gift Baskets W/     Other                                                    misc
     Baskets          Food
    Gift & Fruit     Snack Packs W/Food  Other                                                    misc
     Baskets
    Indian Foods     Authentic Indian    Other                                                    misc
                      Foods
    Infant Formula   Baby Isotonic       Other                                                    infant formula/
                      Drinks                                                                       baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Concentrate                                                                  baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Milk Base                                                                    baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Ready To Use                                                                 baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Solutions Large                                                              baby food
    Infant Formula   Infant Formula Soy  Other                                                    infant formula/
                      Base                                                                         baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Specialty                                                                    baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Starter Large Pk                                                             baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Starter/Solution                                                             baby food
    Infant Formula   Infant Formula      Other                                                    infant formula/
                      Toddler                                                                      baby food
    Infant Formula   Infant Formula Up   Other                                                    infant formula/
                      Age                                                                          baby food
    Isotonic Drinks  Isotonic Drinks     Other                                                    supplements/meal
                      Multi-Pack                                                                   replacements/
                                                                                                   energy drinks
    Isotonic Drinks  Isotonic Drinks     Other                                                    supplements/meal
                      Multi-Serve                                                                  replacements/
                                                                                                   energy drinks
    Isotonic Drinks  Isotonic Drinks     Other                                                    supplements/meal
                      Powdered                                                                     replacements/
                                                                                                   energy drinks
    Isotonic Drinks  Isotonic Drinks     Other                                                    supplements/meal
                      Single Serve                                                                 replacements/
                                                                                                   energy drinks
    Isotonic Drinks  Sports Bars         Other                                                    supplements/meal
                                                                                                   replacements/
                                                                                                   energy drinks
    Isotonic Drinks  Sports Drink N/     Other                                                    supplements/meal
                      Supplmnt Milk                                                                replacements/
                                                                                                   energy drinks
    Isotonic Drinks  Sports Drink        Other                                                    supplements/meal
                      Supplement                                                                   replacements/
                                                                                                   energy drinks
    Juices Super     Juices Antioxidant/ Other                                                    supplements/meal
     Premium          Wellness                                                                     replacements/
                                                                                                   energy drinks
    Juices Super     Juices Proteins     Other                                                    supplements/meal
     Premium                                                                                       replacements/
                                                                                                   energy drinks
    Kosher           Exotic [Kosher      Other                                                    misc
                      Foods]
    Kosher           Further Prepared    Other                                                    misc
    Kosher Foods     Kosher Baking       Other                                                    seasoning/baking
     And Products     Needs                                                                        need
    Kosher Foods     Kosher Condiments   Other                                                    condiments
     And Products
    Kosher Foods     Passover Products   Other                                                    misc
     And Products
    Mediterranean    Sal: Olives/        Other                                                    condiments
     Bar              Pickles--Bulk
    Mediterranean    Sal: Olives/        Other                                                    condiments
     Bar              Pickles--Bulk
    Mediterranean    Sal: Olives/        Other                                                    condiments
     Bar              Pickls--Prpck
    Mediterranean    Sal: Olives/        Other                                                    condiments
     Bar              Pickls--Prpck
    Mixers           Margarita Salt/     Other                                                    condiments
                      Sugar/Misc
    Multicultural    Asian Processed     Other                                                    misc
     Products
    Multicultural    Hispanic Processed  Other                                                    misc
     Products         Produce
    Non-Dairy/Dairy  Aseptic Soy/Rice    Other                                                    misc
                      Powder
    Pickle/Relish/   Green Olives        Other                                                    condiments
     Pckld Veg &
     Olives
    Pickle/Relish/   Peppers             Other                                                    condiments
     Pckld Veg &
     Olives
    Pickle/Relish/   Pickld Veg/Peppers/ Other                                                    condiments
     Pckld Veg &      Etc.
     Olives
    Pickle/Relish/   Relishes            Other                                                    condiments
     Pckld Veg &
     Olives
    Pickle/Relish/   Ripe Olives         Other                                                    condiments
     Pckld Veg &
     Olives
    Pickle/Relish/   Specialty Olives    Other                                                    condiments
     Pckld Veg &
     Olives
    Powder &         Sugar Free          Other                                                    unsweetened
     Crystal Drink    Canister [Powder                                                             beverage
     Mix              Drink Mix]
    Powder &         Sugar Free Sticks   Other                                                    unsweetened
     Crystal Drink    [Powder Drink                                                                beverage
     Mix              Mix]
    Powder &         Tea                 Other                                                    unsweetened
     Crystal Drink                                                                                 beverage
     Mix
    Powder &         Unsweetened         Other                                                    unsweetened
     Crystal Drink    Envelope [Powder                                                             beverage
     Mix              Drink Mix]
    Prepared/Pdgd    Prepared/Pkgd Food  Other                                                    misc
     Foods            Misc
    Processed        Packaged Dry Mixes  Other                                                    misc
    Processed        Processed Other     Other                                                    misc
    Refrgratd        Dairy Case Tea No   Other                                                    unsweetened
     Juices/Drinks    Sugar Or Swe                                                                 beverage
    Refrigerated     Non-Dairy Milks     Other                                                    misc
     Dairy Case
    Refrigerated     Tea W/O Sweetener/  Other                                                    unsweetened
     Dairy Case       Sugar                                                                        beverage
    Refrigerated     Misc: Herring/      Other                                                    condiments
     Grocery          Pickles/Horserad
    Refrigerated     Refrigerated        Other                                                    misc
     Grocery          Kosher Products
    Refrigerated     Hispanic Cultured   Other                                                    misc
     Hispanic         Products
     Grocery
    Refrigerated     Misc Hispanic       Other                                                    misc
     Hispanic         Grocery
     Grocery
    Refrigerated     Refrigerated        Other                                                    misc
     Hispanic         Hispanic Drinks
     Grocery
    Refrigerated     Vegetarian Misc     Other                                                    misc
     Vegetarian
    Restricted Diet  Baking              Other                                                    seasoning/baking
                                                                                                   need
    Restricted Diet  Beverage            Other                                                    supplements/meal
                                                                                                   replacements/
                                                                                                   energy drinks
    Restricted Diet  Breakfast Foods     Other                                                    supplements/meal
                                                                                                   replacements/
                                                                                                   energy drinks
    Restricted Diet  Diet Bars/Diet      Other                                                    supplements/meal
                      Liquid Meals                                                                 replacements/
                                                                                                   energy drinks
    Restricted Diet  Misc Diet           Other                                                    supplements/meal
                                                                                                   replacements/
                                                                                                   energy drinks
    Rtd Tea/New Age  Sparkling Tea       Other                                                    unsweetened
     Juice                                                                                         beverage
    Rtd Tea/New Age  Tea Unsweetened     Other                                                    unsweetened
     Juice                                                                                         beverage
    Salad & Dips     Sal: Kosher         Other                                                    misc
    Salad & Dips     Sal:Dip Prepack     Other                                                    condiments
    Salad Bar        Condiments/         Other                                                    condiments
                      Supplies
    Salad Bar        Salad Bar Other     Other                                                    misc
    Salad Dresing &  Dry Salad Dressing  Other                                                    condiments
     Sandwich         & Dip Mixes
     Spreads
    Seafood--Salad/  Dips/Spreads        Other                                                    condiments
     Dip/Sce/Cond
    Seafood--Salad/  Sauces              Other                                                    condiments
     Dip/Sce/Cond
    Seafood--Salad/  Other Pkgd Dip/     Other                                                    condiments
     Dips/Sce/Cond    Sauce/Condiment
    Seafood--Salad/  Sauces              Other                                                    condiments
     Dips/Sce/Cond
    Seafood--Salad/  Spices/Marinades    Other                                                    condiments
     Dips/Sce/Cond
    Service          Sv Bev: Coffee      Other                                                    unsweetened
     Beverage                                                                                      beverage
    Service          Sv Bev: Flav Tea    Other                                                    unsweetened
     Beverage         Products                                                                     beverage
    Service          Sv Bev: N/Carb Flv  Other                                                    unsweetened
     Beverage         Frk/Minwtr                                                                   beverage
    Service          Sv Bev: Spring      Other                                                    unsweetened
     Beverage         Water                                                                        beverage
    Shelf Stable     Tea Bottles         Other                                                    unsweetened
     Juice                                                                                         beverage
    Soft Drinks      Club Soda           Other                                                    unsweetened
                                                                                                   beverage
    Soft Drinks      Misc Items For      Other                                                    unsweetened
                      Soft Drinks                                                                  beverage
    Soft Drinks      Seltzer Unflavored  Other                                                    unsweetened
                                                                                                   beverage
    Soft Drinks      Unswntd Flavored    Other                                                    unsweetened
                      Seltzer Water                                                                beverage
    Spices &         Food Colorings      Other                                                    seasoning/baking
     Extracts                                                                                      need
    Spices &         Gourmet Spices      Other                                                    seasoning/baking
     Extracts                                                                                      need
    Spices &         Imitation Extracts  Other                                                    seasoning/baking
     Extracts                                                                                      need
    Spices &         Pure Extracts       Other                                                    seasoning/baking
     Extracts                                                                                      need
    Spices &         Salt Substitutes    Other                                                    seasoning/baking
     Extracts                                                                                      need
    Spices &         Spices &            Other                                                    seasoning/baking
     Extracts         Seasonings                                                                   need
    Spices &         Table Salt/Popcorn  Other                                                    seasoning/baking
     Extracts         Salt/Ice Cr                                                                  need
    Spices &         Traditional Spices  Other                                                    seasoning/baking
     Extracts                                                                                      need
    Spices/Jarred    Spices &            Other                                                    seasoning/baking
     Garlic           Seasonings                                                                   need
    Spices/Jarred    Spices &            Other                                                    seasoning/baking
     Garlic           Seasonings                                                                   need
                      Organic
    Teas             Bulk Tea            Other                                                    unsweetened
                                                                                                   beverage
    Teas             Instant Tea & Tea   Other                                                    unsweetened
                      Mix                                                                          beverage
    Teas             Supplemental Tea    Other                                                    unsweetened
                                                                                                   beverage
    Teas             Tea Bags & Bulk     Other                                                    unsweetened
                      Tea                                                                          beverage
    Teas             Tea Bags/Chai       Other                                                    unsweetened
                                                                                                   beverage
    Teas             Tea Bags/Green      Other                                                    unsweetened
                                                                                                   beverage
    Teas             Tea Bags/Herbal     Other                                                    unsweetened
                                                                                                   beverage
    Traditional      Asian Other Sauces/ Other                                                    seasoning/baking
     Asian Foods      Marinad                                                                      need
    Traditional      Asian Soy Sauce     Other                                                    seasoning/baking
     Asian Foods                                                                                   need
    Traditional      Traditional Thai    Other                                                    misc
     Asian Foods      Foods
    Traditional      Mexican Seasoning   Other                                                    seasoning/baking
     Mexican Foods    Mixes                                                                        need
    Traditional      Mexican Taco Sauce  Other                                                    condiments
     Mexican Foods
    Unknown          Frozen Misc         Other                                                    misc
    Vinegar &        Cooking Wines       Other                                                    seasoning/baking
     Cooking Wines                                                                                 need
    Vinegar &        Specialty Vinegar   Other                                                    seasoning/baking
     Cooking Wines                                                                                 need
    Vinegar &        Vinegar/White &     Other                                                    seasoning/baking
     Cooking Wines    Cider                                                                        need
    Water            Carb Water Unflvrd  Other                                                    unsweetened
                                                                                                   beverage
    Water            Carb Water--Flvrd   Other                                                    unsweetened
                      Unsweetened                                                                  beverage
    Water            Fortified/Water     Other                                                    unsweetened
                                                                                                   beverage
    Water            Non-Carb Water      Other                                                    unsweetened
                      Flvr--Drnk/Mnr                                                               beverage
    Water            Non-Carb Water      Other                                                    unsweetened
                      Flvr--Unsweetened                                                            beverage
    Water--(Sparkli  Distilled Water     Other                                                    unsweetened
     ng & Still)                                                                                   beverage
    Water--(Sparkli  Sparkling Water--   Other                                                    unsweetened
     ng & Still)      Flvrd Sweet                                                                  beverage
    Water--(Sparkli  Sparkling Water--   Other                                                    unsweetened
     ng & Still)      Flvrd Unsweetened                                                            beverage
    Water--(Sparkli  Sparkling Water--   Other                                                    unsweetened
     ng & Still)      Unflavored                                                                   beverage
    Water--(Sparkli  Spring Water        Other                                                    unsweetened
     ng & Still)                                                                                   beverage
    Water--(Sparkli  Still Water         Other                                                    unsweetened
     ng & Still)      Drnking/Mnrl                                                                 beverage
                      Water
    Water--(Sparkli  Still Water Flvrd   Other                                                    unsweetened
     ng & Still)      Drnk/Mnrl Wt                                                                 beverage
    Water--(Sparkli  Still Water Flvrd   Other                                                    unsweetened
     ng & Still)      Unsweetened                                                                  beverage
    Water--(Sparkli  Water--Supplies     Other                                                    unsweetened
     ng & Still)                                                                                   beverage
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.

    Appendix D. Top 100 Subcommodities for SNAP Households By Expenditure
            for Each USDA Food Pattern Category

                                                   Exhibit D-1: Dairy
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
         Dairy                                      ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $191.1        33.25%  1          $853.8        25.69%  1       $1,044.9        26.80%
     White Only
    Shredded        2           $74.7        13.00%  2          $342.0        10.29%  2         $416.7        10.69%
     Cheese
    American        3           $44.1         7.67%  4          $136.6         4.11%  4         $180.7         4.63%
     Single Cheese
    Natural Cheese  4           $35.3         6.14%  3          $216.1         6.50%  3         $251.4         6.45%
     Chunks
    Bagged Cheese   5           $17.1         2.98%  16          $52.0         1.56%  15         $69.1         1.77%
     Snacks
    Flavored Milk   6           $16.0         2.78%  14          $59.4         1.79%  12         $75.4         1.93%
    String Cheese   7           $15.1         2.63%  9           $99.0         2.98%  8         $114.1         2.93%
    Yogurt/Kids     8           $14.0         2.44%  20          $42.4         1.28%  17         $56.5         1.45%
    Cottage Cheese  9           $13.9         2.42%  7          $108.8         3.27%  6         $122.7         3.15%
    Natural Cheese  10          $13.4         2.33%  6          $113.2         3.41%  5         $126.6         3.25%
     Slices
    Yogurt/Ss       11          $11.0         1.91%  11          $69.0         2.07%  11         $79.9         2.05%
     Regular
    Loaf Cheese     12          $10.9         1.90%  23          $38.1         1.15%  21         $49.1         1.26%
    Yogurt/Ss       13          $10.2         1.78%  8          $103.1         3.10%  9         $113.3         2.91%
     Light
    Yogurt/Pro      14           $7.4         1.29%  13          $63.5         1.91%  13         $70.9         1.82%
     Active Health
    Yogurt/Adult    15           $7.2         1.25%  19          $42.5         1.28%  20         $49.7         1.28%
     Multi-Packs
    Specialty/      16           $6.7         1.17%  17          $48.4         1.46%  18         $55.1         1.41%
     Lactose Free
     Milk
    Grated Cheese   17           $6.2         1.08%  25          $33.6         1.01%  24         $39.9         1.02%
    Bulk Semi-Hard  18           $6.1         1.05%  18          $44.0         1.32%  19         $50.1         1.28%
     [Cheese]
    Fluid Milk      19           $5.9         1.02%  5          $113.3         3.41%  7         $119.2         3.06%
    Canned Milk     20           $5.5         0.96%  27          $27.9         0.84%  26         $33.4         0.86%
    Yogurt/         21           $5.0         0.86%  10          $77.4         2.33%  10         $82.4         2.11%
     Specialty
     Greek
    Half & Half     22           $4.4         0.77%  15          $54.6         1.64%  16         $59.1         1.52%
    Yogurt/Large    23           $4.4         0.76%  22          $40.4         1.22%  23         $44.8         1.15%
     Size (16oz Or
     Lar)
    Miscellaneous   24           $3.8         0.67%  21          $42.1         1.27%  22         $45.9         1.18%
     Cheese
    Bulk Processed  25           $3.4         0.59%  29          $19.8         0.60%  29         $23.2         0.59%
     [Cheese]
    Yogurt          26           $3.2         0.56%  12          $67.0         2.02%  14         $70.2         1.80%
    Bulk Semi-Soft  27           $3.0         0.53%  28          $23.3         0.70%  28         $26.3         0.68%
     [Cheese]
    Egg Nog/Boiled  28           $2.7         0.47%  39          $13.3         0.40%  35         $16.0         0.41%
     Custard
    Buttermilk      29           $2.4         0.42%  33          $15.9         0.48%  31         $18.3         0.47%
    Organic Milk    30           $2.0         0.34%  24          $35.4         1.06%  25         $37.3         0.96%
    Ricotta Cheese  31           $1.9         0.33%  34          $15.6         0.47%  32         $17.5         0.45%
    Aerosol Cheese  32           $1.8         0.31%  54           $5.2         0.16%  51          $7.0         0.18%
    Hispanic        33           $1.7         0.29%  50           $6.9         0.21%  45          $8.6         0.22%
     Cheese
    Specialty Ppk   34           $1.5         0.27%  26          $28.7         0.86%  27         $30.2         0.78%
     Cheese Hard/
     Grat
    Aseptic Milk    35           $1.4         0.24%  38          $13.6         0.41%  38         $15.0         0.38%
    Misc Dry        36           $1.4         0.24%  46           $7.3         0.22%  44          $8.7         0.22%
     Cheese
    Soy Milk        37           $1.3         0.22%  49           $7.1         0.22%  47          $8.4         0.22%
    Specialty Ppk   38           $1.2         0.21%  31          $16.2         0.49%  33         $17.5         0.45%
     Cheese
     Spreads
    Mexican Con     39           $1.2         0.21%  63           $3.1         0.09%  61          $4.3         0.11%
     Queso
    Specialty Ppk   40           $1.2         0.20%  30          $18.5         0.56%  30         $19.6         0.50%
     Cheese Feta
    Pre-Sliced      41           $1.1         0.20%  35          $14.4         0.43%  36         $15.5         0.40%
     Semi-Soft
     [Cheese]
    Pre-Sliced      42           $1.0         0.18%  36          $14.3         0.43%  37         $15.3         0.39%
     Semi-Hard
     [Cheese]
    Specialty Ppk   43           $0.9         0.15%  32          $16.2         0.49%  34         $17.1         0.44%
     Cheese
     Mozzarell
    Specialty Ppk   44           $0.8         0.15%  52           $6.0         0.18%  52          $6.8         0.17%
     Cheese
     Processed
    Yogurt/Adult    45           $0.8         0.14%  60           $3.8         0.12%  60          $4.7         0.12%
     Drinks
    Specialty Ppk   46           $0.8         0.14%  37          $13.9         0.42%  39         $14.7         0.38%
     Cheese
     Cheddar & C
    Soy Beverage    47           $0.7         0.12%  53           $5.3         0.16%  54          $6.0         0.15%
    Specialty Ppk   48           $0.6         0.10%  40          $11.4         0.34%  40         $12.0         0.31%
     Cheese Semi
     Soft
    Specialty Ppk   49           $0.6         0.10%  42          $10.8         0.32%  41         $11.4         0.29%
     Cheese Soft &
     Ripe
    Specialty Ppk   50           $0.6         0.10%  41          $10.8         0.33%  42         $11.4         0.29%
     Cheese Blue/
     Gorg
    Non Fat Dry     51           $0.6         0.10%  55           $5.2         0.16%  55          $5.7         0.15%
     Milk
    Kefir           52           $0.6         0.10%  48           $7.2         0.22%  48          $7.8         0.20%
    Specialty Ppk   53           $0.5         0.09%  68           $1.5         0.05%  68          $2.0         0.05%
     Cheese
     Hispanic
    Specialty Ppk   54           $0.5         0.08%  44           $8.0         0.24%  46          $8.5         0.22%
     Cheese Gouda
     & Eda
    Specialty Ppk   55           $0.5         0.08%  43          $10.4         0.31%  43         $10.9         0.28%
     Cheese Goat
     Milk
                   -------------------------------------------------------------------------------------------------
      Total Dairy              $571.2        99.37%           $3,989.3        98.04%          $4,767.6        98.22%
       Expenditure
       s * Among
       Top 1,000
       Subcommodit
       ies
                   =================================================================================================
        Total                  $574.9          100%           $3,323.6          100%          $3,898.5          100%
         Dairy
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Only 55 dairy subcommodities among the top 1,000 subcommodities.

                                                   Exhibit D-2: Fruit
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
         Fruit                                      ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Dairy Case      1           $43.5        10.18%  1          $269.0         9.35%  1         $312.6         9.46%
     100% Pure
     Juice--O
    Bananas         2           $34.2         8.00%  2          $242.7         8.43%  2         $276.9         8.38%
    Strawberries    3           $23.5         5.48%  3          $178.4         6.20%  3         $201.9         6.11%
    Fruit Snacks    4           $17.6         4.13%  17          $43.2         1.50%  12         $60.8         1.84%
    Grapes Red      5           $15.8         3.70%  4          $121.7         4.23%  4         $137.5         4.16%
    Grapes White    6           $15.5         3.61%  6           $84.9         2.95%  5         $100.4         3.04%
    Apple Juice &   7           $13.3         3.11%  14          $45.8         1.59%  13         $59.0         1.79%
     Cider (Over
     50%)
    Instore Cut     8           $13.2         3.09%  5           $85.8         2.98%  6          $99.0         3.00%
     Fruit
    Oranges Navels  9           $12.6         2.94%  8           $79.3         2.75%  7          $91.8         2.78%
     All
    Fruit Cup       10          $10.6         2.47%  19          $42.7         1.49%  14         $53.3         1.61%
    Blended Juice   11           $9.3         2.17%  29          $29.6         1.03%  24         $38.9         1.18%
     &
     Combinations
     (Ov)
    Clementines     12           $8.8         2.06%  9           $78.6         2.73%  8          $87.5         2.65%
    Melons Instore  13           $8.2         1.93%  18          $42.8         1.49%  17         $51.1         1.55%
     Cut
    Watermelon      14           $7.9         1.84%  16          $43.9         1.53%  16         $51.8         1.57%
     Seedless
     Whole
    Cherries Red    15           $6.9         1.61%  11          $56.7         1.97%  11         $63.6         1.93%
    Apples Gala     16           $6.6         1.54%  10          $69.3         2.41%  10         $75.9         2.30%
     (Bulk & Bag)
    Cranapple/Cran  17           $6.1         1.43%  31          $27.3         0.95%  29         $33.4         1.01%
     Grape Juice
     (50)
    Apples Red      18           $5.8         1.35%  23          $35.2         1.22%  20         $41.0         1.24%
     Delicious
     (Bulk & Bag)
    Dairy Case      19           $5.4         1.26%  25          $32.3         1.12%  26         $37.7         1.14%
     100% Pure
     Juice Oth
    Cantaloupe      20           $5.3         1.24%  15          $44.4         1.54%  18         $49.7         1.50%
     Whole
    Blueberries     21           $5.1         1.19%  7           $79.4         2.76%  9          $84.5         2.56%
    Pineapple       22           $4.9         1.15%  33          $24.0         0.83%  33         $28.9         0.87%
    Peaches Yellow  23           $4.8         1.13%  22          $35.6         1.24%  21         $40.5         1.22%
     Flesh
    Grape Juice     24           $4.8         1.12%  44          $17.1         0.60%  41         $21.9         0.66%
     (Over 50%
     Juice)
    Lemons          25           $4.6         1.08%  24          $33.6         1.17%  25         $38.2         1.16%
    Peaches         26           $4.6         1.07%  39          $21.3         0.74%  35         $25.9         0.78%
    Apples Granny   27           $4.4         1.03%  27          $30.9         1.07%  28         $35.3         1.07%
     Smith (Bulk &
     Bag)
    Frozen Fruit    28           $4.3         1.01%  12          $48.6         1.69%  15         $52.9         1.60%
    Applesauce Cup  29           $4.1         0.95%  35          $22.6         0.79%  34         $26.7         0.81%
    Non-Carb Jce    30           $3.8         0.88%  26          $31.7         1.10%  27         $35.4         1.07%
     (Over 50%
     Jce)
    Raspberries     31           $3.5         0.83%  13          $45.8         1.59%  19         $49.3         1.49%
    Grapes Black/   32           $3.4         0.80%  37          $21.8         0.76%  37         $25.2         0.76%
     Blue
    Fruit Cocktail/ 33           $3.4         0.79%  54          $12.5         0.43%  52         $15.8         0.48%
     Fruit Salad
    Mixed Fruit     34           $3.2         0.75%  79           $5.7         0.20%  73          $8.9         0.27%
     Bags
    Jarred Fruit    35           $3.1         0.73%  49          $14.6         0.51%  47         $17.7         0.54%
     Single Serve
    Raisins         36           $2.9         0.69%  32          $26.0         0.90%  32         $28.9         0.87%
    Apples Other    37           $2.8         0.66%  30          $27.4         0.95%  31         $30.2         0.91%
     (Bulk & Bag)
    Apples Fuji     38           $2.8         0.65%  21          $36.2         1.26%  23         $39.0         1.18%
     (Bulk & Bag)
    Apples Gold     39           $2.8         0.65%  43          $17.9         0.62%  43         $20.7         0.62%
     Delicious
     (Bulk & Bag)
    Blackberries    40           $2.7         0.63%  28          $29.9         1.04%  30         $32.6         0.99%
    Limes           41           $2.7         0.62%  34          $22.7         0.79%  36         $25.3         0.77%
    Nectarines      42           $2.5         0.60%  42          $18.6         0.64%  42         $21.1         0.64%
     Yellow Flesh
    Pineapple       43           $2.5         0.59%  36          $22.1         0.77%  38         $24.6         0.75%
     Whole & Peel/
     Cored
    Apples          44           $2.4         0.57%  20          $36.9         1.28%  22         $39.4         1.19%
     Honeycrisp
    Grapefruit      45           $2.4         0.56%  40          $21.2         0.74%  39         $23.6         0.71%
    Plums           46           $2.4         0.56%  52          $13.1         0.46%  53         $15.5         0.47%
    Mandarin        47           $2.3         0.53%  53          $12.6         0.44%  54         $14.8         0.45%
     Oranges/
     Citrus Sect
    Frzn Conc       48           $2.2         0.52%  57          $10.1         0.35%  56         $12.3         0.37%
     Allieds Over
     50% Jui
    Mango           49           $2.2         0.52%  50          $14.1         0.49%  50         $16.3         0.49%
    Apple Sauce     50           $2.2         0.51%  51          $13.8         0.48%  51         $16.0         0.48%
     (Excludes
     Cup)
    Tangerines &    51           $2.1         0.49%  55          $11.3         0.39%  55         $13.4         0.41%
     Tangelos
    Frzn Oj & Oj    52           $1.9         0.44%  45          $16.2         0.56%  45         $18.1         0.55%
     Substitutes
     (Over 5)
    Watermelon      53           $1.9         0.44%  46          $15.9         0.55%  46         $17.8         0.54%
     Personal
    Bananas         54           $1.9         0.44%  41          $18.7         0.65%  44         $20.6         0.62%
     Organic
    Pears           55           $1.9         0.43%  59          $10.0         0.35%  58         $11.8         0.36%
    Convenience/    56           $1.8         0.41%  64           $9.4         0.33%  60         $11.2         0.34%
     Snacking
     Fruit Pro
    Cranberry       57           $1.7         0.39%  58          $10.0         0.35%  59         $11.6         0.35%
     Sauce
    Strawberries    58           $1.6         0.38%  38          $21.4         0.74%  40         $23.0         0.70%
     Organic
    Cut Fruit All   59           $1.6         0.38%  69           $8.5         0.29%  65         $10.1         0.31%
     Other Prepack
    Caramel/Candy   60           $1.6         0.36%  94           $3.4         0.12%  84          $4.9         0.15%
     Apples
    Pears Bartlett  61           $1.5         0.35%  47          $15.7         0.55%  48         $17.2         0.52%
    Fruit Party     62           $1.4         0.33%  74           $6.5         0.23%  75          $7.9         0.24%
     Tray Prepack
    Dried Fruit--   63           $1.4         0.33%  48          $15.6         0.54%  49         $17.0         0.51%
     Other
    Pineapple       64           $1.4         0.33%  75           $6.4         0.22%  76          $7.8         0.24%
     Juice (Over
     50% Juic)
    Cranberry       65           $1.4         0.32%  70           $8.4         0.29%  69          $9.8         0.30%
     Juice (Over
     50% Jce)
    Lemon Juice &   66           $1.2         0.29%  72           $7.8         0.27%  72          $9.0         0.27%
     Lime Juice
     (Over)
    Oranges Non     67           $1.2         0.28%  81           $5.0         0.18%  80          $6.2         0.19%
     Navel All
    Prune Juice     68           $1.2         0.27%  71           $8.3         0.29%  71          $9.5         0.29%
     (Over 50%
     Juice)
    Drinks--Carb    69           $1.1         0.26%  61           $9.7         0.34%  62         $10.8         0.33%
     Juice (Over
     50%)
    Juice Single    70           $1.1         0.26%  66           $9.4         0.33%  63         $10.5         0.32%
     Blend
    Pears Anjou     71           $1.1         0.26%  60           $9.8         0.34%  61         $10.9         0.33%
    Kiwi Fruit      72           $1.0         0.24%  73           $7.0         0.24%  74          $8.0         0.24%
    Dried Plums     73           $1.0         0.24%  56          $11.0         0.38%  57         $12.0         0.36%
    Cherries        74           $1.0         0.23%  68           $9.0         0.31%  68         $10.0         0.30%
     Ranier
    Cranapple/Cran  75           $0.9         0.21%  77           $6.3         0.22%  77          $7.2         0.22%
     Grape Juice
     (Ov)
    Juice (Over     76           $0.9         0.21%  100          $2.7         0.09%  98          $3.6         0.11%
     50% Juice)
    Watermelon W/   77           $0.9         0.20%  98           $3.0         0.11%  93          $3.9         0.12%
     Seeds Whole
    Honeydew Whole  78           $0.8         0.18%  78           $5.9         0.21%  79          $6.7         0.20%
    Grapes Red      79           $0.8         0.18%  92           $3.5         0.12%  91          $4.2         0.13%
     Globe
    Pomegranates    80           $0.7         0.17%  85           $4.3         0.15%  83          $5.0         0.15%
    Grapes Other    81           $0.7         0.17%  89           $3.8         0.13%  89          $4.6         0.14%
    Maraschino      82           $0.7         0.17%  88           $4.1         0.14%  87          $4.8         0.14%
     Cherries
    Apples          83           $0.7         0.17%  63           $9.4         0.33%  64         $10.1         0.31%
     Braeburn
     (Bulk & Bag)
    Grapefruit      84           $0.7         0.17%  86           $4.1         0.14%  85          $4.8         0.15%
     Juice (Over
     50% Jui)
    Apples Gala     85           $0.6         0.15%  65           $9.4         0.33%  67         $10.0         0.30%
     (Bulk & Bag)
     Organic
    Peaches White   86           $0.6         0.15%  80           $5.5         0.19%  81          $6.2         0.19%
     Flesh
    Jarred Fruit    87           $0.6         0.14%  82           $4.5         0.16%  82          $5.1         0.16%
     Multi Serve
    Squeeze Lemons/ 88           $0.5         0.12%  95           $3.3         0.12%  94          $3.9         0.12%
     Limes
    Raspberries     89           $0.5         0.12%  67           $9.1         0.32%  70          $9.6         0.29%
     Organic
    Pears Bosc      90           $0.5         0.11%  84           $4.3         0.15%  86          $4.8         0.14%
    Blueberries     91           $0.5         0.11%  62           $9.6         0.33%  66         $10.1         0.30%
     Organic
    Pears Asian     92           $0.4         0.10%  90           $3.8         0.13%  92          $4.2         0.13%
                           -------------------------        --------------------------------------------------------
      Total Fruit              $416.8        97.49%           $2,772.4        96.36%          $3,189.2        96.54%
       Expenditure
       s * Among
       Top 1,000
       subcommodit
       ies
                           =========================        ========================================================
        Total                  $427.6          100%           $2,877.2          100%          $3,304.8          100%
         Fruit
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    *Only 92 fruit subcommodities among top 1,000 subcommodities.

                                                   Exhibit D-3: Grains
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
         Grain                                      ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Kids Cereal     1           $78.1         9.88%  3          $186.4         4.51%  1         $264.5         5.37%
    Mainstream      2           $48.0         6.07%  7          $136.8         3.31%  6         $184.7         3.75%
     White Bread
    Tortilla/Nacho  3           $47.4         5.99%  2          $209.0         5.05%  2         $256.4         5.21%
     Chips
    Mainstream      4           $38.4         4.86%  5          $173.2         4.19%  4         $211.7         4.30%
     Variety
     Breads
    All Family      5           $36.2         4.58%  1          $214.9         5.20%  3         $251.1         5.10%
     Cereal
    Adult Cereal    6           $24.9         3.15%  4          $182.6         4.42%  5         $207.5         4.21%
    Mexican Soft    7           $23.7         3.00%  8          $113.1         2.74%  8         $136.8         2.78%
     Tortillas And
     Wra
    Waffles/        8           $17.3         2.19%  13          $77.4         1.87%  12         $94.7         1.92%
     Pancakes/
     French Toast
    Ramen Noodles/  9           $16.7         2.12%  43          $28.1         0.68%  34         $44.8         0.91%
     Ramen Cups
    Cheese          10          $16.5         2.08%  10          $90.2         2.18%  10        $106.7         2.17%
     Crackers
    Hamburger Buns  11          $16.2         2.05%  14          $70.2         1.70%  14         $86.4         1.75%
    Hot Dog Buns    12          $16.2         2.05%  18          $62.2         1.50%  16         $78.4         1.59%
    Refrigerated    13          $14.7         1.86%  30          $45.2         1.09%  26         $59.9         1.22%
     Biscuits
    Butter Spray    14          $14.6         1.85%  15          $68.7         1.66%  15         $83.3         1.69%
     Cracker
    Toaster         15          $14.0         1.77%  27          $47.6         1.15%  23         $61.6         1.25%
     Pastries
    Rice Side Dish  16          $14.0         1.76%  28          $46.7         1.13%  24         $60.6         1.23%
     Mixes Dry
    Popcorn--Micro  17          $13.1         1.65%  17          $63.4         1.53%  17         $76.5         1.55%
     wave
    Long Cut Pasta  18          $13.0         1.64%  19          $60.4         1.46%  19         $73.4         1.49%
    Granola Bars    19          $12.8         1.61%  11          $88.9         2.15%  11        $101.7         2.06%
    Premium Bread   20          $12.3         1.55%  6          $144.7         3.50%  7         $157.0         3.19%
    Cereal Bars     21          $10.9         1.38%  12          $78.4         1.90%  13         $89.3         1.81%
    Short Cut       22           $9.9         1.25%  21          $56.2         1.36%  20         $66.1         1.34%
     Pasta
    Rolls: Dinner   23           $9.5         1.21%  23          $50.5         1.22%  25         $60.1         1.22%
    Frzn Garlic     24           $9.1         1.16%  44          $27.8         0.67%  39         $36.9         0.75%
     Toast
    Corn Chips      25           $9.1         1.15%  29          $45.6         1.10%  28         $54.7         1.11%
    Instant         26           $8.9         1.13%  33          $41.1         0.99%  32         $50.0         1.02%
     Oatmeal
    Snack Crackers  27           $8.9         1.13%  9           $98.6         2.39%  9         $107.6         2.18%
    Saltine/Oyster  28           $8.2         1.03%  31          $43.1         1.04%  30         $51.3         1.04%
    Multi-Pack      29           $8.0         1.01%  32          $41.3         1.00%  33         $49.3         1.00%
     Crackers
    Bagels          30           $7.8         0.99%  16          $66.9         1.62%  18         $74.7         1.52%
    Noodle Side     31           $7.3         0.92%  53          $21.1         0.51%  49         $28.4         0.58%
     Dish Mixes
    Rice--Dry Bag   32           $7.1         0.90%  37          $33.9         0.82%  36         $41.1         0.83%
     And Box
    Sandwich Buns   33           $7.1         0.90%  20          $56.8         1.37%  21         $63.9         1.30%
    Rice--Instant   34           $6.8         0.86%  34          $38.0         0.92%  35         $44.8         0.91%
     & Microwave
    Frzn Breakfast  35           $6.5         0.82%  57          $19.0         0.46%  52         $25.4         0.52%
     Pastry
    Flour: White &  36           $6.4         0.81%  42          $28.8         0.70%  41         $35.2         0.71%
     Self Rising
    Pretzels        37           $6.2         0.79%  22          $55.4         1.34%  22         $61.6         1.25%
    Bread: Italian/ 38           $6.1         0.77%  25          $49.0         1.19%  27         $55.1         1.12%
     French
    Muffin & Corn   39           $6.0         0.76%  41          $28.9         0.70%  42         $34.9         0.71%
     Bread Mix
    Refrigerated    40           $5.5         0.70%  45          $27.5         0.66%  44         $33.0         0.67%
     Specialty
     Rolls
    Refrigerated    41           $5.4         0.68%  38          $31.2         0.76%  40         $36.6         0.74%
     Crescent
     Rolls
    Mexican Taco/   42           $5.2         0.66%  56          $19.1         0.46%  55         $24.3         0.49%
     Tostado/
     Shells
    Noodles Dry     43           $4.5         0.58%  48          $24.9         0.60%  47         $29.4         0.60%
    Rolls:          44           $4.1         0.52%  46          $26.7         0.65%  46         $30.9         0.63%
     Sandwich
    Salad Toppers   45           $4.1         0.52%  68          $15.1         0.37%  64         $19.2         0.39%
    Graham          46           $4.0         0.51%  47          $24.9         0.60%  48         $29.0         0.59%
     Crackers
    Standard        47           $3.9         0.49%  39          $29.9         0.72%  43         $33.8         0.69%
     Oatmeal
    English         48           $3.8         0.48%  24          $49.5         1.20%  29         $53.3         1.08%
     Muffins/
     Waffles
    Main Meal       49           $3.8         0.48%  36          $34.9         0.84%  37         $38.7         0.79%
     Bread
    Dinner Rolls    50           $3.5         0.44%  71          $14.5         0.35%  67         $18.0         0.36%
    Breadings/      51           $3.2         0.41%  65          $16.0         0.39%  62         $19.3         0.39%
     Coatings/
     Crumbs
    Bread:          52           $3.2         0.40%  51          $22.9         0.55%  51         $26.0         0.53%
     Specialty
    Bagged Popped   53           $3.0         0.38%  77          $12.5         0.30%  75         $15.5         0.32%
     Popcorn
    Frzn Dinner     54           $3.0         0.38%  54          $20.9         0.50%  56         $23.9         0.48%
     Rolls
    Rolls:          55           $2.9         0.37%  64          $16.5         0.40%  61         $19.4         0.39%
     Croissants/
     Breadsticks
    Grits           56           $2.8         0.36%  96           $6.7         0.16%  92          $9.6         0.19%
    Cereal--Cold    57           $2.8         0.36%  26          $47.8         1.16%  31         $50.7         1.03%
    Refrigerated    58           $2.8         0.36%  86           $9.4         0.23%  80         $12.3         0.25%
     Tortillas
    Croutons        59           $2.8         0.36%  73          $14.0         0.34%  69         $16.8         0.34%
    Frzn Garlic     60           $2.7         0.34%  78          $11.1         0.27%  78         $13.8         0.28%
     Bread
    Frzn Biscuits   61           $2.6         0.33%  76          $12.9         0.31%  74         $15.6         0.32%
    Frozen Pasta    62           $2.6         0.33%  62          $16.9         0.41%  59         $19.6         0.40%
    Pasta/Grain     63           $2.6         0.33%  82          $10.3         0.25%  79         $12.9         0.26%
     Salads--Prepa
     ck
    Cornmeal        64           $2.5         0.32%  95           $7.3         0.18%  90          $9.8         0.20%
    Refrigerated    65           $2.5         0.32%  93           $7.7         0.19%  87         $10.2         0.21%
     Bagels
    Refrigerated    66           $2.4         0.30%  40          $29.3         0.71%  45         $31.7         0.64%
     Pasta
    Diet/Light      67           $2.4         0.30%  49          $24.0         0.58%  50         $26.3         0.53%
     Bread
    Pasta/Grain     68           $2.3         0.30%  63          $16.9         0.41%  63         $19.3         0.39%
     Salads--Bulk
    Mini-Cakes      69           $2.3         0.30%  60          $17.2         0.42%  60         $19.5         0.40%
    Fruit/          70           $2.2         0.28%  58          $18.7         0.45%  58         $21.0         0.43%
     Breakfast
     Bread
    Breading        71           $2.2         0.28%  114          $3.7         0.09%  104         $5.9         0.12%
    Frzn            72           $2.2         0.28%  106          $5.0         0.12%  97          $7.2         0.15%
     Breadsticks
    Rye Breads      73           $2.0         0.25%  52          $22.3         0.54%  54         $24.3         0.49%
    Other Hot       74           $1.9         0.24%  80          $10.3         0.25%  81         $12.2         0.25%
     Cereal
    Rolls: Bagels   75           $1.9         0.24%  67          $15.4         0.37%  68         $17.3         0.35%
    Biscuit Flour   76           $1.9         0.23%  74          $13.8         0.33%  72         $15.7         0.32%
     & Mixes
    Bread: Artisan  77           $1.7         0.22%  35          $36.7         0.89%  38         $38.4         0.78%
    Flour: Misc/    78           $1.6         0.20%  75          $13.6         0.33%  77         $15.2         0.31%
     Specialty/
     Blend Et
    Bread: Pita/    79           $1.5         0.19%  72          $14.1         0.34%  73         $15.6         0.32%
     Pocket/
     Flatbrd
    Pizza Mix Dry   80           $1.4         0.18%  102          $5.4         0.13%  98          $6.8         0.14%
    Breakfast Bars/ 81           $1.4         0.18%  50          $23.6         0.57%  53         $25.0         0.51%
     Tarts/Scones
    Popcorn--Other  82           $1.4         0.17%  84          $10.0         0.24%  84         $11.4         0.23%
    Asian Noodles/  83           $1.3         0.17%  79          $10.5         0.25%  82         $11.8         0.24%
     Rice
    Instant         84           $1.3         0.16%  91           $8.1         0.20%  93          $9.4         0.19%
     Breakfast
    Tortilla Chips  85           $1.3         0.16%  55          $19.9         0.48%  57         $21.2         0.43%
    Bread: Sweet/   86           $1.3         0.16%  90           $8.4         0.20%  91          $9.7         0.20%
     Breakfast
    Refrigerated    87           $1.2         0.16%  83          $10.2         0.25%  83         $11.5         0.23%
     Breads
    Bread:          88           $1.2         0.15%  61          $17.1         0.41%  66         $18.3         0.37%
     Sourdough
    Bread:          89           $1.0         0.13%  85           $9.8         0.24%  86         $10.8         0.22%
     Tortillas/
     Wraps
    Vending Size/   90           $1.0         0.12%  124          $2.3         0.06%  120         $3.3         0.07%
     Sngl Serve
     Cracke
    Snacks: Pita    91           $0.9         0.12%  66          $15.7         0.38%  70         $16.7         0.34%
     Chips
    Granola         92           $0.9         0.12%  69          $15.1         0.37%  71         $16.0         0.33%
    Caramel Coated  93           $0.9         0.11%  118          $3.1         0.08%  115         $4.0         0.08%
     Snacks
    Specialty       94           $0.9         0.11%  59          $17.8         0.43%  65         $18.7         0.38%
     Crackers
    Crackers        95           $0.8         0.10%  70          $14.6         0.35%  76         $15.4         0.31%
    Bread: Rye/     96           $0.7         0.09%  92           $8.1         0.20%  95          $8.8         0.18%
     Cocktail
    Whole Grain     97           $0.7         0.09%  88           $9.2         0.22%  88          $9.9         0.20%
     Bread
    Frzn Bagels     98           $0.7         0.09%  120          $2.9         0.07%  119         $3.6         0.07%
    Bread: Wheat/   99           $0.7         0.09%  81          $10.3         0.25%  85         $11.0         0.22%
     Whl Grain
    Pies: Sugar     100          $0.7         0.09%  111          $4.5         0.11%  111         $5.2         0.11%
     Free
                           -------------------------        --------------------------------------------------------
      Top 100                  $778.3        98.43%           $3,989.3        96.47%          $4,767.6        96.79%
       Grain
       Expenditure
       s *
                           -------------------------        --------------------------------------------------------
      Total Grain              $783.8        99.13%           $4,049.9        96.28%          $4,833.8        98.63%
       Expenditure
       s Among Top
       1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total                  $790.7          100%           $4,135.0          100%          $4,925.7          100%
         Grain
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

                                                    Exhibit D-4: Oils
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
          Oil                                       ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Pourable Salad  1           $29.0        22.71%  1          $139.4        24.28%  1         $168.4        23.99%
     Dressings
    Mayonnaise &    2           $27.3        21.34%  2          $119.1        20.73%  2         $146.3        20.84%
     Whipped
     Dressing
    Margarine:      3           $23.4        18.37%  3          $100.9        17.56%  3         $124.3        17.71%
     Tubs And
     Bowls
    Vegetable Oil   4           $20.5        16.07%  5           $35.4         6.16%  5          $55.9         7.96%
    Canola Oils     5            $8.3         6.49%  6           $29.3         5.10%  6          $37.6         5.35%
    Olive Oil       6            $7.3         5.69%  4           $63.8        11.11%  4          $71.1        10.12%
    Cooking Sprays  7            $3.2         2.49%  7           $21.0         3.65%  7          $24.1         3.44%
    Dressing        8            $1.6         1.23%  8           $14.5         2.53%  8          $16.1         2.30%
     Creamy
    Sand/           9            $1.4         1.14%  10           $7.2         1.26%  10          $8.7         1.23%
     Horseradish &
     Tartar Sauce
    Corn Oil        10           $1.3         1.01%  14           $4.1         0.71%  12          $5.4         0.77%
    Cooking Oil:    11           $1.1         0.89%  11           $6.7         1.17%  11          $7.8         1.12%
     Peanut/
     Safflower/
    Dressing Blue   12           $0.9         0.71%  9            $9.5         1.65%  9          $10.4         1.48%
     Cheese
    Margarine:      13           $0.6         0.44%  13           $4.2         0.74%  14          $4.8         0.68%
     Squeeze
                           -------------------------        --------------------------------------------------------
      Total Oil                $125.9        98.58%             $555.0        96.65%            $680.9        96.99%
       Expenditure
       s * Among
       Top 1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total Oil              $127.0          100%             $574.4          100%            $702.1          100%
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Only 13 oil subcommodities among the top 1,000 subcommodities.

                                               Exhibit D-5: Protein Foods
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
     Protein Foods                                  ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Lean [Beef]     1          $112.4         7.38%  2          $257.9         4.03%  1         $370.3         4.67%
    Primal [Beef]   2           $62.4         4.10%  5          $219.8         3.43%  5         $282.2         3.56%
    Lunchment--Del  3           $55.8         3.67%  4          $242.6         3.79%  4         $298.4         3.76%
     i Fresh
    Eggs--Large     4           $52.1         3.43%  3          $251.6         3.93%  3         $303.7         3.83%
    Chicken Breast  5           $49.6         3.26%  1          $292.9         4.57%  2         $342.5         4.32%
     Boneless
    Enhanced [Pork  6           $41.5         2.73%  6          $168.0         2.62%  6         $209.5         2.64%
     Boneless Loin/
     Rib]
    Bacon--Trad     7           $40.7         2.68%  8          $157.6         2.46%  7         $198.3         2.50%
     16oz Or Less
    Ribs [Pork]     8           $35.0         2.30%  15         $106.8         1.67%  13        $141.8         1.79%
    Frzn Chicken--  9           $30.0         1.97%  17          $99.8         1.56%  16        $129.8         1.64%
     Wht Meat
    Choice Beef     10          $28.4         1.87%  11         $136.6         2.13%  10        $165.1         2.08%
     (Loins)
    Select Beef     11          $27.9         1.83%  9          $143.7         2.24%  9         $171.5         2.16%
    Hot Dogs--Base  12          $25.1         1.65%  27          $56.8         0.89%  23         $81.9         1.03%
     Meat
    Choice Beef     13          $24.0         1.58%  20          $72.5         1.13%  19         $96.5         1.22%
     (Rounds)
    Chicken Wings   14          $22.2         1.46%  58          $28.6         0.45%  40         $50.9         0.64%
    Frzn Chicken--  15          $22.2         1.46%  97          $17.4         0.27%  52         $39.5         0.50%
     Wings
    Lunchment--Bol  16          $21.8         1.43%  24          $60.9         0.95%  22         $82.7         1.04%
     ogna/Sausage
    Tuna            17          $21.1         1.39%  14         $109.9         1.72%  15        $131.0         1.65%
    Peanut Butter   18          $20.4         1.34%  12         $127.8         1.99%  12        $148.2         1.87%
    Meat: Turkey    19          $19.3         1.27%  7          $159.6         2.49%  8         $178.9         2.26%
     Bulk
    Frzn Meat--     20          $19.0         1.25%  34          $46.3         0.72%  30         $65.2         0.82%
     Beef
    Value Forms/    21          $18.6         1.22%  41          $42.6         0.67%  33         $61.2         0.77%
     18oz And
     Larger
     [Chicken]
    Chicken Drums   22          $17.3         1.14%  49          $31.5         0.49%  44         $48.8         0.62%
    Angus [Beef]    23          $17.1         1.13%  16         $103.8         1.62%  17        $120.9         1.53%
    Dnr Sausage--   24          $16.4         1.08%  45          $37.6         0.59%  38         $54.1         0.68%
     Links Pork
     Ckd/S
    Meat: Ham Bulk  25          $15.3         1.00%  13         $115.9         1.81%  14        $131.2         1.65%
    Bkfst Sausage-- 26          $15.1         0.99%  23          $61.4         0.96%  25         $76.5         0.96%
     Fresh Rolls
    Shrimp--Raw     27          $15.0         0.99%  21          $69.0         1.08%  21         $84.1         1.06%
    Shrimp--Cooked  28          $14.8         0.97%  29          $54.0         0.84%  28         $68.8         0.87%
    Prepared        29          $13.4         0.88%  28          $55.3         0.86%  29         $68.7         0.87%
     Beans--Baked
     W/Pork
    Chili: Canned   30          $13.3         0.88%  39          $42.8         0.67%  36         $56.1         0.71%
    Ground Turkey   31          $13.1         0.86%  19          $78.0         1.22%  20         $91.1         1.15%
    Dnr Sausage--   32          $13.0         0.86%  25          $58.0         0.91%  26         $71.1         0.90%
     Links Fresh
    Whole Chicken   33          $12.9         0.85%  26          $56.9         0.89%  27         $69.8         0.88%
     (Roasters/
     Fryer)
    Chicken Thighs  34          $12.2         0.80%  31          $50.0         0.78%  31         $62.2         0.78%
    Dnr Sausage--   35          $12.1         0.80%  43          $38.2         0.60%  42         $50.4         0.64%
     Pork Rope Ckd/
     Sm
    Bacon--Trad     36          $12.0         0.79%  35          $44.6         0.70%  35         $56.6         0.71%
     Greater Than
     16oz
    Soup/Stew       37          $11.2         0.74%  36          $44.1         0.69%  37         $55.3         0.70%
    Whole Muscle    38          $11.1         0.73%  53          $29.9         0.47%  49         $41.0         0.52%
     Breaded/18oz
     And
    Variety Beans-- 39          $10.5         0.69%  22          $68.0         1.06%  24         $78.5         0.99%
     Kidney/Pinto/
     E
    Cubed Meats     40          $10.5         0.69%  54          $29.8         0.46%  51         $40.3         0.51%
     [Beef]
    Hot Dogs--Base  41          $10.3         0.68%  32          $49.4         0.77%  34         $59.8         0.75%
     Beef
    Eggs--Medium    42          $10.1         0.66%  81          $21.0         0.33%  64         $31.1         0.39%
    Butts [Pork     43           $9.7         0.63%  56          $29.2         0.46%  54         $38.8         0.49%
     Shoulder]
    Boneless Snack/ 44           $9.6         0.63%  77          $21.5         0.33%  65         $31.1         0.39%
     18oz And
     Larger
    Chix: Value-    45           $9.5         0.63%  62          $26.7         0.42%  58         $36.2         0.46%
     Added (Cold)
    Angus [Beef]    46           $9.3         0.61%  50          $31.4         0.49%  50         $40.6         0.51%
    Patties [Beef]  47           $9.1         0.60%  42          $39.7         0.62%  45         $48.8         0.61%
    Bkfst Sausage-- 48           $8.9         0.59%  64          $26.3         0.41%  59         $35.3         0.44%
     Fresh Links
    Bone-In Wings   49           $8.8         0.58%  123         $12.0         0.19%  94         $20.8         0.26%
    Hams--Half/     50           $8.2         0.54%  52          $30.0         0.47%  56         $38.2         0.48%
     Port Bone-In
    Meat: Beef      51           $7.9         0.52%  30          $53.4         0.83%  32         $61.3         0.77%
     Bulk
    Hams--Spiral    52           $7.6         0.50%  46          $36.5         0.57%  47         $44.1         0.56%
    Hot Dogs--      53           $7.4         0.49%  40          $42.7         0.67%  43         $50.1         0.63%
     Premium
    Snack Meat--    54           $7.4         0.48%  48          $32.1         0.50%  53         $39.5         0.50%
     Pepperoni
    Frzn Meat--     55           $7.3         0.48%  128         $11.3         0.18%  109        $18.6         0.23%
     Breakfast
     Sausage
    Angus [Beef]    56           $7.3         0.48%  37          $43.3         0.68%  41         $50.7         0.64%
    Select Beef     57           $7.1         0.46%  51          $30.4         0.47%  57         $37.5         0.47%
    Frz Coated      58           $6.9         0.45%  79          $21.1         0.33%  74         $28.0         0.35%
     Fish Fillets
    Jerky/Nuggets/  59           $6.8         0.45%  67          $25.8         0.40%  62         $32.6         0.41%
     Tenders
    Catfish--Fille  60           $6.8         0.45%  110         $13.1         0.20%  102        $19.9         0.25%
     t
    Chicken Legs/   61           $6.6         0.43%  109         $13.5         0.21%  101        $20.1         0.25%
     Quarters
    Value-Added     62           $6.4         0.42%  98          $16.9         0.26%  86         $23.3         0.29%
     Breaded
     Shrimp
    Pancake Mixes   63           $6.3         0.41%  65          $21.9         0.34%  68         $28.1         0.35%
    Frz Fishsticks/ 64           $6.1         0.40%  104         $14.7         0.23%  95         $20.8         0.26%
     Tenders/
     Nuggets
    Crab--Snow      65           $6.1         0.40%  127         $11.4         0.18%  110        $17.5         0.22%
    Chix: Frd 8pc/  66           $6.0         0.39%  117         $12.7         0.20%  107        $18.7         0.24%
     Cut Up (Cold)
    Lunchmeat--Cho  67           $5.1         0.34%  121         $12.1         0.19%  111        $17.2         0.22%
     p/Form Pltry
     & Ha
    Salmon Fr--     68           $5.0         0.33%  33          $48.8         0.76%  39         $53.8         0.68%
     Altantic
    Party Tray--    69           $4.8         0.32%  73          $24.8         0.39%  71         $29.6         0.37%
     Shrimp
    Ham Steaks/     70           $4.7         0.31%  63          $26.3         0.41%  66         $31.0         0.39%
     Cubes/Slices
    Eggs--X-Large   71           $4.5         0.29%  44          $37.9         0.59%  48         $42.4         0.54%
    Bacon--Poultry  72           $4.5         0.29%  91          $18.4         0.29%  88         $22.9         0.29%
    Hams--Whole     73           $4.5         0.29%  105         $14.6         0.23%  106        $19.1         0.24%
     Boneless
    Meat Bulk:      74           $4.4         0.29%  59          $28.3         0.44%  61         $32.8         0.41%
     Specialty Dry
     Meats
    Chunk Meats--   75           $4.4         0.29%  70          $25.3         0.40%  70         $29.7         0.37%
     Chix/Ham/Etc.
    Whole Toms      76           $4.3         0.28%  84          $20.0         0.31%  83         $24.2         0.31%
     (Over 16lbs)
     [Turkey]
    Lunchmeat--Who  77           $4.2         0.28%  86          $19.7         0.31%  84         $24.0         0.30%
     le Muscle
     Pltry
    Bacon--Pre-     78           $4.1         0.27%  72          $24.8         0.39%  72         $28.9         0.36%
     Cooked
    Baking Nuts     79           $4.1         0.27%  38          $43.2         0.67%  46         $47.3         0.60%
    Bologna/Loaves/ 80           $4.0         0.26%  87          $19.2         0.30%  87         $23.1         0.29%
     Franks
    Pistachios      81           $3.9         0.26%  57          $29.1         0.45%  60         $33.0         0.42%
    Seasoned        82           $3.9         0.26%  100         $16.5         0.26%  99         $20.4         0.26%
     Poultry
    Protein         83           $3.9         0.26%  65          $26.3         0.41%  69         $30.2         0.38%
     Salads--Bulk
    Bkfst Sausage-- 84           $3.8         0.25%  136          $9.8         0.15%  126        $13.6         0.17%
     Fresh Patties
    Meat: Chicken   85           $3.7         0.25%  47          $34.6         0.54%  55         $38.4         0.48%
     Bulk
    Bkfst Sausage-- 86           $3.7         0.25%  78          $21.4         0.33%  80         $25.2         0.32%
     Precooked
    Dnr Sausage--   87           $3.7         0.24%  120         $12.2         0.19%  115        $15.9         0.20%
     Beef Rope Ckd/
     Sm
    Whole Hens      88           $3.6         0.24%  89          $19.0         0.30%  89         $22.6         0.29%
     (Under 16lbs)
     [Turkey]
    Dnr Sausage--   89           $3.6         0.24%  76          $21.6         0.34%  81         $25.2         0.32%
     Other Forms
    External Fresh  90           $3.5         0.23%  204          $4.2         0.06%  169         $7.7         0.10%
     [Pork Offal]
    Corned Beef     91           $3.5         0.23%  99          $16.9         0.26%  98         $20.4         0.26%
    Fz Meatballs    92           $3.5         0.23%  95          $17.7         0.28%  93         $21.1         0.27%
    Hams--Half/     93           $3.4         0.23%  80          $21.0         0.33%  82         $24.5         0.31%
     Port Boneless
    Lunchmeat--Chi  94           $3.3         0.22%  138          $9.7         0.15%  130        $13.1         0.16%
     p Meat
    Salmon          95           $3.2         0.21%  108         $13.6         0.21%  113        $16.8         0.21%
    Sandwich Sauce  96           $3.2         0.21%  156          $7.7         0.12%  146        $10.8         0.14%
    Tilapia--Fille  97           $3.2         0.21%  101         $16.4         0.26%  103        $19.6         0.25%
     t
    Frozen Burgers  98           $3.2         0.21%  217          $3.1         0.05%  185         $6.3         0.08%
    Frozen          99           $3.1         0.20%  135          $9.8         0.15%  132        $12.9         0.16%
     Breakfast
     Sausage
    Stuffed/Mixed   100          $3.1         0.20%  88          $19.2         0.30%  90         $22.3         0.28%
     Beef
                           -------------------------        --------------------------------------------------------
      Top 100                $1,342.3        87.82%           $5,249.5        81.66%          $6,591.7        82.84%
       Protein
       Foods
       Expenditure
       s *
                           -------------------------        --------------------------------------------------------
      Total                  $1,512.2        98.95%           $6,288.8        97.83%          $7,801.0        98.04%
       Protein
       Foods
       Expenditure
       s Among Top
       1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total                $1,528.3          100%           $6,428.5          100%          $7,956.9          100%
         Protein
         Foods
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

                                  Exhibit D-6: Saturated Fats and Added Sugars (SoFAS)
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
        (SoFAS)                                     ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Soft Drinks 12/ 1          $164.6        18.86%  1          $601.2        16.11%  1         $765.8        16.63%
     18 & 15pk Can
     Car
    Sft Drnk 2      2           $70.9         8.12%  2          $230.1         6.17%  2         $301.0         6.54%
     Liter Btl
     Carb Incl
    Soft Drinks     3           $39.7         4.55%  9          $106.4         2.85%  8         $146.1         3.17%
     20pk & 24pk
     Can Carb
    Sugar           4           $36.9         4.23%  8          $112.7         3.02%  7         $149.6         3.25%
    Sft Drnk Mlt-   5           $34.0         3.90%  4          $173.6         4.65%  3         $207.6         4.51%
     Pk Btl Carb
     (Excp)
    Sft Drnk Sngl   6           $27.8         3.18%  11          $71.4         1.91%  11         $99.2         2.15%
     Srv Btl Carb
     (Ex)
    Aseptic Pack    7           $24.2         2.78%  16          $57.1         1.53%  15         $81.4         1.77%
     Juice And
     Drinks
    Refrigerated    8           $24.1         2.76%  6          $147.2         3.95%  5         $171.3         3.72%
     Coffee
     Creamers
    Candy Bags--    9           $21.5         2.46%  5          $147.5         3.95%  6         $169.1         3.67%
     Chocolate
    Butter          10          $19.6         2.24%  3          $175.6         4.71%  4         $195.2         4.24%
    Sour Creams     11          $17.5         2.00%  10          $95.2         2.55%  10        $112.7         2.45%
    Cream Cheese    12          $17.2         1.97%  7          $115.5         3.10%  9         $132.7         2.88%
    Candy Bars      13          $16.3         1.87%  18          $54.9         1.47%  16         $71.3         1.55%
     (Singles)
     (Including)
    Dairy Case      14          $16.0         1.83%  22          $48.0         1.29%  19         $64.0         1.39%
     Juice Drnk
     Under 10
    Candy Bars      15          $15.6         1.79%  12          $69.6         1.86%  12         $85.2         1.85%
     (Multi Pack)
    Tea Sweetened   16          $13.9         1.59%  13          $68.7         1.84%  13         $82.6         1.79%
    Chewing Gum     17          $13.2         1.51%  14          $68.3         1.83%  14         $81.5         1.77%
    Candy Bags--    18          $12.6         1.44%  19          $54.9         1.47%  18         $67.5         1.46%
     Non Chocolate
    Molasses &      19          $11.7         1.34%  15          $58.7         1.57%  17         $70.4         1.53%
     Syrups
    Dairy Case      20          $11.0         1.26%  27          $34.4         0.92%  26         $45.4         0.99%
     Citrus Pnch/
     Oj Subs
    Fruit Drinks:   21          $10.6         1.21%  60          $10.9         0.29%  46         $21.5         0.47%
     Canned &
     Glass
    Non Dairy       22          $10.5         1.20%  25          $35.4         0.95%  25         $45.9         1.00%
     Creamer
    Seasonal        23           $9.2         1.05%  23          $46.9         1.26%  23         $56.0         1.22%
     Miscellaneous
     [Candy]
    Dairy Case Tea  24           $8.4         0.96%  36          $23.1         0.62%  33         $31.5         0.68%
     With Sugar Or
     S
    Seasonal Candy  25           $7.9         0.90%  20          $54.8         1.47%  21         $62.7         1.36%
     Bags--Chocola
     te
    Energy Drink--  26           $7.7         0.88%  32          $26.3         0.70%  29         $33.9         0.74%
     Single Serve
    Energy Drink--  27           $7.1         0.82%  24          $39.5         1.06%  24         $46.7         1.01%
     Single Serve
     (N)
    Preserves/Jam/  28           $6.7         0.77%  17          $56.2         1.51%  20         $63.0         1.37%
     Marmalade
    Margarine       29           $6.7         0.77%  41          $22.3         0.60%  37         $29.0         0.63%
     Stick
    Juice (Under    30           $6.7         0.76%  40          $22.4         0.60%  36         $29.1         0.63%
     10% Juice)
    Sweeteners      31           $6.4         0.73%  21          $49.8         1.33%  22         $56.2         1.22%
    Frosting        32           $6.3         0.72%  31          $27.0         0.72%  30         $33.4         0.72%
    Soft Drinks     33           $5.9         0.67%  57          $11.5         0.31%  54         $17.4         0.38%
     Can Non-Carb
     (Exce)
    Refrig Dips     34           $5.7         0.66%  34          $24.7         0.66%  34         $30.4         0.66%
    Aseptic Pack    35           $5.3         0.61%  46          $17.5         0.47%  44         $22.9         0.50%
     Juice And
     Drinks
    Candy Bars      36           $5.1         0.59%  50          $15.9         0.43%  48         $21.1         0.46%
     (Singles)
     (Including)
    Cranberry       37           $5.0         0.58%  39          $22.6         0.61%  40         $27.6         0.60%
     Juice (50%
     And Under)
    Frzn Whipped    38           $5.0         0.57%  28          $30.9         0.83%  28         $35.9         0.78%
     Topping
    Blended Juice   39           $4.8         0.55%  37          $22.9         0.61%  39         $27.7         0.60%
     &
     Combinations
     (50)
    Jelly           40           $4.7         0.54%  44          $18.1         0.48%  45         $22.8         0.50%
    Energy Drink--  41           $4.3         0.49%  43          $19.0         0.51%  42         $23.3         0.51%
     Multi-Pack
    Honey           42           $4.1         0.48%  29          $28.9         0.78%  31         $33.1         0.72%
    Gum (Packaged)  43           $4.1         0.47%  33          $25.9         0.69%  35         $30.0         0.65%
    Soft Drinks     44           $4.1         0.47%  30          $27.8         0.74%  32         $31.9         0.69%
     6pk Can Carb
     (Exp)
    Miscellaneous   45           $4.0         0.46%  42          $19.0         0.51%  43         $23.0         0.50%
     Candy
     (Including)
    Juices          46           $3.8         0.44%  38          $22.8         0.61%  41         $26.6         0.58%
     Superfoods/
     Enhanced
    Dairy Case      47           $3.7         0.42%  102          $2.8         0.08%  80          $6.5         0.14%
     Fruit Drinks
     (No Ju)
    Aseptic Pack    48           $3.5         0.41%  87           $4.2         0.11%  72          $7.7         0.17%
     Juice And
     Drinks
    Aerosol         49           $3.5         0.40%  35          $24.5         0.66%  38         $28.0         0.61%
     Toppings
     [Milk By-
     Products]
    Hot Chocolate/  50           $3.5         0.40%  45          $17.8         0.48%  47         $21.2         0.46%
     Cocoa Mix
    Seasonal Candy  51           $3.4         0.39%  47          $16.6         0.45%  49         $20.0         0.43%
     Box--Chocolat
     e
    Sft Drnk 1      52           $3.3         0.38%  65           $8.2         0.22%  63         $11.5         0.25%
     Liter Btl
     Carb (Exc)
    Fruit Drinks:   53           $3.2         0.37%  80           $5.0         0.13%  71          $8.2         0.18%
     Canned &
     Glass
    Soft Drink      54           $3.1         0.36%  66           $7.9         0.21%  65         $11.1         0.24%
     Canisters
    Marshmallows    55           $3.0         0.34%  48          $16.4         0.44%  50         $19.4         0.42%
    Whipping Cream  56           $3.0         0.34%  26          $35.2         0.94%  27         $38.1         0.83%
    Solid           57           $2.9         0.33%  54          $14.0         0.38%  55         $16.9         0.37%
     Shortening
    Tea Can With    58           $2.7         0.31%  74           $6.1         0.16%  67          $8.8         0.19%
     Sweetener/
     Sugar
    Soft Drink      59           $2.6         0.30%  83           $4.7         0.13%  76          $7.4         0.16%
     Bottle Non-
     Carb (Ex)
    Ice Cream       60           $2.6         0.30%  53          $14.1         0.38%  56         $16.7         0.36%
     Toppings
    Seasonal Candy  61           $2.6         0.30%  52          $14.9         0.40%  53         $17.5         0.38%
     Bags Non-
     Chocol
    Candy Bars      62           $2.6         0.29%  64           $8.8         0.23%  64         $11.3         0.25%
     Multi Pack W/
     Flour
    Candy Bags--    63           $2.5         0.29%  51          $15.2         0.41%  52         $17.7         0.38%
     Chocolate W/
     Flour
    Pork Skins/     64           $2.2         0.26%  73           $6.2         0.17%  68          $8.4         0.18%
     Cracklins
    Mints/Candy &   65           $2.1         0.25%  56          $12.1         0.32%  57         $14.3         0.31%
     Breath (Not
     Life)
    Juices          66           $2.1         0.24%  59          $11.0         0.29%  60         $13.1         0.28%
     Smoothies/
     Blended
    Miscellaneous   67           $1.9         0.22%  58          $11.2         0.30%  59         $13.1         0.28%
     Candy
     (Including)
    Cocktail        68           $1.9         0.22%  49          $16.4         0.44%  51         $18.3         0.40%
     Mixes--Fluid:
     Add Liq
    Cake Decors &   69           $1.8         0.20%  62          $10.0         0.27%  62         $11.7         0.25%
     Icing
    Enhanced Stick  70           $1.7         0.20%  61          $10.7         0.29%  61         $12.5         0.27%
     [Powder Drink
     Mix]
    Novelty Candy   71           $1.6         0.19%  76           $5.7         0.15%  77          $7.4         0.16%
    Sugar           72           $1.4         0.16%  104          $2.5         0.07%  96          $3.9         0.08%
     Sweetened
     Sticks
    Dips Caramel/   73           $1.3         0.15%  75           $5.9         0.16%  78          $7.2         0.16%
     Fruit Glazes
    Seasonal        74           $1.2         0.14%  68           $7.1         0.19%  69          $8.4         0.18%
     Miscellaneous
     W/Flour
    Instant Tea &   75           $1.1         0.13%  84           $4.4         0.12%  85          $5.6         0.12%
     Tea Mix (W/
     Sugar)
    Misc Checklane  76           $1.1         0.13%  103          $2.6         0.07%  97          $3.7         0.08%
     Candy
    Fluid Pouch     77           $1.1         0.13%  71           $6.6         0.18%  73          $7.7         0.17%
     [Powder Drink
     Mix]
    Sweet Goods:    78           $1.1         0.12%  85           $4.4         0.12%  87          $5.4         0.12%
     Candy
    Tea Bottles     79           $1.1         0.12%  114          $1.9         0.05%  105         $3.0         0.06%
     With
     Sweetener/Sug
    Hispanic        80           $1.1         0.12%  93           $3.5         0.09%  92          $4.6         0.10%
     Carbonated
     Beverages
    Candy W/O       81           $1.0         0.12%  78           $5.4         0.15%  81          $6.5         0.14%
     Flour
    Candy Boxed     82           $1.0         0.12%  79           $5.3         0.14%  83          $6.3         0.14%
     Chocolates W/
     Flour
    Apple Juice &   83           $1.0         0.12%  98           $3.0         0.08%  95          $4.0         0.09%
     Cider (50%
     And U)
    Energy Drink--  84           $1.0         0.11%  63           $9.4         0.25%  66         $10.4         0.22%
     Multi-Pack
     (Non)
    Candy Boxed     85           $0.9         0.11%  70           $6.7         0.18%  74          $7.7         0.17%
     Chocolates
    Seasonal Candy  86           $0.9         0.11%  89           $4.0         0.11%  88          $4.9         0.11%
     Box Non-
     Chocola
    Candy Box Non-- 87           $0.9         0.11%  90           $3.9         0.10%  89          $4.8         0.10%
     Chocolate
    Cake Decors--   88           $0.9         0.10%  77           $5.4         0.15%  82          $6.3         0.14%
     Candies
    Non-Carb Jce    89           $0.9         0.10%  82           $4.8         0.13%  84          $5.7         0.12%
     (Under 50%
     Jce)
    Candy Bags--    90           $0.8         0.09%  91           $3.7         0.10%  93          $4.5         0.10%
     Non Chocolate
     W/Flo
    Hispanic Juice  91           $0.7         0.08%  113          $2.0         0.07%  109         $2.7         0.05%
     Under 50%
     Juice
    Can/Btl Carb    92           $0.7         0.08%  67           $7.6         0.20%  70          $8.3         0.18%
     Beve 50% And
     Unde
    Cranapple/Cran  93           $0.6         0.07%  69           $7.0         0.19%  75          $7.6         0.17%
     Grape Juice
     (Un)
    Grapefruit      94           $0.6         0.07%  96           $3.1         0.08%  98          $3.7         0.08%
     Juice (50%
     And Unde)
    Blended Juice   95           $0.6         0.07%  97           $3.0         0.08%  100         $3.6         0.08%
     &
     Combinations
     (Un)
    Mixers (Tonic   96           $0.5         0.06%  55          $13.2         0.35%  58         $13.7         0.30%
     Water/Gngr
     Ale) Un
    Marshmallow     97           $0.5         0.06%  92           $3.5         0.09%  94          $4.1         0.09%
     Creme
    Coconut         98           $0.5         0.06%  81           $4.9         0.13%  86          $5.5         0.12%
     [Baking
     Needs]
    Honey/Syrup     99           $0.5         0.06%  86           $4.3         0.11%  90          $4.8         0.10%
    Dips Fruit And  100          $0.5         0.06%  106          $1.9         0.05%  112         $2.4         0.04%
     Chocolate
                           -------------------------        --------------------------------------------------------
      Top 100                  $862.5        98.70%           $3,660.7        97.93%          $4,523.2        98.05%
       SoFAS
       Expenditure
       s *
                           -------------------------        --------------------------------------------------------
      Total SoFAS              $864.1        98.96%           $3,673.1        98.42%          $4,537.3        98.53%
       Expenditure
       s Among Top
       1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total                  $873.2          100%           $3,731.9          100%          $4,605.0          100%
         SoFAS
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

                                                 Exhibit D-7: Vegetables
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
       Vegetable                                    ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Potatoes        1           $35.8         6.74%  1          $154.5         4.60%  1         $190.2         4.89%
     Russet (Bulk
     & Bag)
    Fz Bag          2           $25.7         4.85%  2          $131.9         3.93%  2         $157.7         4.05%
     Vegetables--P
     lain
    Mainstream      3           $23.0         4.33%  6           $81.0         2.41%  5         $103.9         2.67%
     [Pasta &
     Pizza Sauce]
    Frzn French     4           $20.5         3.86%  19          $50.3         1.50%  9          $70.8         1.82%
     Fries
    Avocado         5           $13.4         2.52%  4          $112.6         3.35%  4         $126.0         3.24%
    Blends [Salad   6           $13.1         2.47%  3          $124.0         3.69%  3         $137.1         3.52%
     Mix]
    Green Beans:    7           $12.8         2.41%  15          $53.1         1.58%  15         $65.9         1.69%
     Fs/Whl/Cut
    Potatoes: Dry   8           $12.3         2.31%  33          $32.3         0.96%  28         $44.6         1.15%
    Corn            9           $12.1         2.28%  22          $44.0         1.31%  19         $56.0         1.44%
    Head Lettuce    10          $11.6         2.18%  13          $55.5         1.65%  14         $67.1         1.72%
    Frzn Steamable  11          $10.5         1.98%  5           $81.4         2.42%  6          $91.9         2.36%
     Vegetables
    Mexican Sauces  12          $10.2         1.93%  9           $62.3         1.85%  8          $72.5         1.86%
     And Picante
     Sau
    Tomatoes Diced  13           $9.5         1.79%  11          $59.9         1.78%  11         $69.4         1.79%
    Tomatoes        14           $9.2         1.74%  7           $77.7         2.31%  7          $86.9         2.23%
     Hothouse On
     The Vine
    Onions Yellow   15           $8.7         1.65%  27          $39.3         1.17%  24         $48.1         1.24%
     (Bulk & Bag)
    Cucumbers       16           $8.2         1.55%  12          $58.9         1.75%  13         $67.1         1.73%
    Vegetable       17           $7.8         1.48%  29          $36.6         1.09%  29         $44.4         1.14%
     Salads--Prepa
     ck
    Peppers Green   18           $7.8         1.47%  25          $41.5         1.24%  22         $49.3         1.27%
     Bell
    Regular Garden  19           $7.8         1.46%  35          $31.9         0.95%  31         $39.6         1.02%
    Roma Tomatoes   20           $7.5         1.41%  26          $39.6         1.18%  25         $47.1         1.21%
     (Bulk/Pkg)
    Carrots Mini    21           $7.0         1.32%  10          $61.4         1.83%  12         $68.5         1.76%
     Peeled
    Onions Sweet    22           $6.2         1.16%  20          $47.4         1.41%  21         $53.6         1.38%
     (Bulk & Bag)
    Celery          23           $5.9         1.11%  17          $51.2         1.52%  18         $57.1         1.47%
    Tomatoes Vine   24           $5.7         1.07%  51          $22.5         0.67%  48         $28.2         0.72%
     Ripe Bulk
    Garden Plus     25           $5.5         1.03%  36          $31.8         0.95%  34         $37.2         0.96%
     [Salad Mix]
    Cabbage         26           $5.3         1.00%  43          $25.1         0.75%  43         $30.5         0.78%
    Frzn Tater      27           $5.2         0.99%  55          $18.8         0.56%  53         $24.1         0.62%
     Tots/Other
     Extruded
    Broccoli Whole  28           $5.2         0.97%  16          $52.0         1.55%  17         $57.1         1.47%
     & Crowns
    Tomato Sauce    29           $5.1         0.96%  48          $24.2         0.72%  45         $29.3         0.75%
    Variety         30           $5.1         0.96%  8           $65.2         1.94%  10         $70.3         1.81%
     Lettuce
    Tomatoes Hot    31           $5.0         0.94%  39          $30.3         0.90%  37         $35.3         0.91%
     House Bulk
    Potatoes Sweet  32           $4.8         0.91%  28          $37.1         1.11%  30         $41.9         1.08%
     & Yams
    Tomatoes Grape  33           $4.7         0.88%  14          $54.6         1.63%  16         $59.3         1.52%
    Mexican Beans/  34           $4.7         0.88%  52          $21.0         0.63%  51         $25.6         0.66%
     Refried
    Frzn Hashbrown  35           $4.6         0.86%  45          $24.8         0.74%  44         $29.3         0.75%
     Potatoes
    Corn Bulk       36           $4.5         0.85%  32          $32.5         0.97%  35         $37.1         0.95%
    Fz Box          37           $4.4         0.83%  46          $24.7         0.73%  47         $29.1         0.75%
     Vegetables--V
     alue-Added
    Kits [Salad     38           $4.2         0.79%  31          $33.5         1.00%  33         $37.6         0.97%
     Mix]
    Potatoes Red    39           $4.1         0.78%  34          $32.0         0.95%  36         $36.1         0.93%
     (Bulk & Bag)
    Frzn Corn On    40           $4.0         0.75%  94           $8.4         0.25%  83         $12.4         0.32%
     The Cob
    Vegetable       41           $4.0         0.75%  44          $25.1         0.75%  46         $29.1         0.75%
     Party Tray
    Cut Vegetables  42           $4.0         0.75%  24          $42.2         1.26%  26         $46.2         1.19%
     All Other
    Vegetable       43           $3.8         0.72%  37          $31.0         0.92%  38         $34.8         0.89%
     Salads--Bulk
    Veg Juice       44           $3.8         0.72%  38          $30.4         0.91%  39         $34.2         0.88%
     (Except
     Tomato) (Ove)
    Asparagus       45           $3.8         0.72%  18          $50.7         1.51%  20         $54.5         1.40%
    Tomatoes Vine   46           $3.6         0.68%  101          $7.3         0.22%  89         $10.9         0.28%
     Ripe Pkg
    Peppers Red     47           $3.6         0.68%  23          $42.5         1.27%  27         $46.1         1.19%
     Bell
    Value (Pasta    48           $3.5         0.67%  87           $9.7         0.29%  78         $13.2         0.34%
     Tomato Sauce)
    Peas/Green      49           $3.5         0.66%  64          $14.7         0.44%  61         $18.2         0.47%
    Spinach &       50           $3.5         0.66%  103          $7.0         0.21%  92         $10.5         0.27%
     Greens
    Peppers Other   51           $3.4         0.63%  41          $28.4         0.85%  41         $31.8         0.82%
     Bell
    Mushrooms       52           $3.3         0.63%  42          $27.8         0.83%  42         $31.2         0.80%
     White Sliced
     Pkg
    Shredded        53           $3.3         0.62%  81          $10.9         0.32%  75         $14.2         0.36%
     Lettuce
    Mushrooms       54           $3.1         0.58%  40          $29.6         0.88%  40         $32.7         0.84%
     White Whole
     Pkg
    Green Onions    55           $3.0         0.57%  49          $23.5         0.70%  50         $26.5         0.68%
    Salad Bowls     56           $2.9         0.54%  74          $12.3         0.37%  69         $15.2         0.39%
    Fz Bag          57           $2.8         0.54%  65          $14.7         0.44%  63         $17.6         0.45%
     Vegetables--V
     alue-Added
    Sal: Hommus     58           $2.8         0.52%  21          $45.4         1.35%  23         $48.2         1.24%
    Mushrooms Cnd   59           $2.7         0.52%  67          $14.3         0.42%  64         $17.0         0.44%
     & Glass
    Mexican         60           $2.7         0.51%  69          $13.7         0.41%  66         $16.4         0.42%
     Enchilada
     Sauce
    Onions Red      61           $2.5         0.48%  53          $20.9         0.62%  54         $23.5         0.60%
     (Bulk & Bag)
    Onions White    62           $2.5         0.47%  60          $15.8         0.47%  60         $18.3         0.47%
     (Bulk & Bag)
    Authentic       63           $2.3         0.43%  89           $9.2         0.27%  87         $11.5         0.30%
     Sauces/Salsa/
     Picante
    Salad Mix       64           $2.3         0.43%  30          $36.5         1.09%  32         $38.8         1.00%
     Blends
     Organic
    Salad: Lettuce  65           $2.2         0.42%  77          $12.2         0.36%  72         $14.5         0.37%
    Cauliflower     66           $2.2         0.42%  47          $24.5         0.73%  49         $26.8         0.69%
     Whole
    Mushrooms       67           $2.2         0.42%  50          $22.6         0.67%  52         $24.8         0.64%
     Portabella
    Mexican         68           $2.2         0.41%  61          $15.7         0.47%  62         $17.9         0.46%
     Peppers
     Chilies
    Fried Onions    69           $2.1         0.39%  75          $12.3         0.37%  73         $14.3         0.37%
    Carrots Bagged  70           $2.0         0.39%  58          $17.2         0.51%  58         $19.2         0.49%
    Potatoes        71           $2.0         0.38%  54          $20.3         0.60%  55         $22.3         0.57%
     Gourmet
    Sweet Potatoes  72           $2.0         0.38%  104          $6.7         0.20%  101         $8.7         0.22%
    Corn Is         73           $1.9         0.36%  70          $12.8         0.38%  71         $14.7         0.38%
     Packaged
    Salad Spinach   74           $1.8         0.34%  57          $17.9         0.53%  57         $19.7         0.51%
    Tomato Paste    75           $1.8         0.34%  83          $10.2         0.30%  84         $12.0         0.31%
    Sal: Salsa/     76           $1.8         0.33%  98           $7.7         0.23%  95          $9.5         0.24%
     Dips Bulk
    Beans           77           $1.7         0.32%  59          $16.9         0.50%  59         $18.6         0.48%
    Tomato Juice    78           $1.7         0.32%  88           $9.6         0.28%  88         $11.2         0.29%
     (Over 50%
     Jce)
    Authentic       79           $1.7         0.32%  136          $3.2         0.10%  128         $4.9         0.13%
     Vegetables
     And Foods
    Potatoes Gold   80           $1.6         0.29%  63          $14.8         0.44%  65         $16.4         0.42%
     (Bulk & Bag)
    Garlic Whole    81           $1.6         0.29%  71          $12.7         0.38%  74         $14.3         0.37%
     Cloves
    Coleslaw        82           $1.6         0.29%  79          $11.9         0.35%  77         $13.5         0.35%
    Carrots Bagged  83           $1.5         0.29%  56          $18.6         0.55%  56         $20.2         0.52%
     Organic
    Pumpkins        84           $1.5         0.29%  82          $10.3         0.31%  85         $11.9         0.31%
    Herbs Cilanto   85           $1.4         0.26%  84          $10.1         0.30%  86         $11.5         0.30%
    Frzn Baked/     86           $1.3         0.25%  91           $9.0         0.27%  93         $10.4         0.27%
     Stuffed/
     Mashed & Spec
    Broccoli/       87           $1.3         0.25%  72          $12.5         0.37%  76         $13.8         0.36%
     Cauliflower
     Processed
    Mixed           88           $1.3         0.24%  124          $4.5         0.13%  119         $5.8         0.15%
     Vegetables
    Authentic       89           $1.3         0.24%  125          $4.5         0.13%  120         $5.7         0.15%
     Peppers
    Sal: Salsa      90           $1.3         0.24%  68          $13.7         0.41%  70         $15.0         0.38%
     Prepack
    Carrots         91           $1.1         0.21%  123          $4.5         0.14%  121         $5.7         0.15%
    Peppers Yellow  92           $1.1         0.21%  80          $11.4         0.34%  82         $12.5         0.32%
     Bell
    Pizza Sauce     93           $1.1         0.21%  110          $6.1         0.18%  107         $7.2         0.18%
    Garlic Jar      94           $1.1         0.21%  97           $7.7         0.23%  99          $8.8         0.23%
    Peppers         95           $1.0         0.19%  126          $4.4         0.13%  125         $5.5         0.14%
     Jalapeno
    Tomatoes        96           $1.0         0.19%  78          $12.1         0.36%  80         $13.1         0.34%
     Cherry
    Instore Cut     97           $1.0         0.19%  86           $9.7         0.29%  91         $10.7         0.28%
     Vegetables
    Tomato Stewed   98           $1.0         0.19%  108          $6.4         0.19%  105         $7.4         0.19%
    White Potatoes  99           $1.0         0.18%  128          $4.3         0.13%  127         $5.2         0.13%
    Sauerkraut and  100          $0.9         0.17%  111          $6.0         0.18%  109         $6.9         0.18%
     Cabbage
                           -------------------------        --------------------------------------------------------
      Top 100                  $500.7        94.36%           $3,035.6        90.37%          $3,536.4        90.91%
       Vegetable
       Expenditure
       s *
                           -------------------------        --------------------------------------------------------
      Total                    $520.5        98.08%           $3,251.8        96.80%          $3,772.3        96.97%
       Vegetable
       Expenditure
       s Among Top
       1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total                  $530.7          100%           $3,359.3          100%          $3,890.0          100%
         Vegetable
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

                                              Exhibit D-8: Composite Foods
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
       Composite                                    ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Potato Chips    1           $64.4         5.19%  2          $253.2         4.88%  1         $317.6         4.94%
    Snacks/         2           $44.6         3.59%  10         $100.5         1.94%  7         $145.0         2.26%
     Appetizers
    Fz Ss Prem      3           $43.8         3.53%  4          $175.4         3.38%  4         $219.3         3.41%
     Traditional
     Meals
    Snack Cake--    4           $41.6         3.36%  9          $101.7         1.96%  9         $143.3         2.23%
     Multi Pack
    Fz Ss Economy   5           $40.9         3.30%  15          $80.7         1.56%  11        $121.6         1.89%
     Meals All
    Pizza/Premium   6           $39.7         3.20%  6          $153.3         2.95%  5         $193.0         3.00%
    Sandwiches &    7           $35.9         2.89%  17          $73.6         1.42%  13        $109.4         1.70%
     Handhelds
    Convenient      8           $34.2         2.76%  19          $69.7         1.34%  14        $104.0         1.62%
     Meals--Kids
     Meal C
    Premium [Ice    9           $31.2         2.52%  3          $226.0         4.35%  3         $257.2         4.00%
     Cream &
     Sherbert]
    Condensed Soup  10          $29.7         2.39%  5          $153.6         2.96%  6         $183.2         2.85%
    Fz Family       11          $27.6         2.23%  13          $83.5         1.61%  12        $111.1         1.73%
     Style Entrees
    Traditional     12          $25.6         2.07%  8          $118.7         2.29%  8         $144.4         2.25%
     [Ice Cream &
     Sherbert]
    Fz Ss Prem      13          $24.7         1.99%  1          $271.6         5.23%  2         $296.3         4.61%
     Nutritional
     Meals
    Macaroni &      14          $24.3         1.96%  24          $59.7         1.15%  21         $84.0         1.31%
     Cheese Dnrs
    Can Pasta       15          $22.2         1.79%  36          $47.7         0.92%  29         $69.9         1.09%
    Mult Pk Bag     16          $21.6         1.74%  38          $43.4         0.84%  32         $65.0         1.01%
     Snacks
    Sw Gds: Donuts  17          $21.3         1.72%  14          $82.3         1.58%  15        $103.6         1.61%
    Pizza/Economy   18          $19.8         1.60%  37          $45.1         0.87%  33         $65.0         1.01%
    Frzn Breakfast  19          $19.1         1.54%  29          $55.7         1.07%  23         $74.8         1.16%
     Sandwiches
    Fz Skillet      20          $18.8         1.51%  16          $79.3         1.53%  17         $98.1         1.53%
     Meals
    Cakes:          21          $18.6         1.50%  33          $50.3         0.97%  31         $68.9         1.07%
     Birthday/
     Celebration
     Sh
    Sandwich        22          $18.0         1.45%  18          $71.8         1.38%  19         $89.8         1.40%
     Cookies
    Pizza/          23          $17.9         1.44%  22          $64.1         1.24%  22         $82.0         1.27%
     Traditional
    Rts Soup:       24          $17.6         1.42%  7          $119.9         2.31%  10        $137.5         2.14%
     Chunky/
     Homestyle/Et
    Salsa & Dips    25          $17.1         1.38%  28          $57.0         1.10%  24         $74.1         1.15%
    Sandwiches--(C  26          $16.9         1.36%  20          $67.7         1.30%  20         $84.6         1.32%
     old)
    Sweet Goods--   27          $15.8         1.28%  27          $57.9         1.12%  26         $73.8         1.15%
     Full Size
    Tray Pack/Choc  28          $15.3         1.23%  31          $53.9         1.04%  30         $69.2         1.08%
     Chip Cookies
    Sticks/Enrobed  29          $14.2         1.14%  25          $59.7         1.15%  25         $73.9         1.15%
     [Frozen
     Novelties]
    Water Ice       30          $14.0         1.13%  32          $50.6         0.97%  34         $64.6         1.00%
     [Frozen
     Novelties]
    Pails [Ice      31          $13.9         1.12%  46          $35.1         0.68%  41         $49.1         0.76%
     Cream &
     Sherbert]
    Skillet         32          $13.0         1.05%  57          $25.8         0.50%  49         $38.9         0.60%
     Dinners
    Pizza/Single    33          $12.8         1.03%  39          $43.2         0.83%  38         $56.0         0.87%
     Serve/
     Microwave
    Super Premium   34          $11.8         0.95%  11          $91.1         1.76%  16        $103.0         1.60%
     Pints [Ice
     Cream &
     Sherbert]
    Cakes:          35          $11.1         0.89%  45          $35.3         0.68%  43         $46.3         0.72%
     Cupcakes
    Corn Dogs       36          $10.9         0.88%  68          $20.6         0.40%  59         $31.5         0.49%
    Cookies:        37          $10.8         0.87%  26          $59.6         1.15%  28         $70.4         1.09%
     Regular
    Burritos        38          $10.2         0.82%  69          $20.0         0.39%  61         $30.1         0.47%
    Microwave       39           $9.8         0.79%  40          $39.9         0.77%  40         $49.8         0.77%
     Dinners
    Cakes: Layers   40           $9.8         0.79%  42          $38.2         0.74%  42         $48.1         0.75%
    Sushi--In       41           $9.2         0.74%  12          $85.4         1.64%  18         $94.6         1.47%
     Store
     Prepared
    Canister        42           $9.1         0.73%  44          $36.4         0.70%  45         $45.5         0.71%
     Snacks
    Pudding &       43           $8.7         0.70%  53          $27.6         0.53%  51         $36.3         0.56%
     Gelatin Cups/
     Cans
    Salty Snacks    44           $8.4         0.67%  80          $15.8         0.31%  67         $24.2         0.38%
     Vending
    Cones [Frozen   45           $7.9         0.64%  50          $31.2         0.60%  48         $39.2         0.61%
     Novelties]
    Vanilla Wafer/  46           $7.5         0.60%  43          $36.7         0.71%  46         $44.2         0.69%
     Kids Cookies
    Ice Cream       47           $7.4         0.60%  60          $24.2         0.47%  58         $31.6         0.49%
     Sandwiches
    Cakes: Creme/   48           $7.4         0.59%  58          $25.8         0.50%  54         $33.2         0.52%
     Pudding
    Refrigerated    49           $7.0         0.57%  34          $49.5         0.95%  37         $56.5         0.88%
     Pudding
    Layer Cake Mix  50           $7.0         0.56%  47          $35.1         0.68%  47         $42.1         0.65%
    Refrigerated    51           $6.8         0.55%  51          $28.8         0.56%  53         $35.6         0.55%
     Cookies--Bran
     d
    Broth           52           $6.7         0.54%  21          $65.6         1.26%  27         $72.3         1.12%
    Pies: Fruit/    53           $6.3         0.51%  41          $39.6         0.76%  44         $45.9         0.71%
     Nut
    Snack Cake--    54           $5.7         0.46%  77          $16.2         0.31%  74         $22.0         0.34%
     Single Serve
    Better For You  55           $5.6         0.45%  35          $48.1         0.93%  39         $53.7         0.84%
     Snacks
    Cookies:        56           $5.5         0.44%  56          $26.8         0.52%  56         $32.2         0.50%
     Holiday/
     Special Occas
    Misc Bag        57           $5.5         0.44%  98          $11.5         0.22%  83         $17.0         0.26%
     Snacks
    Frozen Fruit    58           $5.3         0.43%  62          $23.7         0.46%  62         $28.9         0.45%
     Pies &
     Cobblers
    Frozen Cream    59           $4.9         0.39%  71          $18.9         0.36%  69         $23.8         0.37%
     Pies
    Sw Gds: Sw      60           $4.8         0.39%  55          $26.9         0.52%  57         $31.7         0.49%
     Rolls/Dan
    Brownie Mix     61           $4.8         0.39%  54          $27.5         0.53%  55         $32.3         0.50%
    Fz Meal Kits/   62           $4.8         0.38%  96          $12.2         0.23%  84         $16.9         0.26%
     Stuffed/Other
    Sw Gds:         63           $4.5         0.36%  48          $31.8         0.61%  50         $36.3         0.57%
     Muffins
    Frzn Breakfast  64           $4.5         0.36%  78          $16.2         0.31%  78         $20.7         0.32%
     Entrees
    Convenient      65           $4.5         0.36%  102         $11.2         0.22%  92         $15.7         0.24%
     Meals--Adult
     Meal
    Dry Beans/Peas/ 66           $4.2         0.34%  72          $18.8         0.36%  71         $23.1         0.36%
     Barley: Bag &
     B
    Adult Premium   67           $4.2         0.34%  30          $54.5         1.05%  36         $58.7         0.91%
     [Frozen
     Novelties]
    Mexican         68           $4.2         0.34%  100         $11.4         0.22%  93         $15.6         0.24%
     Dinners And
     Foods
    Premium         69           $4.2         0.33%  49          $31.5         0.61%  52         $35.7         0.55%
     Cookies (Ex:
     Pepperidg)
    Chocolate       70           $4.0         0.32%  73          $18.5         0.36%  73         $22.5         0.35%
     Covered
     Cookies
    Microwavable    71           $3.7         0.29%  116          $9.0         0.17%  106        $12.7         0.20%
     Cups
    Cakes:          72           $3.6         0.29%  84          $14.7         0.28%  81         $18.3         0.28%
     Cheesecake
    Deli Tray:      73           $3.5         0.28%  65          $21.5         0.41%  66         $25.0         0.39%
     Meat And
     Cheese
    Dry Soup        74           $3.5         0.28%  63          $23.3         0.45%  64         $26.8         0.42%
    Treats          75           $3.5         0.28%  103         $11.2         0.22%  95         $14.6         0.23%
    Fitness &       76           $3.4         0.28%  23          $59.8         1.15%  35         $63.2         0.98%
     Diet--Bars W/
     Flour
    Refrigerated    77           $3.4         0.28%  90          $12.9         0.25%  89         $16.3         0.25%
     Cookie Dough
    Cakes: Fancy/   78           $3.3         0.27%  76          $17.4         0.34%  77         $20.7         0.32%
     Service Case
    Package         79           $3.3         0.26%  112          $9.5         0.18%  105        $12.7         0.20%
     Dinners/Pasta
     Salads
    Cakes: Layers/  80           $3.3         0.26%  94          $12.5         0.24%  91         $15.8         0.25%
     Sheets
     Novelties
    Pies: Pumpkin/  81           $3.2         0.26%  89          $13.1         0.25%  87         $16.3         0.25%
     Custard
    Puddings Dry    82           $3.2         0.26%  67          $20.8         0.40%  68         $23.9         0.37%
    Vendor Size/    83           $3.1         0.25%  126          $6.8         0.13%  120         $9.9         0.15%
     Single Serve
     Cooki
    Snack Mix       84           $3.0         0.24%  75          $17.5         0.34%  79         $20.5         0.32%
    Multi-Pack      85           $2.9         0.23%  99          $11.4         0.22%  96         $14.3         0.22%
     Cookies
    Cups/Push Ups/  86           $2.8         0.23%  110          $9.6         0.18%  108        $12.4         0.19%
     Other
    Frzn Pie        87           $2.7         0.22%  79          $16.0         0.31%  80         $18.7         0.29%
     Shells/Pastry
     Shell/F
    Frozen Cakes/   88           $2.7         0.22%  105         $11.0         0.21%  101        $13.7         0.21%
     Desserts
    Cakes: Angel    89           $2.7         0.22%  74          $18.1         0.35%  76         $20.8         0.32%
     Fds/Cke Rolls
    Wellness/       90           $2.7         0.22%  61          $23.8         0.46%  65         $26.5         0.41%
     Portion
     Control
    Pie Filling/    91           $2.7         0.22%  59          $24.8         0.48%  63         $27.5         0.43%
     Mincemeat/
     Glazes
    Misc Snacks     92           $2.6         0.21%  87          $13.2         0.25%  90         $15.8         0.25%
    Cakes: Ice      93           $2.6         0.21%  120          $8.6         0.17%  113        $11.2         0.17%
     Cream
    Sushi--Prepack  94           $2.6         0.21%  70          $19.2         0.37%  75         $21.8         0.34%
     aged
    Cakes:          95           $2.5         0.20%  114          $9.1         0.18%  110        $11.6         0.18%
     Birthday/
     Celebration
     Lay
    Sw Gds: Swt/    96           $2.4         0.20%  85          $13.9         0.27%  88         $16.3         0.25%
     Flvrd Loaves
    Cakes: Sheet    97           $2.4         0.19%  124          $7.2         0.14%  121         $9.6         0.15%
    Cookies:        98           $2.4         0.19%  66          $20.8         0.40%  70         $23.2         0.36%
     Gourmet
    Premium Pints   99           $2.3         0.18%  128          $6.5         0.13%  125         $8.8         0.14%
     [Ice Cream &
     Sherbert]
    Sw Gds:         100          $1.9         0.15%  104         $11.2         0.22%  104        $13.1         0.20%
     Brownie/Bar
     Cookie
                           -------------------------        --------------------------------------------------------
      Top 100                $1,179.3        95.05%           $4,717.8        90.90%          $5,897.1        91.70%
       Composite
       Expenditure
       s *
                           -------------------------        --------------------------------------------------------
      Total                  $1,235.4        99.57%           $5,132.0        98.88%          $6,367.4        99.01%
       Composite
       Expenditure
       s Among Top
       1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total                $1,240.7          100%           $5,190.0          100%          $6,430.7          100%
         Composite
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

                                            Exhibit D-9: Other Subcommodities
    ----------------------------------------------------------------------------------------------------------------
                      SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   ---------------------------------           Expenditures          -------------------------------
         Other                                      ---------------------------------
     Subcommodity    Rank      $ in        % of                 $ in        % of       Rank     $ in        % of
                             millions  Expenditures   Rank    millions  Expenditures          millions  Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Infant Formula  1           $54.2         9.60%  14          $45.3         1.70%  6          $99.5         3.07%
     Starter/
     Solution
    Still Water     2           $48.8         8.64%  2          $187.7         7.03%  2         $236.5         7.31%
     Drnking/Mnrl
     Water
    Unflavored Can  3           $41.3         7.32%  1          $198.0         7.41%  1         $239.3         7.39%
     Coffee
    Isotonic        4           $30.5         5.40%  4          $119.5         4.47%  3         $150.0         4.63%
     Drinks Single
     Serve
    Spring Water    5           $16.2         2.87%  5           $95.6         3.58%  5         $111.8         3.45%
    Traditional     6           $14.1         2.49%  8           $61.2         2.29%  7          $75.2         2.32%
     Spices
    Bbq Sauce       7           $12.3         2.17%  16          $38.6         1.45%  16         $50.9         1.57%
    Baby Food--     8           $11.7         2.07%  21          $28.1         1.05%  18         $39.8         1.23%
     Beginner
    Non-Carb Water  9           $11.6         2.05%  7           $63.4         2.37%  8          $74.9         2.32%
     Flvr--Drnk/
     Mnr
    Catsup          10          $11.5         2.03%  15          $41.5         1.55%  15         $53.0         1.64%
    Sauce Mixes/    11          $11.5         2.03%  13          $46.7         1.75%  12         $58.2         1.80%
     Gravy Mixes
     Dry
    Baby Food       12          $11.2         1.98%  22          $27.5         1.03%  19         $38.7         1.20%
     Junior/All
     Brands
    Isotonic        13          $10.8         1.92%  9           $58.1         2.17%  10         $68.9         2.13%
     Drinks Multi-
     Pack
    Ice--Crushed/   14           $9.3         1.65%  11          $49.9         1.87%  11         $59.2         1.83%
     Cubed
    Unflavored Bag  15           $8.5         1.50%  3          $137.3         5.14%  4         $145.8         4.50%
     Coffee
    Infant Formula  16           $8.4         1.49%  71           $9.1         0.34%  47         $17.5         0.54%
     Specialty
    Infant Formula  17           $8.3         1.46%  30          $22.8         0.85%  27         $31.0         0.96%
     Starter Large
     P
    Steak &         18           $8.2         1.44%  25          $26.7         1.00%  21         $34.9         1.08%
     Worchester
     Sauce
    Unflavored      19           $7.6         1.34%  23          $27.3         1.02%  22         $34.8         1.08%
     Instant
     Coffee
    Non-Dairy       20           $7.1         1.25%  6           $67.7         2.53%  9          $74.8         2.31%
     Milks
    Unsweetened     21           $7.0         1.25%  88           $6.2         0.23%  61         $13.3         0.41%
     Envelope
     [Powder Drink
     Mix]
    Malted Mlk/     22           $6.9         1.23%  28          $25.3         0.95%  26         $32.2         1.00%
     Syrup/Pwdrs
     (Eggnog)
    Still Water     23           $6.3         1.11%  17          $38.1         1.43%  17         $44.4         1.37%
     Flvrd Drnk/
     Mnrl Wt
    Infant Formula  24           $6.0         1.06%  55          $12.4         0.46%  45         $18.4         0.57%
     Toddler
    Mexican         25           $5.9         1.05%  33          $20.6         0.77%  32         $26.5         0.82%
     Seasoning
     Mixes
    Hot Sauce       26           $5.8         1.03%  42          $16.4         0.61%  38         $22.2         0.69%
    Ready To Drink  27           $5.5         0.98%  34          $20.5         0.77%  33         $26.0         0.80%
     Coffee
    Tea Bags &      28           $5.4         0.95%  24          $27.2         1.02%  25         $32.5         1.01%
     Bulk Tea
    Infant Formula  29           $5.3         0.95%  47          $15.2         0.57%  42         $20.5         0.63%
     Solutions
     Large
    Stuffing Mixes  30           $5.3         0.94%  31          $22.1         0.83%  30         $27.4         0.85%
    Infant Formula  31           $4.9         0.86%  111          $3.9         0.15%  82          $8.8         0.27%
     Concentrate
    Salad Bar       32           $4.5         0.81%  41          $18.2         0.68%  36         $22.8         0.70%
     Other
    Bits & Morsels  33           $4.4         0.77%  10          $50.3         1.88%  13         $54.7         1.69%
     [Baking
     Needs]
    Ripe Olives     34           $4.1         0.73%  27          $25.3         0.95%  28         $29.5         0.91%
    Gravy Can/      35           $4.0         0.72%  44          $15.7         0.59%  44         $19.8         0.61%
     Glass
    Marinades       36           $3.9         0.70%  39          $18.4         0.69%  37         $22.4         0.69%
    Baby Food       37           $3.8         0.67%  82           $7.1         0.27%  70         $10.9         0.34%
     Cereals
    Diet Cntrl      38           $3.7         0.66%  20          $30.3         1.13%  24         $34.0         1.05%
     Liqs
     Nutritional
    Enhancements--  39           $3.6         0.64%  36          $19.8         0.74%  35         $23.4         0.72%
     Pickles/Kraut
    Infant Formula  40           $3.5         0.61%  85           $6.9         0.26%  72         $10.4         0.32%
     Ready To Use
    Sugar Free      41           $3.5         0.61%  32          $21.1         0.79%  34         $24.5         0.76%
     Canister
     [Powder Drink
     Mix]
    Coffee Pods/    42           $3.4         0.60%  12          $49.8         1.87%  14         $53.2         1.65%
     Singles/
     Filter Pac
    Sugar Free      43           $3.3         0.58%  38          $18.8         0.70%  39         $22.1         0.68%
     Sticks
     [Powder Drink
     Mix]
    Sparkling       44           $3.1         0.55%  29          $24.1         0.90%  31         $27.2         0.84%
     Water--Flvrd
     Sweet
    Tea Bags/       45           $3.1         0.54%  19          $31.2         1.17%  23         $34.3         1.06%
     Herbal
    Yellow Mustard  46           $3.0         0.53%  56          $12.4         0.46%  55         $15.4         0.48%
    Asian Other     47           $2.8         0.50%  37          $18.9         0.71%  40         $21.8         0.67%
     Sauces/
     Marinad
    Peppers         48           $2.7         0.48%  52          $13.5         0.50%  53         $16.2         0.50%
    Mexican Taco    49           $2.6         0.47%  84           $7.0         0.26%  76          $9.7         0.30%
     Sauce
    Green Olives    50           $2.6         0.46%  43          $15.8         0.59%  46         $18.3         0.57%
    Relishes        51           $2.5         0.44%  60          $11.6         0.43%  57         $14.1         0.44%
    Flavored Bag    52           $2.4         0.42%  26          $26.2         0.98%  29         $28.6         0.88%
     Coffee
    Gourmet Spices  53           $2.4         0.42%  18          $33.2         1.24%  20         $35.6         1.10%
    Baby Juices     54           $2.3         0.40%  118          $3.1         0.11%  105         $5.3         0.16%
    Dry Salad       55           $2.0         0.35%  48          $15.1         0.57%  49         $17.1         0.53%
     Dressing &
     Dip Mixes
    Mustard--All    56           $2.0         0.35%  40          $18.3         0.69%  43         $20.3         0.63%
     Other
    Gelatin         57           $2.0         0.35%  51          $14.3         0.54%  52         $16.3         0.50%
    Vinegar/White   58           $1.9         0.34%  50          $14.4         0.54%  51         $16.3         0.50%
     & Cider
    Baby Isotonic   59           $1.9         0.33%  101          $4.9         0.18%  92          $6.8         0.21%
     Drinks
    Wing Sauce      60           $1.8         0.33%  100          $5.0         0.19%  91          $6.8         0.21%
    Pure Extracts   61           $1.7         0.31%  46          $15.4         0.58%  48         $17.2         0.53%
    Infant Formula  62           $1.7         0.31%  161          $1.1         0.04%  135         $2.8         0.09%
     Soy Base
    Juices          63           $1.7         0.30%  66          $10.1         0.38%  64         $11.8         0.36%
     Proteins
    Sal: Dip        64           $1.7         0.30%  59          $12.1         0.45%  58         $13.8         0.43%
     Prepack
    Diet Energy     65           $1.7         0.30%  54          $12.8         0.48%  56         $14.5         0.45%
     Drinks
    Baby Spring     66           $1.7         0.30%  138          $2.0         0.07%  119         $3.7         0.11%
     Waters
    Frozen          67           $1.6         0.28%  86           $6.7         0.25%  83          $8.3         0.26%
     Internaional
    Table Salt/     68           $1.6         0.28%  72           $8.6         0.32%  73         $10.2         0.31%
     Popcorn Salt/
     Ice Cr
    Distilled       69           $1.6         0.28%  57          $12.2         0.46%  59         $13.7         0.42%
     Water
    Enhancements--  70           $1.5         0.26%  99           $5.2         0.19%  95          $6.6         0.21%
     Salads/
     Spreads
    Asian Soy       71           $1.5         0.26%  64          $10.3         0.39%  66         $11.7         0.36%
     Sauce
    Central         72           $1.4         0.25%  94           $5.5         0.21%  90          $6.9         0.21%
     American
     Foods
    Misc Dairy      73           $1.4         0.25%  70           $9.1         0.34%  71         $10.5         0.32%
     Refigerated
    Diet Cntrl      74           $1.4         0.24%  35          $19.9         0.74%  41         $21.3         0.66%
     Bars
     Nutritional
    Tea Bags/Green  75           $1.2         0.22%  61          $11.2         0.42%  63         $12.5         0.38%
    Flours/Grains/  76           $1.2         0.22%  49          $14.6         0.55%  54         $15.9         0.49%
     Sugar
    Specialty       77           $1.2         0.22%  77           $7.7         0.29%  81          $8.9         0.27%
     Instant
     Coffee W/Swe
    Misc Hispanic   78           $1.2         0.21%  65          $10.2         0.38%  67         $11.4         0.35%
     Grocery
    Baking Powder   79           $1.1         0.20%  75           $8.2         0.31%  77          $9.4         0.29%
     & Soda
    Isotonic        80           $1.1         0.19%  103          $4.7         0.18%  103         $5.7         0.18%
     Drinks Multi-
     Serve
    Juices          81           $1.0         0.19%  76           $8.1         0.30%  78          $9.2         0.28%
     Antioxidant/
     Wellness
    Spices &        82           $1.0         0.19%  104          $4.6         0.17%  104         $5.7         0.17%
     Seasonings
    Infant Formula  83           $1.0         0.18%  119          $3.0         0.11%  117         $4.1         0.13%
     Up Age
    Oils/Vinegar    84           $1.0         0.18%  67          $10.0         0.37%  69         $11.0         0.34%
    Miscellaneous   85           $1.0         0.18%  80           $7.2         0.27%  84          $8.2         0.25%
     Package Mixes
    Sal: Olives/    86           $1.0         0.18%  45          $15.5         0.58%  50         $16.5         0.51%
     Pickles--Bulk
    Cooking Bags    87           $1.0         0.17%  132          $2.4         0.09%  124         $3.4         0.10%
     With Spices/
     Seaso
    Cooking         88           $0.9         0.16%  63          $10.3         0.39%  68         $11.2         0.35%
     Chocolate
     (Ex: Smi-Swt)
    Tea Bags        89           $0.9         0.15%  69           $9.2         0.34%  74         $10.0         0.31%
     (Supplement)
    Specialty       90           $0.8         0.15%  53          $12.9         0.48%  60         $13.7         0.42%
     Vinegar
    Traditional     91           $0.8         0.14%  74           $8.3         0.31%  80          $9.1         0.28%
     Thai Foods
    Pickld Veg/     92           $0.8         0.14%  91           $5.9         0.22%  94          $6.7         0.21%
     Peppers/Etc.
    Specialty       93           $0.8         0.14%  62          $11.0         0.41%  65         $11.7         0.36%
     Olives
    Authentic       94           $0.8         0.14%  81           $7.1         0.27%  86          $7.9         0.24%
     Japanese
     Foods
    Chili Sauce/    95           $0.7         0.13%  89           $6.0         0.22%  93          $6.7         0.21%
     Cocktail
     Sauce
    Flavored Can    96           $0.7         0.13%  92           $5.8         0.22%  96          $6.5         0.20%
     Coffee
    Fortified/      97           $0.7         0.13%  108          $4.4         0.17%  107         $5.1         0.16%
     Water
    Sparkling       98           $0.7         0.12%  58          $12.1         0.45%  62         $12.8         0.40%
     Water--Unflav
     ored
    Fitness &       99           $0.7         0.12%  78           $7.3         0.27%  85          $8.0         0.25%
     Diet--Powder
     Ntrtnl
    Imitation       100          $0.7         0.12%  115          $3.5         0.13%  116         $4.2         0.13%
     Extracts
                           -------------------------        --------------------------------------------------------
      Top 100                  $540.1        95.68%           $2,453.1        91.80%          $2,993.1        92.48%
       Other
       Expenditure
       s *
                           -------------------------        --------------------------------------------------------
      Total Other              $550.7        97.56%           $2,533.2        94.80%          $3,083.9        95.28%
       Expenditure
       s Among Top
       1,000
       Subcommodit
       ies
                           =========================        ========================================================
        Total                  $564.5          100%           $2,672.1          100%          $3,236.6          100%
         Other
         Expenditu
         res Among
         1,792
         Subcommod
         ities
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

    Appendix E. Top 100 Subcommodities for SNAP Households by Expenditure
            by Demographic and Store Characteristics

       Exhibit E-1: Top 100 Subcommodities for SNAP Households by Expenditure: Household Head Age 19-44 Year Olds
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $30.7         0.47%  1          $143.7         0.46%  1          $174.3         0.46%
     White Only
    Soft Drinks 12/ 2          $25.1         0.38%  2           $95.9         0.30%  2          $121.0         0.32%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $17.2         0.26%  8           $42.7         0.14%  5           $59.9         0.16%
    Kids Cereal     4          $13.8         0.21%  5           $44.6         0.14%  6           $58.4         0.15%
    Shredded        5          $13.0         0.20%  3           $67.1         0.21%  3           $80.1         0.21%
     Cheese
    Sft Drnk 2      6          $11.3         0.17%  13          $39.1         0.12%  8           $50.5         0.13%
     Liter Btl
     Carb Incl
    Potato Chips    7          $10.1         0.15%  11          $39.4         0.13%  9           $49.5         0.13%
    Primal [Beef]   8          $10.0         0.15%  16          $35.6         0.11%  14          $45.5         0.12%
    Infant Formula  9           $9.8         0.15%  150          $9.2         0.03%  73          $19.0         0.05%
     Starter/
     Solutio
    Lunchment--Del  10          $8.9         0.14%  6           $43.0         0.14%  7           $51.9         0.14%
     i Fresh
    Chicken Breast  11          $8.4         0.13%  4           $54.2         0.17%  4           $62.5         0.16%
     Boneless
    Tortilla/Nacho  12          $8.2         0.13%  10          $41.1         0.13%  10          $49.3         0.13%
     Chips
    Eggs--Large     13          $7.8         0.12%  12          $39.4         0.13%  12          $47.2         0.12%
    Snacks/         14          $7.7         0.12%  45          $20.6         0.07%  32          $28.3         0.07%
     Appetizers
    Still Water     15          $7.6         0.12%  20          $30.5         0.10%  18          $38.1         0.10%
     Drnking/Mnrl
     Water
    Mainstream      16          $7.4         0.11%  31          $23.4         0.07%  25          $30.8         0.08%
     White Bread
    American        17          $7.0         0.11%  34          $22.8         0.07%  26          $29.8         0.08%
     Single Cheese
    Dairy Case      18          $6.8         0.10%  9           $41.4         0.13%  11          $48.2         0.13%
     100% Pure
     Juice--O
    Enhanced [Pork  19          $6.6         0.10%  24          $27.1         0.09%  23          $33.6         0.09%
     Boneless Loin/
     Rib]
    Pizza/Premium   20          $6.5         0.10%  22          $28.2         0.09%  20          $34.8         0.09%
    Snack Cake--    21          $6.5         0.10%  57          $18.9         0.06%  40          $25.5         0.07%
     Multi Pack
    Fz Ss Economy   22          $6.3         0.10%  90          $13.6         0.04%  72          $19.9         0.05%
     Meals All
    Convenient      23          $6.2         0.09%  48          $20.3         0.06%  38          $26.6         0.07%
     Meals--Kids
     Meal C
    All Family      24          $6.2         0.09%  14          $37.6         0.12%  15          $43.8         0.11%
     Cereal
    Fz Ss Prem      25          $6.1         0.09%  52          $19.7         0.06%  39          $25.8         0.07%
     Traditional
     Meals
    Sandwiches &    26          $6.0         0.09%  77          $14.9         0.05%  64          $20.9         0.05%
     Handhelds
    Soft Drinks     27          $6.0         0.09%  61          $17.9         0.06%  48          $23.9         0.06%
     20pk & 24pk
     Can Carb
    Bacon--Trad     28          $6.0         0.09%  30          $23.5         0.07%  29          $29.4         0.08%
     16oz Or Less
    Mainstream      29          $5.8         0.09%  23          $28.0         0.09%  22          $33.8         0.09%
     Variety
     Breads
    Sugar           30          $5.6         0.09%  62          $17.9         0.06%  50          $23.5         0.06%
    Natural Cheese  31          $5.6         0.08%  17          $34.5         0.11%  17          $40.1         0.11%
     Chunks
    Unflavored Can  32          $5.5         0.08%  32          $23.3         0.07%  30          $28.8         0.08%
     Coffee
    Frzn Chicken--  33          $5.4         0.08%  51          $19.9         0.06%  42          $25.2         0.07%
     Wht Meat
    Potatoes        34          $5.3         0.08%  37          $22.4         0.07%  35          $27.7         0.07%
     Russet (Bulk
     & Bag)
    Bananas         35          $5.2         0.08%  15          $37.0         0.12%  16          $42.2         0.11%
    Isotonic        36          $5.1         0.08%  33          $22.9         0.07%  34          $28.0         0.07%
     Drinks Single
     Serve
    Ribs [Pork]     37          $5.1         0.08%  78          $14.8         0.05%  71          $19.9         0.05%
    Sft Drnk Mlt-   38          $5.0         0.08%  35          $22.6         0.07%  36          $27.6         0.07%
     Pk Btl Carb
     (Excp)
    Premium [Ice    39          $4.7         0.07%  18          $32.9         0.10%  19          $37.6         0.10%
     Cream &
     Sherbert]
    Sft Drnk Sngl   40          $4.7         0.07%  89          $13.7         0.04%  77          $18.4         0.05%
     Srv Btl Carb
     (Ex)
    Pourable Salad  41          $4.7         0.07%  36          $22.4         0.07%  37          $27.1         0.07%
     Dressings
    Condensed Soup  42          $4.6         0.07%  29          $24.0         0.08%  31          $28.6         0.08%
    Choice Beef     43          $4.5         0.07%  86          $14.0         0.04%  76          $18.5         0.05%
    Fz Family       44          $4.5         0.07%  82          $14.3         0.05%  74          $18.8         0.05%
     Style Entrees
    Aseptic Pack    45          $4.4         0.07%  66          $16.9         0.05%  61          $21.3         0.06%
     Juice And
     Drinks
    Select Beef     46          $4.3         0.06%  46          $20.5         0.07%  45          $24.8         0.07%
    Macaroni &      47          $4.2         0.06%  92          $13.5         0.04%  82          $17.7         0.05%
     Cheese Dnrs
    Choice Beef     48          $4.1         0.06%  63          $17.8         0.06%  56          $21.9         0.06%
    Mainstream      49          $4.0         0.06%  70          $16.1         0.05%  67          $20.1         0.05%
     [Pasta &
     Pizza Sauce]
    Mayonnaise &    50          $4.0         0.06%  67          $16.8         0.05%  65          $20.8         0.05%
     Whipped
     Dressing
    Fz Ss Prem      51          $4.0         0.06%  7           $42.9         0.14%  13          $46.9         0.12%
     Nutritional
     Meals
    Refrigerated    52          $4.0         0.06%  26          $25.8         0.08%  27          $29.7         0.08%
     Coffee
     Creamers
    Fz Bag          53          $3.9         0.06%  54          $19.4         0.06%  51          $23.3         0.06%
     Vegetables--P
     lain
    Hot Dogs--Base  54          $3.9         0.06%  137          $9.8         0.03%  113         $13.6         0.04%
     Meat
    Strawberries    55          $3.8         0.06%  19          $30.7         0.10%  21          $34.5         0.09%
    Adult Cereal    56          $3.8         0.06%  25          $25.8         0.08%  28          $29.6         0.08%
    Can Pasta       57          $3.8         0.06%  119         $10.8         0.03%  102         $14.6         0.04%
    Mexican Soft    58          $3.8         0.06%  39          $21.7         0.07%  41          $25.4         0.07%
     Tortillas And
     Wra
    Traditional     59          $3.8         0.06%  69          $16.2         0.05%  70          $19.9         0.05%
     [Ice Cream &
     Sherbert]
    Choice Beef     60          $3.7         0.06%  124         $10.6         0.03%  104         $14.3         0.04%
    Mult Pk Bag     61          $3.6         0.05%  132         $10.0         0.03%  114         $13.6         0.04%
     Snacks
    Pizza/Economy   62          $3.5         0.05%  128         $10.3         0.03%  111         $13.7         0.04%
    Margarine:      63          $3.5         0.05%  88          $13.8         0.04%  84          $17.3         0.05%
     Tubs And
     Bowls
    Frzn Chicken--  64          $3.4         0.05%  441          $3.0         0.01%  269          $6.4         0.02%
     Wings
    Frzn French     65          $3.4         0.05%  143          $9.6         0.03%  119         $13.0         0.03%
     Fries
    Peanut Butter   66          $3.4         0.05%  40          $21.4         0.07%  44          $24.8         0.07%
    Candy Bags--    67          $3.4         0.05%  42          $20.8         0.07%  47          $24.2         0.06%
     Chocolate
    Value Forms/    68          $3.3         0.05%  120         $10.7         0.03%  108         $13.9         0.04%
     18oz And
     Larger
     [Chicken]
    Fruit Snacks    69          $3.3         0.05%  104         $12.1         0.04%  94          $15.4         0.04%
    Sw Gds: Donuts  70          $3.2         0.05%  98          $12.5         0.04%  92          $15.7         0.04%
    Meat: Turkey    71          $3.2         0.05%  21          $28.5         0.09%  24          $31.8         0.08%
     Bulk
    Frzn Meat--     72          $3.2         0.05%  161          $8.8         0.03%  139         $12.0         0.03%
     Beef
    Chicken Wings   73          $3.1         0.05%  350          $4.0         0.01%  247          $7.2         0.02%
    Frzn Breakfast  74          $3.1         0.05%  125         $10.5         0.03%  115         $13.6         0.04%
     Sandwiches
    Tuna            75          $3.1         0.05%  74          $15.6         0.05%  75          $18.8         0.05%
    Waffles/        76          $3.1         0.05%  59          $18.2         0.06%  62          $21.3         0.06%
     Pancakes/
     French Toast
    Cakes:          77          $3.1         0.05%  152          $9.2         0.03%  136         $12.2         0.03%
     Birthday/
     Celebration
     Sh
    Sour Creams     78          $3.0         0.05%  64          $17.5         0.06%  66          $20.5         0.05%
    Cheese          79          $3.0         0.05%  44          $20.7         0.07%  49          $23.7         0.06%
     Crackers
    Fz Skillet      80          $3.0         0.05%  97          $12.6         0.04%  93          $15.6         0.04%
     Meals
    Vegetable Oil   81          $3.0         0.05%  253          $5.7         0.02%  196          $8.7         0.02%
    Lunchment--Bol  82          $3.0         0.05%  177          $8.1         0.03%  149         $11.1         0.03%
     ogna/Sausage
    Pizza/          83          $3.0         0.05%  101         $12.3         0.04%  97          $15.3         0.04%
     Traditional
    Cream Cheese    84          $3.0         0.04%  49          $20.3         0.06%  53          $23.2         0.06%
    Sandwich        85          $2.9         0.04%  100         $12.4         0.04%  95          $15.4         0.04%
     Cookies
    Butter          86          $2.9         0.04%  27          $25.1         0.08%  33          $28.0         0.07%
    Ramen Noodles/  87          $2.9         0.04%  258          $5.6         0.02%  208          $8.5         0.02%
     Ramen Cups
    String Cheese   88          $2.8         0.04%  38          $22.0         0.07%  46          $24.7         0.06%
    Bagged Cheese   89          $2.7         0.04%  153          $9.0         0.03%  142         $11.7         0.03%
     Snacks
    Salsa & Dips    90          $2.7         0.04%  136          $9.8         0.03%  129         $12.5         0.03%
    Toaster         91          $2.7         0.04%  107         $11.8         0.04%  103         $14.5         0.04%
     Pastries
    Hot Dog Buns    92          $2.7         0.04%  110         $11.2         0.04%  109         $13.9         0.04%
    Hamburger Buns  93          $2.7         0.04%  103         $12.2         0.04%  100         $14.9         0.04%
    Rts Soup:       94          $2.7         0.04%  65          $17.4         0.06%  68          $20.0         0.05%
     Chunky/
     Homestyle/Et
    Flavored Milk   95          $2.6         0.04%  118         $10.8         0.03%  116         $13.4         0.04%
    Candy Bars      96          $2.6         0.04%  158          $8.9         0.03%  146         $11.5         0.03%
     (Singles)
     (Including)
    Yogurt/Kids     97          $2.6         0.04%  80          $14.4         0.05%  85          $17.0         0.04%
    Angus [Beef]    98          $2.6         0.04%  75          $15.3         0.05%  80          $17.9         0.05%
    Chicken Drums   99          $2.5         0.04%  297          $4.8         0.02%  241          $7.3         0.02%
    Sweet Goods--   100         $2.5         0.04%  145          $9.5         0.03%  137         $12.0         0.03%
     Full Size
                          -------------------------       ----------------------------------------------------------
      Top 100                 $537.8         8.17%           $2,251.0         7.14%           $2,788.8         7.32%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

       Exhibit E-2: Top 100 Subcommodities for SNAP Households by Expenditure: Household Head Age 45-64 Year Olds
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $41.3         0.63%  1          $258.9         0.82%  1          $300.1         0.79%
     White Only
    Soft Drinks 12/ 2          $36.6         0.56%  2          $197.3         0.63%  2          $233.9         0.61%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $22.4         0.34%  8           $77.3         0.25%  5           $99.7         0.26%
    Shredded        4          $16.7         0.25%  3          $112.7         0.36%  6          $129.4         0.34%
     Cheese
    Sft Drnk 2      5          $15.6         0.24%  14          $70.8         0.22%  3           $86.4         0.23%
     Liter Btl
     Carb Incl
    Kids Cereal     6          $15.0         0.23%  27          $52.7         0.17%  8           $67.7         0.18%
    Primal [Beef]   7          $14.6         0.22%  11          $74.6         0.24%  9           $89.2         0.23%
    Potato Chips    8          $14.6         0.22%  6           $85.6         0.27%  14         $100.2         0.26%
    Lunchment--Del  9          $12.2         0.19%  9           $76.8         0.24%  73          $89.1         0.23%
     i Fresh
    Eggs--Large     10         $11.3         0.17%  10          $75.4         0.24%  7           $86.7         0.23%
    Chicken Breast  11         $11.1         0.17%  4           $95.0         0.30%  4          $106.1         0.28%
     Boneless
    Unflavored Can  12         $10.2         0.16%  18          $64.2         0.20%  10          $74.4         0.20%
     Coffee
    Mainstream      13         $10.2         0.15%  44          $40.6         0.13%  12          $50.8         0.13%
     White Bread
    Fz Ss Prem      14         $10.1         0.15%  26          $53.5         0.17%  32          $63.7         0.17%
     Traditional
     Meals
    Tortilla/Nacho  15         $10.0         0.15%  17          $67.1         0.21%  18          $77.1         0.20%
     Chips
    Still Water     16          $9.9         0.15%  22          $56.0         0.18%  25          $65.9         0.17%
     Drnking/Mnrl
     Water
    Infant Formula  17          $9.8         0.15%  363          $7.7         0.02%  26          $17.4         0.05%
     Starter/
     Solutio
    Dairy Case      18          $9.7         0.15%  7           $80.7         0.26%  11          $90.4         0.24%
     100% Pure
     Juice--O
    American        19          $9.4         0.14%  42          $41.5         0.13%  23          $50.9         0.13%
     Single Cheese
    Bacon--Trad     20          $9.1         0.14%  30          $50.1         0.16%  20          $59.2         0.16%
     16oz Or Less
    Enhanced [Pork  21          $9.0         0.14%  24          $54.8         0.17%  40          $63.9         0.17%
     Boneless Loin/
     Rib]
    Snacks/         22          $8.9         0.14%  64          $32.2         0.10%  72          $41.1         0.11%
     Appetizers
    Snack Cake--    23          $8.8         0.13%  66          $31.8         0.10%  38          $40.5         0.11%
     Multi Pack
    Sft Drnk Mlt-   24          $8.6         0.13%  19          $61.3         0.19%  15          $69.9         0.18%
     Pk Btl Carb
     (Excp)
    Mainstream      25          $8.4         0.13%  29          $50.8         0.16%  39          $59.2         0.16%
     Variety
     Breads
    Fz Ss Economy   26          $8.3         0.13%  104         $22.2         0.07%  64          $30.6         0.08%
     Meals All
    Pizza/Premium   27          $8.3         0.13%  34          $48.7         0.15%  48          $57.0         0.15%
    Natural Cheese  28          $8.3         0.13%  15          $69.9         0.22%  29          $78.2         0.21%
     Chunks
    All Family      29          $8.1         0.12%  16          $68.0         0.22%  22          $76.1         0.20%
     Cereal
    Soft Drinks     30          $8.1         0.12%  62          $33.3         0.11%  50          $41.5         0.11%
     20pk & 24pk
     Can Carb
    Potatoes        31          $8.1         0.12%  31          $49.4         0.16%  17          $57.5         0.15%
     Russet (Bulk
     & Bag)
    Bananas         32          $7.9         0.12%  12          $74.3         0.24%  30          $82.3         0.22%
    Sugar           33          $7.7         0.12%  57          $35.2         0.11%  42          $42.9         0.11%
    Ribs [Pork]     34          $7.7         0.12%  59          $34.9         0.11%  35          $42.6         0.11%
    Premium [Ice    35          $7.4         0.11%  13          $73.2         0.23%  16          $80.6         0.21%
     Cream &
     Sherbert]
    Condensed Soup  36          $7.2         0.11%  33          $49.0         0.16%  34          $56.2         0.15%
    Sandwiches &    37          $7.1         0.11%  100         $22.5         0.07%  71          $29.5         0.08%
     Handhelds
    Fz Ss Prem      38          $6.7         0.10%  5           $91.3         0.29%  36          $98.0         0.26%
     Nutritional
     Meals
    Convenient      39          $6.6         0.10%  143         $18.0         0.06%  19          $24.6         0.06%
     Meals--Kids
     Meal C
    Isotonic        40          $6.6         0.10%  54          $36.0         0.11%  77          $42.6         0.11%
     Drinks Single
     Serve
    Select Beef     41          $6.6         0.10%  32          $49.3         0.16%  37          $55.9         0.15%
    Frzn Chicken--  42          $6.5         0.10%  65          $32.0         0.10%  31          $38.5         0.10%
     Wht Meat
    Choice Beef     43          $6.5         0.10%  70          $30.7         0.10%  76          $37.2         0.10%
    Choice Beef     44          $6.5         0.10%  39          $45.3         0.14%  74          $51.8         0.14%
    Pourable Salad  45          $6.5         0.10%  37          $46.3         0.15%  61          $52.7         0.14%
     Dressings
    Traditional     46          $6.2         0.09%  52          $37.1         0.12%  45          $43.3         0.11%
     [Ice Cream &
     Sherbert]
    Fz Bag          47          $6.2         0.09%  40          $42.0         0.13%  82          $48.2         0.13%
     Vegetables--P
     lain
    Mayonnaise &    48          $6.0         0.09%  49          $38.0         0.12%  56          $44.0         0.12%
     Whipped
     Dressing
    Refrigerated    49          $5.9         0.09%  35          $48.1         0.15%  67          $54.0         0.14%
     Coffee
     Creamers
    Fz Family       50          $5.8         0.09%  80          $26.5         0.08%  65          $32.3         0.08%
     Style Entrees
    Sft Drnk Sngl   51          $5.7         0.09%  111         $21.2         0.07%  13          $26.9         0.07%
     Srv Btl Carb
     (Ex)
    Adult Cereal    52          $5.6         0.08%  21          $57.0         0.18%  27          $62.6         0.16%
    Butter          53          $5.4         0.08%  20          $60.1         0.19%  51          $65.5         0.17%
    Strawberries    54          $5.4         0.08%  25          $54.8         0.17%  113         $60.1         0.16%
    Candy Bags--    55          $5.2         0.08%  28          $50.9         0.16%  21          $56.1         0.15%
     Chocolate
    Hot Dogs--Base  56          $5.1         0.08%  161         $16.6         0.05%  28          $21.7         0.06%
     Meat
    Margarine:      57          $5.1         0.08%  71          $30.5         0.10%  102         $35.6         0.09%
     Tubs And
     Bowls
    Choice Beef     58          $5.1         0.08%  99          $22.6         0.07%  41          $27.7         0.07%
    Mainstream      59          $4.9         0.07%  87          $25.0         0.08%  70          $29.9         0.08%
     [Pasta &
     Pizza Sauce]
    Tuna            60          $4.8         0.07%  58          $35.1         0.11%  104         $39.9         0.10%
    Lunchment--Bol  61          $4.7         0.07%  138         $18.5         0.06%  114         $23.2         0.06%
     ogna/Sausage
    Meat: Turkey    62          $4.7         0.07%  23          $55.8         0.18%  111         $60.5         0.16%
     Bulk
    Macaroni &      63          $4.7         0.07%  154         $17.1         0.05%  84          $21.8         0.06%
     Cheese Dnrs
    Peanut Butter   64          $4.7         0.07%  45          $40.5         0.13%  269         $45.1         0.12%
    Aseptic Pack    65          $4.5         0.07%  194         $14.2         0.04%  119         $18.7         0.05%
     Juice And
     Drinks
    Chicken Wings   66          $4.5         0.07%  346          $8.1         0.03%  44          $12.6         0.03%
    Mexican Soft    67          $4.5         0.07%  63          $33.0         0.10%  47          $37.5         0.10%
     Tortillas And
     Wra
    Can Pasta       68          $4.4         0.07%  206         $13.4         0.04%  108         $17.9         0.05%
    Sw Gds: Donuts  69          $4.4         0.07%  91          $23.6         0.07%  94          $27.9         0.07%
    Frzn French     70          $4.3         0.07%  166         $16.2         0.05%  92          $20.5         0.05%
     Fries
    Angus [Beef]    71          $4.3         0.07%  53          $36.2         0.11%  24          $40.5         0.11%
    Rts Soup:       72          $4.2         0.06%  48          $38.2         0.12%  139         $42.4         0.11%
     Chunky/
     Homestyle/Et
    Fz Skillet      73          $4.1         0.06%  85          $25.2         0.08%  247         $29.4         0.08%
     Meals
    Cream Cheese    74          $4.1         0.06%  51          $37.6         0.12%  115         $41.7         0.11%
    Frzn Chicken--  75          $4.1         0.06%  514          $4.8         0.02%  75           $8.9         0.02%
     Wings
    Mult Pk Bag     76          $4.1         0.06%  208         $13.4         0.04%  62          $17.5         0.05%
     Snacks
    Frzn Breakfast  77          $4.0         0.06%  147         $17.7         0.06%  136         $21.6         0.06%
     Sandwiches
    Sandwich        78          $3.9         0.06%  94          $23.3         0.07%  66          $27.2         0.07%
     Cookies
    Vegetable Oil   79          $3.9         0.06%  279          $9.8         0.03%  49          $13.7         0.04%
    Sour Creams     80          $3.9         0.06%  67          $31.0         0.10%  93          $34.9         0.09%
    Frzn Meat--     81          $3.9         0.06%  180         $15.2         0.05%  196         $19.1         0.05%
     Beef
    Meat: Ham Bulk  82          $3.9         0.06%  46          $40.3         0.13%  149         $44.1         0.12%
    Pizza/          83          $3.8         0.06%  125         $19.6         0.06%  97          $23.4         0.06%
     Traditional
    Hamburger Buns  84          $3.8         0.06%  93          $23.5         0.07%  53          $27.2         0.07%
    Pizza/Economy   85          $3.8         0.06%  238         $11.7         0.04%  95          $15.5         0.04%
    Flavored Milk   86          $3.7         0.06%  116         $20.3         0.06%  33          $24.0         0.06%
    Cheese          87          $3.7         0.06%  74          $29.0         0.09%  46          $32.7         0.09%
     Crackers
    Candy Bars      88          $3.6         0.05%  96          $22.9         0.07%  142         $26.5         0.07%
     (Multi Pack)
    Value Forms/    89          $3.6         0.05%  240         $11.6         0.04%  129         $15.2         0.04%
     18oz And
     Larger
     [Chicken]
    Grapes Red      90          $3.6         0.05%  50          $37.6         0.12%  103         $41.2         0.11%
    Hot Dog Buns    91          $3.6         0.05%  122         $19.7         0.06%  109         $23.3         0.06%
    Waffles/        92          $3.6         0.05%  105         $22.1         0.07%  100         $25.6         0.07%
     Pancakes/
     French Toast
    Spring Water    93          $3.6         0.05%  73          $29.4         0.09%  68          $32.9         0.09%
    Sweet Goods--   94          $3.6         0.05%  144         $18.0         0.06%  116         $21.5         0.06%
     Full Size
    Cottage Cheese  95          $3.5         0.05%  56          $35.4         0.11%  146         $38.9         0.10%
    Cakes:          96          $3.5         0.05%  190         $14.6         0.05%  85          $18.2         0.05%
     Birthday/
     Celebration
     Sh
    Bkfst Sausage-- 97          $3.5         0.05%  117         $20.2         0.06%  80          $23.7         0.06%
     Fresh Rolls
    Dnr Sausage--   98          $3.5         0.05%  242         $11.5         0.04%  241         $15.0         0.04%
     Links Pork
     Ckd/S
    Candy Bars      99          $3.5         0.05%  155         $17.1         0.05%  137         $20.5         0.05%
     (Singles)
     (Including)
    Fruit Snacks    100         $3.5         0.05%  224         $12.2         0.04%  203         $15.6         0.04%
                          -------------------------       ----------------------------------------------------------
      Top 100                 $731.2        11.09%           $4,237.7        13.52%           $5,004.7        13.17%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

      Exhibit E-3: Top 100 Subcommodities for SNAP Households by Expenditure: Household Head Age 65 Years or Older
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $12.6         0.19%  1          $109.6         0.35%  1          $122.2         0.32%
     White Only
    Soft Drinks 12/ 2          $10.9         0.17%  2           $69.4         0.22%  2           $80.3         0.21%
     18 & 15pk Can
     Car
    Lean [Beef]     3           $6.3         0.10%  18          $26.1         0.08%  12          $32.4         0.09%
    Sft Drnk 2      4           $4.2         0.06%  29          $21.4         0.07%  24          $25.6         0.07%
     Liter Btl
     Carb Incl
    Primal [Beef]   5           $4.2         0.06%  15          $27.5         0.09%  13          $31.7         0.08%
    Shredded        6           $4.2         0.06%  10          $29.8         0.09%  10          $34.0         0.09%
     Cheese
    Potato Chips    7           $4.0         0.06%  13          $28.8         0.09%  11          $32.7         0.09%
    Kids Cereal     8           $3.8         0.06%  72          $10.7         0.03%  59          $14.5         0.04%
    Eggs--Large     9           $3.6         0.06%  8           $32.7         0.10%  8           $36.4         0.10%
    Unflavored Can  10          $3.5         0.05%  6           $35.6         0.11%  5           $39.1         0.10%
     Coffee
    Fz Ss Prem      11          $3.4         0.05%  9           $31.9         0.10%  9           $35.3         0.09%
     Traditional
     Meals
    Lunchment--Del  12          $3.4         0.05%  19          $24.6         0.08%  19          $28.0         0.07%
     i Fresh
    Mainstream      13          $3.2         0.05%  40          $16.9         0.05%  36          $20.1         0.05%
     White Bread
    Dairy Case      14          $3.1         0.05%  3           $38.6         0.12%  3           $41.7         0.11%
     100% Pure
     Juice--O
    Bacon--Trad     15          $2.9         0.04%  24          $23.1         0.07%  23          $26.0         0.07%
     16oz Or Less
    Chicken Breast  16          $2.8         0.04%  17          $26.2         0.08%  18          $29.0         0.08%
     Boneless
    Bananas         17          $2.7         0.04%  4           $37.1         0.12%  4           $39.8         0.10%
    American        18          $2.7         0.04%  38          $17.4         0.06%  35          $20.1         0.05%
     Single Cheese
    Enhanced [Pork  19          $2.7         0.04%  26          $22.9         0.07%  25          $25.6         0.07%
     Boneless Loin/
     Rib]
    Mainstream      20          $2.7         0.04%  27          $22.6         0.07%  28          $25.3         0.07%
     Variety
     Breads
    Sft Drnk Mlt-   21          $2.6         0.04%  20          $24.5         0.08%  20          $27.1         0.07%
     Pk Btl Carb
     (Excp)
    Still Water     22          $2.6         0.04%  49          $15.2         0.05%  43          $17.8         0.05%
     Drnking/Mnrl
     Water
    Potatoes        23          $2.6         0.04%  25          $22.9         0.07%  27          $25.5         0.07%
     Russet (Bulk
     & Bag)
    Snack Cake--    24          $2.6         0.04%  68          $11.4         0.04%  62          $14.0         0.04%
     Multi Pack
    Natural Cheese  25          $2.5         0.04%  14          $28.3         0.09%  16          $30.8         0.08%
     Chunks
    All Family      26          $2.5         0.04%  12          $29.0         0.09%  14          $31.5         0.08%
     Cereal
    Fz Ss Economy   27          $2.5         0.04%  87           $9.3         0.03%  73          $11.8         0.03%
     Meals All
    Premium [Ice    28          $2.5         0.04%  7           $35.5         0.11%  6           $38.0         0.10%
     Cream &
     Sherbert]
    Tortilla/Nacho  29          $2.5         0.04%  48          $15.6         0.05%  41          $18.0         0.05%
     Chips
    Condensed Soup  30          $2.4         0.04%  22          $24.5         0.08%  21          $26.8         0.07%
    Soft Drinks     31          $2.3         0.04%  82           $9.7         0.03%  70          $12.1         0.03%
     20pk & 24pk
     Can Carb
    Sugar           32          $2.3         0.04%  51          $15.1         0.05%  47          $17.5         0.05%
    Traditional     33          $2.3         0.03%  23          $23.2         0.07%  26          $25.5         0.07%
     [Ice Cream &
     Sherbert]
    Ribs [Pork]     34          $2.3         0.03%  57          $13.4         0.04%  53          $15.6         0.04%
    Snacks/         35          $2.2         0.03%  144          $6.6         0.02%  112          $8.9         0.02%
     Appetizers
    Infant Formula  36          $2.2         0.03%  583          $1.4         0.00%  336          $3.6         0.01%
     Starter/
     Solutio
    Pizza/Premium   37          $2.2         0.03%  59          $12.7         0.04%  57          $14.9         0.04%
    Select Beef     38          $2.1         0.03%  35          $17.9         0.06%  37          $19.9         0.05%
    Fz Ss Prem      39          $2.0         0.03%  5           $35.8         0.11%  7           $37.8         0.10%
     Nutritional
     Meals
    Fz Bag          40          $2.0         0.03%  32          $19.9         0.06%  31          $21.9         0.06%
     Vegetables--P
     lain
    Choice Beef     41          $1.9         0.03%  60          $12.7         0.04%  58          $14.6         0.04%
    Mayonnaise &    42          $1.9         0.03%  34          $18.2         0.06%  34          $20.1         0.05%
     Whipped
     Dressing
    Choice Beef     43          $1.9         0.03%  36          $17.7         0.06%  38          $19.6         0.05%
    Adult Cereal    44          $1.9         0.03%  11          $29.4         0.09%  15          $31.2         0.08%
    Butter          45          $1.9         0.03%  16          $27.4         0.09%  17          $29.3         0.08%
    Margarine:      46          $1.8         0.03%  33          $18.5         0.06%  33          $20.4         0.05%
     Tubs And
     Bowls
    Pourable Salad  47          $1.8         0.03%  39          $16.9         0.05%  39          $18.7         0.05%
     Dressings
    Sandwiches &    48          $1.8         0.03%  219          $4.9         0.02%  165          $6.7         0.02%
     Handhelds
    Strawberries    49          $1.7         0.03%  21          $24.5         0.08%  22          $26.1         0.07%
    Candy Bags--    50          $1.6         0.02%  28          $22.4         0.07%  29          $24.1         0.06%
     Chocolate
    Convenient      51          $1.6         0.02%  324          $3.4         0.01%  240          $5.0         0.01%
     Meals--Kids
     Meal C
    Refrigerated    52          $1.6         0.02%  45          $16.1         0.05%  44          $17.7         0.05%
     Coffee
     Creamers
    Frzn Chicken--  53          $1.6         0.02%  96           $8.8         0.03%  86          $10.4         0.03%
     Wht Meat
    Lunchment--Bol  54          $1.6         0.02%  84           $9.5         0.03%  78          $11.1         0.03%
     ogna/Sausage
    Fz Family       55          $1.6         0.02%  90           $9.0         0.03%  85          $10.6         0.03%
     Style Entrees
    Isotonic        56          $1.6         0.02%  123          $7.4         0.02%  108          $9.0         0.02%
     Drinks Single
     Serve
    Choice Beef     57          $1.5         0.02%  80           $9.8         0.03%  76          $11.3         0.03%
    Sw Gds: Donuts  58          $1.5         0.02%  62          $12.5         0.04%  61          $14.1         0.04%
    Hot Dogs--Base  59          $1.5         0.02%  146          $6.6         0.02%  125          $8.1         0.02%
     Meat
    Peanut Butter   60          $1.4         0.02%  44          $16.1         0.05%  45          $17.6         0.05%
    Sft Drnk Sngl   61          $1.4         0.02%  237          $4.5         0.01%  195          $6.0         0.02%
     Srv Btl Carb
     (Ex)
    Tuna            62          $1.4         0.02%  54          $13.9         0.04%  55          $15.3         0.04%
    Angus [Beef]    63          $1.4         0.02%  50          $15.2         0.05%  51          $16.6         0.04%
    Cottage Cheese  64          $1.3         0.02%  31          $20.3         0.06%  32          $21.6         0.06%
    Rts Soup:       65          $1.3         0.02%  41          $16.6         0.05%  42          $17.9         0.05%
     Chunky/
     Homestyle/Et
    Chicken Wings   66          $1.3         0.02%  405          $2.6         0.01%  310          $3.9         0.01%
    Meat: Turkey    67          $1.2         0.02%  47          $15.9         0.05%  48          $17.1         0.04%
     Bulk
    Mainstream      68          $1.2         0.02%  142          $6.9         0.02%  126          $8.1         0.02%
     [Pasta &
     Pizza Sauce]
    Grapes Red      69          $1.2         0.02%  37          $17.4         0.06%  40          $18.6         0.05%
    Macaroni &      70          $1.2         0.02%  277          $4.0         0.01%  231          $5.2         0.01%
     Cheese Dnrs
    Mexican Soft    71          $1.2         0.02%  115          $7.9         0.03%  106          $9.1         0.02%
     Tortillas And
     Wra
    Frzn Breakfast  72          $1.2         0.02%  165          $6.1         0.02%  150          $7.2         0.02%
     Sandwiches
    Cream Cheese    73          $1.1         0.02%  55          $13.9         0.04%  56          $15.0         0.04%
    Can Pasta       74          $1.1         0.02%  321          $3.4         0.01%  268          $4.6         0.01%
    Sweet Goods--   75          $1.1         0.02%  93           $8.9         0.03%  90          $10.1         0.03%
     Full Size
    Meat: Ham Bulk  76          $1.1         0.02%  46          $15.9         0.05%  49          $17.0         0.04%
    Bkfst Sausage-- 77          $1.1         0.02%  105          $8.3         0.03%  97           $9.5         0.02%
     Fresh Rolls
    Fz Skillet      78          $1.1         0.02%  83           $9.6         0.03%  82          $10.8         0.03%
     Meals
    Vegetable Oil   79          $1.1         0.02%  305          $3.6         0.01%  258          $4.7         0.01%
    Frzn French     80          $1.1         0.02%  234          $4.6         0.01%  212          $5.7         0.01%
     Fries
    Sandwich        81          $1.1         0.02%  102          $8.4         0.03%  96           $9.5         0.03%
     Cookies
    Candy Bars      82          $1.1         0.02%  78           $9.9         0.03%  79          $11.0         0.03%
     (Multi Pack)
    Butter Spray    83          $1.1         0.02%  69          $10.9         0.03%  71          $12.0         0.03%
     Cracker
    Premium Bread   84          $1.1         0.02%  30          $21.2         0.07%  30          $22.3         0.06%
    Aseptic Pack    85          $1.1         0.02%  420          $2.5         0.01%  343          $3.6         0.01%
     Juice And
     Drinks
    Sticks/Enrobed  86          $1.1         0.02%  76          $10.2         0.03%  77          $11.3         0.03%
     [Frozen
     Novelties]
    Sour Creams     87          $1.1         0.02%  71          $10.7         0.03%  72          $11.8         0.03%
    Waffles/        88          $1.1         0.02%  111          $8.1         0.03%  102          $9.2         0.02%
     Pancakes/
     French Toast
    Spring Water    89          $1.1         0.02%  73          $10.3         0.03%  75          $11.3         0.03%
    Hamburger Buns  90          $1.1         0.02%  116          $7.9         0.02%  110          $8.9         0.02%
    Mult Pk Bag     91          $1.0         0.02%  408          $2.6         0.01%  341          $3.6         0.01%
     Snacks
    Frzn Chicken--  92          $1.0         0.02%  654          $1.2         0.00%  479          $2.2         0.01%
     Wings
    Flavored Milk   93          $1.0         0.02%  178          $5.8         0.02%  161          $6.8         0.02%
    Refrigerated    94          $1.0         0.02%  164          $6.2         0.02%  151          $7.2         0.02%
     Biscuits
    Grapes White    95          $1.0         0.02%  70          $10.8         0.03%  74          $11.8         0.03%
    Dnr Sausage--   96          $1.0         0.02%  284          $3.9         0.01%  249          $4.9         0.01%
     Links Pork
     Ckd/S
    Pizza/Economy   97          $1.0         0.02%  357          $3.0         0.01%  305          $4.0         0.01%
    Frzn Meat--     98          $1.0         0.01%  279          $3.9         0.01%  248          $4.9         0.01%
     Beef
    Pizza/          99          $1.0         0.01%  211          $5.1         0.02%  184          $6.1         0.02%
     Traditional
    Candy Bars      100         $1.0         0.01%  167          $6.0         0.02%  154          $7.0         0.02%
     (Singles)
                          -------------------------       ----------------------------------------------------------
      Top 100                 $213.1         3.29%           $1,664.6         5.23%           $1,877.6         4.94%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

        Exhibit E-4: Top 100 Subcommodities for SNAP Households by Expenditure: Households with Children Present
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $33.9         0.52%  1          $190.0         0.60%  1          $223.9         0.59%
     White Only
    Soft Drinks 12/ 2          $28.4         0.43%  2          $128.5         0.41%  2          $156.9         0.41%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $17.5         0.27%  10          $51.4         0.16%  5           $68.9         0.18%
    Kids Cereal     4          $14.0         0.21%  7           $53.4         0.17%  6           $67.4         0.18%
    Shredded        5          $13.9         0.21%  3           $82.7         0.26%  3           $96.7         0.25%
     Cheese
    Sft Drnk 2      6          $12.4         0.19%  12          $49.7         0.16%  9           $62.2         0.16%
     Liter Btl
     Carb Incl
    Primal [Beef]   7          $11.4         0.17%  13          $49.7         0.16%  10          $61.0         0.16%
    Potato Chips    8          $11.3         0.17%  5           $55.3         0.18%  7           $66.6         0.17%
    Lunchment--Del  9           $9.6         0.15%  8           $53.4         0.17%  8           $63.0         0.17%
     i Fresh
    Chicken Breast  10          $8.9         0.14%  4           $65.2         0.21%  4           $74.1         0.19%
     Boneless
    Infant Formula  11          $8.7         0.13%  258          $7.1         0.02%  127         $15.8         0.04%
     Starter/
     Solutio
    Tortilla/Nacho  12          $8.5         0.13%  11          $50.4         0.16%  12          $58.9         0.15%
     Chips
    Eggs--Large     13          $8.5         0.13%  14          $49.1         0.16%  13          $57.6         0.15%
    Mainstream      14          $8.3         0.13%  32          $31.1         0.10%  28          $39.4         0.10%
     White Bread
    Snacks/         15          $8.2         0.12%  41          $27.4         0.09%  34          $35.6         0.09%
     Appetizers
    Still Water     16          $7.8         0.12%  21          $37.7         0.12%  19          $45.5         0.12%
     Drnking/Mnrl
     Water
    American        17          $7.5         0.11%  36          $28.9         0.09%  33          $36.4         0.10%
     Single Cheese
    Dairy Case      18          $7.5         0.11%  6           $53.5         0.17%  11          $61.0         0.16%
     100% Pure
     Juice--O
    Snack Cake--    19          $7.2         0.11%  47          $25.7         0.08%  41          $32.9         0.09%
     Multi Pack
    Enhanced [Pork  20          $7.2         0.11%  22          $36.4         0.12%  21          $43.6         0.11%
     Boneless Loin/
     Rib]
    Fz Ss Prem      21          $7.1         0.11%  39          $27.9         0.09%  36          $35.0         0.09%
     Traditional
     Meals
    Pizza/Premium   22          $6.9         0.11%  27          $34.2         0.11%  24          $41.1         0.11%
    Fz Ss Economy   23          $6.9         0.10%  90          $16.7         0.05%  73          $23.5         0.06%
     Meals All
    All Family      24          $6.8         0.10%  15          $48.9         0.16%  15          $55.7         0.15%
     Cereal
    Unflavored Can  25          $6.8         0.10%  26          $34.3         0.11%  25          $41.0         0.11%
     Coffee
    Bacon--Trad     26          $6.8         0.10%  30          $32.1         0.10%  30          $38.8         0.10%
     16oz Or Less
    Convenient      27          $6.7         0.10%  58          $23.7         0.08%  43          $30.3         0.08%
     Meals--Kids
     Meal C
    Soft Drinks     28          $6.5         0.10%  63          $22.3         0.07%  53          $28.7         0.08%
     20pk & 24pk
     Can Carb
    Mainstream      29          $6.3         0.10%  24          $35.3         0.11%  22          $41.6         0.11%
     Variety
     Breads
    Sandwiches &    30          $6.2         0.09%  79          $18.6         0.06%  67          $24.8         0.07%
     Handhelds
    Sft Drnk Mlt-   31          $6.2         0.09%  28          $33.7         0.11%  26          $39.9         0.10%
     Pk Btl Carb
     (Excp)
    Natural Cheese  32          $6.2         0.09%  18          $42.9         0.14%  18          $49.1         0.13%
     Chunks
    Sugar           33          $6.1         0.09%  60          $23.3         0.07%  52          $29.4         0.08%
    Potatoes        34          $6.0         0.09%  33          $30.7         0.10%  32          $36.7         0.10%
     Russet (Bulk
     & Bag)
    Bananas         35          $6.0         0.09%  16          $48.2         0.15%  16          $54.2         0.14%
    Frzn Chicken--  36          $5.6         0.09%  54          $24.6         0.08%  45          $30.2         0.08%
     Wht Meat
    Ribs [Pork]     37          $5.6         0.08%  70          $20.7         0.07%  61          $26.3         0.07%
    Premium [Ice    38          $5.5         0.08%  17          $46.9         0.15%  17          $52.4         0.14%
     Cream &
     Sherbert]
    Isotonic        39          $5.5         0.08%  37          $28.3         0.09%  39          $33.8         0.09%
     Drinks Single
     Serve
    Condensed Soup  40          $5.4         0.08%  29          $32.7         0.10%  31          $38.2         0.10%
    Pourable Salad  41          $5.1         0.08%  35          $29.1         0.09%  37          $34.2         0.09%
     Dressings
    Sft Drnk Sngl   42          $4.9         0.07%  104         $15.3         0.05%  85          $20.2         0.05%
     Srv Btl Carb
     (Ex)
    Choice Beef     43          $4.9         0.07%  77          $19.0         0.06%  71          $23.9         0.06%
    Fz Family       44          $4.8         0.07%  80          $18.6         0.06%  74          $23.4         0.06%
     Style Entrees
    Select Beef     45          $4.8         0.07%  38          $28.3         0.09%  40          $33.0         0.09%
    Fz Ss Prem      46          $4.7         0.07%  9           $52.3         0.17%  14          $57.0         0.15%
     Nutritional
     Meals
    Traditional     47          $4.6         0.07%  50          $24.9         0.08%  50          $29.6         0.08%
     [Ice Cream &
     Sherbert]
    Aseptic Pack    48          $4.6         0.07%  74          $19.4         0.06%  69          $24.0         0.06%
     Juice And
     Drinks
    Choice Beef     49          $4.6         0.07%  49          $25.1         0.08%  49          $29.7         0.08%
    Fz Bag          50          $4.5         0.07%  48          $25.4         0.08%  48          $29.9         0.08%
     Vegetables--P
     lain
    Mayonnaise &    51          $4.4         0.07%  66          $22.0         0.07%  60          $26.5         0.07%
     Whipped
     Dressing
    Refrigerated    52          $4.4         0.07%  31          $31.1         0.10%  35          $35.5         0.09%
     Coffee
     Creamers
    Strawberries    53          $4.4         0.07%  19          $40.0         0.13%  20          $44.4         0.12%
    Adult Cereal    54          $4.2         0.06%  25          $35.0         0.11%  29          $39.2         0.10%
    Macaroni &      55          $4.2         0.06%  101         $15.5         0.05%  88          $19.7         0.05%
     Cheese Dnrs
    Mainstream      56          $4.2         0.06%  72          $19.8         0.06%  70          $24.0         0.06%
     [Pasta &
     Pizza Sauce]
    Hot Dogs--Base  57          $4.2         0.06%  134         $12.6         0.04%  115         $16.8         0.04%
     Meat
    Choice Beef     58          $4.0         0.06%  114         $14.4         0.05%  99          $18.5         0.05%
    Can Pasta       59          $4.0         0.06%  133         $12.8         0.04%  113         $16.8         0.04%
    Candy Bags--    60          $4.0         0.06%  34          $29.9         0.09%  38          $33.8         0.09%
     Chocolate
    Margarine:      61          $3.9         0.06%  78          $18.9         0.06%  78          $22.8         0.06%
     Tubs And
     Bowls
    Peanut Butter   62          $3.8         0.06%  40          $27.8         0.09%  42          $31.6         0.08%
    Butter          63          $3.7         0.06%  23          $35.8         0.11%  27          $39.5         0.10%
    Meat: Turkey    64          $3.7         0.06%  20          $37.8         0.12%  23          $41.5         0.11%
     Bulk
    Mult Pk Bag     65          $3.7         0.06%  132         $12.9         0.04%  118         $16.6         0.04%
     Snacks
    Frzn French     66          $3.6         0.06%  138         $12.5         0.04%  123         $16.1         0.04%
     Fries
    Mexican Soft    67          $3.6         0.06%  59          $23.4         0.07%  58          $27.0         0.07%
     Tortillas And
     Wra
    Sw Gds: Donuts  68          $3.6         0.05%  91          $16.7         0.05%  84          $20.2         0.05%
    Pizza/Economy   69          $3.5         0.05%  158         $11.4         0.04%  136         $14.9         0.04%
    Fruit Snacks    70          $3.5         0.05%  111         $14.5         0.05%  102         $18.0         0.05%
    Tuna            71          $3.4         0.05%  73          $19.6         0.06%  77          $23.1         0.06%
    Lunchment--Bol  72          $3.4         0.05%  156         $11.5         0.04%  135         $14.9         0.04%
     ogna/Sausage
    Value Forms/    73          $3.4         0.05%  139         $12.4         0.04%  128         $15.8         0.04%
     18oz And
     Larger
     [Chicken]
    Frzn Breakfast  74          $3.4         0.05%  122         $13.6         0.04%  110         $17.0         0.04%
     Sandwiches
    Cheese          75          $3.4         0.05%  44          $26.8         0.09%  46          $30.2         0.08%
     Crackers
    Frzn Meat--     76          $3.3         0.05%  151         $11.7         0.04%  133         $15.1         0.04%
     Beef
    Waffles/        77          $3.3         0.05%  62          $22.5         0.07%  65          $25.9         0.07%
     Pancakes/
     French Toast
    Frzn Chicken--  78          $3.3         0.05%  470          $3.4         0.01%  308          $6.8         0.02%
     Wings
    Cream Cheese    79          $3.3         0.05%  45          $26.1         0.08%  51          $29.4         0.08%
    Sandwich        80          $3.2         0.05%  83          $17.6         0.06%  83          $20.8         0.05%
     Cookies
    Pizza/          81          $3.2         0.05%  100         $15.7         0.05%  94          $18.9         0.05%
     Traditional
    Fz Skillet      82          $3.2         0.05%  103         $15.4         0.05%  97          $18.6         0.05%
     Meals
    Sour Creams     83          $3.2         0.05%  69          $21.3         0.07%  68          $24.5         0.06%
    Cakes:          84          $3.2         0.05%  160         $11.3         0.04%  143         $14.6         0.04%
     Birthday/
     Celebration
     Sh
    Angus [Beef]    85          $3.2         0.05%  61          $22.8         0.07%  64          $25.9         0.07%
    Flavored Milk   86          $3.2         0.05%  93          $16.4         0.05%  90          $19.6         0.05%
    Chicken Wings   87          $3.2         0.05%  372          $4.7         0.01%  276          $7.8         0.02%
    Hamburger Buns  88          $3.0         0.05%  92          $16.6         0.05%  89          $19.6         0.05%
    Rts Soup:       89          $3.0         0.05%  65          $22.0         0.07%  66          $25.1         0.07%
     Chunky/
     Homestyle/Et
    Vegetable Oil   90          $3.0         0.05%  269          $6.7         0.02%  221          $9.7         0.03%
    Meat: Ham Bulk  91          $3.0         0.05%  43          $27.2         0.09%  44          $30.2         0.08%
    String Cheese   92          $3.0         0.05%  51          $24.8         0.08%  55          $27.8         0.07%
    Hot Dog Buns    93          $2.9         0.04%  115         $14.4         0.05%  106         $17.3         0.05%
    Sweet Goods--   94          $2.9         0.04%  123         $13.5         0.04%  119         $16.4         0.04%
     Full Size
    Bagged Cheese   95          $2.9         0.04%  149         $11.9         0.04%  138         $14.8         0.04%
     Snacks
    Toaster         96          $2.9         0.04%  95          $16.1         0.05%  93          $19.0         0.05%
     Pastries
    Grapes Red      97          $2.8         0.04%  42          $27.3         0.09%  47          $30.2         0.08%
    Candy Bars      98          $2.8         0.04%  159         $11.4         0.04%  148         $14.2         0.04%
     (Singles)
     (Including)
    Salsa & Dips    99          $2.8         0.04%  150         $11.8         0.04%  142         $14.6         0.04%
    Ramen Noodles/  100         $2.8         0.04%  274          $6.5         0.02%  229          $9.3         0.02%
     Ramen Cups
                          -------------------------       ----------------------------------------------------------
      Top 100                 $585.8         8.90%           $2,937.8         9.32%           $3,523.7         9.25%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

       Exhibit E-5: Top 100 Subcommodities for SNAP Households by Expenditure: Households Without Children Present
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $50.6         0.77%  1          $322.1         1.02%  1          $372.7         0.98%
     White Only
    Soft Drinks 12/ 2          $44.1         0.67%  2          $234.1         0.74%  2          $278.3         0.73%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $28.4         0.43%  10          $94.8         0.30%  6          $123.1         0.32%
    Shredded        4          $19.9         0.30%  3          $126.8         0.40%  3          $146.7         0.39%
     Cheese
    Sft Drnk 2      5          $18.7         0.28%  17          $81.5         0.26%  15         $100.2         0.26%
     Liter Btl
     Carb Incl
    Kids Cereal     6          $18.6         0.28%  40          $54.6         0.17%  30          $73.2         0.19%
    Primal [Beef]   7          $17.4         0.26%  15          $88.0         0.28%  12         $105.4         0.28%
    Potato Chips    8          $17.3         0.26%  8           $98.4         0.31%  8          $115.8         0.30%
    Lunchment--Del  9          $14.9         0.23%  12          $91.0         0.29%  11         $105.9         0.28%
     i Fresh
    Eggs--Large     10         $14.2         0.22%  9           $98.4         0.31%  9          $112.7         0.30%
    Chicken Breast  11         $13.3         0.20%  5          $110.1         0.35%  5          $123.5         0.32%
     Boneless
    Infant Formula  12         $13.1         0.20%  314         $11.2         0.04%  157         $24.3         0.06%
     Starter/
     Solutio
    Fz Ss Prem      13         $12.6         0.19%  19          $77.2         0.24%  18          $89.7         0.24%
     Traditional
     Meals
    Unflavored Can  14         $12.5         0.19%  14          $88.7         0.28%  14         $101.2         0.27%
     Coffee
    Mainstream      15         $12.5         0.19%  49          $49.8         0.16%  41          $62.3         0.16%
     White Bread
    Still Water     16         $12.3         0.19%  29          $64.1         0.20%  25          $76.4         0.20%
     Drnking/Mnrl
     Water
    Tortilla/Nacho  17         $12.1         0.18%  22          $73.4         0.23%  19          $85.6         0.22%
     Chips
    Dairy Case      18         $12.1         0.18%  6          $107.2         0.34%  7          $119.3         0.31%
     100% Pure
     Juice--O
    American        19         $11.6         0.18%  42          $52.8         0.17%  38          $64.4         0.17%
     Single Cheese
    Bacon--Trad     20         $11.2         0.17%  27          $64.6         0.20%  27          $75.8         0.20%
     16oz Or Less
    Enhanced [Pork  21         $11.1         0.17%  24          $68.3         0.22%  23          $79.4         0.21%
     Boneless Loin/
     Rib]
    Snacks/         22         $10.7         0.16%  81          $32.0         0.10%  69          $42.7         0.11%
     Appetizers
    Snack Cake--    23         $10.6         0.16%  68          $36.4         0.12%  61          $47.1         0.12%
     Multi Pack
    Mainstream      24         $10.5         0.16%  25          $66.1         0.21%  24          $76.6         0.20%
     Variety
     Breads
    Fz Ss Economy   25         $10.3         0.16%  94          $28.4         0.09%  75          $38.7         0.10%
     Meals All
    Natural Cheese  26         $10.2         0.15%  13          $89.8         0.28%  16         $100.0         0.26%
     Chunks
    Pizza/Premium   27         $10.1         0.15%  39          $55.5         0.18%  36          $65.6         0.17%
    Soft Drinks     28         $10.0         0.15%  64          $38.7         0.12%  59          $48.7         0.13%
     20pk & 24pk
     Can Carb
    All Family      29         $10.0         0.15%  16          $85.8         0.27%  17          $95.7         0.25%
     Cereal
    Sft Drnk Mlt-   30         $10.0         0.15%  21          $74.7         0.24%  20          $84.7         0.22%
     Pk Btl Carb
     (Excp)
    Potatoes        31          $9.9         0.15%  30          $64.0         0.20%  28          $73.9         0.19%
     Russet (Bulk
     & Bag)
    Bananas         32          $9.9         0.15%  7          $100.3         0.32%  10         $110.1         0.29%
    Sugar           33          $9.6         0.15%  55          $44.8         0.14%  50          $54.4         0.14%
    Ribs [Pork]     34          $9.4         0.14%  60          $42.4         0.13%  53          $51.8         0.14%
    Premium [Ice    35          $9.1         0.14%  11          $94.7         0.30%  13         $103.8         0.27%
     Cream &
     Sherbert]
    Condensed Soup  36          $8.7         0.13%  26          $64.7         0.21%  29          $73.4         0.19%
    Sandwiches &    37          $8.7         0.13%  128         $23.7         0.08%  94          $32.4         0.08%
     Handhelds
    Select Beef     38          $8.1         0.12%  33          $59.5         0.19%  33          $67.6         0.18%
    Choice Beef     39          $8.1         0.12%  65          $38.3         0.12%  63          $46.4         0.12%
    Fz Ss Prem      40          $8.0         0.12%  4          $117.8         0.37%  4          $125.7         0.33%
     Nutritional
     Meals
    Choice Beef     41          $7.9         0.12%  38          $55.7         0.18%  39          $63.6         0.17%
    Frzn Chicken--  42          $7.9         0.12%  70          $36.1         0.11%  66          $44.0         0.12%
     Wht Meat
    Pourable Salad  43          $7.9         0.12%  36          $56.5         0.18%  37          $64.4         0.17%
     Dressings
    Isotonic        44          $7.8         0.12%  66          $37.9         0.12%  64          $45.7         0.12%
     Drinks Single
     Serve
    Convenient      45          $7.8         0.12%  186         $18.0         0.06%  139         $25.8         0.07%
     Meals--Kids
     Meal C
    Traditional     46          $7.7         0.12%  44          $51.5         0.16%  43          $59.2         0.16%
     [Ice Cream &
     Sherbert]
    Fz Bag          47          $7.6         0.12%  37          $55.9         0.18%  40          $63.5         0.17%
     Vegetables--P
     lain
    Mayonnaise &    48          $7.5         0.11%  45          $50.9         0.16%  44          $58.4         0.15%
     Whipped
     Dressing
    Refrigerated    49          $7.1         0.11%  34          $58.8         0.19%  35          $65.9         0.17%
     Coffee
     Creamers
    Fz Family       50          $7.0         0.11%  85          $31.3         0.10%  76          $38.3         0.10%
     Style Entrees
    Adult Cereal    51          $7.0         0.11%  18          $77.2         0.24%  21          $84.2         0.22%
    Sft Drnk Sngl   52          $6.9         0.11%  122         $24.2         0.08%  101         $31.1         0.08%
     Srv Btl Carb
     (Ex)
    Margarine:      53          $6.5         0.10%  57          $44.0         0.14%  56          $50.5         0.13%
     Tubs And
     Bowls
    Strawberries    54          $6.5         0.10%  23          $69.9         0.22%  26          $76.4         0.20%
    Butter          55          $6.5         0.10%  20          $76.9         0.24%  22          $83.3         0.22%
    Hot Dogs--Base  56          $6.3         0.10%  164         $20.4         0.06%  125         $26.7         0.07%
     Meat
    Choice Beef     57          $6.3         0.10%  93          $28.5         0.09%  86          $34.8         0.09%
    Candy Bags--    58          $6.2         0.09%  28          $64.3         0.20%  31          $70.5         0.19%
     Chocolate
    Mainstream      59          $5.9         0.09%  96          $28.2         0.09%  88          $34.1         0.09%
     [Pasta &
     Pizza Sauce]
    Lunchment--Bol  60          $5.9         0.09%  117         $24.6         0.08%  102         $30.5         0.08%
     ogna/Sausage
    Tuna            61          $5.9         0.09%  54          $45.0         0.14%  54          $50.9         0.13%
    Macaroni &      62          $5.8         0.09%  175         $19.1         0.06%  148         $24.9         0.07%
     Cheese Dnrs
    Mexican Soft    63          $5.8         0.09%  63          $39.2         0.12%  65          $45.0         0.12%
     Tortillas And
     Wra
    Chicken Wings   64          $5.8         0.09%  355         $10.0         0.03%  253         $15.8         0.04%
    Peanut Butter   65          $5.7         0.09%  47          $50.3         0.16%  46          $55.9         0.15%
    Sw Gds: Donuts  66          $5.6         0.09%  83          $31.9         0.10%  77          $37.5         0.10%
    Meat: Turkey    67          $5.6         0.08%  31          $62.3         0.20%  32          $67.9         0.18%
     Bulk
    Aseptic Pack    68          $5.4         0.08%  242         $14.1         0.04%  202         $19.5         0.05%
     Juice And
     Drinks
    Can Pasta       69          $5.4         0.08%  232         $14.8         0.05%  191         $20.2         0.05%
    Frzn Chicken--  70          $5.2         0.08%  547          $5.6         0.02%  372         $10.8         0.03%
     Wings
    Frzn French     71          $5.2         0.08%  190         $17.8         0.06%  162         $23.0         0.06%
     Fries
    Rts Soup:       72          $5.2         0.08%  48          $50.1         0.16%  48          $55.3         0.15%
     Chunky/
     Homestyle/Et
    Angus [Beef]    73          $5.1         0.08%  58          $43.9         0.14%  58          $49.0         0.13%
    Fz Skillet      74          $5.0         0.08%  80          $32.0         0.10%  79          $37.1         0.10%
     Meals
    Mult Pk Bag     75          $5.0         0.08%  263         $13.1         0.04%  220         $18.1         0.05%
     Snacks
    Vegetable Oil   76          $5.0         0.08%  278         $12.5         0.04%  226         $17.5         0.05%
    Frzn Breakfast  77          $4.9         0.07%  159         $20.6         0.07%  143         $25.5         0.07%
     Sandwiches
    Cream Cheese    78          $4.9         0.07%  52          $45.6         0.14%  55          $50.5         0.13%
    Sour Creams     79          $4.8         0.07%  67          $37.9         0.12%  70          $42.7         0.11%
    Pizza/Economy   80          $4.8         0.07%  256         $13.5         0.04%  217         $18.3         0.05%
    Sandwich        81          $4.7         0.07%  105         $26.5         0.08%  100         $31.2         0.08%
     Cookies
    Frzn Meat--     82          $4.7         0.07%  209         $16.2         0.05%  184         $20.9         0.05%
     Beef
    Pizza/          83          $4.5         0.07%  150         $21.4         0.07%  138         $25.9         0.07%
     Traditional
    Chix: Frd 8pc/  84          $4.5         0.07%  73          $35.1         0.11%  73          $39.6         0.10%
     Cut Up (Hot)
    Meat: Ham Bulk  85          $4.5         0.07%  51          $47.9         0.15%  52          $52.4         0.14%
    Hamburger Buns  86          $4.4         0.07%  101         $26.9         0.09%  97          $31.4         0.08%
    Grapes Red      87          $4.4         0.07%  50          $48.5         0.15%  51          $52.9         0.14%
    Spring Water    88          $4.4         0.07%  71          $36.1         0.11%  71          $40.5         0.11%
    Cottage Cheese  89          $4.4         0.07%  46          $50.7         0.16%  49          $55.1         0.14%
    Waffles/        90          $4.4         0.07%  109         $25.8         0.08%  105         $30.2         0.08%
     Pancakes/
     French Toast
    Value Forms/    91          $4.4         0.07%  271         $12.7         0.04%  232         $17.1         0.04%
     18oz And
     Larger
     [Chicken]
    Candy Bars      92          $4.3         0.07%  97          $28.1         0.09%  93          $32.5         0.09%
     (Multi Pack)
    Cakes:          93          $4.3         0.07%  204         $16.7         0.05%  183         $21.0         0.06%
     Birthday/
     Celebration
     Sh
    Hot Dog Buns    94          $4.3         0.07%  137         $22.9         0.07%  120         $27.2         0.07%
    Salsa & Dips    95          $4.3         0.07%  163         $20.5         0.06%  151         $24.7         0.06%
    Sweet Goods--   96          $4.3         0.07%  139         $22.9         0.07%  121         $27.2         0.07%
     Full Size
    Dnr Sausage--   97          $4.3         0.07%  248         $13.9         0.04%  219         $18.2         0.05%
     Links Pork
     Ckd/S
    Bkfst Sausage-- 98          $4.3         0.06%  113         $25.2         0.08%  111         $29.4         0.08%
     Fresh Rolls
    Cheese          99          $4.2         0.06%  87          $30.0         0.10%  87          $34.2         0.09%
     Crackers
    Bagged Cheese   100         $4.2         0.06%  177         $18.8         0.06%  161         $23.1         0.06%
     Snacks
                          -------------------------       ----------------------------------------------------------
      Top 100                 $894.8        13.60%           $5,251.7        16.66%           $6,146.5        16.13%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

              Exhibit E-6: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in the Midwest
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $64.3         0.98%  1          $237.1         0.75%  1          $301.4         0.79%
     White Only
    Soft Drinks 12/ 2          $60.9         0.93%  2          $175.6         0.56%  2          $236.5         0.62%
     18 & 15pk Can
     Car
    Primal [Beef]   3          $34.5         0.52%  4          $101.5         0.32%  3          $136.0         0.36%
    Lean [Beef]     4          $32.9         0.50%  28          $43.8         0.14%  12          $76.7         0.20%
    Shredded        5          $28.5         0.43%  3          $102.0         0.32%  4          $130.4         0.34%
     Cheese
    Kids Cereal     6          $26.3         0.40%  18          $51.4         0.16%  11          $77.7         0.20%
    Sft Drnk 2      7          $26.3         0.40%  8           $67.4         0.21%  6           $93.7         0.25%
     Liter Btl
     Carb Incl
    Potato Chips    8          $23.0         0.35%  5           $76.5         0.24%  5           $99.5         0.26%
    Snacks/         9          $19.5         0.30%  43          $33.6         0.11%  31          $53.0         0.14%
     Appetizers
    Infant Formula  10         $18.9         0.29%  180         $12.1         0.04%  68          $31.1         0.08%
     Starter/
     Solutio
    Lunchment--Del  11         $17.9         0.27%  10          $60.7         0.19%  10          $78.6         0.21%
     i Fresh
    Mainstream      12         $17.4         0.26%  35          $38.8         0.12%  28          $56.1         0.15%
     White Bread
    Enhanced [Pork  13         $17.2         0.26%  16          $54.2         0.17%  16          $71.4         0.19%
     Boneless Loin/
     Rib]
    American        14         $17.1         0.26%  30          $43.2         0.14%  22          $60.3         0.16%
     Single Cheese
    Tortilla/Nacho  15         $16.2         0.25%  14          $56.2         0.18%  15          $72.4         0.19%
     Chips
    Unflavored Can  16         $16.1         0.24%  12          $60.0         0.19%  13          $76.1         0.20%
     Coffee
    Fz Ss Economy   17         $15.7         0.24%  68          $25.0         0.08%  45          $40.7         0.11%
     Meals All
    Soft Drinks     18         $15.5         0.24%  38          $36.7         0.12%  34          $52.3         0.14%
     20pk & 24pk
     Can Carb
    Snack Cake--    19         $15.4         0.23%  42          $33.6         0.11%  38          $49.0         0.13%
     Multi Pack
    Chicken Breast  20         $15.4         0.23%  7           $68.8         0.22%  7           $84.2         0.22%
     Boneless
    Fz Ss Prem      21         $15.2         0.23%  22          $46.5         0.15%  21          $61.7         0.16%
     Traditional
     Meals
    Bacon--Trad     22         $14.5         0.22%  32          $42.7         0.14%  25          $57.2         0.15%
     16oz Or Less
    Eggs--Large     23         $14.2         0.22%  15          $55.8         0.18%  18          $70.0         0.18%
    Dairy Case      24         $13.6         0.21%  9           $65.7         0.21%  9           $79.3         0.21%
     100% Pure
     Juice--O
    Still Water     25         $13.5         0.20%  29          $43.5         0.14%  27          $57.0         0.15%
     Drnking/Mnrl
     Water
    Convenient      26         $13.0         0.20%  82          $20.7         0.07%  61          $33.7         0.09%
     Meals--Kids
     Meal C
    Potatoes        27         $13.0         0.20%  31          $42.9         0.14%  29          $55.9         0.15%
     Russet (Bulk
     & Bag)
    Pizza/Premium   28         $12.9         0.20%  37          $37.1         0.12%  36          $50.0         0.13%
    All Family      29         $12.6         0.19%  11          $60.1         0.19%  14          $72.7         0.19%
     Cereal
    Sft Drnk Mlt-   30         $12.5         0.19%  19          $50.1         0.16%  19          $62.6         0.16%
     Pk Btl Carb
     (Excp)
    Sandwiches &    31         $12.4         0.19%  88          $20.2         0.06%  65          $32.6         0.09%
     Handhelds
    Frzn Chicken--  32         $12.4         0.19%  48          $31.9         0.10%  41          $44.3         0.12%
     Wht Meat
    Ribs [Pork]     33         $12.3         0.19%  58          $27.8         0.09%  47          $40.1         0.11%
    Mainstream      34         $11.8         0.18%  23          $45.3         0.14%  26          $57.1         0.15%
     Variety
     Breads
    Sugar           35         $11.7         0.18%  56          $27.9         0.09%  49          $39.6         0.10%
    Choice Beef     36         $11.3         0.17%  57          $27.9         0.09%  50          $39.2         0.10%
    Condensed Soup  37         $11.2         0.17%  21          $46.8         0.15%  23          $58.0         0.15%
    Traditional     38         $10.8         0.16%  26          $44.2         0.14%  30          $55.0         0.14%
     [Ice Cream &
     Sherbert]
    Bananas         39         $10.7         0.16%  13          $59.9         0.19%  17          $70.6         0.19%
    Pourable Salad  40         $10.6         0.16%  36          $38.6         0.12%  37          $49.2         0.13%
     Dressings
    Fz Family       41          $9.7         0.15%  74          $22.9         0.07%  66          $32.6         0.09%
     Style Entrees
    Macaroni &      42          $9.7         0.15%  97          $19.0         0.06%  74          $28.7         0.08%
     Cheese Dnrs
    Choice Beef     43          $9.6         0.15%  44          $33.0         0.10%  43          $42.5         0.11%
    Natural Cheese  44          $9.5         0.14%  20          $48.3         0.15%  24          $57.7         0.15%
     Chunks
    Mainstream      45          $9.4         0.14%  60          $27.2         0.09%  56          $36.6         0.10%
     [Pasta &
     Pizza Sauce]
    Margarine:      46          $9.1         0.14%  51          $29.9         0.09%  51          $39.0         0.10%
     Tubs And
     Bowls
    Hot Dogs--Base  47          $9.1         0.14%  95          $19.5         0.06%  75          $28.6         0.08%
     Meat
    Can Pasta       48          $9.0         0.14%  117         $16.1         0.05%  95          $25.1         0.07%
    Mayonnaise &    49          $9.0         0.14%  54          $28.7         0.09%  54          $37.7         0.10%
     Whipped
     Dressing
    Fz Ss Prem      50          $8.6         0.13%  6           $72.5         0.23%  8           $81.1         0.21%
     Nutritional
     Meals
    Strawberries    51          $8.6         0.13%  17          $53.1         0.17%  20          $61.7         0.16%
    Sft Drnk Sngl   52          $8.3         0.13%  127         $15.4         0.05%  100         $23.7         0.06%
     Srv Btl Carb
     (Ex)
    Meat: Turkey    53          $8.1         0.12%  27          $43.9         0.14%  35          $52.0         0.14%
     Bulk
    Lunchment--Bol  54          $8.1         0.12%  93          $19.7         0.06%  78          $27.8         0.07%
     ogna/Sausage
    Aseptic Pack    55          $7.9         0.12%  124         $15.6         0.05%  101         $23.6         0.06%
     Juice And
     Drinks
    Isotonic        56          $7.9         0.12%  59          $27.6         0.09%  58          $35.4         0.09%
     Drinks Single
     Serve
    Fz Bag          57          $7.8         0.12%  45          $32.7         0.10%  46          $40.6         0.11%
     Vegetables--P
     lain
    Select Beef     58          $7.7         0.12%  100         $18.5         0.06%  89          $26.2         0.07%
    Frzn French     59          $7.6         0.12%  128         $15.3         0.05%  104         $23.0         0.06%
     Fries
    Adult Cereal    60          $7.6         0.12%  24          $45.1         0.14%  32          $52.7         0.14%
    Pizza/Economy   61          $7.6         0.12%  113         $16.6         0.05%  96          $24.2         0.06%
    Sw Gds: Donuts  62          $7.6         0.11%  66          $25.4         0.08%  64          $32.9         0.09%
    Frzn Chicken--  63          $7.5         0.11%  467          $4.2         0.01%  248         $11.7         0.03%
     Wings
    Flavored Milk   64          $7.5         0.11%  75          $22.7         0.07%  72          $30.3         0.08%
    Premium [Ice    65          $7.5         0.11%  25          $45.1         0.14%  33          $52.6         0.14%
     Cream &
     Sherbert]
    Candy Bags--    66          $7.3         0.11%  34          $39.3         0.12%  40          $46.6         0.12%
     Chocolate
    Peanut Butter   67          $7.1         0.11%  40          $34.5         0.11%  44          $41.6         0.11%
    Sweet Goods--   68          $7.1         0.11%  81          $20.9         0.07%  77          $28.0         0.07%
     Full Size
    Meat: Ham Bulk  69          $7.0         0.11%  39          $36.5         0.12%  42          $43.4         0.11%
    Refrigerated    70          $7.0         0.11%  49          $31.2         0.10%  53          $38.2         0.10%
     Coffee
     Creamers
    Bkfst Sausage-- 71          $6.6         0.10%  92          $19.7         0.06%  86          $26.4         0.07%
     Fresh Rolls
    Tuna            72          $6.6         0.10%  62          $26.4         0.08%  63          $33.0         0.09%
    Value Forms     73          $6.6         0.10%  157         $13.3         0.04%  126         $19.9         0.05%
     Frz Chick/
     18oz & Larger
    Cakes:          74          $6.5         0.10%  147         $14.1         0.04%  119         $20.6         0.05%
     Birthday/
     Celebration
     Sh
    Pizza/          75          $6.5         0.10%  96          $19.2         0.06%  93          $25.7         0.07%
     Traditional
    Cream Cheese    76          $6.4         0.10%  47          $32.0         0.10%  52          $38.4         0.10%
    Fruit Snacks    77          $6.4         0.10%  167         $13.0         0.04%  129         $19.4         0.05%
    Vegetable Oil   78          $6.4         0.10%  265          $8.5         0.03%  189         $14.9         0.04%
    Frzn Breakfast  79          $6.4         0.10%  145         $14.3         0.05%  118         $20.7         0.05%
     Sandwiches
    Frzn Meat--     80          $6.3         0.10%  164         $13.1         0.04%  130         $19.4         0.05%
     Beef
    Sandwich        81          $6.2         0.09%  89          $20.1         0.06%  85          $26.4         0.07%
     Cookies
    Hamburger Buns  82          $6.2         0.09%  76          $22.4         0.07%  76          $28.6         0.08%
    Fz Skillet      83          $6.2         0.09%  83          $20.7         0.07%  82          $26.9         0.07%
     Meals
    Chicken Wings   84          $6.1         0.09%  368          $5.9         0.02%  240         $12.0         0.03%
    Sour Creams     85          $6.1         0.09%  71          $24.3         0.08%  71          $30.4         0.08%
    Cottage Cheese  86          $6.1         0.09%  41          $33.8         0.11%  48          $39.9         0.10%
    Butter          87          $6.0         0.09%  33          $41.9         0.13%  39          $47.9         0.13%
    Dnr Sausage--   88          $6.0         0.09%  103         $17.8         0.06%  99          $23.8         0.06%
     Links Fresh
    Cheese          89          $5.9         0.09%  65          $25.5         0.08%  67          $31.4         0.08%
     Crackers
    Rts Soup:       90          $5.8         0.09%  50          $30.3         0.10%  57          $36.1         0.09%
     Chunky/
     Homestyle/Et
    Hot Dog Buns    91          $5.7         0.09%  102         $17.9         0.06%  102         $23.5         0.06%
    Waffles/        92          $5.6         0.09%  85          $20.5         0.07%  90          $26.1         0.07%
     Pancakes/
     French Toast
    Mult Pk Bag     93          $5.6         0.09%  234          $9.9         0.03%  178         $15.5         0.04%
     Snacks
    Candy Bars      94          $5.6         0.08%  91          $20.0         0.06%  94          $25.6         0.07%
     (Multi Pack)
    Toaster         95          $5.5         0.08%  121         $15.8         0.05%  113         $21.3         0.06%
     Pastries
    Salsa & Dips    96          $5.4         0.08%  151         $13.9         0.04%  131         $19.2         0.05%
    Angus [Beef]    97          $5.3         0.08%  55          $28.0         0.09%  62          $33.4         0.09%
    Dnr Sausage--   98          $5.3         0.08%  182         $12.0         0.04%  155         $17.4         0.05%
     Links Pork
     Ckd/S
    Tray Pack/Choc  99          $5.2         0.08%  125         $15.6         0.05%  116         $20.8         0.05%
     Chip Cookies
    Grapes White    100         $5.2         0.08%  80          $21.3         0.07%  84          $26.5         0.07%
                          -------------------------       ----------------------------------------------------------
      Top 100               $1,174.1        17.84%           $3,685.6        11.70%           $4,859.7        12.76%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

               Exhibit E-7: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in the South
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $66.4         1.01%  1          $305.9         0.97%  1          $372.3         0.98%
     White Only
    Soft Drinks 12/ 2          $63.3         0.96%  2          $229.6         0.73%  2          $292.8         0.77%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $38.6         0.59%  15          $75.2         0.24%  8          $113.8         0.30%
    Kids Cereal     4          $29.8         0.45%  23          $63.5         0.20%  15          $93.3         0.24%
    Sft Drnk 2      5          $26.2         0.40%  9           $91.0         0.29%  7          $117.2         0.31%
     Liter Btl
     Carb Incl
    Primal [Beef]   6          $25.7         0.39%  6          $100.9         0.32%  5          $126.6         0.33%
    Shredded        7          $25.6         0.39%  3          $121.8         0.39%  3          $147.4         0.39%
     Cheese
    Potato Chips    8          $23.5         0.36%  12          $87.7         0.28%  10         $111.2         0.29%
    Lunchment--Del  9          $22.8         0.35%  7           $95.8         0.30%  6          $118.6         0.31%
     i Fresh
    Mainstream      10         $21.3         0.32%  24          $62.7         0.20%  21          $84.0         0.22%
     White Bread
    Still Water     11         $20.1         0.31%  16          $74.1         0.24%  14          $94.2         0.25%
     Drnking/Mnrl
     Water
    Snack Cake--    12         $19.8         0.30%  37          $48.3         0.15%  32          $68.1         0.18%
     Multi Pack
    Eggs--Large     13         $18.8         0.29%  11          $88.4         0.28%  12         $107.2         0.28%
    American        14         $17.9         0.27%  32          $56.0         0.18%  27          $73.9         0.19%
     Single Cheese
    Chicken Breast  15         $17.5         0.27%  4          $109.1         0.35%  4          $126.6         0.33%
     Boneless
    Sugar           16         $17.4         0.26%  41          $46.5         0.15%  35          $63.9         0.17%
    Sft Drnk Mlt-   17         $17.2         0.26%  10          $89.0         0.28%  13         $106.2         0.28%
     Pk Btl Carb
     (Excp)
    Fz Ss Prem      18         $16.7         0.25%  27          $59.9         0.19%  24          $76.6         0.20%
     Traditional
     Meals
    Infant Formula  19         $16.5         0.25%  247         $13.1         0.04%  108         $29.5         0.08%
     Starter/
     Solutio
    Tortilla/Nacho  20         $16.1         0.24%  19          $71.5         0.23%  18          $87.6         0.23%
     Chips
    Dairy Case      21         $15.9         0.24%  8           $92.7         0.29%  11         $108.6         0.29%
     100% Pure
     Juice--O
    Pizza/Premium   22         $15.9         0.24%  29          $59.0         0.19%  26          $74.9         0.20%
    Fz Ss Economy   23         $15.2         0.23%  84          $27.9         0.09%  59          $43.1         0.11%
     Meals All
    Snacks/         24         $15.2         0.23%  59          $35.7         0.11%  47          $50.9         0.13%
     Appetizers
    Soft Drinks     25         $15.2         0.23%  58          $36.1         0.11%  46          $51.2         0.13%
     20pk & 24pk
     Can Carb
    Bacon--Trad     26         $14.8         0.23%  30          $58.3         0.18%  29          $73.1         0.19%
     16oz Or Less
    Mainstream      27         $14.6         0.22%  18          $72.1         0.23%  19          $86.8         0.23%
     Variety
     Breads
    Sandwiches &    28         $14.6         0.22%  87          $27.1         0.09%  63          $41.7         0.11%
     Handhelds
    Ribs [Pork]     29         $14.1         0.21%  51          $40.4         0.13%  41          $54.5         0.14%
    Convenient      30         $14.1         0.21%  80          $28.6         0.09%  60          $42.7         0.11%
     Meals--Kids
     Meal C
    Enhanced [Pork  31         $14.0         0.21%  21          $66.0         0.21%  23          $80.0         0.21%
     Boneless Loin/
     Rib]
    Potatoes        32         $13.8         0.21%  26          $61.4         0.19%  25          $75.3         0.20%
     Russet (Bulk
     & Bag)
    Unflavored Can  33         $13.4         0.20%  17          $73.0         0.23%  20          $86.3         0.23%
     Coffee
    Chicken Wings   34         $13.4         0.20%  224         $14.2         0.05%  119         $27.6         0.07%
    Mult Pk Bag     35         $12.2         0.19%  137         $20.4         0.06%  87          $32.6         0.09%
     Snacks
    Fz Bag          36         $12.2         0.19%  33          $54.9         0.17%  33          $67.1         0.18%
     Vegetables--P
     lain
    Sft Drnk Sngl   37         $12.2         0.18%  85          $27.5         0.09%  66          $39.7         0.10%
     Srv Btl Carb
     (Ex)
    Premium [Ice    38         $12.1         0.18%  13          $79.1         0.25%  16          $91.3         0.24%
     Cream &
     Sherbert]
    Frzn Chicken--  39         $12.1         0.18%  338          $9.0         0.03%  173         $21.1         0.06%
     Wings
    Bananas         40         $11.6         0.18%  14          $78.9         0.25%  17          $90.5         0.24%
    All Family      41         $11.3         0.17%  20          $70.1         0.22%  22          $81.4         0.21%
     Cereal
    Pourable Salad  42         $11.1         0.17%  38          $48.1         0.15%  36          $59.2         0.16%
     Dressings
    Hot Dogs--Base  43         $11.0         0.17%  106         $23.9         0.08%  80          $34.9         0.09%
     Meat
    Condensed Soup  44         $10.9         0.17%  31          $56.2         0.18%  34          $67.1         0.18%
    Fz Family       45         $10.5         0.16%  69          $32.1         0.10%  61          $42.6         0.11%
     Style Entrees
    Isotonic        46         $10.2         0.16%  49          $40.6         0.13%  48          $50.8         0.13%
     Drinks Single
     Serve
    Frzn Chicken--  47         $10.2         0.16%  55          $37.3         0.12%  53          $47.5         0.12%
     Wht Meat
    Vegetable Oil   48         $10.1         0.15%  204         $15.4         0.05%  132         $25.5         0.07%
    Mayonnaise &    49         $10.1         0.15%  46          $43.1         0.14%  43          $53.2         0.14%
     Whipped
     Dressing
    Aseptic Pack    50          $9.9         0.15%  115         $22.7         0.07%  88          $32.5         0.09%
     Juice And
     Drinks
    Frzn Breakfast  51          $9.5         0.14%  83          $27.9         0.09%  70          $37.4         0.10%
     Sandwiches
    Macaroni &      52          $9.4         0.14%  121         $21.8         0.07%  98          $31.3         0.08%
     Cheese Dnrs
    Fz Ss Prem      53          $9.2         0.14%  5          $102.2         0.32%  9          $111.5         0.29%
     Nutritional
     Meals
    Frzn French     54          $9.2         0.14%  127         $21.2         0.07%  103         $30.4         0.08%
     Fries
    Choice Beef     55          $8.9         0.14%  56          $37.2         0.12%  55          $46.1         0.12%
    Lunchment--Bol  56          $8.9         0.14%  110         $23.5         0.07%  89          $32.4         0.09%
     ogna/Sausage
    Natural Cheese  57          $8.9         0.14%  28          $59.2         0.19%  31          $68.1         0.18%
     Chunks
    Can Pasta       58          $8.8         0.13%  156         $18.7         0.06%  121         $27.5         0.07%
    Adult Cereal    59          $8.5         0.13%  22          $64.7         0.21%  28          $73.2         0.19%
    Traditional     60          $8.5         0.13%  50          $40.5         0.13%  49          $49.0         0.13%
     [Ice Cream &
     Sherbert]
    Mainstream      61          $8.4         0.13%  81          $28.5         0.09%  74          $36.9         0.10%
     [Pasta &
     Pizza Sauce]
    Dnr Sausage--   62          $8.3         0.13%  199         $15.7         0.05%  144         $24.1         0.06%
     Links Pork
     Ckd/S
    Chicken Drums   63          $8.3         0.13%  249         $12.9         0.04%  172         $21.2         0.06%
    Margarine:      64          $8.1         0.12%  63          $33.4         0.11%  64          $41.5         0.11%
     Tubs And
     Bowls
    Tuna            65          $8.0         0.12%  48          $40.9         0.13%  50          $48.9         0.13%
    Pizza/Economy   66          $7.9         0.12%  181         $16.4         0.05%  142         $24.3         0.06%
    Strawberries    67          $7.8         0.12%  25          $62.0         0.20%  30          $69.9         0.18%
    Angus [Beef]    68          $7.8         0.12%  40          $46.9         0.15%  40          $54.7         0.14%
    Shrimp--Raw     69          $7.6         0.12%  70          $31.8         0.10%  68          $39.4         0.10%
    Value Forms/    70          $7.5         0.11%  179         $16.5         0.05%  145 $        24.0         0.06%
     18oz And
     Larger
     [Chicken]
    Select Beef     71          $7.5         0.11%  36          $51.3         0.16%  37          $58.8         0.15%
    Fz Skillet      72          $7.4         0.11%  76          $29.7         0.09%  72          $37.1         0.10%
     Meals
    Cakes:          73          $7.3         0.11%  142         $19.7         0.06%  122         $27.1         0.07%
     Birthday/
     Celebration
     Sh
    Bacon--Trad     74          $7.2         0.11%  108         $23.7         0.08%  100         $30.9         0.08%
     Greater Than
     16oz
    Pizza/          75          $7.2         0.11%  91          $26.2         0.08%  84          $33.4         0.09%
     Traditional
    Refrigerated    76          $7.1         0.11%  114         $22.8         0.07%  106         $29.9         0.08%
     Biscuits
    Sw Gds: Donuts  77          $7.0         0.11%  107         $23.8         0.08%  101         $30.8         0.08%
    Frzn Meat--     78          $7.0         0.11%  185         $16.3         0.05%  151         $23.3         0.06%
     Beef
    Salsa & Dips    79          $7.0         0.11%  122         $21.7         0.07%  114         $28.7         0.08%
    Fruit Snacks    80          $7.0         0.11%  194         $16.0         0.05%  154         $23.0         0.06%
    Candy Bags--    81          $6.9         0.11%  42          $46.5         0.15%  42          $53.4         0.14%
     Chocolate
    Peanut Butter   82          $6.7         0.10%  43          $45.2         0.14%  45          $51.9         0.14%
    Sandwich        83          $6.7         0.10%  100         $24.9         0.08%  93          $31.6         0.08%
     Cookies
    Ramen Noodles/  84          $6.6         0.10%  327          $9.5         0.03%  243         $16.2         0.04%
     Ramen Cups
    Waffles/        85          $6.6         0.10%  82          $27.9         0.09%  81          $34.5         0.09%
     Pancakes/
     French Toast
    Hot Dog Buns    86          $6.3         0.10%  116         $22.5         0.07%  113         $28.9         0.08%
    Candy Bars      87          $6.2         0.09%  96          $25.4         0.08%  95          $31.6         0.08%
     (Multi Pack)
    Bagged Cheese   88          $6.2         0.09%  147         $19.4         0.06%  133         $25.5         0.07%
     Snacks
    Prepared        89          $6.1         0.09%  125         $21.5         0.07%  118         $27.6         0.07%
     Beans--Baked
     W/Pork
    Loaf Cheese     90          $6.1         0.09%  145         $19.5         0.06%  130         $25.6         0.07%
    Meat: Turkey    91          $6.0         0.09%  34          $52.7         0.17%  38          $58.8         0.15%
     Bulk
    Tray Pack/Choc  92          $6.0         0.09%  141         $19.9         0.06%  129         $26.0         0.07%
     Chip Cookies
    Hamburger Buns  93          $6.0         0.09%  99          $25.1         0.08%  99          $31.1         0.08%
    Green Beans:    94          $6.0         0.09%  102         $24.8         0.08%  102         $30.8         0.08%
     Fs/Whl/Cut
    Grapes White    95          $6.0         0.09%  75          $29.7         0.09%  79          $35.6         0.09%
    Spring Water    96          $6.0         0.09%  64          $32.9         0.10%  69          $38.8         0.10%
    Rts Soup:       97          $5.9         0.09%  54          $38.6         0.12%  57          $44.5         0.12%
     Chunky/
     Homestyle/Et
    Butter Spray    98          $5.9         0.09%  88          $26.2         0.08%  91          $32.1         0.08%
     Cracker
    Instore Cut     99          $5.9         0.09%  57          $36.6         0.12%  62          $42.5         0.11%
     Fruit
    Toaster         100         $5.8         0.09%  134         $20.5         0.07%  125         $26.4         0.07%
     Pastries
                          -------------------------       ----------------------------------------------------------
      Top 100               $1,268.9        19.28%           $4,783.8        15.18%           $6,052.7        15.89%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

               Exhibit E-8: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in the West
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $60.4         0.92%  1          $310.8         0.99%  1          $371.2         0.97%
     White Only
    Lean [Beef]     2          $40.9         0.62%  3          $138.9         0.44%  3          $179.8         0.47%
    Soft Drinks 12/ 3          $40.5         0.62%  2          $196.0         0.62%  2          $236.5         0.62%
     18 & 15pk Can
     Car
    Kids Cereal     4          $22.0         0.33%  22          $71.5         0.23%  17          $93.5         0.25%
    Shredded        5          $20.7         0.31%  4          $118.2         0.38%  4          $138.9         0.36%
     Cheese
    Eggs--Large     6          $19.1         0.29%  8          $107.4         0.34%  6          $126.5         0.33%
    Infant Formula  7          $18.8         0.29%  167         $20.1         0.06%  75          $38.9         0.10%
     Starter/
     Solutio
    Sft Drnk 2      8          $18.4         0.28%  21          $71.8         0.23%  18          $90.2         0.24%
     Liter Btl
     Carb Incl
    Potato Chips    9          $17.9         0.27%  13          $89.0         0.28%  11         $106.9         0.28%
    Natural Cheese  10         $16.9         0.26%  7          $108.6         0.34%  7          $125.6         0.33%
     Chunks
    Chicken Breast  11         $16.7         0.25%  5          $115.0         0.36%  5          $131.7         0.35%
     Boneless
    Still Water     12         $15.2         0.23%  24          $70.1         0.22%  23          $85.3         0.22%
     Drnking/Mnrl
     Water
    Lunchment--Del  13         $15.2         0.23%  14          $86.0         0.27%  13         $101.2         0.27%
     i Fresh
    Tortilla/Nacho  14         $15.1         0.23%  17          $81.3         0.26%  16          $96.4         0.25%
     Chips
    Mexican Soft    15         $15.1         0.23%  23          $71.5         0.23%  21          $86.6         0.23%
     Tortillas And
     Wra
    Dairy Case      16         $14.0         0.21%  6          $110.7         0.35%  8          $124.7         0.33%
     100% Pure
     Juice--O
    Select Beef     17         $12.6         0.19%  19          $73.9         0.23%  22          $86.5         0.23%
    Isotonic        18         $12.4         0.19%  39          $51.4         0.16%  38          $63.7         0.17%
     Drinks Single
     Serve
    All Family      19         $12.3         0.19%  15          $84.7         0.27%  15          $97.0         0.25%
     Cereal
    Mainstream      20         $12.0         0.18%  37          $55.8         0.18%  36          $67.8         0.18%
     Variety
     Breads
    Fz Ss Prem      21         $11.9         0.18%  27          $69.1         0.22%  25          $81.0         0.21%
     Traditional
     Meals
    Bananas         22         $11.9         0.18%  9          $103.9         0.33%  9          $115.8         0.30%
    Unflavored Can  23         $11.9         0.18%  29          $65.0         0.21%  27          $76.9         0.20%
     Coffee
    Premium [Ice    24         $11.6         0.18%  10         $101.7         0.32%  10         $113.3         0.30%
     Cream &
     Sherbert]
    Refrigerated    25         $11.5         0.17%  18          $75.9         0.24%  20          $87.4         0.23%
     Coffee
     Creamers
    Bacon--Trad     26         $11.4         0.17%  36          $56.6         0.18%  34          $68.1         0.18%
     16oz Or Less
    Pizza/Premium   27         $10.9         0.17%  35          $57.2         0.18%  35          $68.1         0.18%
    Enhanced [Pork  28         $10.3         0.16%  49          $47.8         0.15%  42          $58.1         0.15%
     Boneless Loin/
     Rib]
    Fz Ss Economy   29         $10.0         0.15%  104         $27.8         0.09%  83          $37.8         0.10%
     Meals All
    Snacks/         30         $10.0         0.15%  85          $31.2         0.10%  70          $41.1         0.11%
     Appetizers
    Choice Beef     31          $9.9         0.15%  28          $66.5         0.21%  28          $76.5         0.20%
    Mainstream      32          $9.3         0.14%  71          $35.3         0.11%  64          $44.6         0.12%
     White Bread
    American        33          $9.0         0.14%  66          $37.4         0.12%  62          $46.5         0.12%
     Single Cheese
    Soft Drinks     34          $9.0         0.14%  77          $33.6         0.11%  67          $42.6         0.11%
     20pk & 24pk
     Can Carb
    Potatoes        35          $9.0         0.14%  44          $50.1         0.16%  40          $59.1         0.16%
     Russet (Bulk
     & Bag)
    Adult Cereal    36          $8.8         0.13%  20          $72.8         0.23%  24          $81.6         0.21%
    Sandwiches &    37          $8.8         0.13%  113         $26.3         0.08%  92          $35.1         0.09%
     Handhelds
    Ribs [Pork]     38          $8.6         0.13%  62          $38.5         0.12%  59          $47.1         0.12%
    Avocado         39          $8.4         0.13%  26          $69.5         0.22%  26          $77.9         0.20%
    Choice Beef     40          $8.2         0.13%  102         $28.4         0.09%  85          $36.6         0.10%
    Mayonnaise &    41          $8.2         0.12%  50          $47.2         0.15%  45          $55.4         0.15%
     Whipped
     Dressing
    Sandwiches--(C  42          $8.1         0.12%  54          $44.1         0.14%  51          $52.2         0.14%
     old)
    Butter          43          $8.0         0.12%  16          $81.6         0.26%  19          $89.6         0.24%
    Premium Bread   44          $7.9         0.12%  12          $89.1         0.28%  14          $97.0         0.25%
    Sugar           45          $7.8         0.12%  64          $38.3         0.12%  63          $46.1         0.12%
    Condensed Soup  46          $7.6         0.12%  42          $50.6         0.16%  41          $58.2         0.15%
    Frzn Chicken--  47          $7.4         0.11%  90          $30.6         0.10%  81          $38.0         0.10%
     Wht Meat
    Fz Family       48          $7.4         0.11%  100         $28.5         0.09%  87          $35.9         0.09%
     Style Entrees
    Sft Drnk Sngl   49          $7.3         0.11%  101         $28.5         0.09%  88          $35.8         0.09%
     Srv Btl Carb
     (Ex)
    Candy Bags--    50          $7.3         0.11%  33          $61.8         0.20%  32          $69.0         0.18%
     Chocolate
    Pourable Salad  51          $7.3         0.11%  38          $52.8         0.17%  39          $60.1         0.16%
     Dressings
    Convenient      52          $7.1         0.11%  160         $20.5         0.06%  126         $27.6         0.07%
     Meals--Kids
     Meal C
    Strawberries    53          $7.0         0.11%  31          $63.3         0.20%  31          $70.3         0.18%
    Fz Ss Prem      54          $6.9         0.10%  11          $96.9         0.31%  12         $103.7         0.27%
     Nutritional
     Meals
    Sw Gds: Donuts  55          $6.7         0.10%  79          $33.1         0.11%  74          $39.8         0.10%
    Peanut Butter   56          $6.6         0.10%  48          $48.1         0.15%  46          $54.7         0.14%
    Tuna            57          $6.5         0.10%  59          $42.6         0.14%  57          $49.2         0.13%
    Snack Cake--    58          $6.5         0.10%  168         $19.8         0.06%  141         $26.3         0.07%
     Multi Pack
    Aseptic Pack    59          $6.4         0.10%  174         $18.8         0.06%  152         $25.3         0.07%
     Juice And
     Drinks
    Traditional     60          $6.3         0.10%  75          $34.1         0.11%  73          $40.4         0.11%
     [Ice Cream &
     Sherbert]
    Margarine:      61          $6.2         0.09%  65          $37.5         0.12%  65          $43.8         0.11%
     Tubs And
     Bowls
    Sour Creams     62          $6.2         0.09%  60          $41.7         0.13%  58          $47.9         0.13%
    String Cheese   63          $6.2         0.09%  55          $43.8         0.14%  54          $50.0         0.13%
    Candy Bars      64          $6.2         0.09%  103         $28.1         0.09%  95          $34.2         0.09%
     (Singles)
     (Including)
    Bagged Cheese   65          $6.1         0.09%  166         $20.2         0.06%  139         $26.4         0.07%
     Snacks
    Cream Cheese    66          $6.1         0.09%  46          $48.4         0.15%  47          $54.5         0.14%
    Dairy Case      67          $6.0         0.09%  132         $23.5         0.07%  115         $29.5         0.08%
     Juice Drnk
     Under 10
    Rts Soup:       68          $5.9         0.09%  40          $51.0         0.16%  43          $56.9         0.15%
     Chunky/
     Homestyle/Et
    Fz Bag          69          $5.7         0.09%  53          $44.3         0.14%  55          $50.0         0.13%
     Vegetables--P
     lain
    Frzn Meat--     70          $5.7         0.09%  199         $16.9         0.05%  168         $22.6         0.06%
     Beef
    Tea Sweetened   71          $5.7         0.09%  89          $30.6         0.10%  86          $36.3         0.10%
    Chix:           72          $5.6         0.09%  30          $64.7         0.21%  30          $70.3         0.18%
     Rotisserie
     (Hot)
    Burritos        73          $5.4         0.08%  286         $12.2         0.04%  220         $17.6         0.05%
    Spring Water    74          $5.3         0.08%  52          $44.9         0.14%  53          $50.3         0.13%
    Ramen Noodles/  75          $5.3         0.08%  268         $12.8         0.04%  217         $18.1         0.05%
     Ramen Cups
    Macaroni &      76          $5.2         0.08%  173         $18.8         0.06%  156         $24.0         0.06%
     Cheese Dnrs
    Natural Cheese  77          $5.2         0.08%  41          $51.0         0.16%  44          $56.2         0.15%
     Slices
    Fz Skillet      78          $5.2         0.08%  94          $29.0         0.09%  96          $34.1         0.09%
     Meals
    Waffles/        79          $5.2         0.08%  95          $28.9         0.09%  97          $34.1         0.09%
     Pancakes/
     French Toast
    Mainstream      80          $5.1         0.08%  117         $25.3         0.08%  113         $30.4         0.08%
     [Pasta &
     Pizza Sauce]
    Meat: Turkey    81          $5.1         0.08%  32          $63.0         0.20%  33          $68.1         0.18%
     Bulk
    Cheese          82          $5.1         0.08%  78          $33.1         0.11%  79          $38.2         0.10%
     Crackers
    Grapes Red      83          $5.1         0.08%  51          $46.6         0.15%  52          $51.6         0.14%
    Sandwich        84          $5.1         0.08%  110         $26.7         0.08%  107         $31.8         0.08%
     Cookies
    Shrimp--Cooked  85          $5.1         0.08%  124         $24.5         0.08%  114         $29.5         0.08%
    Whole Chicken   86          $5.0         0.08%  107         $27.3         0.09%  104         $32.3         0.08%
     (Roasters/
     Fryer)
    Shrimp--Raw     87          $5.0         0.08%  109         $27.2         0.09%  106         $32.2         0.08%
    Hot Dogs--Base  88          $4.9         0.08%  255         $13.5         0.04%  213         $18.4         0.05%
     Meat
    Cottage Cheese  89          $4.9         0.07%  45          $48.8         0.15%  49          $53.7         0.14%
    Oranges Navels  90          $4.9         0.07%  68          $36.8         0.12%  69          $41.6         0.11%
     All
    Chewing Gum     91          $4.8         0.07%  80          $33.0         0.10%  84          $37.8         0.10%
    Lunchment--Bol  92          $4.8         0.07%  190         $17.7         0.06%  170         $22.5         0.06%
     ogna/Sausage
    Apple Juice &   93          $4.7         0.07%  188         $18.0         0.06%  167         $22.7         0.06%
     Cider (Over
     50%)
    Super Premium   94          $4.7         0.07%  47          $48.3         0.15%  50          $53.1         0.14%
     Pints [Ice
     Cream &
     Sherbert]
    Salsa & Dips    95          $4.7         0.07%  152         $21.4         0.07%  143         $26.2         0.07%
    Cakes:          96          $4.7         0.07%  206         $16.5         0.05%  184         $21.2         0.06%
     Birthday/
     Celebration
     Sh
    Yogurt/Ss       97          $4.7         0.07%  70          $36.3         0.12%  71          $41.0         0.11%
     Regular
    Value Forms/    98          $4.6         0.07%  270         $12.8         0.04%  226         $17.3         0.05%
     18oz And
     Larger
     [Chicken]
    Energy Drink--  99          $4.5         0.07%  108         $27.3         0.09%  108         $31.8         0.08%
     Single Serve
     (N)
    Non-Carb Water  100         $4.5         0.07%  88          $30.7         0.09%  90          $35.1         0.09%
     Flvr--Drnk/
     Mnr
                          -------------------------       ----------------------------------------------------------
      Top 100                 $971.3        14.76%           $5,340.7        16.93%           $6,312.0        16.56%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

      Exhibit E-9: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in Large Metropolitan Counties
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1         $102.1         1.55%  1          $484.1         1.54%  1          $586.2         1.54%
     White Only
    Soft Drinks 12/ 2          $84.7         1.29%  2          $346.6         1.10%  2          $431.3         1.13%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $58.3         0.89%  11         $142.4         0.45%  5          $200.7         0.53%
    Kids Cereal     4          $44.8         0.68%  18         $110.5         0.35%  14         $155.3         0.41%
    Shredded        5          $41.0         0.62%  3          $197.3         0.63%  3          $238.2         0.63%
     Cheese
    Sft Drnk 2      6          $39.6         0.60%  13         $135.9         0.43%  10         $175.5         0.46%
     Liter Btl
     Carb Incl
    Potato Chips    7          $35.3         0.54%  9          $145.9         0.46%  8          $181.2         0.48%
    Lunchment--Del  8          $30.4         0.46%  12         $140.6         0.45%  11         $171.0         0.45%
     i Fresh
    Eggs--Large     9          $29.6         0.45%  8          $147.8         0.47%  9          $177.3         0.47%
    Primal [Beef]   10         $29.6         0.45%  19         $109.9         0.35%  18         $139.5         0.37%
    Infant Formula  11         $29.1         0.44%  198         $26.5         0.08%  88          $55.6         0.15%
     Starter/
     Solution
    Still Water     12         $28.9         0.44%  17         $119.0         0.38%  16         $147.9         0.39%
     Drnking/Mnrl
     Water
    Chicken Breast  13         $27.5         0.42%  4          $178.4         0.57%  4          $205.9         0.54%
     Boneless
    Dairy Case      14         $26.7         0.41%  6          $168.2         0.53%  6          $194.9         0.51%
     100% Pure
     Juice--O
    Tortilla/Nacho  15         $25.7         0.39%  15         $122.3         0.39%  15         $148.0         0.39%
     Chips
    Fz Ss Prem      16         $25.6         0.39%  23         $108.0         0.34%  20         $133.5         0.35%
     Traditional
     Meals
    Snacks/         17         $24.7         0.38%  65          $61.0         0.19%  45          $85.7         0.22%
     Appetizers
    Mainstream      18         $24.3         0.37%  49          $73.5         0.23%  39          $97.8         0.26%
     White Bread
    American        19         $23.7         0.36%  43          $77.3         0.25%  34         $101.0         0.27%
     Single Cheese
    Mainstream      20         $23.2         0.35%  25         $102.4         0.32%  22         $125.7         0.33%
     Variety
     Breads
    Fz Ss Economy   21         $22.6         0.34%  91          $46.0         0.15%  70          $68.7         0.18%
     Meals All
    Bacon--Trad     22         $22.5         0.34%  31          $90.3         0.29%  28         $112.9         0.30%
     16oz Or Less
    Snack Cake--    23         $22.3         0.34%  72          $55.8         0.18%  59          $78.1         0.21%
     Multi Pack
    Pizza/Premium   24         $21.7         0.33%  29          $91.8         0.29%  26         $113.5         0.30%
    Unflavored Can  25         $20.3         0.31%  22         $108.3         0.34%  21         $128.7         0.34%
     Coffee
    Sugar           26         $20.1         0.31%  62          $62.1         0.20%  54          $82.1         0.22%
    Bananas         27         $19.9         0.30%  7          $148.3         0.47%  12         $168.2         0.44%
    Enhanced [Pork  28         $19.8         0.30%  33          $86.6         0.27%  31         $106.5         0.28%
     Boneless Loin/
     Rib]
    All Family      29         $19.8         0.30%  14         $124.8         0.40%  17         $144.6         0.38%
     Cereal
    Premium [Ice    30         $19.3         0.29%  10         $144.6         0.46%  13         $163.9         0.43%
     Cream &
     Sherbert]
    Sandwiches &    31         $19.2         0.29%  95          $43.3         0.14%  78          $62.5         0.16%
     Handhelds
    Ribs [Pork]     32         $19.1         0.29%  64          $61.4         0.19%  56          $80.6         0.21%
    Convenient      33         $18.7         0.28%  103         $41.8         0.13%  82          $60.5         0.16%
     Meals--Kids
     Meal C
    Natural Cheese  34         $18.6         0.28%  16         $120.3         0.38%  19         $138.9         0.36%
     Chunks
    Potatoes        35         $18.5         0.28%  36          $85.2         0.27%  32         $103.7         0.27%
     Russet (Bulk
     & Bag)
    Isotonic        36         $17.7         0.27%  47          $73.7         0.23%  43          $91.4         0.24%
     Drinks Single
     Serve
    Soft Drinks     37         $17.5         0.27%  75          $54.2         0.17%  64          $71.6         0.19%
     20pk & 24pk
     Can Carb
    Frzn Chicken--  38         $16.9         0.26%  73          $55.6         0.18%  63          $72.5         0.19%
     Wht Meat
    Sft Drnk Mlt-   39         $16.3         0.25%  30          $90.4         0.29%  29         $106.7         0.28%
     Pk Btl Carb
     (Excp)
    Pourable Salad  40         $16.2         0.25%  39          $82.7         0.26%  37          $98.9         0.26%
     Dressings
    Choice Beef     41         $16.1         0.24%  40          $81.9         0.26%  38          $98.0         0.26%
    Fz Family       42         $15.5         0.24%  82          $49.6         0.16%  74          $65.1         0.17%
     Style Entrees
    Condensed Soup  43         $15.4         0.23%  38          $84.7         0.27%  35         $100.2         0.26%
    Fz Bag          44         $15.1         0.23%  42          $77.6         0.25%  42          $92.7         0.24%
     Vegetables--P
     lain
    Frzn Chicken--  45         $15.1         0.23%  444         $11.1         0.04%  242         $26.3         0.07%
     Wings
    Mayonnaise &    46         $14.9         0.23%  55          $68.0         0.22%  50          $82.9         0.22%
     Whipped
     Dressing
    Select Beef     47         $14.9         0.23%  34          $86.5         0.27%  33         $101.4         0.27%
    Fz Ss Prem      48         $14.6         0.22%  5          $172.2         0.55%  7          $186.7         0.49%
     Nutritional
     Meals
    Adult Cereal    49         $14.4         0.22%  20         $109.6         0.35%  23         $124.0         0.33%
    Sft Drnk Sngl   50         $14.4         0.22%  107         $40.1         0.13%  92          $54.5         0.14%
     Srv Btl Carb
     (Ex)
    Aseptic Pack    51         $14.3         0.22%  122         $36.3         0.12%  100         $50.6         0.13%
     Juice And
     Drinks
    Chicken Wings   52         $14.0         0.21%  282         $18.6         0.06%  190         $32.6         0.09%
    Traditional     53         $13.6         0.21%  58          $63.3         0.20%  62          $76.9         0.20%
     [Ice Cream &
     Sherbert]
    Mult Pk Bag     54         $13.5         0.21%  182         $28.3         0.09%  134         $41.8         0.11%
     Snacks
    Refrigerated    55         $13.5         0.20%  27          $93.2         0.30%  30         $106.6         0.28%
     Coffee
     Creamers
    Mexican Soft    56         $13.4         0.20%  53          $69.5         0.22%  51          $82.9         0.22%
     Tortillas And
     Wra
    Strawberries    57         $13.4         0.20%  21         $109.1         0.35%  24         $122.5         0.32%
    Hot Dogs--Base  58         $13.1         0.20%  174         $29.5         0.09%  130         $42.5         0.11%
     Meat
    Mainstream      59         $13.0         0.20%  86          $48.2         0.15%  80          $61.2         0.16%
     [Pasta &
     Pizza Sauce]
    Macaroni &      60         $12.8         0.19%  136         $34.4         0.11%  109         $47.1         0.12%
     Cheese Dnrs
    Choice Beef     61         $12.6         0.19%  114         $38.4         0.12%  99          $51.0         0.13%
    Margarine:      62         $12.6         0.19%  68          $58.4         0.19%  65          $71.0         0.19%
     Tubs And
     Bowls
    Tuna            63         $12.2         0.19%  56          $68.0         0.22%  57          $80.2         0.21%
    Meat: Turkey    64         $12.1         0.18%  24         $105.2         0.33%  25         $117.4         0.31%
     Bulk
    Vegetable Oil   65         $11.7         0.18%  256         $20.5         0.06%  194         $32.2         0.08%
    Frzn French     66         $11.4         0.17%  180         $28.5         0.09%  147         $39.8         0.10%
     Fries
    Lunchment--Bol  67         $11.3         0.17%  152         $32.9         0.10%  121         $44.2         0.12%
     ogna/Sausage
    Candy Bags--    68         $11.3         0.17%  37          $84.8         0.27%  41          $96.0         0.25%
     Chocolate
    Can Pasta       69         $11.3         0.17%  204         $26.0         0.08%  163         $37.3         0.10%
    Fz Skillet      70         $11.2         0.17%  84          $48.9         0.16%  85          $60.1         0.16%
     Meals
    Sw Gds: Donuts  71         $11.1         0.17%  99          $43.0         0.14%  93          $54.1         0.14%
    Butter          72         $11.1         0.17%  26         $102.0         0.32%  27         $113.1         0.30%
    Peanut Butter   73         $11.0         0.17%  45          $74.1         0.23%  46          $85.0         0.22%
    Frzn Meat--     74         $10.7         0.16%  196         $26.6         0.08%  162         $37.3         0.10%
     Beef
    Frzn Breakfast  75         $10.7         0.16%  143         $33.6         0.11%  120         $44.3         0.12%
     Sandwiches
    Cakes:          76         $10.7         0.16%  169         $30.1         0.10%  140         $40.8         0.11%
     Birthday/
     Celebration
     Sh
    Waffles/        77         $10.4         0.16%  81          $50.0         0.16%  83          $60.5         0.16%
     Pancakes/
     French Toast
    Spring Water    78         $10.4         0.16%  57          $67.7         0.21%  60          $78.0         0.20%
    Value Forms/    79         $10.2         0.16%  212         $24.9         0.08%  177         $35.1         0.09%
     18oz And
     Larger
     [Chicken]
    Sandwiches--(C  80         $10.2         0.16%  92          $46.0         0.15%  87          $56.2         0.15%
     old)
    Dairy Case      81         $10.2         0.15%  158         $31.8         0.10%  131         $42.0         0.11%
     Juice Drnk
     Under 10
    Dnr Sausage--   82         $10.2         0.15%  232         $23.0         0.07%  186         $33.2         0.09%
     Links Pork
     Ckd/S
    Sandwich        83         $10.1         0.15%  102         $42.0         0.13%  97          $52.1         0.14%
     Cookies
    Pizza/Economy   84         $10.0         0.15%  234         $22.9         0.07%  188         $32.9         0.09%
    Chicken Drums   85         $10.0         0.15%  276         $18.9         0.06%  225         $28.9         0.08%
    Rts Soup:       86          $9.9         0.15%  50          $73.4         0.23%  48          $83.4         0.22%
     Chunky/
     Homestyle/Et
    Ramen Noodles/  87          $9.8         0.15%  302         $17.2         0.05%  237         $27.0         0.07%
     Ramen Cups
    Cream Cheese    88          $9.8         0.15%  54          $68.9         0.22%  58          $78.7         0.21%
    Sour Creams     89          $9.7         0.15%  70          $56.7         0.18%  72          $66.4         0.17%
    Bagged Cheese   90          $9.6         0.15%  167         $30.8         0.10%  144         $40.4         0.11%
     Snacks
    Fruit Snacks    91          $9.6         0.15%  211         $25.1         0.08%  181         $34.6         0.09%
    Salsa & Dips    92          $9.5         0.14%  139         $34.0         0.11%  124         $43.5         0.11%
    Ground Turkey   93          $9.4         0.14%  74          $55.3         0.18%  75          $64.7         0.17%
    Pizza/          94          $9.3         0.14%  128         $35.3         0.11%  117         $44.7         0.12%
     Traditional
    Sweet Goods--   95          $9.3         0.14%  119         $36.5         0.12%  113         $45.7         0.12%
     Full Size
    Candy Bars      96          $9.2         0.14%  155         $32.3         0.10%  136         $41.5         0.11%
     (Singles)
     (Including)
    Hot Dog Buns    97          $9.2         0.14%  118         $36.7         0.12%  112         $46.0         0.12%
    Cheese          98          $9.2         0.14%  71          $55.9         0.18%  73          $65.1         0.17%
     Crackers
    Shrimp--Raw     99          $9.2         0.14%  104         $41.3         0.13%  101         $50.5         0.13%
    Grapes Red      100         $9.2         0.14%  51          $72.9         0.23%  55          $82.1         0.22%
                          -------------------------       ----------------------------------------------------------
      Top 100               $1,843.6        28.02%           $7,796.5        24.74%           $9,640.1        25.31%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

    Exhibit E-10: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in Smaller Metropolitan Counties
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $62.4         0.95%  1          $264.0         0.84%  1          $326.5         0.86%
     White Only
    Soft Drinks 12/ 2          $52.7         0.80%  2          $176.7         0.56%  2          $229.4         0.60%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $38.9         0.59%  5           $80.9         0.26%  4          $119.7         0.31%
    Kids Cereal     4          $24.8         0.38%  20          $55.9         0.18%  13          $80.7         0.21%
    Shredded        5          $24.6         0.37%  3          $104.4         0.33%  3          $129.1         0.34%
     Cheese
    Primal [Beef]   6          $23.2         0.35%  8           $76.1         0.24%  6           $99.3         0.26%
    Sft Drnk 2      7          $23.2         0.35%  12          $70.0         0.22%  8           $93.1         0.24%
     Liter Btl
     Carb Incl
    Potato Chips    8          $20.9         0.32%  7           $76.3         0.24%  7           $97.3         0.26%
    Infant Formula  9          $18.7         0.28%  180         $13.8         0.04%  73          $32.5         0.09%
     Starter/
     Solutio
    Lunchment--Del  10         $18.4         0.28%  11          $74.4         0.24%  9           $92.8         0.24%
     i Fresh
    Eggs--Large     11         $16.4         0.25%  9           $74.8         0.24%  10          $91.2         0.24%
    Mainstream      12         $16.1         0.24%  33          $42.8         0.14%  29          $58.9         0.15%
     White Bread
    Chicken Breast  13         $15.9         0.24%  4           $84.6         0.27%  5          $100.5         0.26%
     Boneless
    Tortilla/Nacho  14         $15.8         0.24%  16          $63.2         0.20%  16          $79.0         0.21%
     Chips
    Enhanced [Pork  15         $14.7         0.22%  21          $54.7         0.17%  20          $69.4         0.18%
     Boneless Loin/
     Rib]
    American        16         $14.5         0.22%  35          $41.3         0.13%  33          $55.8         0.15%
     Single Cheese
    Snacks/         17         $14.2         0.22%  66          $28.6         0.09%  48          $42.8         0.11%
     Appetizers
    Unflavored Can  18         $14.2         0.22%  17          $61.8         0.20%  18          $75.9         0.20%
     Coffee
    Soft Drinks     19         $14.0         0.21%  49          $35.1         0.11%  38          $49.1         0.13%
     20pk & 24pk
     Can Carb
    Still Water     20         $13.9         0.21%  28          $47.9         0.15%  24          $61.8         0.16%
     Drnking/Mnrl
     Water
    Fz Ss Prem      21         $13.6         0.21%  25          $50.3         0.16%  22          $64.0         0.17%
     Traditional
     Meals
    Fz Ss Economy   22         $13.4         0.20%  76          $25.0         0.08%  59          $38.3         0.10%
     Meals All
    Bacon--Trad     23         $13.2         0.20%  30          $46.6         0.15%  26          $59.8         0.16%
     16oz Or Less
    Snack Cake--    24         $13.0         0.20%  61          $30.5         0.10%  46          $43.5         0.11%
     Multi Pack
    Pizza/Premium   25         $12.8         0.19%  32          $44.8         0.14%  31          $57.6         0.15%
    Dairy Case      26         $12.7         0.19%  10          $74.5         0.24%  11          $87.2         0.23%
     100% Pure
     Juice--O
    Potatoes        27         $12.0         0.18%  29          $47.4         0.15%  28          $59.4         0.16%
     Russet (Bulk
     & Bag)
    Sugar           28         $11.9         0.18%  50          $35.0         0.11%  42          $47.0         0.12%
    Natural Cheese  29         $11.9         0.18%  14          $68.4         0.22%  14          $80.3         0.21%
     Chunks
    All Family      30         $11.8         0.18%  15          $66.4         0.21%  17          $78.2         0.21%
     Cereal
    Sandwiches &    31         $11.7         0.18%  89          $21.8         0.07%  70          $33.5         0.09%
     Handhelds
    Sft Drnk Mlt-   32         $11.7         0.18%  19          $57.3         0.18%  21          $68.9         0.18%
     Pk Btl Carb
     (Excp)
    Ribs [Pork]     33         $11.4         0.17%  57          $31.2         0.10%  50          $42.6         0.11%
    Mainstream      34         $11.2         0.17%  24          $50.9         0.16%  23          $62.2         0.16%
     Variety
     Breads
    Convenient      35         $11.1         0.17%  103         $20.1         0.06%  77          $31.2         0.08%
     Meals--Kids
     Meal C
    Bananas         36         $10.4         0.16%  13          $69.3         0.22%  15          $79.7         0.21%
    Condensed Soup  37         $10.0         0.15%  27          $48.8         0.15%  30          $58.7         0.15%
    Frzn Chicken--  38          $9.6         0.15%  58          $31.1         0.10%  51          $40.7         0.11%
     Wht Meat
    Choice Beef     39          $9.5         0.14%  36          $40.9         0.13%  36          $50.4         0.13%
    Pourable Salad  40          $9.3         0.14%  37          $40.9         0.13%  37          $50.2         0.13%
     Dressings
    Select Beef     41          $9.3         0.14%  34          $41.5         0.13%  35          $50.8         0.13%
    Sft Drnk Sngl   42          $9.3         0.14%  87          $22.6         0.07%  76          $31.9         0.08%
     Srv Btl Carb
     (Ex)
    Isotonic        43          $9.2         0.14%  53          $33.6         0.11%  49          $42.7         0.11%
     Drinks Single
     Serve
    Premium [Ice    44          $8.9         0.14%  18          $61.5         0.19%  19          $70.4         0.18%
     Cream &
     Sherbert]
    Fz Family       45          $8.8         0.13%  77          $24.8         0.08%  69          $33.6         0.09%
     Style Entrees
    Mayonnaise &    46          $8.8         0.13%  45          $36.0         0.11%  45          $44.8         0.12%
     Whipped
     Dressing
    Traditional     47          $8.7         0.13%  41          $39.7         0.13%  39          $48.4         0.13%
     [Ice Cream &
     Sherbert]
    Hot Dogs--Base  48          $8.3         0.13%  121         $18.0         0.06%  92          $26.3         0.07%
     Meat
    Choice Beef     49          $8.2         0.13%  79          $23.8         0.08%  74          $32.1         0.08%
    Macaroni &      50          $8.2         0.12%  118         $18.1         0.06%  93          $26.3         0.07%
     Cheese Dnrs
    Fz Bag          51          $7.8         0.12%  42          $39.6         0.13%  41          $47.4         0.12%
     Vegetables--P
     lain
    Refrigerated    52          $7.7         0.12%  39          $40.6         0.13%  40          $48.3         0.13%
     Coffee
     Creamers
    Margarine:      53          $7.7         0.12%  63          $30.0         0.10%  61          $37.6         0.10%
     Tubs And
     Bowls
    Adult Cereal    54          $7.7         0.12%  22          $54.1         0.17%  25          $61.7         0.16%
    Can Pasta       55          $7.6         0.12%  157         $15.3         0.05%  114         $22.9         0.06%
    Mexican Soft    56          $7.6         0.12%  56          $31.9         0.10%  56          $39.5         0.10%
     Tortillas And
     Wra
    Fz Ss Prem      57          $7.6         0.12%  6           $76.8         0.24%  12          $84.4         0.22%
     Nutritional
     Meals
    Aseptic Pack    58          $7.3         0.11%  155         $15.3         0.05%  118         $22.6         0.06%
     Juice And
     Drinks
    Mainstream      59          $7.3         0.11%  80          $23.8         0.08%  78          $31.1         0.08%
     [Pasta &
     Pizza Sauce]
    Candy Bags--    60          $7.3         0.11%  31          $46.3         0.15%  34          $53.5         0.14%
     Chocolate
    Strawberries    61          $7.2         0.11%  26          $50.2         0.16%  32          $57.4         0.15%
    Lunchment--Bol  62          $7.2         0.11%  115         $18.6         0.06%  97          $25.8         0.07%
     ogna/Sausage
    Sw Gds: Donuts  63          $7.1         0.11%  70          $27.0         0.09%  66          $34.1         0.09%
    Pizza/Economy   64          $7.0         0.11%  151         $15.7         0.05%  117         $22.7         0.06%
    Peanut Butter   65          $6.6         0.10%  43          $39.0         0.12%  44          $45.7         0.12%
    Frzn French     66          $6.5         0.10%  159         $15.2         0.05%  125         $21.7         0.06%
     Fries
    Vegetable Oil   67          $6.5         0.10%  246         $10.4         0.03%  184         $16.9         0.04%
    Tuna            68          $6.5         0.10%  60          $30.7         0.10%  63          $37.2         0.10%
    Chicken Wings   69          $6.4         0.10%  338          $7.6         0.02%  223         $14.1         0.04%
    Butter          70          $6.3         0.09%  23          $53.3         0.17%  27          $59.5         0.16%
    Frzn Meat--     71          $6.1         0.09%  177         $14.2         0.04%  142         $20.3         0.05%
     Beef
    Mult Pk Bag     72          $6.1         0.09%  231         $11.1         0.04%  177         $17.1         0.04%
     Snacks
    Value Forms/    73          $6.0         0.09%  197         $12.7         0.04%  158         $18.7         0.05%
     18oz And
     Larger
     [Chicken]
    Frzn Breakfast  74          $6.0         0.09%  147         $15.8         0.05%  123         $21.8         0.06%
     Sandwiches
    Pizza/          75          $5.9         0.09%  101         $20.2         0.06%  94          $26.1         0.07%
     Traditional
    Fruit Snacks    76          $5.9         0.09%  189         $13.3         0.04%  154         $19.2         0.05%
    Frzn Chicken--  77          $5.9         0.09%  479          $4.7         0.01%  289         $10.6         0.03%
     Wings
    Fz Skillet      78          $5.7         0.09%  85          $23.0         0.07%  83          $28.7         0.08%
     Meals
    Sandwich        79          $5.7         0.09%  93          $21.4         0.07%  86          $27.1         0.07%
     Cookies
    Sour Creams     80          $5.7         0.09%  69          $28.0         0.09%  68          $33.7         0.09%
    Cakes:          81          $5.7         0.09%  178         $14.1         0.04%  147         $19.8         0.05%
     Birthday/
     Celebration
     Sh
    Rts Soup:       82          $5.6         0.09%  51          $34.7         0.11%  53          $40.3         0.11%
     Chunky/
     Homestyle/Et
    Chicken Drums   83          $5.5         0.08%  277          $9.0         0.03%  215         $14.6         0.04%
    Bagged Cheese   84          $5.4         0.08%  161         $15.0         0.05%  141         $20.5         0.05%
     Snacks
    Cream Cheese    85          $5.4         0.08%  52          $33.8         0.11%  57          $39.2         0.10%
    Salsa & Dips    86          $5.4         0.08%  139         $16.5         0.05%  121         $21.9         0.06%
    Flavored Milk   87          $5.4         0.08%  116         $18.5         0.06%  107         $23.9         0.06%
    Ramen Noodles/  88          $5.3         0.08%  312          $8.1         0.03%  233         $13.5         0.04%
     Ramen Cups
    Cheese          89          $5.3         0.08%  74          $25.8         0.08%  79          $31.0         0.08%
     Crackers
    Hamburger Buns  90          $5.3         0.08%  92          $21.5         0.07%  90          $26.8         0.07%
    Meat: Turkey    91          $5.3         0.08%  38          $40.9         0.13%  43          $46.1         0.12%
     Bulk
    Waffles/        92          $5.2         0.08%  99          $20.7         0.07%  96          $25.9         0.07%
     Pancakes/
     French Toast
    Candy Bars      93          $5.2         0.08%  90          $21.7         0.07%  89          $26.9         0.07%
     (Multi Pack)
    Candy Bars      94          $5.1         0.08%  140         $16.5         0.05%  127         $21.6         0.06%
     (Singles)
     (Including)
    Bkfst Sausage-- 95          $5.1         0.08%  105         $19.4         0.06%  103         $24.5         0.06%
     Fresh Rolls
    Angus [Beef]    96          $5.0         0.08%  65          $28.7         0.09%  67          $33.7         0.09%
    Hot Dog Buns    97          $5.0         0.08%  119         $18.1         0.06%  112         $23.1         0.06%
    Cottage Cheese  98          $5.0         0.08%  55          $33.0         0.10%  60          $38.0         0.10%
    String Cheese   99          $4.9         0.07%  68          $28.1         0.09%  71          $33.0         0.09%
    Sandwiches--(C  100         $4.9         0.07%  145         $16.0         0.05%  135       $20.9 0          .05%
     old)
                          -------------------------       ----------------------------------------------------------
      Top 100               $1,084.4        16.48%           $3,993.9        12.67%           $5,078.3        13.33%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

         Exhibit E-11: Top 100 Subcommodities for SNAP Households by Expenditure: Smaller Micropolitan Counties
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Soft Drinks 12/ 1          $20.5         0.31%  2           $61.5         0.20%  2           $82.0         0.22%
     18 & 15pk Can
     Car
    Fluid Milk/     2          $20.2         0.31%  1           $82.6         0.26%  1          $102.9         0.27%
     White Only
    Lean [Beef]     3          $12.0         0.18%  4           $27.1         0.09%  4           $39.0         0.10%
    Primal [Beef]   4           $7.5         0.11%  5           $27.0         0.09%  5           $34.5         0.09%
    Shredded        5           $7.2         0.11%  3           $31.9         0.10%  3           $39.1         0.10%
     Cheese
    Kids Cereal     6           $6.8         0.10%  23          $16.0         0.05%  17          $22.8         0.06%
    Sft Drnk 2      7           $6.4         0.10%  15          $19.6         0.06%  12          $26.0         0.07%
     Liter Btl
     Carb Incl
    Soft Drinks     8           $6.3         0.10%  33          $13.7         0.04%  24          $20.0         0.05%
     20pk & 24pk
     Can Carb
    Potato Chips    9           $6.3         0.10%  6           $24.3         0.08%  6           $30.5         0.08%
    Mainstream      10          $5.6         0.08%  27          $15.7         0.05%  20          $21.3         0.06%
     White Bread
    Lunchment--Del  11          $5.4         0.08%  10          $21.7         0.07%  8           $27.2         0.07%
     i Fresh
    Enhanced [Pork  12          $5.4         0.08%  11          $21.1         0.07%  11          $26.5         0.07%
     Boneless Loin/
     Rib]
    Unflavored Can  13          $5.1         0.08%  9           $21.8         0.07%  10          $26.9         0.07%
     Coffee
    Infant Formula  14          $5.0         0.08%  190          $4.0         0.01%  78           $9.0         0.02%
     Starter/
     Solutio
    Chicken Breast  15          $4.8         0.07%  7           $23.8         0.08%  7           $28.7         0.08%
     Boneless
    Snack Cake--    16          $4.8         0.07%  41          $11.9         0.04%  36          $16.6         0.04%
     Multi Pack
    Eggs--Large     17          $4.7         0.07%  8           $22.4         0.07%  9           $27.1         0.07%
    Still Water     18          $4.7         0.07%  21          $16.4         0.05%  21          $21.0         0.06%
     Drnking/Mnrl
     Water
    Tortilla/Nacho  19          $4.6         0.07%  19          $18.4         0.06%  16          $23.0         0.06%
     Chips
    American        20          $4.5         0.07%  31          $14.0         0.04%  28          $18.5         0.05%
     Single Cheese
    Sft Drnk Mlt-   21          $4.5         0.07%  14          $20.1         0.06%  13          $24.5         0.06%
     Pk Btl Carb
     (Excp)
    Snacks/         22          $4.4         0.07%  65           $8.6         0.03%  47          $13.0         0.03%
     Appetizers
    Potatoes        23          $4.0         0.06%  20          $16.9         0.05%  22          $20.9         0.05%
     Russet (Bulk
     & Bag)
    Pizza/Premium   24          $4.0         0.06%  35          $13.0         0.04%  34          $17.0         0.04%
    Fz Ss Economy   25          $3.9         0.06%  71           $7.8         0.02%  56          $11.7         0.03%
     Meals All
    Sandwiches &    26          $3.8         0.06%  85           $6.8         0.02%  65          $10.7         0.03%
     Handhelds
    Bacon--Trad     27          $3.8         0.06%  24          $15.9         0.05%  25          $19.7         0.05%
     16oz Or Less
    Sugar           28          $3.8         0.06%  39          $12.0         0.04%  37          $15.8         0.04%
    Fz Ss Prem      29          $3.7         0.06%  32          $13.7         0.04%  31          $17.4         0.05%
     Traditional
     Meals
    Natural Cheese  30          $3.6         0.06%  12          $20.8         0.07%  14          $24.5         0.06%
     Chunks
    Ribs [Pork]     31          $3.6         0.06%  45          $11.3         0.04%  41          $14.9         0.04%
    Convenient      32          $3.5         0.05%  95           $6.3         0.02%  74           $9.8         0.03%
     Meals--Kids
     Meal C
    All Family      33          $3.5         0.05%  17          $18.8         0.06%  19          $22.3         0.06%
     Cereal
    Condensed Soup  34          $3.3         0.05%  22          $16.1         0.05%  26          $19.4         0.05%
    Dairy Case      35          $3.2         0.05%  13          $20.7         0.07%  15          $23.9         0.06%
     100% Pure
     Juice--O
    Select Beef     36          $3.2         0.05%  34          $13.6         0.04%  35          $16.8         0.04%
    Sft Drnk Sngl   37          $3.2         0.05%  86           $6.7         0.02%  73           $9.8         0.03%
     Srv Btl Carb
     (Ex)
    Mainstream      38          $3.1         0.05%  28          $15.7         0.05%  27          $18.8         0.05%
     Variety
     Breads
    Bananas         39          $3.0         0.05%  16          $19.6         0.06%  18          $22.6         0.06%
    Isotonic        40          $2.9         0.04%  53          $10.0         0.03%  50          $12.9         0.03%
     Drinks Single
     Serve
    Hot Dogs--Base  41          $2.8         0.04%  78           $7.2         0.02%  68          $10.1         0.03%
     Meat
    Frzn Chicken--  42          $2.8         0.04%  50          $10.5         0.03%  46          $13.3         0.04%
     Wht Meat
    Pourable Salad  43          $2.8         0.04%  37          $12.4         0.04%  38          $15.2         0.04%
     Dressings
    Mayonnaise &    44          $2.7         0.04%  42          $11.8         0.04%  42          $14.5         0.04%
     Whipped
     Dressing
    Macaroni &      45          $2.7         0.04%  107          $5.8         0.02%  88           $8.4         0.02%
     Cheese Dnrs
    Can Pasta       46          $2.7         0.04%  129          $5.1         0.02%  94           $7.8         0.02%
    Fz Family       47          $2.7         0.04%  77           $7.2         0.02%  71           $9.9         0.03%
     Style Entrees
    Traditional     48          $2.6         0.04%  38          $12.3         0.04%  40          $14.9         0.04%
     [Ice Cream &
     Sherbert]
    Lunchment--Bol  49          $2.5         0.04%  80           $7.2         0.02%  75           $9.7         0.03%
     ogna/Sausage
    Margarine:      50          $2.5         0.04%  57           $9.8         0.03%  51          $12.2         0.03%
     Tubs And
     Bowls
    Sw Gds: Donuts  51          $2.4         0.04%  59           $9.4         0.03%  55          $11.8         0.03%
    Premium [Ice    52          $2.4         0.04%  25          $15.8         0.05%  29          $18.2         0.05%
     Cream &
     Sherbert]
    Angus [Beef]    53          $2.4         0.04%  40          $12.0         0.04%  43          $14.3         0.04%
    Choice Beef     54          $2.3         0.03%  72           $7.6         0.02%  72           $9.9         0.03%
    Fz Bag          55          $2.3         0.03%  43          $11.8         0.04%  44          $14.0         0.04%
     Vegetables--P
     lain
    Refrigerated    56          $2.3         0.03%  46          $10.7         0.03%  48          $13.0         0.03%
     Coffee
     Creamers
    Pizza/Economy   57          $2.3         0.03%  124          $5.2         0.02%  97           $7.5         0.02%
    Choice Beef     58          $2.3         0.03%  48          $10.6         0.03%  49          $12.9         0.03%
    Candy Bags--    59          $2.3         0.03%  36          $12.9         0.04%  39          $15.1         0.04%
     Chocolate
    Adult Cereal    60          $2.2         0.03%  30          $15.0         0.05%  33          $17.1         0.05%
    Strawberries    61          $2.2         0.03%  29          $15.0         0.05%  32          $17.1         0.05%
    Peanut Butter   62          $2.2         0.03%  44          $11.6         0.04%  45          $13.7         0.04%
    Mexican Soft    63          $2.1         0.03%  64           $8.9         0.03%  59          $11.0         0.03%
     Tortillas And
     Wra
    Mainstream      64          $2.1         0.03%  81           $7.1         0.02%  77           $9.2         0.02%
     [Pasta &
     Pizza Sauce]
    Fz Ss Prem      65          $2.1         0.03%  18          $18.6         0.06%  23          $20.7         0.05%
     Nutritional
     Meals
    Aseptic Pack    66          $2.0         0.03%  163          $4.5         0.01%  121          $6.5         0.02%
     Juice And
     Drinks
    Frzn French     67          $2.0         0.03%  128          $5.1         0.02%  108          $7.2         0.02%
     Fries
    Flavored Milk   68          $2.0         0.03%  96           $6.2         0.02%  91           $8.2         0.02%
    Pizza/          69          $2.0         0.03%  89           $6.6         0.02%  86           $8.6         0.02%
     Traditional
    Tuna            70          $2.0         0.03%  62           $8.9         0.03%  64          $10.9         0.03%
    Frzn Breakfast  71          $1.9         0.03%  132          $5.1         0.02%  112          $7.0         0.02%
     Sandwiches
    Hamburger Buns  72          $1.9         0.03%  68           $8.1         0.03%  69          $10.1         0.03%
    Value Forms/    73          $1.9         0.03%  187          $4.0         0.01%  146          $5.9         0.02%
     18oz And
     Larger
     [Chicken]
    Vegetable Oil   74          $1.8         0.03%  214          $3.5         0.01%  168          $5.3         0.01%
    Pails [Ice      75          $1.8         0.03%  131          $5.1         0.02%  114          $6.9         0.02%
     Cream &
     Sherbert]
    Butter          76          $1.8         0.03%  26          $15.8         0.05%  30          $17.6         0.05%
    Candy Bars      77          $1.7         0.03%  83           $6.9         0.02%  83           $8.7         0.02%
     (Multi Pack)
    Cakes:          78          $1.7         0.03%  154          $4.7         0.01%  126          $6.4         0.02%
     Birthday/
     Celebration
     Sh
    Fruit Snacks    79          $1.7         0.03%  198          $3.9         0.01%  159          $5.6         0.01%
    Cottage Cheese  80          $1.7         0.03%  52          $10.2         0.03%  54          $11.9         0.03%
    Sandwich        81          $1.7         0.03%  91           $6.5         0.02%  90           $8.2         0.02%
     Cookies
    Salsa & Dips    82          $1.7         0.03%  133          $5.0         0.02%  116          $6.7         0.02%
    Frzn Meat--     83          $1.7         0.03%  174          $4.3         0.01%  144          $6.0         0.02%
     Beef
    Mult Pk Bag     84          $1.7         0.03%  230          $3.2         0.01%  186          $4.9         0.01%
     Snacks
    Bkfst Sausage-- 85          $1.7         0.03%  76           $7.3         0.02%  80           $8.9         0.02%
     Fresh Rolls
    Refrigerated    86          $1.6         0.03%  116          $5.4         0.02%  111          $7.0         0.02%
     Biscuits
    Sour Creams     87          $1.6         0.02%  66           $8.3         0.03%  70          $10.0         0.03%
    Rts Soup:       88          $1.6         0.02%  60           $9.4         0.03%  61          $11.0         0.03%
     Chunky/
     Homestyle/Et
    Bagged Cheese   89          $1.6         0.02%  143          $4.8         0.02%  129          $6.4         0.02%
     Snacks
    Cream Cheese    90          $1.6         0.02%  54          $10.0         0.03%  57          $11.6         0.03%
    Skillet         91          $1.6         0.02%  245          $3.1         0.01%  198          $4.7         0.01%
     Dinners
    Cheese          92          $1.6         0.02%  84           $6.8         0.02%  89           $8.4         0.02%
     Crackers
    Chicken Wings   93          $1.5         0.02%  374          $2.0         0.01%  258          $3.5         0.01%
    Angus [Beef]    94          $1.5         0.02%  148          $4.8         0.02%  133          $6.3         0.02%
    String Cheese   95          $1.5         0.02%  75           $7.3         0.02%  81           $8.9         0.02%
    Fz Skillet      96          $1.5         0.02%  99           $6.0         0.02%  98           $7.5         0.02%
     Meals
    Hot Dog Buns    97          $1.5         0.02%  110          $5.7         0.02%  104          $7.2         0.02%
    Sweet Goods--   98          $1.5         0.02%  135          $5.0         0.02%  123          $6.5         0.02%
     Full Size
    Candy Bars      99          $1.5         0.02%  153          $4.7         0.01%  135          $6.2         0.02%
     (Singles)
     (Including)
    Toaster         100         $1.5         0.02%  155          $4.7         0.01%  136          $6.2         0.02%
     Pastries
                          -------------------------       ----------------------------------------------------------
      Top 100                 $339.6        $5.16%           $1,243.8        $3.95%           $1,583.4        $4.16%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5         $100%          $31,513.8         $100%          $38,094.2         $100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

           Exhibit E-12: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in Noncore Counties
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Soft Drinks 12/ 1           $6.7         0.10%  2           $16.3         0.05%  2           $23.1         0.06%
     18 & 15pk Can
     Car
    Fluid Milk/     2           $6.4         0.10%  1           $23.0         0.07%  1           $29.4         0.08%
     White Only
    Lean [Beef]     3           $3.2         0.05%  4            $7.6         0.02%  3           $10.8         0.03%
    Primal [Beef]   4           $2.1         0.03%  5            $6.8         0.02%  5            $8.9         0.02%
    Shredded        5           $2.0         0.03%  3            $8.4         0.03%  4           $10.3         0.03%
     Cheese
    Soft Drinks     6           $2.0         0.03%  34           $3.5         0.01%  24           $5.5         0.01%
     20pk & 24pk
     Can Carb
    Mainstream      7           $1.9         0.03%  20           $4.8         0.02%  14           $6.7         0.02%
     White Bread
    Potato Chips    8           $1.9         0.03%  6            $6.7         0.02%  6            $8.6         0.02%
    Kids Cereal     9           $1.8         0.03%  27           $4.0         0.01%  22           $5.8         0.02%
    Sft Drnk 2      10          $1.7         0.03%  21           $4.7         0.01%  16           $6.4         0.02%
     Liter Btl
     Carb Incl
    Unflavored Can  11          $1.7         0.03%  9            $6.1         0.02%  8            $7.8         0.02%
     Coffee
    Sft Drnk Mlt-   12          $1.6         0.02%  11           $5.8         0.02%  10           $7.5         0.02%
     Pk Btl Carb
     (Excp)
    Lunchment--Del  13          $1.6         0.02%  12           $5.8         0.02%  11           $7.4         0.02%
     i Fresh
    Snack Cake--    14          $1.6         0.02%  36           $3.5         0.01%  27           $5.0         0.01%
     Multi Pack
    Enhanced [Pork  15          $1.5         0.02%  14           $5.5         0.02%  13           $7.1         0.02%
     Boneless Loin/
     Rib]
    Eggs--Large     16          $1.4         0.02%  7            $6.6         0.02%  7            $8.0         0.02%
    Infant Formula  17          $1.4         0.02%  186          $1.1         0.00%  81           $2.5         0.01%
     Starter/
     Solutio
    American        18          $1.4         0.02%  29           $4.0         0.01%  25           $5.4         0.01%
     Single Cheese
    Chicken Breast  19          $1.3         0.02%  10           $6.1         0.02%  12           $7.4         0.02%
     Boneless
    Tortilla/Nacho  20          $1.3         0.02%  16           $5.1         0.02%  18           $6.4         0.02%
     Chips
    Potatoes        21          $1.3         0.02%  17           $5.0         0.02%  19           $6.2         0.02%
     Russet (Bulk
     & Bag)
    Still Water     22          $1.3         0.02%  23           $4.5         0.01%  23           $5.7         0.02%
     Drnking/Mnrl
     Water
    Snacks/         23          $1.2         0.02%  67           $2.3         0.01%  49           $3.5         0.01%
     Appetizers
    Pizza/Premium   24          $1.2         0.02%  32           $3.7         0.01%  30           $4.9         0.01%
    Bacon--Trad     25          $1.2         0.02%  19           $4.8         0.02%  20           $6.0         0.02%
     16oz Or Less
    Natural Cheese  26          $1.1         0.02%  8            $6.5         0.02%  9            $7.7         0.02%
     Chunks
    Sugar           27          $1.1         0.02%  35           $3.5         0.01%  34           $4.6         0.01%
    Sandwiches &    28          $1.0         0.02%  96           $1.7         0.01%  71           $2.8         0.01%
     Handhelds
    All Family      29          $1.0         0.02%  18           $4.9         0.02%  21           $5.9         0.02%
     Cereal
    Fz Ss Economy   30          $1.0         0.02%  80           $2.0         0.01%  65           $3.0         0.01%
     Meals All
    Fz Ss Prem      31          $1.0         0.01%  38           $3.4         0.01%  36           $4.4         0.01%
     Traditional
     Meals
    Convenient      32          $1.0         0.01%  111          $1.6         0.00%  79           $2.5         0.01%
     Meals--Kids
     Meal C
    Sft Drnk Sngl   33          $0.9         0.01%  77           $2.0         0.01%  67           $2.9         0.01%
     Srv Btl Carb
     (Ex)
    Condensed Soup  34          $0.9         0.01%  28           $4.0         0.01%  29           $5.0         0.01%
    Bananas         35          $0.9         0.01%  15           $5.5         0.02%  17           $6.4         0.02%
    Dairy Case      36          $0.9         0.01%  13           $5.7         0.02%  15           $6.6         0.02%
     100% Pure
     Juice--O
    Mainstream      37          $0.9         0.01%  24           $4.2         0.01%  26           $5.1         0.01%
     Variety
     Breads
    Choice Beef     38          $0.9         0.01%  59           $2.7         0.01%  48           $3.5         0.01%
    Hot Dogs--Base  39          $0.8         0.01%  74           $2.1         0.01%  66           $2.9         0.01%
     Meat
    Ribs [Pork]     40          $0.8         0.01%  48           $2.9         0.01%  43           $3.7         0.01%
    Lunchment--Bol  41          $0.8         0.01%  71           $2.2         0.01%  62           $3.0         0.01%
     ogna/Sausage
    Mayonnaise &    42          $0.8         0.01%  41           $3.3         0.01%  40           $4.1         0.01%
     Whipped
     Dressing
    Sw Gds: Donuts  43          $0.8         0.01%  49           $2.9         0.01%  45           $3.7         0.01%
    Traditional     44          $0.8         0.01%  39           $3.4         0.01%  38           $4.2         0.01%
     [Ice Cream &
     Sherbert]
    Pourable Salad  45          $0.8         0.01%  40           $3.4         0.01%  39           $4.1         0.01%
     Dressings
    Frzn Chicken--  46          $0.7         0.01%  60           $2.5         0.01%  56           $3.3         0.01%
     Wht Meat
    Margarine:      47          $0.7         0.01%  58           $2.7         0.01%  51           $3.4         0.01%
     Tubs And
     Bowls
    Can Pasta       48          $0.7         0.01%  159          $1.3         0.00%  108          $2.0         0.01%
    Candy Bags--    49          $0.7         0.01%  33           $3.6         0.01%  37           $4.3         0.01%
     Chocolate
    Macaroni &      50          $0.7         0.01%  121          $1.5         0.00%  93           $2.2         0.01%
     Cheese Dnrs
    Isotonic        51          $0.7         0.01%  66           $2.3         0.01%  64           $3.0         0.01%
     Drinks Single
     Serve
    Fz Family       52          $0.7         0.01%  89           $1.8         0.01%  77           $2.5         0.01%
     Style Entrees
    Peanut Butter   53          $0.7         0.01%  44           $3.1         0.01%  42           $3.8         0.01%
    Strawberries    54          $0.7         0.01%  25           $4.2         0.01%  31           $4.8         0.01%
    Adult Cereal    55          $0.6         0.01%  31           $4.0         0.01%  33           $4.6         0.01%
    Hamburger Buns  56          $0.6         0.01%  64           $2.4         0.01%  63           $3.0         0.01%
    Pizza/          57          $0.6         0.01%  79           $2.0         0.01%  76           $2.6         0.01%
     Traditional
    Choice Beef     58          $0.6         0.01%  42           $3.2         0.01%  41           $3.9         0.01%
    Premium [Ice    59          $0.6         0.01%  26           $4.1         0.01%  32           $4.7         0.01%
     Cream &
     Sherbert]
    Flavored Milk   60          $0.6         0.01%  107          $1.6         0.01%  91           $2.2         0.01%
    Refrigerated    61          $0.6         0.01%  56           $2.8         0.01%  53           $3.4         0.01%
     Coffee
     Creamers
    Angus [Beef]    62          $0.6         0.01%  57           $2.7         0.01%  54           $3.3         0.01%
    Pails [Ice      63          $0.6         0.01%  110          $1.6         0.00%  95           $2.2         0.01%
     Cream &
     Sherbert]
    Mexican Soft    64          $0.6         0.01%  52           $2.8         0.01%  52           $3.4         0.01%
     Tortillas And
     Wra
    Pizza/Economy   65          $0.6         0.01%  162          $1.3         0.00%  117          $1.9         0.00%
    Cottage Cheese  66          $0.6         0.01%  45           $3.1         0.01%  46           $3.6         0.01%
    Mainstream      67          $0.6         0.01%  84           $1.9         0.01%  83           $2.4         0.01%
     [Pasta &
     Pizza Sauce]
    Frzn French     68          $0.6         0.01%  123          $1.5         0.00%  107          $2.0         0.01%
     Fries
    Fz Bag          69          $0.5         0.01%  46           $3.0         0.01%  47           $3.5         0.01%
     Vegetables--P
     lain
    Candy Bars      70          $0.5         0.01%  78           $2.0         0.01%  78           $2.5         0.01%
     (Multi Pack)
    Cakes:          71          $0.5         0.01%  149          $1.3         0.00%  116          $1.9         0.00%
     Birthday/
     Celebration
     Sh
    Aseptic Pack    72          $0.5         0.01%  183          $1.1         0.00%  146          $1.6         0.00%
     Juice And
     Drinks
    Refrigerated    73          $0.5         0.01%  104          $1.6         0.01%  99           $2.1         0.01%
     Biscuits
    Salsa & Dips    74          $0.5         0.01%  130          $1.4         0.00%  111          $1.9         0.01%
    Value Forms/    75          $0.5         0.01%  192          $1.1         0.00%  158          $1.6         0.00%
     18oz And
     Larger
     [Chicken]
    Fz Ss Prem      76          $0.5         0.01%  30           $4.0         0.01%  35           $4.5         0.01%
     Nutritional
     Meals
    Tuna            77          $0.5         0.01%  70           $2.2         0.01%  72           $2.8         0.01%
    Sandwich        78          $0.5         0.01%  83           $1.9         0.01%  85           $2.4         0.01%
     Cookies
    Bkfst Sausage-- 79          $0.5         0.01%  73           $2.1         0.01%  75           $2.6         0.01%
     Fresh Rolls
    Butter          80          $0.5         0.01%  22           $4.5         0.01%  28           $5.0         0.01%
    Frzn Breakfast  81          $0.5         0.01%  172          $1.2         0.00%  139          $1.7         0.00%
     Sandwiches
    Vegetable Oil   82          $0.5         0.01%  203          $1.0         0.00%  166          $1.5         0.00%
    Sweet Goods--   83          $0.5         0.01%  129          $1.4         0.00%  114          $1.9         0.00%
     Full Size
    Hot Dog Buns    84          $0.5         0.01%  98           $1.7         0.01%  94           $2.2         0.01%
    Candy Bars      85          $0.5         0.01%  119          $1.5         0.00%  110          $2.0         0.01%
     (Singles)
     (Including)
    Bagged Cheese   86          $0.5         0.01%  147          $1.3         0.00%  127          $1.8         0.00%
     Snacks
    Sandwiches--(C  87          $0.5         0.01%  102          $1.6         0.01%  103          $2.1         0.01%
     old)
    Cream Cheese    88          $0.5         0.01%  54           $2.8         0.01%  57           $3.3         0.01%
    Sour Creams     89          $0.5         0.01%  69           $2.3         0.01%  73           $2.7         0.01%
    Select Beef     90          $0.5         0.01%  75           $2.0         0.01%  80           $2.5         0.01%
    Frzn Meat--     91          $0.5         0.01%  166          $1.2         0.00%  136          $1.7         0.00%
     Beef
    Sticks/Enrobed  92          $0.5         0.01%  124          $1.5         0.00%  113          $1.9         0.01%
     [Frozen
     Novelties]
    String Cheese   93          $0.4         0.01%  76           $2.0         0.01%  82           $2.5         0.01%
    Fruit Snacks    94          $0.4         0.01%  222          $0.9         0.00%  185          $1.4         0.00%
    Rts Soup:       95          $0.4         0.01%  63           $2.4         0.01%  68           $2.8         0.01%
     Chunky/
     Homestyle/Et
    Angus [Beef]    96          $0.4         0.01%  177          $1.1         0.00%  156          $1.6         0.00%
    Cheese          97          $0.4         0.01%  93           $1.8         0.01%  92           $2.2         0.01%
     Crackers
    Meat: Ham Bulk  98          $0.4         0.01%  62           $2.4         0.01%  69           $2.8         0.01%
    Meat: Turkey    99          $0.4         0.01%  51           $2.8         0.01%  58           $3.3         0.01%
     Bulk
    Tray Pack/Choc  100         $0.4         0.01%  133          $1.4         0.00%  119          $1.8         0.00%
     Chip Cookies
                          -------------------------       ----------------------------------------------------------
      Top 100                  $99.1         1.57%             $341.8         1.08%             $440.9         1.23%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

      Exhibit E-13: Top 100 Subcommodities for SNAP Households by Expenditure: Stores with more than $12 Million in
                                                          Sales
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $38.9         0.59%  1          $229.9         0.73%  1          $268.8         0.71%
     White Only
    Soft Drinks 12/ 2          $32.4         0.49%  2          $162.4         0.52%  2          $194.8         0.51%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $22.2         0.34%  8           $74.1         0.24%  5           $96.4         0.25%
    Shredded        4          $16.2         0.25%  3          $103.2         0.33%  3          $119.4         0.31%
     Cheese
    Kids Cereal     5          $15.5         0.23%  23          $52.1         0.17%  17          $67.5         0.18%
    Sft Drnk 2      6          $13.3         0.20%  18          $56.1         0.18%  16          $69.4         0.18%
     Liter Btl
     Carb Incl
    Potato Chips    7          $13.0         0.20%  10          $70.8         0.22%  9           $83.8         0.22%
    Lunchment--Del  8          $11.6         0.18%  13          $69.9         0.22%  11          $81.5         0.21%
     i Fresh
    Chicken Breast  9          $11.4         0.17%  4           $89.3         0.28%  4          $100.7         0.26%
     Boneless
    Infant Formula  10         $11.1         0.17%  259         $10.4         0.03%  119         $21.5         0.06%
     Starter/
     Solutio
    Eggs--Large     11         $10.8         0.16%  9           $73.1         0.23%  8           $83.9         0.22%
    Primal [Beef]   12         $10.8         0.16%  24          $49.1         0.16%  23          $59.9         0.16%
    Snacks/         13         $10.4         0.16%  63          $31.6         0.10%  47          $42.1         0.11%
     Appetizers
    Tortilla/Nacho  14          $9.9         0.15%  15          $62.4         0.20%  15          $72.3         0.19%
     Chips
    Dairy Case      15          $9.4         0.14%  6           $80.1         0.25%  6           $89.5         0.23%
     100% Pure
     Juice--O
    Fz Ss Prem      16          $9.1         0.14%  26          $47.5         0.15%  25          $56.6         0.15%
     Traditional
     Meals
    Unflavored Can  17          $9.1         0.14%  21          $54.4         0.17%  19          $63.4         0.17%
     Coffee
    Natural Cheese  18          $9.0         0.14%  12          $70.0         0.22%  12          $79.1         0.21%
     Chunks
    Still Water     19          $8.8         0.13%  30          $46.5         0.15%  28          $55.3         0.15%
     Drnking/Mnrl
     Water
    Mainstream      20          $8.6         0.13%  56          $33.6         0.11%  46          $42.3         0.11%
     White Bread
    Enhanced [Pork  21          $8.6         0.13%  28          $47.3         0.15%  26          $55.9         0.15%
     Boneless Loin/
     Rib]
    Bacon--Trad     22          $8.4         0.13%  34          $44.1         0.14%  29          $52.6         0.14%
     16oz Or Less
    All Family      23          $8.4         0.13%  14          $66.3         0.21%  14          $74.7         0.20%
     Cereal
    Pizza/Premium   24          $8.4         0.13%  29          $47.0         0.15%  27          $55.4         0.15%
    American        25          $8.3         0.13%  51          $35.4         0.11%  44          $43.7         0.11%
     Single Cheese
    Fz Ss Economy   26          $8.1         0.12%  105         $21.1         0.07%  81          $29.2         0.08%
     Meals All
    Soft Drinks     27          $7.9         0.12%  67          $30.2         0.10%  58          $38.1         0.10%
     20pk & 24pk
     Can Carb
    Bananas         28          $7.8         0.12%  7           $74.4         0.24%  10          $82.2         0.22%
    Snack Cake--    29          $7.4         0.11%  81          $25.3         0.08%  73          $32.7         0.09%
     Multi Pack
    Premium [Ice    30          $7.4         0.11%  11          $70.2         0.22%  13          $77.6         0.20%
     Cream &
     Sherbert]
    Mainstream      31          $7.3         0.11%  32          $44.6         0.14%  32          $51.8         0.14%
     Variety
     Breads
    Select Beef     32          $7.2         0.11%  37          $41.6         0.13%  36          $48.8         0.13%
    Sandwiches &    33          $7.2         0.11%  107         $20.6         0.07%  89          $27.8         0.07%
     Handhelds
    Frzn Chicken--  34          $7.2         0.11%  65          $31.2         0.10%  57          $38.4         0.10%
     Wht Meat
    Potatoes        35          $7.2         0.11%  35          $42.4         0.13%  35          $49.6         0.13%
     Russet (Bulk
     & Bag)
    Ribs [Pork]     36          $6.8         0.10%  69          $29.4         0.09%  65          $36.2         0.10%
    Sugar           37          $6.8         0.10%  64          $31.3         0.10%  59          $38.1         0.10%
    Choice Beef     38          $6.7         0.10%  40          $41.1         0.13%  38          $47.8         0.13%
    Convenient      39          $6.7         0.10%  114         $19.5         0.06%  98          $26.2         0.07%
     Meals--Kids
     Meal C
    Condensed Soup  40          $6.5         0.10%  33          $44.1         0.14%  34          $50.6         0.13%
    Refrigerated    41          $6.4         0.10%  31          $46.0         0.15%  31          $52.3         0.14%
     Coffee
     Creamers
    Isotonic        42          $6.2         0.09%  66          $30.9         0.10%  62          $37.1         0.10%
     Drinks Single
     Serve
    Fz Family       43          $6.1         0.09%  85          $24.7         0.08%  77          $30.8         0.08%
     Style Entrees
    Pourable Salad  44          $6.0         0.09%  38          $41.5         0.13%  39          $47.6         0.12%
     Dressings
    Sft Drnk Mlt-   45          $5.9         0.09%  36          $42.2         0.13%  37          $48.1         0.13%
     Pk Btl Carb
     (Excp)
    Fz Ss Prem      46          $5.9         0.09%  5           $82.0         0.26%  7           $87.9         0.23%
     Nutritional
     Meals
    Sft Drnk Sngl   47          $5.8         0.09%  103         $21.3         0.07%  93          $27.1         0.07%
     Srv Btl Carb
     (Ex)
    Mayonnaise &    48          $5.7         0.09%  54          $34.5         0.11%  54          $40.2         0.11%
     Whipped
     Dressing
    Choice Beef     49          $5.7         0.09%  97          $22.6         0.07%  85          $28.3         0.07%
    Adult Cereal    50          $5.6         0.08%  20          $55.1         0.17%  22          $60.7         0.16%
    Strawberries    51          $5.4         0.08%  19          $55.9         0.18%  21          $61.3         0.16%
    Meat: Turkey    52          $5.4         0.08%  17          $57.3         0.18%  20          $62.7         0.16%
     Bulk
    Mexican Soft    53          $5.4         0.08%  53          $35.2         0.11%  53          $40.6         0.11%
     Tortillas And
     Wra
    Butter          54          $5.4         0.08%  16          $58.3         0.19%  18          $63.7         0.17%
    Fz Bag          55          $5.2         0.08%  49          $36.6         0.12%  48          $41.8         0.11%
     Vegetables--P
     lain
    Candy Bags--    56          $5.0         0.08%  27          $47.4         0.15%  30          $52.4         0.14%
     Chocolate
    Traditional     57          $5.0         0.08%  68          $29.4         0.09%  69          $34.4         0.09%
     [Ice Cream &
     Sherbert]
    Margarine:      58          $5.0         0.08%  71          $29.2         0.09%  70          $34.2         0.09%
     Tubs And
     Bowls
    Macaroni &      59          $4.9         0.07%  139         $17.4         0.06%  113         $22.3         0.06%
     Cheese Dnrs
    Peanut Butter   60          $4.8         0.07%  44          $39.1         0.12%  43          $43.9         0.12%
    Aseptic Pack    61          $4.7         0.07%  168         $15.3         0.05%  136         $20.0         0.05%
     Juice And
     Drinks
    Tuna            62          $4.7         0.07%  60          $33.0         0.10%  61          $37.6         0.10%
    Mainstream      63          $4.6         0.07%  96          $22.9         0.07%  91          $27.5         0.07%
     [Pasta &
     Pizza Sauce]
    Hot Dogs--Base  64          $4.6         0.07%  188         $13.8         0.04%  159         $18.3         0.05%
     Meat
    Cream Cheese    65          $4.5         0.07%  48          $37.3         0.12%  49          $41.7         0.11%
    Sw Gds: Donuts  66          $4.4         0.07%  92          $23.3         0.07%  90          $27.7         0.07%
    Sushi--In       67          $4.3         0.07%  42          $40.4         0.13%  40          $44.7         0.12%
     Store
     Prepared
    Premium Bread   68          $4.3         0.06%  22          $53.9         0.17%  24          $58.1         0.15%
    Can Pasta       69          $4.3         0.06%  216         $12.4         0.04%  179         $16.7         0.04%
    Frzn Meat--     70          $4.2         0.06%  182         $14.1         0.04%  160         $18.3         0.05%
     Beef
    Fz Skillet      71          $4.2         0.06%  87          $24.4         0.08%  84          $28.6         0.08%
     Meals
    Meat: Ham Bulk  72          $4.1         0.06%  43          $40.2         0.13%  41          $44.3         0.12%
    Angus [Beef]    73          $4.1         0.06%  62          $31.9         0.10%  66          $35.9         0.09%
    Cakes:          74          $4.0         0.06%  170         $15.1         0.05%  151         $19.1         0.05%
     Birthday/
     Celebration
     Sh
    Sour Creams     75          $4.0         0.06%  72          $29.2         0.09%  71          $33.2         0.09%
    Cheese          76          $4.0         0.06%  73          $29.0         0.09%  72          $33.0         0.09%
     Crackers
    Value Forms/    77          $4.0         0.06%  218         $12.3         0.04%  188         $16.3         0.04%
     18oz And
     Larger
     [Chicken]
    Frzn French     78          $4.0         0.06%  187         $13.8         0.04%  165         $17.8         0.05%
     Fries
    Rts Soup:       79          $3.9         0.06%  52          $35.2         0.11%  56          $39.2         0.10%
     Chunky/
     Homestyle/Et
    String Cheese   80          $3.9         0.06%  58          $33.2         0.11%  63          $37.1         0.10%
    Sandwiches--(C  81          $3.9         0.06%  98          $22.2         0.07%  99          $26.1         0.07%
     old)
    Instore Cut     82          $3.9         0.06%  55          $33.8         0.11%  60          $37.6         0.10%
     Fruit
    Lunchment--Bol  83          $3.9         0.06%  175         $14.6         0.05%  156         $18.5         0.05%
     ogna/Sausage
    Frzn Chicken--  84          $3.8         0.06%  585          $3.9         0.01%  395          $7.7         0.02%
     Wings
    Frzn Breakfast  85          $3.8         0.06%  161         $15.8         0.05%  142         $19.6         0.05%
     Sandwiches
    Waffles/        86          $3.8         0.06%  91          $23.3         0.07%  92          $27.1         0.07%
     Pancakes/
     French Toast
    Pizza/Economy   87          $3.8         0.06%  226         $11.9         0.04%  200         $15.6         0.04%
    Spring Water    88          $3.7         0.06%  77          $27.7         0.09%  75          $31.4         0.08%
    Mult Pk Bag     89          $3.7         0.06%  222         $12.0         0.04%  198         $15.7         0.04%
     Snacks
    Grapes Red      90          $3.6         0.05%  46          $37.7         0.12%  51          $41.3         0.11%
    Sandwich        91          $3.6         0.05%  110         $20.3         0.06%  107         $23.9         0.06%
     Cookies
    Candy Bars      92          $3.6         0.05%  144         $17.1         0.05%  131         $20.6         0.05%
     (Singles)
     (Including)
    Fruit Snacks    93          $3.5         0.05%  209         $12.6         0.04%  189         $16.2         0.04%
    Pizza/          94          $3.5         0.05%  134         $17.9         0.06%  120         $21.4         0.06%
     Traditional
    Flavored Milk   95          $3.5         0.05%  148         $16.8         0.05%  133         $20.3         0.05%
    Sweet Goods--   96          $3.5         0.05%  162         $15.7         0.05%  150         $19.2         0.05%
     Full Size
    Vegetable Oil   97          $3.4         0.05%  306          $8.8         0.03%  248         $12.2         0.03%
    Natural Cheese  98          $3.4         0.05%  50          $36.0         0.11%  55          $39.4         0.10%
     Slices
    Salsa & Dips    99          $3.4         0.05%  152         $16.5         0.05%  139         $19.9         0.05%
    Avocado         100         $3.4         0.05%  47          $37.5         0.12%  52          $40.9         0.11%
                          -------------------------       ----------------------------------------------------------
      Top 100                 $699.9        10.64%           $4,012.7        12.73%           $4,712.5        12.37%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

     Exhibit E-14: Top 100 Subcommodities for SNAP Households by Expenditure: Stores with $2 to $12 Million in Sales
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1         $151.9         2.31%  1          $622.5         1.98%  1          $774.4         2.03%
     White Only
    Soft Drinks 12/ 2         $131.9         2.00%  2          $437.9         1.39%  2          $569.9         1.50%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $90.0         1.37%  7          $183.4         0.58%  4          $273.4         0.72%
    Kids Cereal     4          $62.6         0.95%  20         $134.2         0.43%  13         $196.7         0.52%
    Shredded        5          $58.4         0.89%  3          $238.3         0.76%  3          $296.8         0.78%
     Cheese
    Sft Drnk 2      6          $57.5         0.87%  10         $173.7         0.55%  7          $231.2         0.61%
     Liter Btl
     Carb Incl
    Primal [Beef]   7          $51.5         0.78%  12         $169.9         0.54%  9          $221.4         0.58%
    Potato Chips    8          $51.3         0.78%  8          $182.1         0.58%  6          $233.4         0.61%
    Lunchment--Del  9          $44.1         0.67%  11         $172.4         0.55%  11         $216.5         0.57%
     i Fresh
    Infant Formula  10         $43.0         0.65%  169         $34.9         0.11%  71          $77.9         0.20%
     Starter/
     Solutio
    Eggs--Large     11         $41.3         0.63%  9          $178.2         0.57%  10         $219.5         0.58%
    Still Water     12         $39.9         0.61%  19         $141.1         0.45%  16         $180.9         0.48%
     Drnking/Mnrl
     Water
    Mainstream      13         $39.2         0.60%  32         $102.9         0.33%  27         $142.1         0.37%
     White Bread
    Chicken Breast  14         $38.1         0.58%  4          $203.4         0.65%  5          $241.5         0.63%
     Boneless
    Tortilla/Nacho  15         $37.4         0.57%  16         $146.3         0.46%  15         $183.7         0.48%
     Chips
    American        16         $35.7         0.54%  36         $101.0         0.32%  31         $136.7         0.36%
     Single Cheese
    Fz Ss Prem      17         $34.7         0.53%  23         $127.8         0.41%  21         $162.5         0.43%
     Traditional
     Meals
    Snack Cake--    18         $34.1         0.52%  57          $76.2         0.24%  43         $110.4         0.29%
     Multi Pack
    Dairy Case      19         $34.1         0.52%  6          $188.7         0.60%  8          $222.9         0.58%
     100% Pure
     Juice--O
    Snacks/         20         $34.1         0.52%  66          $68.7         0.22%  50         $102.8         0.27%
     Appetizers
    Enhanced [Pork  21         $32.9         0.50%  26         $120.4         0.38%  24         $153.2         0.40%
     Boneless Loin/
     Rib]
    Fz Ss Economy   22         $32.8         0.50%  76          $59.5         0.19%  58          $92.3         0.24%
     Meals All
    Bacon--Trad     23         $32.2         0.49%  28         $113.2         0.36%  26         $145.4         0.38%
     16oz Or Less
    Unflavored Can  24         $32.2         0.49%  18         $143.4         0.46%  19         $175.6         0.46%
     Coffee
    Soft Drinks     25         $31.7         0.48%  58          $76.0         0.24%  46         $107.7         0.28%
     20pk & 24pk
     Can Carb
    Pizza/Premium   26         $31.2         0.47%  31         $106.2         0.34%  30         $137.4         0.36%
    Mainstream      27         $31.1         0.47%  22         $128.4         0.41%  22         $159.5         0.42%
     Variety
     Breads
    Sugar           28         $30.1         0.46%  51          $81.2         0.26%  42         $111.3         0.29%
    Sandwiches &    29         $28.6         0.43%  88          $52.9         0.17%  67          $81.5         0.21%
     Handhelds
    Potatoes        30         $28.5         0.43%  29         $111.8         0.35%  28         $140.3         0.37%
     Russet (Bulk
     & Bag)
    Ribs [Pork]     31         $28.2         0.43%  54          $77.3         0.25%  48         $105.4         0.28%
    Sft Drnk Mlt-   32         $28.0         0.43%  21         $131.2         0.42%  23         $159.2         0.42%
     Pk Btl Carb
     (Excp)
    All Family      33         $27.7         0.42%  15         $148.4         0.47%  18         $176.1         0.46%
     Cereal
    Convenient      34         $27.5         0.42%  95          $50.1         0.16%  72          $77.6         0.20%
     Meals--Kids
     Meal C
    Bananas         35         $26.3         0.40%  13         $168.0         0.53%  14         $194.4         0.51%
    Natural Cheese  36         $26.2         0.40%  17         $145.8         0.46%  20         $172.0         0.45%
     Chunks
    Isotonic        37         $24.2         0.37%  45          $88.5         0.28%  41         $112.7         0.30%
     Drinks Single
     Serve
    Premium [Ice    38         $23.9         0.36%  14         $155.6         0.49%  17         $179.5         0.47%
     Cream &
     Sherbert]
    Condensed Soup  39         $23.2         0.35%  30         $109.2         0.35%  32         $132.4         0.35%
    Pourable Salad  40         $22.9         0.35%  39          $97.8         0.31%  35         $120.7         0.32%
     Dressings
    Frzn Chicken--  41         $22.8         0.35%  67          $68.4         0.22%  59          $91.2         0.24%
     Wht Meat
    Sft Drnk Sngl   42         $22.0         0.33%  96          $49.9         0.16%  81          $71.9         0.19%
     Srv Btl Carb
     (Ex)
    Choice Beef     43         $21.7         0.33%  40          $95.4         0.30%  37         $117.1         0.31%
    Fz Family       44         $21.5         0.33%  79          $58.8         0.19%  69          $80.3         0.21%
     Style Entrees
    Mayonnaise &    45         $21.5         0.33%  48          $84.4         0.27%  47         $105.9         0.28%
     Whipped
     Dressing
    Select Beef     46         $20.6         0.31%  34         $102.0         0.32%  34         $122.6         0.32%
    Traditional     47         $20.6         0.31%  43          $89.1         0.28%  44         $109.7         0.29%
     [Ice Cream &
     Sherbert]
    Fz Bag          48         $20.5         0.31%  41          $95.2         0.30%  40         $115.7         0.30%
     Vegetables--P
     lain
    Hot Dogs--Base  49         $20.5         0.31%  121         $42.9         0.14%  93          $63.3         0.17%
     Meat
    Aseptic Pack    50         $19.5         0.30%  131         $41.7         0.13%  99          $61.3         0.16%
     Juice And
     Drinks
    Macaroni &      51         $19.4         0.29%  127         $42.2         0.13%  97          $61.6         0.16%
     Cheese Dnrs
    Adult Cereal    52         $19.3         0.29%  24         $127.3         0.40%  25         $146.7         0.38%
    Chicken Wings   53         $18.9         0.29%  274         $22.1         0.07%  176         $41.0         0.11%
    Fz Ss Prem      54         $18.8         0.29%  5          $189.5         0.60%  12         $208.2         0.55%
     Nutritional
     Meals
    Margarine:      55         $18.4         0.28%  64          $71.5         0.23%  61          $89.9         0.24%
     Tubs And
     Bowls
    Frzn Chicken--  56         $18.3         0.28%  425         $13.4         0.04%  240         $31.8         0.08%
     Wings
    Mainstream      57         $18.3         0.28%  80          $58.0         0.18%  76          $76.3         0.20%
     [Pasta &
     Pizza Sauce]
    Choice Beef     58         $18.3         0.28%  97          $49.7         0.16%  86          $68.0         0.18%
    Mexican Soft    59         $18.3         0.28%  53          $77.8         0.25%  53          $96.1         0.25%
     Tortillas And
     Wra
    Strawberries    60         $18.0         0.27%  25         $122.4         0.39%  29         $140.3         0.37%
    Mult Pk Bag     61         $17.9         0.27%  194         $31.3         0.10%  143         $49.3         0.13%
     Snacks
    Can Pasta       62         $17.9         0.27%  165         $35.2         0.11%  120         $53.1         0.14%
    Lunchment--Bol  63         $17.9         0.27%  105         $46.2         0.15%  91          $64.1         0.17%
     ogna/Sausage
    Refrigerated    64         $17.7         0.27%  35         $101.2         0.32%  36         $118.9         0.31%
     Coffee
     Creamers
    Vegetable Oil   65         $17.1         0.26%  237         $26.5         0.08%  167         $43.6         0.11%
    Sw Gds: Donuts  66         $16.9         0.26%  78          $58.9         0.19%  78          $75.8         0.20%
    Frzn French     67         $16.5         0.25%  157         $36.4         0.12%  121         $52.9         0.14%
     Fries
    Tuna            68         $16.5         0.25%  56          $76.8         0.24%  56          $93.3         0.24%
    Candy Bags--    69         $16.4         0.25%  37         $100.0         0.32%  38         $116.5         0.31%
     Chocolate
    Pizza/Economy   70         $16.0         0.24%  180         $33.1         0.11%  144         $49.2         0.13%
    Peanut Butter   71         $15.6         0.24%  44          $88.6         0.28%  49         $104.2         0.27%
    Frzn Breakfast  72         $15.3         0.23%  139         $39.9         0.13%  112         $55.2         0.14%
     Sandwiches
    Frzn Meat--     73         $14.7         0.22%  190         $32.1         0.10%  154         $46.8         0.12%
     Beef
    Value Forms/    74         $14.7         0.22%  201         $30.2         0.10%  160         $44.9         0.12%
     18oz And
     Larger
     [Chicken]
    Cakes:          75         $14.6         0.22%  167         $35.1         0.11%  139         $49.8         0.13%
     Birthday/
     Celebration
     Sh
    Fz Skillet      76         $14.5         0.22%  82          $54.9         0.17%  85          $69.4         0.18%
     Meals
    Sandwich        77         $14.4         0.22%  92          $51.4         0.16%  88          $65.8         0.17%
     Cookies
    Chicken Drums   78         $14.3         0.22%  251         $23.7         0.08%  197         $38.1         0.10%
    Pizza/          79         $14.3         0.22%  106         $46.1         0.15%  101         $60.4         0.16%
     Traditional
    Butter          80         $14.2         0.22%  27         $117.1         0.37%  33         $131.3         0.34%
    Fruit Snacks    81         $14.1         0.21%  200         $30.5         0.10%  163         $44.6         0.12%
    Meat: Turkey    82         $13.9         0.21%  33         $102.3         0.32%  39         $116.1         0.30%
     Bulk
    Bagged Cheese   83         $13.8         0.21%  146         $38.3         0.12%  125         $52.1         0.14%
     Snacks
    Salsa & Dips    84         $13.7         0.21%  136         $40.4         0.13%  118         $54.0         0.14%
    Ramen Noodles/  85         $13.7         0.21%  293         $20.5         0.07%  225         $34.2         0.09%
     Ramen Cups
    Rts Soup:       86         $13.7         0.21%  47          $84.6         0.27%  52          $98.2         0.26%
     Chunky/
     Homestyle/Et
    Waffles/        87         $13.5         0.21%  85          $54.0         0.17%  87          $67.5         0.18%
     Pancakes/
     French Toast
    Sour Creams     88         $13.5         0.20%  69          $65.9         0.21%  70          $79.4         0.21%
    Dnr Sausage--   89         $13.3         0.20%  233         $26.7         0.08%  184         $40.0         0.11%
     Links Pork
     Ckd/S
    Angus [Beef]    90         $13.1         0.20%  63          $71.9         0.23%  66          $84.9         0.22%
    Hot Dog Buns    91         $13.0         0.20%  111         $45.1         0.14%  105         $58.1         0.15%
    Sandwiches--(C  92         $13.0         0.20%  108         $45.4         0.14%  104         $58.4         0.15%
     old)
    Dairy Case      93         $12.9         0.20%  170         $34.8         0.11%  151         $47.6         0.13%
     Juice Drnk
     Under 10
    Hamburger Buns  94         $12.8         0.20%  94          $50.1         0.16%  94          $63.0         0.17%
    Candy Bars      95         $12.8         0.19%  149         $37.8         0.12%  132         $50.6         0.13%
     (Singles)
     (Including)
    Cream Cheese    96         $12.8         0.19%  52          $78.1         0.25%  60          $90.9         0.24%
    Candy Bars      97         $12.5         0.19%  93          $50.4         0.16%  95          $62.9         0.17%
     (Multi Pack)
    Cheese          98         $12.5         0.19%  74          $61.2         0.19%  79          $73.7         0.19%
     Crackers
    Spring Water    99         $12.5         0.19%  68          $67.9         0.22%  68          $80.3         0.21%
    Flavored Milk   100        $12.4         0.19%  124         $42.5         0.13%  114         $54.9         0.14%
                          -------------------------       ----------------------------------------------------------
      Top 100               $2,658.3        40.40%           $9,463.7        30.03%          $12,122.1        31.82%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

      Exhibit E-15: Top 100 Subcommodities for SNAP Households by Expenditure: Stores with less than $2 Million in
                                                          Sales
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1           $0.4         0.01%  1            $1.4         0.00%  1            $1.8         0.00%
     White Only
    Soft Drinks 12/ 2           $0.3         0.01%  2            $0.8         0.00%  2            $1.2         0.00%
     18 & 15pk Can
     Car
    Primal [Beef]   3           $0.2         0.00%  3            $0.7         0.00%  3            $0.9         0.00%
    Lean [Beef]     4           $0.2         0.00%  6            $0.4         0.00%  5            $0.5         0.00%
    Sft Drnk 2      5           $0.1         0.00%  7            $0.3         0.00%  7            $0.5         0.00%
     Liter Btl
     Carb Incl
    Mainstream      6           $0.1         0.00%  11           $0.3         0.00%  9            $0.4         0.00%
     White Bread
    Soft Drinks     7           $0.1         0.00%  19           $0.2         0.00%  13           $0.3         0.00%
     20pk & 24pk
     Can Carb
    Potato Chips    8           $0.1         0.00%  5            $0.4         0.00%  6            $0.5         0.00%
    Shredded        9           $0.1         0.00%  4            $0.4         0.00%  4            $0.5         0.00%
     Cheese
    Kids Cereal     10          $0.1         0.00%  28           $0.2         0.00%  20           $0.3         0.00%
    Lunchment--Del  11          $0.1         0.00%  8            $0.3         0.00%  8            $0.4         0.00%
     i Fresh
    Snack Cake--    12          $0.1         0.00%  31           $0.2         0.00%  26           $0.3         0.00%
     Multi Pack
    American        13          $0.1         0.00%  16           $0.2         0.00%  14           $0.3         0.00%
     Single Cheese
    Enhanced [Pork  14          $0.1         0.00%  10           $0.3         0.00%  11           $0.3         0.00%
     Boneless Loin/
     Rib]
    Tortilla/Nacho  15          $0.1         0.00%  12           $0.3         0.00%  12           $0.3         0.00%
     Chips
    Unflavored Can  16          $0.1         0.00%  15           $0.2         0.00%  16           $0.3         0.00%
     Coffee
    Eggs--Large     17          $0.1         0.00%  9            $0.3         0.00%  10           $0.3         0.00%
    Potatoes        18          $0.1         0.00%  18           $0.2         0.00%  17           $0.3         0.00%
     Russet (Bulk
     & Bag)
    Still Water     19          $0.1         0.00%  20           $0.2         0.00%  19           $0.3         0.00%
     Drnking/Mnrl
     Water
    Fz Ss Economy   20          $0.1         0.00%  57           $0.1         0.00%  45           $0.2         0.00%
     Meals All
    Sugar           21          $0.1         0.00%  32           $0.2         0.00%  31           $0.2         0.00%
    Bacon--Trad     22          $0.1         0.00%  21           $0.2         0.00%  21           $0.3         0.00%
     16oz Or Less
    Convenient      23          $0.1         0.00%  66           $0.1         0.00%  52           $0.2         0.00%
     Meals--Kids
     Meal C
    Mainstream      24          $0.1         0.00%  13           $0.3         0.00%  15           $0.3         0.00%
     Variety
     Breads
    Infant Formula  25          $0.1         0.00%  143          $0.1         0.00%  78           $0.1         0.00%
     Starter/
     Solutio
    Sft Drnk Sngl   26          $0.1         0.00%  51           $0.1         0.00%  44           $0.2         0.00%
     Srv Btl Carb
     (Ex)
    Sft Drnk Mlt-   27          $0.1         0.00%  27           $0.2         0.00%  27           $0.3         0.00%
     Pk Btl Carb
     (Excp)
    Chicken Breast  28          $0.1         0.00%  14           $0.2         0.00%  18           $0.3         0.00%
     Boneless
    Hot Dogs--Base  29          $0.0         0.00%  46           $0.1         0.00%  36           $0.2         0.00%
     Meat
    Snacks/         30          $0.0         0.00%  70           $0.1         0.00%  60           $0.1         0.00%
     Appetizers
    Traditional     31          $0.0         0.00%  23           $0.2         0.00%  24           $0.3         0.00%
     [Ice Cream &
     Sherbert]
    Pizza/Economy   32          $0.0         0.00%  55           $0.1         0.00%  49           $0.2         0.00%
    Pizza/Premium   33          $0.0         0.00%  43           $0.1         0.00%  38           $0.2         0.00%
    Condensed Soup  34          $0.0         0.00%  25           $0.2         0.00%  25           $0.3         0.00%
    Lunchment--Bol  35          $0.0         0.00%  45           $0.1         0.00%  43           $0.2         0.00%
     ogna/Sausage
    Flavored Milk   36          $0.0         0.00%  64           $0.1         0.00%  57           $0.1         0.00%
    All Family      37          $0.0         0.00%  22           $0.2         0.00%  23           $0.3         0.00%
     Cereal
    Sandwiches &    38          $0.0         0.00%  75           $0.1         0.00%  66           $0.1         0.00%
     Handhelds
    Hamburger Buns  39          $0.0         0.00%  38           $0.1         0.00%  34           $0.2         0.00%
    Bananas         40          $0.0         0.00%  17           $0.2         0.00%  22           $0.3         0.00%
    Pizza/          41          $0.0         0.00%  47           $0.1         0.00%  46           $0.2         0.00%
     Traditional
    Pails [Ice      42          $0.0         0.00%  59           $0.1         0.00%  55           $0.2         0.00%
     Cream &
     Sherbert]
    Margarine:      43          $0.0         0.00%  42           $0.1         0.00%  39           $0.2         0.00%
     Tubs And
     Bowls
    Natural Cheese  44          $0.0         0.00%  26           $0.2         0.00%  29           $0.2         0.00%
     Chunks
    Fz Ss Prem      45          $0.0         0.00%  41           $0.1         0.00%  41           $0.2         0.00%
     Traditional
     Meals
    Macaroni &      46          $0.0         0.00%  88           $0.1         0.00%  74           $0.1         0.00%
     Cheese Dnrs
    Pourable Salad  47          $0.0         0.00%  35           $0.1         0.00%  35           $0.2         0.00%
     Dressings
    Choice Beef     48          $0.0         0.00%  53           $0.1         0.00%  54           $0.2         0.00%
    Isotonic        49          $0.0         0.00%  44           $0.1         0.00%  48           $0.2         0.00%
     Drinks Single
     Serve
    Strawberries    50          $0.0         0.00%  29           $0.2         0.00%  30           $0.2         0.00%
    Can Pasta       51          $0.0         0.00%  118          $0.1         0.00%  97           $0.1         0.00%
    Mayonnaise &    52          $0.0         0.00%  48           $0.1         0.00%  50           $0.2         0.00%
     Whipped
     Dressing
    Ribs [Pork]     53          $0.0         0.00%  52           $0.1         0.00%  53           $0.2         0.00%
    Candy Bags--    54          $0.0         0.00%  36           $0.1         0.00%  37           $0.2         0.00%
     Chocolate
    Cottage Cheese  55          $0.0         0.00%  37           $0.1         0.00%  42           $0.2         0.00%
    Dairy Case      56          $0.0         0.00%  24           $0.2         0.00%  28           $0.2         0.00%
     100% Pure
     Juice--O
    Mexican Soft    57          $0.0         0.00%  56           $0.1         0.00%  58           $0.1         0.00%
     Tortillas And
     Wra
    Frzn French     58          $0.0         0.00%  93           $0.1         0.00%  80           $0.1         0.00%
     Fries
    Candy Bars      59          $0.0         0.00%  71           $0.1         0.00%  70           $0.1         0.00%
     (Multi Pack)
    Sweet Goods--   60          $0.0         0.00%  95           $0.1         0.00%  85           $0.1         0.00%
     Full Size
    Butts [Pork     61          $0.0         0.00%  80           $0.1         0.00%  76           $0.1         0.00%
     Shoulder]
    Frzn Chicken--  62          $0.0         0.00%  54           $0.1         0.00%  59           $0.1         0.00%
     Wht Meat
    Sandwich        63          $0.0         0.00%  63           $0.1         0.00%  63           $0.1         0.00%
     Cookies
    Mainstream      64          $0.0         0.00%  73           $0.1         0.00%  71           $0.1         0.00%
     [Pasta &
     Pizza Sauce]
    Fz Bag          65          $0.0         0.00%  34           $0.2         0.00%  40           $0.2         0.00%
     Vegetables--P
     lain
    Bagged Cheese   66          $0.0         0.00%  90           $0.1         0.00%  79           $0.1         0.00%
     Snacks
    Choice Beef     67          $0.0         0.00%  40           $0.1         0.00%  47           $0.2         0.00%
    Peanut Butter   68          $0.0         0.00%  50           $0.1         0.00%  56           $0.2         0.00%
    Bkfst Sausage-- 69          $0.0         0.00%  61           $0.1         0.00%  62           $0.1         0.00%
     Fresh Rolls
    Adult Cereal    70          $0.0         0.00%  33           $0.2         0.00%  33           $0.2         0.00%
    Loaf Cheese     71          $0.0         0.00%  67           $0.1         0.00%  67           $0.1         0.00%
    Refrigerated    72          $0.0         0.00%  86           $0.1         0.00%  82           $0.1         0.00%
     Biscuits
    Vegetable Oil   73          $0.0         0.00%  131          $0.1         0.00%  108          $0.1         0.00%
    Hot Dog Buns    74          $0.0         0.00%  79           $0.1         0.00%  77           $0.1         0.00%
    Candy Bars      75          $0.0         0.00%  84           $0.1         0.00%  83           $0.1         0.00%
     (Singles)
     (Including)
    Sour Creams     76          $0.0         0.00%  62           $0.1         0.00%  65           $0.1         0.00%
    Sticks/Enrobed  77          $0.0         0.00%  99           $0.1         0.00%  92           $0.1         0.00%
     [Frozen
     Novelties]
    Angus [Beef]    78          $0.0         0.00%  83           $0.1         0.00%  81           $0.1         0.00%
    Tray Pack/Choc  79          $0.0         0.00%  85           $0.1         0.00%  84           $0.1         0.00%
     Chip Cookies
    Salsa & Dips    80          $0.0         0.00%  106          $0.1         0.00%  99           $0.1         0.00%
    Skillet         81          $0.0         0.00%  142          $0.1         0.00%  120          $0.1         0.00%
     Dinners
    Aseptic Pack    82          $0.0         0.00%  154          $0.1         0.00%  126          $0.1         0.00%
     Juice And
     Drinks
    Tuna            83          $0.0         0.00%  72           $0.1         0.00%  75           $0.1         0.00%
    Sw Gds: Donuts  84          $0.0         0.00%  89           $0.1         0.00%  89           $0.1         0.00%
    Head Lettuce    85          $0.0         0.00%  65           $0.1         0.00%  69           $0.1         0.00%
    Fz Family       86          $0.0         0.00%  170          $0.0         0.00%  138          $0.1         0.00%
     Style Entrees
    Cubed Meats     87          $0.0         0.00%  97           $0.1         0.00%  94           $0.1         0.00%
     [Beef]
    Select Beef     88          $0.0         0.00%  91           $0.1         0.00%  91           $0.1         0.00%
    Value Forms/    89          $0.0         0.00%  166          $0.0         0.00%  139          $0.1         0.00%
     18oz And
     Larger
     [Chicken]
    Fz Ss Prem      90          $0.0         0.00%  30           $0.2         0.00%  32           $0.2         0.00%
     Nutritional
     Meals
    Variety Beans-- 91          $0.0         0.00%  77           $0.1         0.00%  87           $0.1         0.00%
     Kidney/Pinto/
     E
    Cream Cheese    92          $0.0         0.00%  58           $0.1         0.00%  64           $0.1         0.00%
    Dnr Sausage--   93          $0.0         0.00%  129          $0.1         0.00%  122          $0.1         0.00%
     Links Pork
     Ckd/S
    Lunchmeat--Cho  94          $0.0         0.00%  186          $0.0         0.00%  155          $0.1         0.00%
     p/Form Pltry
     & Ha
    Frzn Meat--     95          $0.0         0.00%  194          $0.0         0.00%  162          $0.1         0.00%
     Beef
    Toaster         96          $0.0         0.00%  121          $0.1         0.00%  116          $0.1         0.00%
     Pastries
    Bacon--Trad     97          $0.0         0.00%  76           $0.1         0.00%  88           $0.1         0.00%
     Greater Than
     16oz
    Corn Chips      98          $0.0         0.00%  108          $0.1         0.00%  105          $0.1         0.00%
    Water Ice       99          $0.0         0.00%  220          $0.0         0.00%  182          $0.1         0.00%
     [Frozen
     Novelties]
    Eggs--Medium    100         $0.0         0.00%  164          $0.0         0.00%  144          $0.1         0.00%
                          -------------------------       ----------------------------------------------------------
      Top 100                   $4.9         0.07%              $16.8         0.05%              $21.7         0.06%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

     Exhibit E-16: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in Counties with Poverty Rates
                                                      Less than 10%
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $12.2         0.18%  1          $105.5         0.33%  1          $117.6         0.31%
     White Only
    Soft Drinks 12/ 2          $10.3         0.16%  2           $74.1         0.24%  2           $84.4         0.22%
     18 & 15pk Can
     Car
    Lean [Beef]     3           $6.3         0.10%  7           $32.5         0.10%  5           $38.9         0.10%
    Shredded        4           $4.8         0.07%  3           $47.5         0.15%  3           $52.3         0.14%
     Cheese
    Kids Cereal     5           $4.3         0.06%  20          $24.1         0.08%  18          $28.3         0.07%
    Sft Drnk 2      6           $3.9         0.06%  18          $25.3         0.08%  17          $29.2         0.08%
     Liter Btl
     Carb Incl
    Potato Chips    7           $3.8         0.06%  9           $31.6         0.10%  7           $35.4         0.09%
    Primal [Beef]   8           $3.6         0.05%  16          $27.7         0.09%  14          $31.3         0.08%
    Chicken Breast  9           $3.4         0.05%  4           $39.9         0.13%  4           $43.3         0.11%
     Boneless
    Lunchment--Del  10          $3.3         0.05%  11          $29.7         0.09%  10          $33.0         0.09%
     i Fresh
    Eggs--Large     11          $3.1         0.05%  8           $31.8         0.10%  9           $34.9         0.09%
    Infant Formula  12          $3.1         0.05%  268          $4.3         0.01%  169          $7.4         0.02%
     Starter/
     Solutio
    Snacks/         13          $3.0         0.05%  54          $14.2         0.05%  48          $17.3         0.05%
     Appetizers
    Tortilla/Nacho  14          $3.0         0.05%  13          $28.8         0.09%  12          $31.8         0.08%
     Chips
    Enhanced [Pork  15          $2.8         0.04%  21          $23.6         0.07%  20          $26.4         0.07%
     Boneless Loin/
     Rib]
    Mainstream      16          $2.8         0.04%  40          $17.3         0.05%  36          $20.1         0.05%
     White Bread
    Unflavored Can  17          $2.8         0.04%  22          $23.4         0.07%  21          $26.1         0.07%
     Coffee
    Still Water     18          $2.7         0.04%  27          $21.6         0.07%  26          $24.2         0.06%
     Drnking/Mnrl
     Water
    Soft Drinks     19          $2.6         0.04%  59          $13.8         0.04%  53          $16.3         0.04%
     20pk & 24pk
     Can Carb
    Pizza/Premium   20          $2.5         0.04%  28          $21.3         0.07%  27          $23.9         0.06%
    Fz Ss Prem      21          $2.5         0.04%  32          $19.3         0.06%  30          $21.8         0.06%
     Traditional
     Meals
    Dairy Case      22          $2.5         0.04%  6           $33.2         0.11%  6           $35.7         0.09%
     100% Pure
     Juice--O
    Natural Cheese  23          $2.4         0.04%  15          $28.1         0.09%  15          $30.6         0.08%
     Chunks
    American        24          $2.4         0.04%  46          $16.3         0.05%  41          $18.7         0.05%
     Single Cheese
    All Family      25          $2.3         0.04%  14          $28.2         0.09%  16          $30.5         0.08%
     Cereal
    Bacon--Trad     26          $2.3         0.03%  35          $19.0         0.06%  35          $21.3         0.06%
     16oz Or Less
    Snack Cake--    27          $2.2         0.03%  70          $12.5         0.04%  64          $14.7         0.04%
     Multi Pack
    Select Beef     28          $2.2         0.03%  34          $19.2         0.06%  33          $21.4         0.06%
    Bananas         29          $2.2         0.03%  10          $30.5         0.10%  11          $32.7         0.09%
    Potatoes        30          $2.2         0.03%  33          $19.3         0.06%  32          $21.5         0.06%
     Russet (Bulk
     & Bag)
    Sft Drnk Mlt-   31          $2.2         0.03%  25          $22.5         0.07%  24          $24.6         0.06%
     Pk Btl Carb
     (Excp)
    Fz Ss Economy   32          $2.2         0.03%  112          $8.7         0.03%  94          $10.8         0.03%
     Meals All
    Premium [Ice    33          $2.1         0.03%  12          $29.6         0.09%  13          $31.7         0.08%
     Cream &
     Sherbert]
    Mainstream      34          $2.1         0.03%  26          $21.8         0.07%  28          $23.8         0.06%
     Variety
     Breads
    Sft Drnk Sngl   35          $2.1         0.03%  90          $10.1         0.03%  81          $12.2         0.03%
     Srv Btl Carb
     (Ex)
    Convenient      36          $2.1         0.03%  94           $9.7         0.03%  86          $11.8         0.03%
     Meals--Kids
     Meal C
    Sandwiches &    37          $2.0         0.03%  104          $9.0         0.03%  91          $11.0         0.03%
     Handhelds
    Sugar           38          $1.9         0.03%  61          $13.6         0.04%  55          $15.5         0.04%
    Condensed Soup  39          $1.9         0.03%  31          $19.6         0.06%  31          $21.5         0.06%
    Fz Family       40          $1.8         0.03%  83          $11.0         0.03%  77          $12.8         0.03%
     Style Entrees
    Ribs [Pork]     41          $1.8         0.03%  68          $12.9         0.04%  63          $14.7         0.04%
    Isotonic        42          $1.7         0.03%  60          $13.8         0.04%  56          $15.5         0.04%
     Drinks Single
     Serve
    Refrigerated    43          $1.7         0.03%  38          $18.3         0.06%  37          $20.0         0.05%
     Coffee
     Creamers
    Pourable Salad  44          $1.7         0.03%  39          $18.0         0.06%  38          $19.7         0.05%
     Dressings
    Fz Ss Prem      45          $1.7         0.03%  5           $33.6         0.11%  8           $35.3         0.09%
     Nutritional
     Meals
    Frzn Chicken--  46          $1.7         0.03%  74          $12.2         0.04%  69          $13.9         0.04%
     Wht Meat
    Strawberries    47          $1.7         0.03%  17          $26.3         0.08%  19          $27.9         0.07%
    Mayonnaise &    48          $1.6         0.02%  52          $14.6         0.05%  54          $16.1         0.04%
     Whipped
     Dressing
    Mexican Soft    49          $1.6         0.02%  51          $14.8         0.05%  51          $16.4         0.04%
     Tortillas And
     Wra
    Candy Bags--    50          $1.5         0.02%  30          $20.3         0.06%  29          $21.9         0.06%
     Chocolate
    Adult Cereal    51          $1.5         0.02%  24          $22.8         0.07%  25          $24.3         0.06%
    Choice Beef     52          $1.5         0.02%  63          $13.5         0.04%  60          $15.1         0.04%
    Sw Gds: Donuts  53          $1.5         0.02%  77          $11.7         0.04%  76          $13.2         0.03%
    Traditional     54          $1.5         0.02%  56          $13.9         0.04%  58          $15.3         0.04%
     [Ice Cream &
     Sherbert]
    Meat: Turkey    55          $1.4         0.02%  19          $24.3         0.08%  22          $25.7         0.07%
     Bulk
    Aseptic Pack    56          $1.4         0.02%  136          $7.8         0.02%  115          $9.2         0.02%
     Juice And
     Drinks
    Fz Bag          57          $1.4         0.02%  47          $16.0         0.05%  46          $17.4         0.05%
     Vegetables--P
     lain
    Butter          58          $1.4         0.02%  23          $23.3         0.07%  23          $24.7         0.06%
    Margarine:      59          $1.4         0.02%  75          $12.1         0.04%  72          $13.5         0.04%
     Tubs And
     Bowls
    Hot Dogs--Base  60          $1.4         0.02%  174          $6.5         0.02%  149          $7.9         0.02%
     Meat
    Can Pasta       61          $1.4         0.02%  193          $6.1         0.02%  166          $7.4         0.02%
    Macaroni &      62          $1.4         0.02%  133          $7.9         0.02%  114          $9.2         0.02%
     Cheese Dnrs
    Choice Beef     63          $1.4         0.02%  107          $8.9         0.03%  100         $10.2         0.03%
    Pizza/Economy   64          $1.4         0.02%  191          $6.1         0.02%  164          $7.5         0.02%
    Peanut Butter   65          $1.3         0.02%  45          $16.4         0.05%  45          $17.7         0.05%
    Mainstream      66          $1.3         0.02%  88          $10.4         0.03%  88          $11.7         0.03%
     [Pasta &
     Pizza Sauce]
    Pizza/          67          $1.3         0.02%  98           $9.3         0.03%  95          $10.6         0.03%
     Traditional
    Tuna            68          $1.3         0.02%  64          $13.3         0.04%  65          $14.6         0.04%
    Value Forms/    69          $1.2         0.02%  209          $5.8         0.02%  181          $7.0         0.02%
     18oz And
     Larger
     [Chicken]
    Angus           70          $1.2         0.02%  62          $13.6         0.04%  62          $14.8         0.04%
    Meat: Ham Bulk  71          $1.2         0.02%  36          $18.4         0.06%  39          $19.6         0.05%
    Frzn Breakfast  72          $1.2         0.02%  135          $7.8         0.02%  122          $9.0         0.02%
     Sandwiches
    Cream Cheese    73          $1.2         0.02%  49          $15.5         0.05%  50          $16.7         0.04%
    Cheese          74          $1.2         0.02%  66          $13.1         0.04%  67          $14.2         0.04%
     Crackers
    Fz Skillet      75          $1.2         0.02%  89          $10.3         0.03%  90          $11.5         0.03%
     Meals
    String Cheese   76          $1.2         0.02%  53          $14.3         0.05%  57          $15.4         0.04%
    Fruit Snacks    77          $1.2         0.02%  170          $6.6         0.02%  152          $7.8         0.02%
    Frzn Meat--     78          $1.1         0.02%  184          $6.3         0.02%  168          $7.4         0.02%
     Beef
    Frzn French     79          $1.1         0.02%  173          $6.5         0.02%  159          $7.7         0.02%
     Fries
    Instore Cut     80          $1.1         0.02%  57          $13.8         0.04%  61          $14.9         0.04%
     Fruit
    Waffles/        81          $1.1         0.02%  84          $10.9         0.03%  83          $12.0         0.03%
     Pancakes/
     French Toast
    Sandwiches--(C  82          $1.1         0.02%  140          $7.7         0.02%  130          $8.8         0.02%
     old)
    Sour Creams     83          $1.1         0.02%  73          $12.4         0.04%  73          $13.5         0.04%
    Cakes:          84          $1.1         0.02%  164          $6.7         0.02%  150          $7.8         0.02%
     Birthday/
     Celebration
     Sh
    Avocado         85          $1.1         0.02%  48          $15.7         0.05%  49          $16.8         0.04%
    Rts Soup:       86          $1.1         0.02%  55          $14.2         0.05%  59          $15.3         0.04%
     Chunky/
     Homestyle/Et
    Salsa & Dips    87          $1.1         0.02%  132          $7.9         0.02%  124          $9.0         0.02%
    Flavored Milk   88          $1.1         0.02%  145          $7.5         0.02%  137          $8.5         0.02%
    Grapes Red      89          $1.1         0.02%  42          $17.0         0.05%  43          $18.0         0.05%
    Candy Bars      90          $1.1         0.02%  152          $7.1         0.02%  142          $8.2         0.02%
     (Singles)
     (Including)
    Lunchment--Bol  91          $1.1         0.02%  179          $6.4         0.02%  167          $7.4         0.02%
     ogna/Sausage
    Sandwich        92          $1.0         0.02%  99           $9.3         0.03%  98          $10.4         0.03%
     Cookies
    Bkfst Sausage-- 93          $1.0         0.02%  109          $8.8         0.03%  105          $9.9         0.03%
     Fresh Rolls
    Spring Water    94          $1.0         0.02%  82          $11.0         0.03%  82          $12.0         0.03%
    Chix: Frd 8pc/  95          $1.0         0.02%  85          $10.8         0.03%  84          $11.8         0.03%
     Cut Up (Hot)
    Bagged Cheese   96          $1.0         0.02%  176          $6.4         0.02%  165          $7.4         0.02%
     Snacks
    Natural Cheese  97          $1.0         0.02%  50          $15.3         0.05%  52          $16.4         0.04%
     Slices
    Hamburger Buns  98          $1.0         0.02%  102          $9.1         0.03%  103         $10.1         0.03%
    Sweet Goods--   99          $1.0         0.01%  175          $6.5         0.02%  163          $7.5         0.02%
     Full Size
    Yogurt/Kids     100         $1.0         0.01%  165          $6.7         0.02%  155          $7.7         0.02%
                          -------------------------       ----------------------------------------------------------
      Top 100                 $204.3         3.10%           $1,763.9         5.60%           $1,968.2         5.17%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

     Exhibit E-17: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in Counties with Poverty Rates
                                                      of 10% to 20%
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1         $147.5         2.24%  1          $651.2         2.07%  1          $798.7         2.10%
     White Only
    Soft Drinks 12/ 2         $123.8         1.88%  2          $456.0         1.45%  2          $579.8         1.52%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $85.1         1.29%  7          $199.9         0.63%  4          $285.0         0.75%
    Kids Cereal     4          $59.3         0.90%  20         $141.9         0.45%  13         $201.2         0.53%
    Shredded        5          $57.3         0.87%  3          $255.8         0.81%  3          $313.1         0.82%
     Cheese
    Sft Drnk 2      6          $54.3         0.83%  13         $175.5         0.56%  9          $229.8         0.60%
     Liter Btl
     Carb Incl
    Potato Chips    7          $49.2         0.75%  8          $192.5         0.61%  6          $241.8         0.63%
    Primal [Beef]   8          $44.4         0.68%  17         $156.1         0.50%  15         $200.6         0.53%
    Infant Formula  9          $42.1         0.64%  179         $35.8         0.11%  79          $77.9         0.20%
     Starter/
     Solutio
    Lunchment--Del  10         $42.1         0.64%  11         $183.1         0.58%  11         $225.2         0.59%
     i Fresh
    Eggs--Large     11         $40.0         0.61%  9          $191.2         0.61%  8          $231.2         0.61%
    Chicken Breast  12         $38.5         0.58%  4          $221.7         0.70%  5          $260.2         0.68%
     Boneless
    Still Water     13         $37.9         0.58%  19         $146.8         0.47%  19         $184.8         0.48%
     Drnking/Mnrl
     Water
    Tortilla/Nacho  14         $36.3         0.55%  16         $157.8         0.50%  17         $194.1         0.51%
     Chips
    Mainstream      15         $35.0         0.53%  42         $100.2         0.32%  35         $135.3         0.36%
     White Bread
    Snacks/         16         $34.2         0.52%  67          $75.2         0.24%  49         $109.4         0.29%
     Appetizers
    Fz Ss Prem      17         $33.7         0.51%  22         $136.9         0.43%  21         $170.6         0.45%
     Traditional
     Meals
    Dairy Case      18         $33.7         0.51%  6          $206.7         0.66%  7          $240.4         0.63%
     100% Pure
     Juice--O
    American        19         $32.8         0.50%  41         $102.4         0.32%  36         $135.2         0.35%
     Single Cheese
    Unflavored Can  20         $31.4         0.48%  18         $149.8         0.48%  20         $181.2         0.48%
     Coffee
    Enhanced [Pork  21         $31.1         0.47%  27         $122.2         0.39%  24         $153.3         0.40%
     Boneless Loin/
     Rib]
    Fz Ss Economy   22         $31.1         0.47%  80          $62.1         0.20%  65          $93.1         0.24%
     Meals All
    Bacon--Trad     23         $31.0         0.47%  29         $119.4         0.38%  26         $150.3         0.39%
     16oz Or Less
    Pizza/Premium   24         $30.2         0.46%  34         $115.3         0.37%  29         $145.5         0.38%
    Snack Cake--    25         $30.2         0.46%  70          $74.2         0.24%  54         $104.4         0.27%
     Multi Pack
    Mainstream      26         $29.7         0.45%  25         $130.8         0.42%  22         $160.5         0.42%
     Variety
     Breads
    Soft Drinks     27         $29.0         0.44%  62          $79.6         0.25%  50         $108.6         0.29%
     20pk & 24pk
     Can Carb
    Natural Cheese  28         $28.2         0.43%  14         $167.0         0.53%  16         $195.1         0.51%
     Chunks
    All Family      29         $28.0         0.43%  15         $163.5         0.52%  18         $191.6         0.50%
     Cereal
    Sugar           30         $27.3         0.42%  58          $84.4         0.27%  46         $111.8         0.29%
    Sandwiches &    31         $27.0         0.41%  93          $56.0         0.18%  73          $83.0         0.22%
     Handhelds
    Potatoes        32         $26.8         0.41%  32         $116.0         0.37%  30         $142.8         0.37%
     Russet (Bulk
     & Bag)
    Bananas         33         $26.6         0.40%  10         $187.2         0.59%  12         $213.7         0.56%
    Ribs [Pork]     34         $25.8         0.39%  60          $80.9         0.26%  53         $106.7         0.28%
    Convenient      35         $25.2         0.38%  106         $51.5         0.16%  82          $76.7         0.20%
     Meals--Kids
     Meal C
    Premium [Ice    36         $24.8         0.38%  12         $176.1         0.56%  14         $200.9         0.53%
     Cream &
     Sherbert]
    Isotonic        37         $24.2         0.37%  45          $93.9         0.30%  42         $118.1         0.31%
     Drinks Single
     Serve
    Sft Drnk Mlt-   38         $24.0         0.36%  26         $123.5         0.39%  28         $147.5         0.39%
     Pk Btl Carb
     (Excp)
    Select Beef     39         $23.8         0.36%  30         $117.5         0.37%  31         $141.3         0.37%
    Frzn Chicken--  40         $22.7         0.35%  69          $74.8         0.24%  61          $97.5         0.26%
     Wht Meat
    Condensed Soup  41         $22.5         0.34%  33         $115.5         0.37%  32         $138.0         0.36%
    Pourable Salad  42         $21.7         0.33%  39         $105.6         0.34%  39         $127.3         0.33%
     Dressings
    Choice Beef     43         $21.3         0.32%  38         $106.3         0.34%  38         $127.6         0.33%
    Fz Family       44         $21.2         0.32%  78          $63.1         0.20%  72          $84.3         0.22%
     Style Entrees
    Sft Drnk Sngl   45         $20.9         0.32%  99          $53.5         0.17%  85          $74.4         0.20%
     Srv Btl Carb
     (Ex)
    Mayonnaise &    46         $20.9         0.32%  49          $90.9         0.29%  45         $111.8         0.29%
     Whipped
     Dressing
    Mexican Soft    47         $19.8         0.30%  50          $90.3         0.29%  48         $110.1         0.29%
     Tortillas And
     Wra
    Refrigerated    48         $19.5         0.30%  31         $116.6         0.37%  33         $136.1         0.36%
     Coffee
     Creamers
    Adult Cereal    49         $19.3         0.29%  21         $139.5         0.44%  23         $158.8         0.42%
    Traditional     50         $19.2         0.29%  52          $88.6         0.28%  51         $107.8         0.28%
     [Ice Cream &
     Sherbert]
    Fz Ss Prem      51         $19.1         0.29%  5          $208.6         0.66%  10         $227.7         0.60%
     Nutritional
     Meals
    Fz Bag          52         $19.0         0.29%  43          $98.9         0.31%  43         $117.9         0.31%
     Vegetables--P
     lain
    Aseptic Pack    53         $18.6         0.28%  137         $43.3         0.14%  107         $61.9         0.16%
     Juice And
     Drinks
    Choice Beef     54         $18.4         0.28%  97          $53.6         0.17%  89          $72.1         0.19%
    Hot Dogs--Base  55         $18.4         0.28%  145         $42.1         0.13%  111         $60.5         0.16%
     Meat
    Macaroni &      56         $18.2         0.28%  129         $44.6         0.14%  103         $62.8         0.16%
     Cheese Dnrs
    Margarine:      57         $18.1         0.27%  63          $77.4         0.25%  64          $95.5         0.25%
     Tubs And
     Bowls
    Strawberries    58         $17.8         0.27%  24         $132.8         0.42%  25         $150.6         0.40%
    Mainstream      59         $17.4         0.26%  85          $60.8         0.19%  78          $78.2         0.21%
     [Pasta &
     Pizza Sauce]
    Candy Bags--    60         $16.7         0.25%  36         $112.6         0.36%  37         $129.3         0.34%
     Chocolate
    Can Pasta       61         $16.5         0.25%  185         $35.3         0.11%  144         $51.8         0.14%
    Frzn Chicken--  62         $16.4         0.25%  469         $13.0         0.04%  268         $29.4         0.08%
     Wings
    Tuna            63         $16.4         0.25%  59          $84.4         0.27%  58         $100.8         0.26%
    Sw Gds: Donuts  64         $16.2         0.25%  84          $61.0         0.19%  80          $77.2         0.20%
    Peanut Butter   65         $15.8         0.24%  44          $96.9         0.31%  44         $112.7         0.30%
    Lunchment--Bol  66         $15.7         0.24%  124         $45.6         0.14%  108         $61.3         0.16%
     ogna/Sausage
    Mult Pk Bag     67         $15.4         0.23%  205         $32.4         0.10%  161         $47.8         0.13%
     Snacks
    Butter          68         $15.3         0.23%  23         $134.9         0.43%  27         $150.1         0.39%
    Meat: Turkey    69         $15.1         0.23%  28         $120.3         0.38%  34         $135.4         0.36%
     Bulk
    Frzn French     70         $15.1         0.23%  177         $37.0         0.12%  141         $52.1         0.14%
     Fries
    Vegetable Oil   71         $14.9         0.23%  250         $26.7         0.08%  193         $41.6         0.11%
    Pizza/Economy   72         $14.6         0.22%  195         $33.3         0.11%  159         $48.0         0.13%
    Frzn Meat--     73         $14.6         0.22%  188         $35.0         0.11%  154         $49.6         0.13%
     Beef
    Fz Skillet      74         $14.5         0.22%  87          $60.4         0.19%  84          $74.9         0.20%
     Meals
    Value Forms/    75         $14.2         0.22%  214         $31.9         0.10%  168         $46.2         0.12%
     18oz And
     Larger
     [Chicken]
    Frzn Breakfast  76         $14.1         0.21%  154         $41.0         0.13%  128         $55.0         0.14%
     Sandwiches
    Cakes:          77         $14.1         0.21%  172         $37.9         0.12%  143         $52.0         0.14%
     Birthday/
     Celebration
     Sh
    Chicken Wings   78         $14.0         0.21%  319         $20.8         0.07%  238         $34.8         0.09%
    Sandwiches--(C  79         $13.9         0.21%  94          $56.0         0.18%  92          $69.9         0.18%
     old)
    Sandwich        80         $13.8         0.21%  95          $54.6         0.17%  94          $68.4         0.18%
     Cookies
    Sour Creams     81         $13.7         0.21%  71          $73.2         0.23%  71          $86.9         0.23%
    Rts Soup:       82         $13.7         0.21%  47          $93.1         0.30%  52         $106.8         0.28%
     Chunky/
     Homestyle/Et
    Pizza/          83         $13.6         0.21%  118         $47.2         0.15%  109         $60.8         0.16%
     Traditional
    Cream Cheese    84         $13.5         0.21%  53          $88.0         0.28%  57         $101.6         0.27%
    Waffles/        85         $13.4         0.20%  89          $58.6         0.19%  88          $72.1         0.19%
     Pancakes/
     French Toast
    Fruit Snacks    86         $13.4         0.20%  209         $32.1         0.10%  172         $45.5         0.12%
    Bagged Cheese   87         $13.3         0.20%  158         $40.0         0.13%  136         $53.2         0.14%
     Snacks
    Angus [Beef]    88         $13.1         0.20%  64          $77.0         0.24%  67          $90.2         0.24%
    Ramen Noodles/  89         $12.9         0.20%  298         $22.0         0.07%  237         $34.8         0.09%
     Ramen Cups
    Salsa & Dips    90         $12.8         0.20%  140         $42.7         0.14%  124         $55.5         0.15%
    Cheese          91         $12.8         0.19%  74          $67.9         0.22%  77          $80.7         0.21%
     Crackers
    Candy Bars      92         $12.8         0.19%  139         $42.9         0.14%  123         $55.7         0.15%
     (Singles)
     (Including)
    Dairy Case      93         $12.6         0.19%  170         $38.2         0.12%  149         $50.7         0.13%
     Juice Drnk
     Under 10
    Spring Water    94         $12.5         0.19%  65          $76.3         0.24%  68          $88.8         0.23%
    Chicken Drums   95         $12.4         0.19%  276         $23.9         0.08%  226         $36.3         0.10%
    Hot Dog Buns    96         $12.3         0.19%  119         $47.0         0.15%  113         $59.3         0.16%
    Sweet Goods--   97         $12.3         0.19%  128         $44.9         0.14%  118         $57.2         0.15%
     Full Size
    Hamburger Buns  98         $12.2         0.19%  104         $52.5         0.17%  98          $64.8         0.17%
    Grapes Red      99         $12.1         0.18%  48          $91.9         0.29%  55         $104.0         0.27%
    Flavored Milk   100        $12.1         0.18%  130         $44.6         0.14%  120         $56.7         0.15%
                          -------------------------       ----------------------------------------------------------
      Top 100               $2,551.7        38.78%          $10,139.2        32.17%          $12,690.9        33.31%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

     Exhibit E-18: Top 100 Subcommodities for SNAP Households by Expenditure: Stores in Counties with Poverty Rates
                                                    Greater than 20%
    ----------------------------------------------------------------------------------------------------------------
                     SNAP Household  Expenditures          Non-SNAP Household         Total Household  Expenditures
                   --------------------------------           Expenditures          --------------------------------
     Subcommodity                                  ---------------------------------
                     Rank     $ in        % of                $ in         % of       Rank     $ in         % of
                            millions  Expenditures   Rank   millions   Expenditures          millions   Expenditures
    ----------------------------------------------------------------------------------------------------------------
    Fluid Milk/     1          $31.5         0.48%  1           $97.0         0.31%  1          $128.5         0.34%
     White Only
    Soft Drinks 12/ 2          $30.5         0.46%  2           $71.0         0.23%  2          $101.6         0.27%
     18 & 15pk Can
     Car
    Lean [Beef]     3          $21.0         0.32%  13          $25.4         0.08%  5           $46.4         0.12%
    Kids Cereal     4          $14.6         0.22%  21          $20.4         0.06%  13          $35.0         0.09%
    Primal [Beef]   5          $14.4         0.22%  4           $35.9         0.11%  4           $50.3         0.13%
    Shredded        6          $12.7         0.19%  3           $38.6         0.12%  3           $51.3         0.13%
     Cheese
    Sft Drnk 2      7          $12.6         0.19%  8           $29.3         0.09%  6           $42.0         0.11%
     Liter Btl
     Carb Incl
    Potato Chips    8          $11.3         0.17%  10          $29.1         0.09%  7           $40.4         0.11%
    Lunchment--Del  9          $10.5         0.16%  6           $29.8         0.09%  8           $40.2         0.11%
     i Fresh
    Mainstream      10         $10.1         0.15%  26          $19.3         0.06%  19          $29.4         0.08%
     White Bread
    Snack Cake--    11          $9.2         0.14%  38          $15.1         0.05%  30          $24.2         0.06%
     Multi Pack
    Eggs--Large     12          $9.0         0.14%  11          $28.6         0.09%  10          $37.6         0.10%
    Infant Formula  13          $9.0         0.14%  172          $5.2         0.02%  61          $14.2         0.04%
     Starter/
     Solutio
    American        14          $8.8         0.13%  31          $17.9         0.06%  24          $26.8         0.07%
     Single Cheese
    Still Water     15          $8.1         0.12%  24          $19.3         0.06%  21          $27.5         0.07%
     Drnking/Mnrl
     Water
    Soft Drinks     16          $8.1         0.12%  46          $13.1         0.04%  39          $21.2         0.06%
     20pk & 24pk
     Can Carb
    Tortilla/Nacho  17          $8.1         0.12%  17          $22.4         0.07%  16          $30.5         0.08%
     Chips
    Sft Drnk Mlt-   18          $7.9         0.12%  12          $27.7         0.09%  12          $35.6         0.09%
     Pk Btl Carb
     (Excp)
    Fz Ss Economy   19          $7.7         0.12%  64          $10.0         0.03%  48          $17.7         0.05%
     Meals All
    Sugar           20          $7.7         0.12%  41          $14.6         0.05%  36          $22.3         0.06%
    Fz Ss Prem      21          $7.7         0.12%  27          $19.3         0.06%  23          $26.9         0.07%
     Traditional
     Meals
    Chicken Breast  22          $7.6         0.12%  5           $31.3         0.10%  9           $39.0         0.10%
     Boneless
    Chicken Wings   23          $7.6         0.12%  181          $5.1         0.02%  72          $12.7         0.03%
    Enhanced [Pork  24          $7.6         0.11%  18          $22.2         0.07%  18          $29.7         0.08%
     Boneless Loin/
     Rib]
    Bacon--Trad     25          $7.5         0.11%  28          $19.2         0.06%  25          $26.7         0.07%
     16oz Or Less
    Ribs [Pork]     26          $7.4         0.11%  47          $12.9         0.04%  41          $20.3         0.05%
    Dairy Case      27          $7.4         0.11%  9           $29.1         0.09%  11          $36.5         0.10%
     100% Pure
     Juice--O
    Snacks/         28          $7.4         0.11%  60          $11.0         0.03%  44          $18.4         0.05%
     Appetizers
    Unflavored Can  29          $7.2         0.11%  15          $24.9         0.08%  15          $32.1         0.08%
     Coffee
    Convenient      30          $7.0         0.11%  86           $8.5         0.03%  53          $15.5         0.04%
     Meals--Kids
     Meal C
    Pizza/Premium   31          $6.9         0.10%  35          $16.7         0.05%  32          $23.6         0.06%
    Sandwiches &    32          $6.9         0.10%  82           $8.6         0.03%  56          $15.4         0.04%
     Handhelds
    Potatoes        33          $6.7         0.10%  29          $19.2         0.06%  26          $25.9         0.07%
     Russet (Bulk
     & Bag)
    Mainstream      34          $6.6         0.10%  20          $20.7         0.07%  22          $27.3         0.07%
     Variety
     Breads
    All Family      35          $5.8         0.09%  16          $23.2         0.07%  20          $29.0         0.08%
     Cereal
    Frzn Chicken--  36          $5.6         0.09%  49          $12.8         0.04%  42          $18.4         0.05%
     Wht Meat
    Choice Beef     37          $5.6         0.09%  34          $16.8         0.05%  34          $22.5         0.06%
    Pourable Salad  38          $5.6         0.09%  37          $15.8         0.05%  37          $21.4         0.06%
     Dressings
    Bananas         39          $5.5         0.08%  14          $24.9         0.08%  17          $30.4         0.08%
    Fz Bag          40          $5.3         0.08%  33          $17.0         0.05%  35          $22.3         0.06%
     Vegetables--P
     lain
    Hot Dogs--Base  41          $5.3         0.08%  89           $8.2         0.03%  67          $13.5         0.04%
     Meat
    Mult Pk Bag     42          $5.3         0.08%  178          $5.1         0.02%  101         $10.4         0.03%
     Snacks
    Condensed Soup  43          $5.3         0.08%  30          $18.5         0.06%  31          $23.8         0.06%
    Frzn Chicken--  44          $5.2         0.08%  356          $2.6         0.01%  156          $7.8         0.02%
     Wings
    Lunchment--Bol  45          $5.0         0.08%  79           $8.9         0.03%  65          $14.0         0.04%
     ogna/Sausage
    Traditional     46          $5.0         0.08%  36          $16.3         0.05%  38          $21.3         0.06%
     [Ice Cream &
     Sherbert]
    Sft Drnk Sngl   47          $4.8         0.07%  99           $7.8         0.02%  73          $12.6         0.03%
     Srv Btl Carb
     (Ex)
    Vegetable Oil   48          $4.8         0.07%  193          $4.9         0.02%  113          $9.7         0.03%
    Macaroni &      49          $4.8         0.07%  110          $7.2         0.02%  77          $11.9         0.03%
     Cheese Dnrs
    Mayonnaise &    50          $4.7         0.07%  43          $13.6         0.04%  43          $18.4         0.05%
     Whipped
     Dressing
    Natural Cheese  51          $4.7         0.07%  19          $21.0         0.07%  27          $25.7         0.07%
     Chunks
    Fz Family       52          $4.6         0.07%  70           $9.4         0.03%  64          $14.0         0.04%
     Style Entrees
    Isotonic        53          $4.6         0.07%  56          $11.9         0.04%  49          $16.4         0.04%
     Drinks Single
     Serve
    Can Pasta       54          $4.4         0.07%  135          $6.3         0.02%  96          $10.7         0.03%
    Mainstream      55          $4.3         0.07%  67           $9.7         0.03%  63          $14.0         0.04%
     [Pasta &
     Pizza Sauce]
    Premium [Ice    56          $4.3         0.07%  22          $20.3         0.06%  28          $24.6         0.06%
     Cream &
     Sherbert]
    Frzn French     57          $4.3         0.06%  118          $6.8         0.02%  90          $11.0         0.03%
     Fries
    Choice Beef     58          $4.2         0.06%  65          $10.0         0.03%  62          $14.2         0.04%
    Aseptic Pack    59          $4.2         0.06%  144          $6.1         0.02%  102         $10.3         0.03%
     Juice And
     Drinks
    Chicken Drums   60          $4.1         0.06%  231          $4.2         0.01%  140          $8.4         0.02%
    Dnr Sausage--   61          $4.1         0.06%  209          $4.7         0.01%  130          $8.8         0.02%
     Links Pork
     Ckd/S
    Adult Cereal    62          $4.0         0.06%  23          $20.3         0.06%  29          $24.3         0.06%
    Strawberries    63          $4.0         0.06%  25          $19.3         0.06%  33          $23.3         0.06%
    Margarine:      64          $4.0         0.06%  57          $11.3         0.04%  57          $15.3         0.04%
     Tubs And
     Bowls
    Fz Ss Prem      65          $4.0         0.06%  7           $29.4         0.09%  14          $33.4         0.09%
     Nutritional
     Meals
    Frzn Breakfast  66          $3.9         0.06%  116          $6.9         0.02%  95          $10.8         0.03%
     Sandwiches
    Pizza/Economy   67          $3.8         0.06%  160          $5.7         0.02%  119          $9.5         0.02%
    Sw Gds: Donuts  68          $3.7         0.06%  69           $9.5         0.03%  68          $13.2         0.03%
    Tuna            69          $3.5         0.05%  54          $12.2         0.04%  51          $15.7         0.04%
    Cakes:          70          $3.4         0.05%  162          $5.6         0.02%  125          $9.1         0.02%
     Birthday/
     Celebration
     Sh
    Bacon--Trad     71          $3.4         0.05%  117          $6.8         0.02%  103         $10.3         0.03%
     Greater Than
     16oz
    Peanut Butter   72          $3.3         0.05%  42          $14.5         0.05%  46          $17.8         0.05%
    Candy Bags--    73          $3.3         0.05%  40          $14.6         0.05%  45          $17.9         0.05%
     Chocolate
    Sandwich        74          $3.2         0.05%  98           $7.9         0.02%  89          $11.0         0.03%
     Cookies
    Salsa & Dips    75          $3.2         0.05%  130          $6.4         0.02%  115          $9.6         0.03%
    Frzn Meat--     76          $3.2         0.05%  185          $5.0         0.02%  143          $8.2         0.02%
     Beef
    Bkfst Sausage-- 77          $3.2         0.05%  87           $8.5         0.03%  81          $11.7         0.03%
     Fresh Rolls
    Value Forms/    78          $3.2         0.05%  192          $4.9         0.02%  145          $8.1         0.02%
     18oz And
     Larger
     [Chicken]
    Fz Skillet      79          $3.1         0.05%  81           $8.6         0.03%  80          $11.7         0.03%
     Meals
    Refrigerated    80          $3.1         0.05%  121          $6.7         0.02%  109          $9.8         0.03%
     Biscuits
    Fruit Snacks    81          $3.1         0.05%  218          $4.5         0.01%  162          $7.5         0.02%
    Hot Dog Buns    82          $3.0         0.05%  104          $7.5         0.02%  100         $10.5         0.03%
    Ramen Noodles/  83          $3.0         0.05%  330          $2.9         0.01%  213          $5.9         0.02%
     Ramen Cups
    Hamburger Buns  84          $3.0         0.05%  83           $8.5         0.03%  82          $11.5         0.03%
    Tray Pack/Choc  85          $3.0         0.05%  124          $6.6         0.02%  116          $9.6         0.03%
     Chip Cookies
    Pizza/          86          $3.0         0.05%  101          $7.6         0.02%  99          $10.6         0.03%
     Traditional
    Candy Bars      87          $2.9         0.04%  91           $8.1         0.03%  88          $11.1         0.03%
     (Multi Pack)
    Pails [Ice      88          $2.9         0.04%  194          $4.9         0.02%  153          $7.9         0.02%
     Cream &
     Sherbert]
    Grapes White    89          $2.9         0.04%  72           $9.3         0.03%  76          $12.2         0.03%
    Refrigerated    90          $2.9         0.04%  53          $12.3         0.04%  58          $15.2         0.04%
     Coffee
     Creamers
    Butter          91          $2.9         0.04%  32          $17.5         0.06%  40          $20.4         0.05%
    Shrimp--Cooked  92          $2.9         0.04%  161          $5.6         0.02%  135          $8.5         0.02%
    Rts Soup:       93          $2.9         0.04%  51          $12.6         0.04%  55          $15.5         0.04%
     Chunky/
     Homestyle/Et
    Bagged Cheese   94          $2.8         0.04%  163          $5.6         0.02%  138          $8.4         0.02%
     Snacks
    Butter Spray    95          $2.8         0.04%  85           $8.5         0.03%  83          $11.4         0.03%
     Cracker
    Angus [Beef]    96          $2.8         0.04%  45          $13.1         0.04%  50          $15.9         0.04%
    Flavored Milk   97          $2.8         0.04%  107          $7.4         0.02%  105         $10.2         0.03%
    Waffles/        98          $2.8         0.04%  97           $7.9         0.03%  97          $10.7         0.03%
     Pancakes/
     French Toast
    Dnr Sausage--   99          $2.8         0.04%  150          $5.9         0.02%  133          $8.7         0.02%
     Pork Rope Ckd/
     Sm
    Traditional     100         $2.8         0.04%  109          $7.2         0.02%  107         $10.0         0.03%
     Spices
                          -------------------------       ----------------------------------------------------------
      Top 100                 $610.2         9.27%           $1,500.2         4.76%           $2,110.3         5.54%
       Subcommodit
       ies
                          =========================       ==========================================================
        Total               $6,580.5          100%          $31,513.8          100%          $38,094.2          100%
         Expenditu
         res
    ----------------------------------------------------------------------------------------------------------------
    Source: Foods Typically Purchased by SNAP Households, IMPAQ International, LLC, 2016.
    Note: Columns may not sum to total shown due to rounding.
    * Top 100 subcommodities based on SNAP household expenditures.

                                     ______

                    Submitted Policy Brief by Feeding Texas
    Policy Brief: Maintaining Choices for SNAP Recipients
    Feeding Texas
              Our View: SNAP restrictions are an ineffective and costly
            strategy to improve recipient health. Our nation would be
            better served by educating and empowering recipients to make
            better choices, not restricting those choices.
    Obesity: A Problem for All, but Improving
        Obesity and diet-related disease affect Americans of all income
    levels and backgrounds. SNAP consumers face additional barriers to
    healthy eating, including limited geographic access to affordable,
    healthy food; tight food budgets overall; and inadequate SNAP
    allotments. SNAP recipients sometimes manage this shortfall by buying
    less-nutritious foods that can adversely affect their health.
        Despite these challenges, the most recent USDA report on SNAP
    purchases found no major differences in the expenditures of SNAP and
    non-SNAP households. Put simply, SNAP consumers shop like Americans do
    as a whole.
        And Americans as a whole are eating better. Soda consumption, the
    behavior most often targeted for SNAP restrictions, is at a thirty-year
    low in America. And while dietary quality remains poor, American diets
    have steadily improved in recent years.
    SNAP Restrictions Can Not Force Dietary Change
        A recent, peer-reviewed study (https://www.ncbi.nlm.nih.gov/pubmed/
    27653735) in the medical journal JAMA demonstrated how simply
    restricting SNAP purchases would not improve recipients' diets.
    Participants in this study reported a slight reduction in calories
    consumed but no change in overall diet quality.
        An associated meta-study (https://www.ncbi.nlm.nih.gov/pubmed/
    26647851) concluded that restricting SNAP participants from spending
    their benefits on soda only had a ``small to moderate'' impact, because
    recipients substituted their own money to purchase soda.
    SNAP Restrictions Are Neither Free, nor Freeing
        There are significant costs to SNAP purchase restrictions that
    would be borne by participants, businesses and the program itself.
    Participants
        Americans of all income levels view the government restricting food
    choices as an intrusion into their autonomy to decide what is best for
    their families. Because SNAP restrictions unfairly single out low-
    income Americans for a problem that affects all Americans, they
    increase the stigma associated with SNAP participation. Increased
    stigma could actually reduce health outcomes, as it would lead some
    families to forgo nutrition assistance rather than put their dinner
    table under Federal scrutiny.
    Businesses
        Restricting SNAP purchases would constitute an unfunded Federal
    mandate on business. SNAP retailers would likely bear the cost of re-
    training cashiers, creating signage, reprogramming computers and
    implementing rules associated with this broad change.
        Because SNAP serves a diverse group of Americans with a wide range
    of dietary needs, it would be impossible to restrict SNAP benefits to
    an easy-to-control, ``affirmative list'' of approved foods like that
    found in the WIC program. More likely, restrictions would be
    implemented as a short list of restricted foods, forcing retailers to
    evaluate each product on their shelves, as well as thousands of new
    products each year against rules made in Washington.
    Program Efficiency & Effectiveness
        Implementation of EBT technology has made SNAP efficient and cost-
    effective for retailers and government. The introduction of purchase
    restrictions at checkout would complicate SNAP transactions and
    undermine these gains.
        Unless SNAP restrictions were accompanied by an increase in overall
    benefits, they would also result in a de facto benefit cut by forcing
    recipients to purchase alternative foods that cost more. In this way,
    restrictions could result in decreased purchasing power for SNAP
    recipients, resulting in less food on the family table and a less
    effective hunger-fighting program.
    There is a Better Way
        Our nation would be better served pursuing policies that seek to
    educate and empower clients to make better choices, not restrict those
    choices.
        Congress could achieve these aims in two ways:

      1.  Make SNAP benefits reflect the actual costs of eating healthy.
                The Institute of Medicine has recommended (https://
                www.nap.edu/catalog/13485/supplemental-nutrition-
                assistance-program-examining-the-evidence-to-define-
                benefit) increasing SNAP benefit levels to more accurately
                reflect the costs involved in eating a healthy diet. Absent
                a broad increase in benefits, research suggests that
                funding ``double-dollar incentive'' programs may also
                improve participants' consumption patterns

      2.  Promote well-evaluated, outcomes-driven nutrition education.
                Programming directed by Feeding Texas and our local food
                banks has demonstrated that health interventions and
                nutrition education strategies funded through SNAP-Ed can
                effectively promote healthy eating and improve dietary
                health. These strategies are especially effective when
                paired with the distribution of free produce, which helps
                participants to bridge the transition to healthier habits.
                We call this combined approach ``Feeding with Impact
                (https://www.feedingtexas.org/product/2017/02/Feeding-with-
                Impact-Factsheet/).''
                                     ______

              Submitted Statement by Secretaries' Innovation Group
        The Secretaries' Innovation Group (SIG) is a network of state human
    services secretaries who have program responsibility for the state SNAP
    program, among many others. These SIG member secretaries serve under
    Republican governors from states which make up 46% of the country. In
    November 2014 the members of the Secretaries' Innovation Group issued a
    statement from which these recommendations derive.
        The Supplemental Nutrition Assistance Program (SNAP), which is
    known as Food Stamps, has quadrupled in cost since 2001. A common sense
    approach is needed to allow states the ability to ensure welfare
    benefits are being used appropriately. Despite intense opposition,
    states have made significant strides in some areas to tackle wasteful
    expenditures, fraud and abuse in the system, and with the help of
    reform-minded voices in Congress and a new Administration, states will
    be able to go much further.
    Recommendations
        The program which is intended as a nutritional supplement should
    restrict the purchase of soda, candy and other unhealthy products.

        The Supplemental Nutrition Assistance Program is intended to
    subsidize nutrition for needy families. Too many recipients are
    utilizing their benefit to purchase items that are \1/3\ of adults and
    17% of youth in the United States are obese, according to the Journal
    of the American Medical Association.\1\ According to a Health Affairs
    study, the medical costs associated with obesity are an estimated $147
    billion in 2008.\2\
    ---------------------------------------------------------------------------
        \1\ http://jama.jamanetwork.com/article.aspx?articleid=1832542.
        \2\ http://content.healthaffairs.org/content/28/5/
    w822.full.pdf+html.
    ---------------------------------------------------------------------------
        One option to balance SNAP purchases toward healthier choices is to
    allow SNAP purchases to mirror allowable purchases in the Women,
    Infants and Children (WIC) program. A second alternative is to restrict
    the purchase of products with zero nutritional value such as candy,
    energy drinks and other sugar-sweetened drinks. A third alternative is
    to establish a pilot project with up to ten states for a one-time
    waiver that would allow for some nutrition controls on SNAP purchases.
    These pilot waivers would require an evaluation of measurable outcomes.

        Make key SNAP purchase data available to states.

        Micro-level transaction data which shows how SNAP benefits are
    being spent is not available to the states. However this data would
    provide an objective, measurable picture of where reforms are needed to
    ensure the program is effective in providing essential nutrition for
    those in need. SIG recommends FNS and SNAP-EBT vendors (i.e., Xerox) to
    capture all SNAP transaction-level data and make it available to
    states. Transparency is important to inform program officials,
    legislators and the public on what changes are needed in the program to
    ensure its effectiveness as a supplementary nutrition program.

        Convenience stores need more stringent requirements to participate
    in SNAP.

        The ``convenience store'' category of EBT retailers is of
    particular concern (e.g., gas stations, food marts, party stores). The
    majority of EBT trafficking occurs in these venues. These
    establishments typically do not stock the type of eligible food
    products that satisfy the original intent of the SNAP program. EBT
    redemptions often exceed eligible food inventory at these locations. We
    recommend increasing the minimum eligible food inventory requirements
    of the four major food groups to be stocked for sale at convenience
    store category retailers. An alternative option is to require EBT
    retailers to submit food inventory records on a frequency basis
    (quarterly or semi-annually) in order to reconcile with EBT redemptions
    which could serve as a deterrent to trafficking redemptions.
                                     ______

      Submitted Letter by David B. Allison, Ph.D., Distinguished Quetelet
      Endowed Professor; Associate Dean for Research & Science; Director,
      Office of Energetics; Director, Nutrition & Obesity Research Center,
        Department of Nutrition Sciences, School of Health Professions,
                      University of Alabama at Birmingham
    Tuesday, February 14, 2017

      Hon. K. Michael Conaway,
      Chairman,
      House Committee on Agriculture,
      Washington, D.C.

        Thank you for inviting me to testify before the House Committee on
    Agriculture for your February 16, 2017 meeting.
        I regret that I will be unable to join you at that meeting, but
    instead wanted to offer you some thoughts, information, and materials
    that may be helpful to you and the Committee in your deliberations. I
    reference several articles below and include them, as well as my
    current CV,* as enclosed attachments to this e-mail.
    ---------------------------------------------------------------------------
        * The document referred to is retained in Committee file.
    ---------------------------------------------------------------------------
        Before proceeding further, I wish to emphasize that the opinions
    below are my own and I am not speaking on behalf of my university or
    any other organization.
    I. The Challenge in Predicting Intervention Effects
        Some individuals may assert that if society implements a particular
    policy, scientists can predict that it will have a particular effect on
    obesity levels. In the vast majority of cases, at present, such
    statements are unwarranted. This is so for two reasons.
        First, human physiology and even more so human behavior are complex
    and insufficiently understood to permit confident conclusions about how
    even the average person will respond to some intervention, let alone to
    predict with confidence how any one individual will respond, without
    performing an experiment to actually observe the effects. That is why
    scientists do randomized controlled trials (RCTs) to test the effects
    of things. If you look at this website (http://
    www.obesityandenergetics.org/) under the category ``Contrary or Null
    Findings,'' in each weekly entry, you will see many examples of this
    unpredictability of intervention effects. That does not mean that
    scientists have no ability to predict effects, but rather that our
    ability is rather limited.
        Second, some will posit that if it is known that an intervention
    affects energy (calorie) intake or expenditure by a particular amount,
    then one can calculate the expected weight or obesity change that will
    result from such an intervention using validated mathematical models
    (for such a claim, see: http://www.ajpmonline.org/article/S0749-
    3797(13)00269-9/abstract). The problem with such reasoning is that
    these calculations assume that people take no compensatory action,
    i.e., that they do not change their food intake, physical patterns, or
    any other factors that influence weight in response to the proposed
    intervention. However, much evidence indicates that people do take such
    compensatory actions (see: https://www.ncbi.nlm.nih.gov/pmc/articles/
    PMC4516704/). As a result, interventions generally have far lesser
    impact on body weight than one might initially predict.
    II. Myths & Presumptions in Nutrition and Obesity.
        Many academics or nutrition or obesity experts may assert that a
    particular thing is known to be true about nutrition or obesity. In
    some cases, they will be correct. However, experience shows that in
    many cases, propositions asserted to be true by such experts turn out
    to be either false or unsupported presumptions. Therefore, when any
    assertions are made, the complete scientific evidence supporting those
    assertions should be requested. Two papers which discuss the commonness
    of mistaken beliefs about nutrition or obesity are these:

       Casazza, K., Fontaine, K.R., Astrup, A., Birch, L., Brown,
            A.W., Bohan Brown, M.M., Durant, N., Dutton, G., Foster, E.M.,
            Heymsfield, S.B., McIver, K., Mehta, T., Menachemi, N., Newby,
            P.K., Pate, R., Rolls, B. J., Sen, B., Smith, D. L., Thomas,
            D., & Allison, D. B. (2013). Myths, Presumptions, and Facts
            about Obesity. New England Journal of Medicine, Jan. 31;
            368(5): 446-54. doi: 10.1056/NEJMsa1208051. https://
            www.ncbi.nlm.nih.gov/pubmed/23363498.

       Allison D.B., Assaganya-Riera J., Burlingame B., Brown A.,
            Le Coutre J., Dickson S.L., Van Eden W., Garssen J.,
            Hontecillas R., Khoo C.S., Knorr D., Kussmann M., Magiestretti
            P.J., Mehta T., Meule Adrian, Rychlik M., & Vogele C. (2015).
            Goals in Nutrition Science 2015-2020. Frontiers in Nutrition,
            Sep 2015 2:26. doi: 10.3389/fnut.2015.00026. http://
            journal.frontiersin.org/article/10.3389/fnut.2015.00026/
            abstract.
    III. Separating the Moral, Social, and Legal Issues from the Scientific
            Issues
        It is important not to conflate the moral, social, and legal issues
    with the scientific issues in policy questions around nutrition and
    weight. The scientific information can inform the policy decision, but
    generally cannot determine the best policy decision, because moral,
    social, and legal factors are also involved. In some cases, moral,
    social, or legal factors may be overwhelming and may appropriately
    drive a decision largely independently of data.
        You have asked me about the wisdom of restriction on purchases of
    certain food items with SNAP benefits.
        Some persons might offer reasonable arguments for such restriction
    which rely minimally on data. Here the values of beneficence (wanting
    to help people) and responsible stewardship of taxpayer dollars
    predominate. Such persons could argue that certain foods (e.g.,
    confections, pastries, sugar-sweetened beverages) are luxuries which
    are unnecessary for life or health and without which most persons'
    health would be no worse and possibly better. Given that, it can be
    argued that: (a) It is in the best interests of SNAP participants
    (i.e., beneficence) to not consume these items; and (b) It is
    questionable for the government to spend tax-payer money on items which
    are at best unnecessary and at worst harmful. By these arguments, one
    could, with little need to rely on specific data, argue for such
    exclusions.
        Alternatively, other persons might offer reasonable arguments
    against such restriction which rely minimally on data. Here the values
    of autonomy (allowing people to make their own choices about their
    lives) and equity (not disadvantaging lower-income persons further and
    unduly hampering their access to goods others can partake of)
    predominate. Some might argue that these are important values and
    people should have a right to decide how to spend their resources on
    food and which food choices to make, however nutritionally sound or
    unsound those choices are.
        The choice between the two perspectives above is largely not one
    that hinges on data, but rather on the differential value one places on
    beneficence and responsible stewardship of taxpayer dollars vs autonomy
    and equity. These are, of course, not the only values or factors that
    can be brought to bear on these questions. See:

       Brown, A. & Allison, D.B. (2013). Unintended consequences of
            obesity-targeted health policy. Virtual Mentor. 2013 Apr. 1;
            15(4):339-46. doi: 10.1001/virtualmentor.2013.15.4.pfor2-1304.
            http://journalofethics.ama-assn.org/2013/04/pfor2-1304.html.
    IV. Standards of Evidence for Scientific Conclusions vs. Policy
            Decisions
        A frequent question is ``what is the standard of evidence for
    effectiveness of a policy needed to justify a decision to enact a
    policy?'' The answer is that there is no single standard that applies
    in all contexts and this is a matter of social and legal judgment, not
    scientific judgement. In contrast, there are standards (albeit with
    some judgement still involved) for drawing scientific conclusions about
    the effects of interventions or policies. I raise this important
    distinction because this distinction is sometimes blurred by those who
    feel strongly that it is reasonable to move forward with a decision to
    take some action. Such individuals sometimes seem to feel compelled to
    dispute a data-based conclusion that evidence is insufficient to show
    the proposed action will have its desired effects. However,
    definitiveness in a decision to act despite uncertainty about drawing a
    conclusion, poses no contradiction. These ideas are discussed more
    fully in these two papers.

       Allison, D.B. (2011). Evidence, Discourse, and Values in
            Obesity-Oriented Policy: Menu-Labeling as a Conversation
            Starter. International Journal of Obesity, Apr.; 35(4): 464-71.
            http://www.nature.com/ijo/journal/v35/n4/full/ijo201128a.html.

       Richardson, M.B. Williams, M.S., Fontaine, K.R., & Allison,
            D.B. (in press). The development of scientific evidence for
            health policies for obesity: why and how. International Journal
            of Obesity.
    V. Information on Sugar Sweetened Beverages and Weight
        You have specifically asked me about the effects of sugar-sweetened
    beverages (SSBs) on weight. Two papers I have written on this topic
    are:

       Kaiser, K.A., Shikany, J.M., Keating, K.D. & Allison, D.B.
            (2013). Will reducing sugar-sweetened beverage consumption
            reduce obesity? Evidence supporting conjecture is strong, but
            evidence when testing effect is weak. Obesity Reviews, Aug.;
            14(8): 620-33. doi: 10.1111/obr.12048. https://
            www.ncbi.nlm.nih.gov/pmc/articles/PMC3929296/.

       Allison, D.B. (2014). Liquid calories, energy compensation,
            and weight: what we know and what we still need to learn.
            Invited Commentary. British Journal of Nutrition, Feb.;
            111(3):384-6. doi: 10.1017/S0007114513003309. https://
            www.ncbi.nlm.nih.gov/pmc/articles/PMC4973863/.
    VI. Biases and Emotion
        The topics you are addressing are ones where many strong interests
    are at play. These interests include selfless interests in benefitting
    members of our country, economic interests, and personal interests.
    Consideration of this fact is important for at least two reasons:

        A. Some will try to discredit the statements of individuals who
    have some connection to commerce involving food or agriculture,\1\
    based on claims that they are biased. In considering this, persons
    interested in reason and rationality should:
    ---------------------------------------------------------------------------
        \1\ For the record, I disclose that I have received funds from
    multiple for-profit, not-for-profit, and government organizations with
    interests in nutrition and obesity, including commodity groups and
    food, beverage, and restaurant companies.

      1.  First and foremost note that in Science, three things matter: (a)
                The data; (b) The methods by which the data were collected
                which give them their probative value; and (c) The logic by
                which the data are connected to conclusions. Everything
    ---------------------------------------------------------------------------
                else is a distraction.

      2.  The claim that research produced by those with financial
                connections to food and agricultural commerce are biased
                has not been demonstrated. See:

           http://jamanetwork.com/journals/jamainternalmedicine/
                articleabstract/
                  2517951.

           https://www.theatlantic.com/health/archive/2017/01/the-
                limits-of-
                  sugarguidelines/512045/.

           http://journals.sagepub.com/doi/abs/10.1177/
                0162243912456271.

      3.  Trying to overturn arguments or discredit individuals based on
                their personal characteristics is argumentum ad hominem. It
                is logically invalid, uncivil, and unethical. See:

           http://www.nature.com/ijo/journal/v38/n5/full/
                ijo201432a.html.

           http://www.prnewswire.com/news-releases/the-obesity-
                society-encourages-
                  science-industry-collaborations-to-support-obesity-
                science-public-health-
                  252453321.html.

           http://utminers.utep.edu/omwilliamson/ENGL1311/
                fallacies.htm.

        B. Interests other than financial connections to for-profit groups
    can create biases. Therefore,the scientific bases of everyone's
    statements need to be scrutinized. See the articles below.

       Cope, M., Allison, D.B. (2010). White Hat Bias: A Threat to
            the Integrity of Scientific Reporting. Acta Paediatrica, Nov.;
            99(11): 1615-7. https://www.ncbi.nlm.nih.gov/pubmed/21039822

       Cope, M. B. & Allison, D. B. (2010). White Hat Bias:
            Examples of its Presence in Obesity Research and a Call for
            Renewed Commitment to Faithfulness in Research Reporting.
            International Journal of Obesity, 34(1): 84-8. https://
            www.ncbi.nlm.nih.gov/pubmed/19949416.
    VII. Things You Can Do to Enhance The Science
        Finally, there are things your Committee can do to enhance what
    society knows on questions about the effects of interventions. For
    questions such as ``What is the effect of some intervention on health
    or weight,'' the best way to answer that question, if feasible, is with
    randomized controlled trials (RCTs).

       When such trials exist, your Committee could request the raw
            data from all investigators who have conducted these RCTs and
            commission a statistician to analyze all the data together in
            an open and transparent manner and issue a public report to
            you.

       When such trials do not exist or are insufficient to
            generate confident conclusions, your Committee could take steps
            to have a large, statistically powerful, well-designed RCT
            commissioned and executed.

        In doing so, you would add substantially to our objective knowledge
    about outcomes.
        I hope this information is helpful to you in your deliberations.
                Sincerely,

    David B. Allison, Ph.D.
                                  attachment 1
    The Caloric Calculator: Average Caloric Impact of Childhood Obesity
            Interventions
    August 2013
    Y. Claire Wang, M.D., Sc.D., Amber Hsiao, M.P.H., C. Tracy Orleans,
    Ph.D., Steven L. Gortmaker, Ph.D.*
    ---------------------------------------------------------------------------
        * From the Department of Health Policy & Management (Wang, Hsiao),
    Mailman School of Public Health, Columbia University, New York, New
    York; the Robert Wood Johnson Foundation (Orleans), Princeton, New
    Jersey; and Department of Society, Health, and Human Development
    (Gortmaker), Harvard School of Public Health, Cambridge, Massachusetts
        Address correspondence to: Y. Claire Wang, M.D., Sc.D., Department
    of Health Policy and Management, Mailman School of Public Health,
    Columbia University, 600 W 168th St, Rm 602 New York NY 10032. E-mail:
    Ycw2102@columbia.edu.
        0749-3797/$36.00
        http://dx.doi.org/10.1016/j.amepre.2013.03.012
    ---------------------------------------------------------------------------
    This activity is available for CME credit. See page A4 for information.

              Background: The childhood obesity epidemic reflects the daily
            accumulation of an ``energy gap''--excess calories consumed
            over calories expended. Population-level interventions to
            reverse the epidemic can be assessed by the degree to which
            they increase energy expenditure and/or reduce caloric intake.
            However, no common metric exists for such comparative
            assessment.
              Purpose: To develop a common metric, the Average Caloric
            Impact (ACI), for estimating and comparing population-level
            effect sizes of a range of childhood obesity interventions.
              Methods: An iterative, collaborative process was used to
            review literature from 1996 to 2012 and select illustrative
            interventions showing effects on youth diet and/or activity
            levels, energy balance, and weight. The ACIs of physical
            activity interventions were estimated based on program reach,
            frequency, duration, and intensity and mean body weight of the
            targeted age and gender group from the 2009-2010 National
            Health and Nutrition Examination Survey. ACIs of dietary
            interventions were based on reach and changes in foods and/or
            beverages consumed.
              Results: Fifteen interventions informed by 29 studies were
            included, ranging from individual behavioral to population-
            level policies. A web tool, the Caloric Calculator, was
            developed to allow researchers and policymakers to estimate the
            ACIs of interventions on target populations with reference to
            energy gap reductions required to reach the nation's Healthy
            People childhood obesity goals.
              Conclusions: The Caloric Calculator and ACIs provide
            researchers and policymakers with a common metric for
            estimating the potential effect sizes of various interventions
            for reducing childhood obesity, providing a platform for
            evidence-based dialogues on new program or policy approaches as
            data emerge.
              (Am. J. Prev. Med. 2013; 45(2): e3-e13)
            2013 American Journal of Preventive
            Medicine.
    Background
        The obesity epidemic costs the U.S. $147-$210 billion in annual
    healthcare costs.\1\ Although the trends have shown some signs of
    leveling, more than \1/3\ of U.S. adults and nearly 17% of children and
    adolescents are obese.\2\ As a result, it was predicted that one in
    three children born in 2000 would be diagnosed with type 2 diabetes in
    his or her lifetime.\3\
        The rise in childhood obesity since the early 1970s reflects the
    accumulation of the small daily ``energy gap''--the excess of calories
    consumed over calories expended.4-5 Previous analyses
    estimated that an average surplus of 110-165 kcal/day in energy
    accounted for the excess weight gain seen in U.S. children and youth
    over a 10 year period.\4\ Thus, effective interventions would have to
    bring about a net reduction in this energy gap to reverse the epidemic.
    A recent study estimated that among U.S. children aged 2-19 years, a
    net reduction of 64 kcal/day per capita in energy surplus would be
    needed to achieve the Healthy People 2020 childhood obesity goals, with
    a range from 22 kcal/day for those aged 2-5 years, to 77 kcal/day for
    those aged 6-11 years, 98 kcal/day for those aged 12-19 years, and much
    higher levels among those who are already overweight or obese.\5\
        The evidence base for population-level interventions to reduce
    childhood obesity levels has grown rapidly, ranging from strategies to
    change individual behaviors to those that seek to alter policies,
    environments, and social norms. In most cases, however, these policies
    or programs are evaluated independently. No common metric exists to
    allow comparative assessments of effects across interventions with
    varied configurations for a target population.6-7
        In the current paper, the Average Caloric Impact (ACI) is proposed
    as a metric to gauge the population-level average effect on daily
    calories expended/consumed. This metric was applied to an illustrative
    set of interventions evaluated in the literature. Greater emphasis was
    placed on population-, school-, or state-level programs than on medical
    treatments of overweight/obese youth. The results are presented using a
    user-friendly web tool, the Caloric Calculator.
    Methods
    Selection of Interventions
        Using recently published reviews, a set of obesity prevention
    interventions targeting U.S. children and adolescents aged 2-5 years
    (preschool); 6-11 years (primary school); 12-14 years (middle school);
    and/or 15-18 years (high school) was selected. Target populations were
    defined by grade level based on the divisions within the typical K-12
    system. Mean height and weight for each age group (by gender) were
    based on the nationally representative 2009-2010 National Health and
    Nutrition Examination Survey (NHANES).
        From an initial list of 67 studies published between 2000 and 2009,
    as reviewed by Brennan, et al.,\8\ only seven physical activity
    interventions were included that lasted >6 months and reported outcome
    measures that were sufficient to have an influence on calories. For
    example, several studies of school lunch programs or wellness policies
    were excluded because they reported consumption of only specific
    nutrients (e.g., % fat), and/or servings of fruits and vegetables,
    rather than changes in total calories consumed or body weight.
    Similarly, many evaluations of physical activity programs did not use
    objective measures of activity levels (e.g., accelerometers) and thus
    were unable to inform changes in energy expenditure.
        An iterative and collaborative process was used to identify an
    additional 22 studies published between 1996 and 2012; of these, 12
    were empirical studies that met the research design and measurement
    standards used in the Brennan, et al., review. The remaining studies
    provided inputs for the model-based estimates. For dietary
    interventions selected, the studies assessed changes in daily caloric
    intake before and after the intervention (e.g., California schools'
    competitive foods standards).\9\ For studies reporting changes in
    consumption of particular foods and/or beverages, published estimates
    on the average caloric contribution of these foods and beverages in the
    indicated setting (e.g., removing sugar-sweetened beverages from
    schools) \10\ were used. Strategies were categorized by implementation
    level (individual, school, state/national). Because empirical data were
    lacking for some strategies (e.g., promoting walking to schools),
    analytic models were used to incorporate available evidence to estimate
    the likely caloric effect of these strategies, if broadly implemented.
    Caloric Impact Calculations
        Physical activity interventions. The physical activity
    interventions were placed into one of the following categories: (1)
    varied school physical education (PE) classes; (2) school PE
    interventions designed to increase moderate-to-vigorous physical
    activity (MVPA) levels to achieve more active PE; (3) afterschool
    physical activity programs; and (4) active commuting (e.g., walking) to
    school. When multiple high-quality studies were available within a
    category, the study with the largest effect size was typically used to
    represent the best-possible outcome and population-level
    implementation.
        The effect of the intervention on daily caloric impact was
    estimated based on the calculated basal metabolic rate (BMR, which is a
    function of age, gender, and body weight), as well as the frequency
    (e.g., twice a week); duration (e.g., 30 minutes); and the intensity of
    the physical activity (e.g., moderate/vigorous). BMR for an average-
    weight child is calculated based on published equations.\11\
    Intervention intensity was estimated in METs, representing the amount
    of energy expended from carrying out a specific activity relative to
    sitting quietly (MET value of 1.0) for a defined period of time. For
    instance, walking at a pace of 3 miles per hour represents an average
    intensity of 3.3 METs, which burns 3.3 times as many calories than
    sitting quietly for the same individual.\12\
        Pre-intervention activity levels were based on published baseline
    measures of study participants and/or national averages. When MET
    values were not reported, activity-specific MET values from the
    Ainsworth Compendium for adults \12\ were combined with calculated
    youth-specific BMR estimates, following recommendations by Ridley, et
    al.\13\ Table 1 provides examples of how various inputs affect the
    number of calories expended by different physical activity
    interventions.
        Dietary interventions. Dietary interventions were similarly
    reviewed and categorized. For example, a number of interventions only
    measured changes in fruit and vegetable intake, and were excluded
    because net impact on caloric intake could not be estimated. One study
    that empirically measured the caloric impact of competitive food
    policies in high schools was included.\9\ The other five dietary
    interventions (e.g., reducing intake of calories from chips) were
    estimated based on the authors' calculations.
        For policy interventions with limited direct, empirical data (e.g.,
    removing sugar-sweetened beverages [SSBs] from schools, and a portion-
    size cap on sugary drinks sold in New York City),\14\ dietary data from
    NHANES were used to inform the baseline consumption level among those
    who would be hypothetically affected by the policy. For example, NHANES
    1999-2004 showed that SSBs contributed an average of 224 kcal/day to
    the overall caloric intake of U.S. children and adolescents, and 7-15%
    of SSBs were consumed in schools.\10\ The estimated caloric impact of
    replacing all SSB intake from schools (in session 180 days a year) with
    water was averaged across the whole calendar year.
        Combined physical activity/dietary interventions. Sonneville and
    Gortmaker \15\ have estimated that every 1 hour increase in TV watching
    is associated with a 105.5-kcal increase in net total energy intake, or
    a 92-kcal increase in energy intake for video- or computer-game
    playing. Their findings are consistent with a previously published
    randomized trial, which found that reducing TV watching among children
    led to lower caloric intake.16 It was hypothesized that children who
    spend more time watching TV or playing video games may be more exposed
    and/or influenced by food advertising through characters present in
    commercials and interactive games that can shape food preferences and
    intake.17-19

             Table 1. Daily Caloric Effects of Physical Activity for Select Groups Using Schofield Equations
    ----------------------------------------------------------------------------------------------------------------
                                                                                          Inputs
                                                                    ------------------------------------------------
                      Average   Schofield equation                                                         Caloric
      Population      weight         (BMR=) a         Intervention                Duration     School-      effect
                       (kg)                                            D METs    (minutes/    based? b    (kcal/day)
                                                                                    day)                      c
    ----------------------------------------------------------------------------------------------------------------
    Boys, age in
     years:
      2-5                   18  22.706 kg + 504.3   Add 30 minutes/        2.3           30         No            44
                                                     day of walking
      6-11                  34  22.706 kg + 504.3   Add 30 minutes/          7           30         No           186
                                                     day of jogging
      12-14                 59  17.686 kg + 658.2   Add 15 minutes/        2.6           15        Yes            23
                                                     day of PE
      15-18                 77  17.686 kg + 658.2   Implement SPARK        3.5           30        Yes            73
    Girls, age in
     years:
      2-5                   17  20.315 kg + 485.9   Add afterschool        3.5         10.5        Yes            11
                                                     program
      6-11                  35  13.384 kg + 485.9   Make PE more      Varies d           60        Yes             9
                                                     active
      12-14                 57  13.384 kg + 692.6   Add 30 minutes/        2.6           30        Yes            39
                                                     day of PE
      15-18                 65  13.384 kg + 692.6   Add 10 minutes/          7           10         No            76
                                                     day of jogging
    ----------------------------------------------------------------------------------------------------------------
    a The Schofield equations are grouped by gender and age groups (broken down as 0-3 years, 3-10 years, and 10-18
      years). Because of this, some age groups have the same equations.
    b If the intervention is applied over a full school year, it multiples the caloric impact by 180 days. This is
      then averaged over 365 days to account for no change in activity on holidays, weekends, and summer vacation.
    c Daily caloric impact = (BMR  D METs  duration in minutes)  1,440 minutes/day.
    d The MET value for ``Make PE more active'' is a composite of MET values from five different activities, based
      on the Ainsworth Compendium: \12\ lying down, sitting, standing, walking, and running. The change in METs from
      the intervention depends on user input of baseline versus target % MVPA. BMR, basal metabolism rate; MVPA,
      moderate-to-vigorous physical activity; PE, physical education; SPARK, Sports, Play, and Active Recreation for
      Kids.

    Online ``Caloric Calculator'' Tool
        Accompanying the current paper is a web-based tool
    (www.caloriccalculator.org) designed to help users visualize and query
    the estimated caloric effects of defined interventions within a defined
    target population. Programmed in PHP script for HTML, the tool allows
    users to choose one or more interventions and customize their
    configurations. For example, the user can select as the target ``Boys''
    and ``Middle School (12-14)'' from the dropdown menu, and ``implement''
    an intervention to increase PE intensity (e.g., moderate/vigorous) for
    a duration of time by specifying the baseline MVPA (default is 37%) and
    desired post-intervention level (e.g., 50% as recommended).\20\
        The resulting caloric effect is benchmarked against two ``energy
    gap'' goals: to return the prevalence of obesity to (1) the early 1970s
    and/or (2) the Year-2000 levels. The former more ambitious goal
    corresponds to the original goals set in Healthy People 2010; \21\ the
    latter provides a rough estimate of the current, more modest Healthy
    People 2020 goals.\22\ The methodology underlying the calculations of
    these targets for various population subgroups has been described
    previously.\5\ All interventions listed assume that no compensatory
    changes affecting daily energy balance occur, beyond any effects
    observed in the empirical studies cited. For example, the ACI of
    increasing MVPA from 37% to 50% during PE classes assumes that students
    will not consume additional calories to compensate for additional
    physical activity, or that removing a food item from one's diet does
    not result in increased consumption of other foods or beverages.
    Results
        The estimated caloric effect of the 15 interventions in the tool,
    by gender and age group, are summarized in Tables 2 and 3. For
    instance, for high school boys and girls, adding 15 minutes of PE time
    per day for a full school year was estimated to increase mean energy
    expenditure by 25 kcal/day; replacing SSBs with water in schools for
    the same group would reduce mean energy intake by 15 kcal/day. For this
    group, however, an average per capita reduction of 82 kcal/day in
    energy surplus would be needed to meet the Healthy People 2020 obesity
    prevalence goal of reducing obesity rates from 20.8% to 14.8%.
    Returning to the early 1970s level of obesity prevalence--the target
    set by the more ambitious Healthy People 2010 goal--would require an
    average per capita reduction in energy gap of 217 kcal/day. These
    estimates suggest that although any single intervention may not be
    sufficient to achieve the Healthy People goals, substantial progress
    could be made through a combination of feasible, sustained policy and
    environmental interventions.

     Table 2. Caloric Impact of Physical Activity Interventions for Average
                              Student, By Age Group
    ------------------------------------------------------------------------
                                Inputs for caloric calculations
                              ----------------------------------
                   Population                            Avg.
     Intervention     (age                             caloric   Assumptions
                     group,      Target   Avg.weight    impact
                     years)      METs a     (lbs) b     (kcal/
                                                         day)
    ------------------------------------------------------------------------
                                Modeled estimates
    ------------------------------------------------------------------------
    Add walking    Both (2-5)        3.3          39         21  Same
     at a 3-mph    Both (6-          3.3          76         30   baseline
     pace, 15       11)              3.3         127         38   (1.0,
     minutes/day   Both (12-                                      sitting
                    14)                                           quietly)
                                                                  and target
                                                                  METs for
                                                                  all ages,
                                                                  based on
                                                                  Ainsworth,
                                                                  et
                                                                  al.,\12\
                                                                  and
                                                                  Ridley, et
                                                                  al.\13\
                   Both (15-         3.3         157         43
                    18)
    Add jogging    Both (2-5)        8.0          39         64  Same
     at a 5-mph    Both (6-          8.0          76         90   baseline
     pace, 15       11)              8.0         127        115   (1.0,
     minutes/day   Both (12-         8.0         157        130   sitting
                    14)                                           quietly)
                   Both (15-                                      and target
                    18)                                           METs for
                                                                  all ages,
                                                                  based on
                                                                  Ainsworth,
                                                                  et
                                                                  al.,\12\
                                                                  and
                                                                  Ridley, et
                                                                  al.\13\
    Walking to     Both (2-5)        3.3          39          9  Interventio
     and from      Both (6-          3.3          76         12   n model
     school         11)                                           estimates
     (roundtrip)                                                  based on
                                                                  METs from
                                                                  Ainsworth,
                                                                  et
                                                                  al.,\12\
                                                                  and
                                                                  Ridley, et
                                                                  al.,\13\
                   Both (12-         3.3         127         15    and
                    14)              3.3         157         17   published
                   Both (15-                                      data on
                    18)                                           average
                                                                  distances
                                                                  from
                                                                  schools
                                                                  and
                                                                  students
                                                                  living
                                                                  within 1
                                                                  mile of
                                                                  school.23
                                                                  24
                                                                 Caloric
                                                                  impact
                                                                  estimate
                                                                  uses METs
                                                                  of 1.0 as
                                                                  baseline
                                                                  (i.e.,
                                                                  sitting in
                                                                  car).
                                                                 Implemented
                                                                  for a full
                                                                  academic
                                                                  year.b
    ------------------------------------------------------------------------
                               Empirical estimates
    ------------------------------------------------------------------------
    Add school PE  Both (2-5)        3.4          39         11  McKenzie,
     time, 15      Both (6-          3.4          76         15   et
     minutes/day    11)                                           al.,\25\
                                                                  estimate
                                                                  3.4 METs
                                                                  for
                                                                  elementary
                                                                  school PE.
                                                                  Same value
                                                                  used for
                                                                  pre-
                   Both (12-         3.6         127         21    school.
                    14)              3.7         157         25   Nader, et
                   Both (15-                                      al.,\26\
                    18)                                           estimate
                                                                  3.6 METs
                                                                  for middle
                                                                  school PE.
                                                                  Smith, et
                                                                  al.,\27\
                                                                  estimate
                                                                  3.7 METs
                                                                  for high
                                                                  school PE.
                                                                  Implemente
                                                                  d for a
                                                                  full
                                                                  academic
                                                                  year.b
    Make current   Both (2-5)        4.5          39          3  MET values
     PE more       Both (6-          4.5          76          4   used at
     active, 30     11)              4.5         127          6   baseline
     minutes/day   Both (12-                                      and target
                    14)                                           is a
                                                                  composite
                                                                  of
                                                                  estimated
                                                                  MET
                                                                  values,
                                                                  based on
                                                                  Wu, et
                                                                  al.,\7\
                                                                  and
                                                                  Ainsworth,
                                                                  et
                                                                  al.,\12\
                                                                  (4.5 METs)
                   Both (15-         4.5         157          6    for MVPA,
                    18)                                           1.8 METs
                                                                  for non-
                                                                  MVPA).
                                                                 Because of
                                                                  high
                                                                  variance
                                                                  in METs,
                                                                  baseline
                                                                  activity
                                                                  levels,
                                                                  and
                                                                  population
                                                                  characteri
                                                                  stics
                                                                  between
                                                                  CATCH,20,
                                                                  26, 28	29
                                                                  MSPAN,\25\
                                                                  and TAAG
                                                                  30	35
                                                                  interventi
                                                                  ons, same
                                                                  averaged
                                                                  MVPA% used
                                                                  for all
                                                                  age
                                                                  groups.
                                                                 Changing
                                                                  the
                                                                  intensity
                                                                  of current
                                                                  PE time
                                                                  (not
                                                                  adding
                                                                  additional
                                                                  PE time).
                                                                 Base case
                                                                  increases
                                                                  MVPA from
                                                                  37% to
                                                                  50%, based
                                                                  on DHHS
                                                                  national
                                                                  recommenda
                                                                  tion.\20\
                                                                 Implemented
                                                                  for a full
                                                                  academic
                                                                  year.b
    Implement      Both (2-5)        7.2          39         34  7.2 METs
     SPARK using   Both (6-          7.2          76         48   for PE
     only PE        11)              7.2         127         58   specialist
     specialists   Both (12-         7.2         157         64   s for
     to teach PE,   14)                                           SPARK
     30 minutes/   Both (15-                                      interventi
     day            18)                                           on from
                                                                  McKenzie,
                                                                  et
                                                                  al.,\36\
                                                                  and
                                                                  Sallis, et
                                                                  al.,\37\
                                                                  used in
                                                                  calculatio
                                                                  n to
                                                                  demonstrat
                                                                  e maximum
                                                                  potential
                                                                  of
                                                                  interventi
                                                                  on
                                                                  (compared
                                                                  to 5.8
                                                                  METs for
                                                                  trained
                                                                  classroom
                                                                  teachers).
                                                                 Adding PE
                                                                  time to
                                                                  existing
                                                                  PE time.
                                                                 Baseline
                                                                  METs
                                                                  assumed to
                                                                  be 3.4 for
                                                                  preschool
                                                                  and
                                                                  elementary
                                                                  ,\25\ 3.6
                                                                  for
                                                                  middle,\26
                                                                  \ and 3.7
                                                                  for high
                                                                  school.\27
                                                                  \
    Add            Both (2-5)        4.5          39         11  Gortmaker,
     afterschool   Both (6-          4.5          76         16   et
     physical       11)              4.5         127         20   al.,\38\
     activity      Both (12-                                      estimate
     program        14)                                           %4.0 METs
                                                                  in
                                                                  interventi
                                                                  on. 4.5
                                                                  METs is
                                                                  used here
                                                                  as a
                                                                  conservati
                                                                  ve
                                                                  composite
                                                                  target
                                                                  based on
                                                                  Wu, et
                                                                  al.\7\
                   Both (15-         4.5         157         22  Same
                    18)                                           baseline
                                                                  (1.0,
                                                                  sitting
                                                                  quietly)
                                                                  and target
                                                                  METs for
                                                                  all ages,
                                                                  based on
                                                                  Ainsworth,
                                                                  et
                                                                  al.,\12\
                                                                  and
                                                                  Ridley, et
                                                                  al.\13\
                                                                 Implemented
                                                                  for a full
                                                                  academic
                                                                  year.b
    ------------------------------------------------------------------------
    a METs expresses how much energy is needed for physical activities.
      Caloric impacts expressed in this table are calculated assuming the
      physical activity is above a baseline of 1.0 METs (except where noted,
      as with implementing SPARK), which is the baseline resting metabolic
      rate when sitting quietly.
    b Intervention is applied over a full school year (on average, 180
      days). The total caloric impact is averaged over 365 days to account
      for no change in activity on holidays, weekends, and summer vacation.
      CATCH, The Child and Adolescent Trial for Cardiovascular Health;
      MSPAN, The Middle-School Physical Activity and Nutrition intervention;
      MVPA, moderate-to-vigorous physical activity; PE, physical education;
      SPARK, Sports, Play, and Active Recreation for Kids; TAAG, The Trial
      of Activity for Adolescent Girls.

                 Table 3. Caloric Impact of Dietary and Other Interventions for Average Student By Group
    ----------------------------------------------------------------------------------------------------------------
                                                         Inputs for caloric calculations
                                                   ------------------------------------------
                                Population (age                                     Avg.
          Intervention           group, years)                      Affected       caloric          Assumptions
                                                      Amount a      pop., % b   impact (kcal/
                                                                                    day)
    ----------------------------------------------------------------------------------------------------------------
                                                    Modeled estimates
    ----------------------------------------------------------------------------------------------------------------
    Reduce unhealthy food    All                     1-oz bag of           100           154  Intervention models
     intake                  All                       chips per                               estimates based on
                                                             day           100            55   published caloric
                                                    1 cookie per                               values of average bag
                                                             day                               of regular potato
                                                                                               chips and single Oreo
                                                                                               cookie.
    Reduce SSB intake        All                       12-oz can           100           136  Intervention models
                             All                         per day           100           240   estimates based on
                                                    20-oz bottle                               published caloric
                                                         per day                               values of average can
                                                                                               or bottle of regular
                                                                                               caffeinated cola.
    Replace SSBs with water  Both (2-5)                      124           5.5             3  Affected population
     in schools              Both (6-11)                     184           6.5             6   and amounts based on
                             Both (12-14)                    301          10.3            15   published analysis
                             Both (15-18)                    301          10.3            15   from Wang, et al.\10\
                                                                                               Implemented for a
                                                                                               full academic year.c
    Switch from 1 cup of     Both (2-5)                0.64 cups          48.4             7  Averaged grams/cup and
     sugary cereals to       Boys (2-5)                0.64 cups          47.3             7   standardized serving
     cereals scored highest  Girls (2-5)               0.64 cups          49.6             7   sizes of top ten \39\
     in nutritional quality  Both (6-11)               0.93 cups          39.5             6   and bottom ten \40\
                             Boys (6-11)               0.93 cups          40.2             6   cereals by nutrition
                             Girls (6-11)              0.94 cups          38.8             6   score, as determined
                             Both (12-14)              1.16 cups          34.5             5   by CerealFACTS.
                             Boys (12-14)              1.32 cups          35.5             5   org.\41\
                             Girls (12-14)              1.0 cups          33.5             5  Affected population
                             Both (15-18)              1.15 cups          26.6             4   and average grams/
                             Boys (15-18)              1.25 cups          26.1             4   serving consumed
                             Girls (15-18)             1.06 cups          27.0             4   based on analysis of
                                                                                               NHANES 2007-2010 data
                                                                                               on 24-hour dietary
                                                                                               recall.
                                                                                              Proportion of cups
                                                                                               consumed in Amount
                                                                                               column based on
                                                                                               standardized 39.2
                                                                                               grams/cup (as
                                                                                               described above), and
                                                                                               grams/serving from
                                                                                               NHANES.
    Pass NYC's proposed      Both (2-5)                     24.2           0.6             0  Amount is average
     sugary drink size       Boys (2-5)                     21.1           0.9             0   kilocalorie reduction
     limit                   Girls (2-5)                    32.3           0.4             0   per day if limited
                             Both (6-11)                    67.9           5.1             3   consumption to 16 oz/
                             Boys (6-11)                    70.0           6.1             4   day as in Elbel, et
                             Girls (6-11)                   64.9           4.2             3   al.,\42\ and Wang, et
                             Both (12-14)                   93.6           9.4             9   al.\14\
                             Boys (12-14)                  109.3          10.1            11  Affected population
                             Girls (12-14)                  77.7           8.7             7   and average
                             Both (15-18)                  111.8          13.3            15   kilocalorie reduction
                             Boys (15-18)                  120.3          15.3            18   based on analysis of
                             Girls (15-18)                 100.1          11.2            11   NHANES 2007-2010 data
                                                                                               on 24-hour dietary
                                                                                               recall.
                                                                                              Those consuming >16 oz
                                                                                               limit consumption to
                                                                                               maximum of 16 oz/day
                                                                                              No ``upsizing'' occurs
                                                                                               (i.e., individuals
                                                                                               purchase more than
                                                                                               one 16-oz beverage to
                                                                                               compensate for size
                                                                                               limit).
                                                                                              SSB definition
                                                                                               includes sodas,
                                                                                               sports drinks, fruit
                                                                                               drinks and punches,
                                                                                               low-calorie drinks,
                                                                                               sweetened tea, and
                                                                                               other sweetened
                                                                                               beverages consumed in
                                                                                               food service
                                                                                               establishments.
                                                                                              Implemented
                                                                                               nationally.
    ----------------------------------------------------------------------------------------------------------------
                                                   Empirical estimates
    ----------------------------------------------------------------------------------------------------------------
    Pass California's        Both (15-18)                  157.8           100            78  Taber, et al.,\9\
     competitive food                                                                          estimate 157.9 kcal
     nutrition standards in                                                                    per weekday fewer
     high schools                                                                              calories consumed in
     nationally                                                                                California high
                                                                                               schools, compared to
                                                                                               14 other states with
                                                                                               weaker competitive
                                                                                               food laws states.
                                                                                              The intervention only
                                                                                               applies to high
                                                                                               school students.
                                                                                              Implemented for a full
                                                                                               academic year.c
    Reduce TV viewing, 60    All                             106           100           106  Sonneville and
     minutes/day                                                                               Gortmaker \38\
                                                                                               estimate TV watching
                                                                                               and video/computer
                                                                                               game playing
                                                                                               associated with 105.5-
                                                                                               kcal/hour and 91.8-
                                                                                               kcal/hour increase in
                                                                                               total energy intake
                                                                                               in boys aged 13-15
                                                                                               years and girls aged
                                                                                               12-14 years. Epstein,
                                                                                               et al.,\16\ and
                                                                                               Miller, et al.,\18\
                                                                                               report similar
                                                                                               changes in energy
                                                                                               intake.
    Reduce video- or         All                              92           100            92  Same calorie change
     computer-game playing                                                                     for other age groups
     time, 60 minutes/day
    ----------------------------------------------------------------------------------------------------------------
    a The amount designates the current pre-intervention consumption level of the item by the selected population;
      amounts are kilocalories unless otherwise specified.
    b The impact designates the percentage of the selected eligible population that is affected by the intervention.
    c Intervention is applied over a full school year (on average, 180 days). The total caloric impact is averaged
      over 365 days to account for no change in activity on holidays, weekends, and summervacation.
    NHANES, National Health and Nutrition Examination Survey; NYC, New York City; SSB, sugar-sweetened beverage.

        Many of the ACI estimates built into the Caloric Calculator require
    stipulated assumptions, which are shown in detail in Tables 2 and 3, as
    well as within the web tool. For example, the calculations of energy
    expended through increased MVPA during PE involved the following
    assumptions: a national baseline of 37% MVPA during PE time,\28\ a
    target level of 50% recommended by the CDC,\20\ and 180 school days a
    year for school-based interventions. The assumed MET level for non-MVPA
    PE time was estimated as 1.8 METs, using an average of lying down,
    sitting, and standing.\12\
        The time spent on MVPA was estimated to be 4.5 METs based on the
    average of moderate physical activity (3 METs) and vigorous physical
    activity (6 METs).\7\ For example, for a typical high school adolescent
    (average weight: 157 lbs), increasing MVPA from 37% to 50% during a
    daily 30 minute PE class for a school year was estimated to produce an
    average increase in energy expenditure of 6 kcal/day--clearly
    insufficient on its own to reverse the childhood obesity epidemic.
    Further, even this small effect could potentially be diminished if
    compensation occurred for this additional caloric expenditure with
    increased food or beverage consumption.
        It is important to note that all estimates used in creating the
    Caloric Calculator were population-based. In addition, for
    interventions designed to remove a particular food or beverage from the
    diet, caloric benefits were accrued only from the population affected
    (e.g., the population affected by the NYC sugary drink portion-size cap
    was presumed to include those consuming sugary beverages of >16 ounces
    per serving, estimated to include only 12% of adolescents aged 12-19
    years).\14\
    Discussion
        Reversing the nation's current childhood obesity epidemic will
    require multiple individual, behavioral, policy, environmental, and
    normative changes--through public health and clinical strategies--to
    reverse the daily accumulation of a positive ``energy gap'' that
    brought us to this point. New evidence from New York City,\43\
    Philadelphia,\44\ California,9, 45 and Mississippi \46\
    demonstrates that broad approaches involving multifaceted policies and
    environmental strategies have the power to halt and reverse the
    trend.\47\ However, what has been missing is a metric for estimating
    the individual and combined effects of specific interventions to
    increase children's activity levels and reduce their intake of energy-
    dense, low-nutrient foods and beverages.
        This paper expands on the previously published ``energy gap''
    framework--which estimated the magnitude of energy surplus underlying
    the obesity epidemic among U.S. youth 4-5--to examine the
    effects of various interventions, alone or in combination, to favorably
    tip the energy balance. The lack of a common metric for comparing the
    effectiveness of strategies with differing behavioral targets (i.e.,
    reducing excess caloric intake and/or increasing physical activity) has
    stymied past efforts to apply analytic tools to rank existing
    strategies on their contribution to reversing the childhood obesity
    trend. The development and application of the Average Caloric Impact
    (ACI) metric and the Caloric Calculator tool offer an opportunity to
    fill this gap.
        Although the Caloric Calculator begins to address these issues,
    there are nuances in the obesity reduction equation that will require
    further research and discussion. The evidence used to estimate ACIs is
    still in many ways limited and dependent on the rigor of existing
    intervention studies and on the availability and reliability of
    intervention outcome measures (e.g., the use of objectively measured,
    versus self-reported, outcomes or ecologic associations that can be
    examined across studies). In addition, many studies focus narrowly on
    specific populations, such as middle school girls30 or a specific age
    range.29, 36, 37
        Most challenging at this stage in childhood obesity prevention
    research is the lack of high-quality studies with a sufficiently long
    follow-up. A 2011 Cochrane review of obesity prevention efforts found
    that only 14 of the 55 included studies had interventions lasting more
    than 12 months, most of which focused only on children aged 6-12 years.
    There is virtually no evidence from studies aimed at younger children
    to determine whether intervention benefits can be sustained into later
    adolescence or adulthood.\6\ Therefore, it would be inaccurate to make
    predictions of weight change from fixed caloric changes using these
    estimates, particularly given the multitude of factors that drive
    weight change over time \48\ and the large changes seen from childhood
    to adolescence.\49\
        Study populations also have varied widely with respect to racial/
    ethnic composition, SES, and prevalence of obesity at baseline,
    limiting the generalizability and comparability of intervention
    effects. Thus, the tool represents the authors' best effort to assess
    the average impact if these programs were broadly implemented. Local
    contexts and subpopulation characteristics are likely to modify the
    actual outcomes. The estimates will continue to be refined and updated
    as new data emerge from periodic scans of newly published data and
    feedback from collaborators in the field of childhood obesity
    prevention. Going forward, the Calculator will be further developed to
    address specific subsets of the population or allow more user inputs to
    facilitate broader dissemination and policy discussions. For example, a
    principal of a disproportionately low-income school could use the tool
    based on the school's demographics, or parents could use the tool by
    entering their child's age, gender, and body weight.
        Despite these limitations, there is value in the Caloric
    Calculator's ability to translate evidence into practice by generating
    caloric impact estimates and projecting the potential cumulative
    effects of multicomponent interventions addressing one or both sides of
    the energy balance equation. The ACI is a summary measure of several
    dimensions of the program or policy evaluated: reach, effectiveness/
    efficacy, adoption, implementation, and maintenance.\50\ These
    dimensions also convey why the net caloric impact of the same program
    will vary from population to population when implemented in the real
    world. As such, the tool is expected to offer a starting point to
    support policymakers and practitioners in using existing evidence to
    drive decision making in a more straightforward manner.
        The development of a common metric can lay the groundwork for more
    evidence-based resource allocation decisions, both in program
    implementation and in further evidence gathering. Future expansion of
    this framework may include finer granularity in the population
    targeted, such as overweight status, race/ethnicity, and urban/rural
    locations as well as concerns for equity, cost effectiveness, and other
    long-term outcomes.\47\ Further, the current review underscored the
    need to encourage the evaluations of programs and policies to use and
    report objective and comparable outcome measures, such as changes in
    activity levels (e.g., MET values); duration (e.g., minutes of MVPA
    added); net changes in calories consumed in addition to key nutrients
    or diet quality; and measured BMI whenever possible.
        Because the Caloric Calculator uses national data with the aim of
    estimating mean population-level effect sizes, the effect of an
    intervention is averaged across those who received and benefited from
    the program and those who did not. Therefore, an intervention that has
    a large effect but reaches only a small number of children may appear
    to have less of an impact at the population level. For example, an
    active transport program may target children who live within 1 mile of
    their school, which will reach at most 31% of children in Grades K-
    8.\23\ The daily caloric impact, when averaged across all children, is
    therefore a fraction of the net caloric impact for those who
    participate in walking to school. Although not evaluated in the current
    study, the same consideration applies to interventions specifically
    targeted at overweight adolescents (who have an average energy gap of
    700-1,000 kcal/day).\4\
        It is important to note that although the analyses presented in
    this paper focus on intervention effects on daily energy gaps and
    obesity levels in youth, there are important health and nonhealth
    benefits gained from improving physical activity and diet that are not
    captured by the ACI measure. For instance, there is growing evidence
    that physical activity has beneficial effects on mental health outcomes
    and academic performance.\51\ Similarly, an intervention to improve the
    nutritional quality of a la carte foods and beverages improves the
    overall nutritional profile of foods consumed at school despite having
    no significant effect on the total number of calories
    sold.52-53
        Some investments in childhood obesity prevention have been
    projected to be cost effective.\54\ But without knowing what types of
    interventions to invest in, efforts may fail to produce the expected
    results. There have been many controversial, yet noteworthy, recent
    policy recommendations that will be scaled up to the national level
    (e.g., menu labeling). Without experimental evidence, however, it can
    be difficult to convince the public and policymakers of the
    implications and demonstrate the possible impact of implementation. The
    Caloric Calculator provides a novel tool for appraising these policies
    and interventions based on their potential efficacy, alone or combined,
    providing an evidence-based platform to inform practice and policy.

              The authors acknowledge the contribution of Dr. Laura K.
            Brennan, Ph.D., M.P.H., President and CEO of Transtria LLC (St.
            Louis, MO), and her team in the evidence-review process. The
            authors thank Shawn Nowicki, M.P.H., and Andrew Wang, M.P.H.,
            as graduate student assistants in literature review and the
            early development of the tool. The authors also thank Michael
            Slaven, MA, who designed and implemented the web tool,
            www.caloriccalculator.org, as well as Kevin Hall, Ph.D., and
            Carson Chow, Ph.D. (NIH/National Institute of Diabetes and
            Digestive and Kidney Diseases), for their methodologic advice
            on the analysis.
              This work was supported by the Robert Wood Johnson Foundation
            (grant no. 68162). This work is solely the responsibility of
            the authors and does not represent the official views of the
            Robert Wood Johnson Foundation.
              No financial disclosures were reported by the authors of this
            paper.

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                                  attachment 2
    Predicting Adult Weight Change in the Real World: A Systematic Review
            and Meta-Analysis Accounting for Compensatory Changes in Energy
            Intake or Expenditure *
    ---------------------------------------------------------------------------
        * Received 6 May 2014; revised 19 August 2014; accepted 8 September
    2014; accepted article preview online 17 October 2014; advance online
    publication, 23 December 2014.
    ---------------------------------------------------------------------------
    Review
    E.J. Dhurandhar,[1-3, 7] K.A. Kaiser,[1, 3-4, 7]
    J.A. Dawson,[3] A.S. Alcorn,[3] K.D. Keating
    [5-6] and D.B. Allison [1, 3-4
    ---------------------------------------------------------------------------
        \[1]\ Nutrition Obesity Research Center, University of Alabama at
    Birmingham, Birmingham, AL, USA; [2] Department of Health
    Behavior, University of Alabama at Birmingham, Birmingham, AL, USA;
    [3] Office of Energetics, University of Alabama at
    Birmingham, Birmingham, AL, USA; [4] School of Public
    Health, Dean's Office, University of Alabama at Birmingham, Birmingham,
    AL, USA; [5] Department of Biostatistics, School of Public
    Health, University of Alabama at Birmingham, Birmingham, AL, USA and
    [6] Department of Statistics, Kansas State University,
    Manhattan, KS, USA. Correspondence: Dr. Professor D.B. Allison, School
    of Public Health, Dean's Office, University of Alabama at Birmingham,
    1665 University Boulevard, RPHB 140J, Birmingham, AL 35294, USA.
        E-mail: dallison@uab.edu.
        [7] These authors contributed equally to this work.

              Background: Public health and clinical interventions for
            obesity in free-living adults may be diminished by individual
            compensation for the intervention. Approaches to predict weight
            outcomes do not account for all mechanisms of compensation, so
            they are not well suited to predict outcomes in free-living
            adults. Our objective was to quantify the range of compensation
            in energy intake or expenditure observed in human randomized
            controlled trials (RCTs).
              Methods: We searched multiple databases (PubMed, CINAHL,
            SCOPUS, Cochrane, ProQuest, PsycInfo) up to 1 August 2012 for
            RCTs evaluating the effect of dietary and/or physical activity
            interventions on body weight/composition. Inclusion criteria:
            subjects per treatment arm %5; %1 week intervention; a reported
            outcome of body weight/body composition; the intervention was
            either a prescribed amount of over- or underfeeding and/or
            supervised or monitored physical activity was prescribed; %80%
            compliance; and an objective method was used to verify
            compliance with the intervention (for example, observation and
            electronic monitoring). Data were independently extracted and
            analyzed by multiple reviewers with consensus reached by
            discussion. We compared observed weight change with predicted
            weight change using two models that predict weight change
            accounting only for metabolic compensation.
              Findings: Twenty-eight studies met inclusion criteria.
            Overfeeding studies indicate 96% less weight gain than expected
            if no compensation occurred. Dietary restriction and exercise
            studies may result in up to 12-44% and 55-64% less weight loss
            than expected, respectively, under an assumption of no
            behavioral compensation.
              Interpretation: Compensation is substantial even in high-
            compliance conditions, resulting in far less weight change than
            would be expected. The simple algorithm we report allows for
            more realistic predictions of intervention effects in free-
            living populations by accounting for the significant
            compensation that occurs.
              International Journal of Obesity (2015) 39, 1181-1187;
            doi:10.1038/ijo.2014.184.
    Introduction
        Obesity is a serious and prevalent public health concern.\1\ New
    public health and clinical interventions to reduce obesity are
    frequently advocated or implemented based on hypothetical estimates of
    an outcome that may have little empirical support (for example, the
    3,500 kcal rule). For example, imagine an initiative from a large
    company that replaces its 250 kcal candy bars in its vending machines
    with 50 kcal protein bars to reduce energy intake (EI) from snacking
    among its employees. This initiative can be expected to produce (in
    those who consume at least 250 kcal per day from such snacks), on
    average, 5.7 kg of weight loss after 1 year (for example, for a 35 year
    old man who is 183 cm tall and weighs 100 kg at baseline, body mass
    index = 30). This estimate is based on one of the mathematically
    validated prediction models \2\ sometimes used to justify such
    interventions.\3\ But is this estimate realistic?
        On the basis of the evidence, this estimate is likely optimistic
    because current models for predicting weight change are not well suited
    for use in free-living subjects. A common rule of thumb used for
    decades to predict weight change outcomes is that losing or gaining 1
    pound of fat requires a deficit of 3,500 kcals of energy.\4\ This rule
    does not consider that human energy balance is a dynamic and adaptable
    system or that lean and fat mass is lost during negative energy
    balance, and this leads to an underestimation of the change in EI or
    energy expenditure (EE) needed to produce weight change.5-8
    Recently, more sophisticated models have been developed to predict
    weight changes, which consider the metabolic adaptations that occur
    during weight change.9-12 To accurately predict weight
    change in free-living individuals, however, both metabolic and
    behavioral compensatory mechanisms must be accounted for.
        Specifically, we define the modes of possible compensation as
    follows:
    Metabolic Compensation
        It is a compensation for an energy balance intervention through
    physiological changes in metabolism. For example, current mathematical
    models account for changes in resting metabolic rate, fluid balance,
    the thermic effect of food and spontaneous physical activity resulting
    from an energy balance intervention.11-13
    Behavioral Compensation
        It is a compensation for an energy balance intervention through
    behavior changes. For example, when a dietary or physical activity
    intervention attempts to create negative energy balance, an individual
    may respond by reducing voluntary EE and/or increasing EI if these
    avenues are not strictly controlled. Similarly, during an energy
    balance intervention of added energy, voluntary EE may increase and/or
    EI may decrease from other sources.
        Others have shown that behavioral compensation occurs for physical
    activity interventions.\14\ Behavioral compensation may also occur for
    interventions that reduce caloric intake or add calorie-containing
    foods to the diet.15-16 Current prediction models are
    intended for use where interventions are implemented with high fidelity
    (that is, intended intervention exposure was achieved) in isolation,
    and when metabolic compensation is the only route of compensation for
    the intervention possible. During interventions in free-living
    subjects, however, compensation can occur through metabolic
    compensation and through behavioral compensation. Behavioral
    compensation may diminish the effects of an intervention, making it
    important to quantify and account for when predicting outcomes in free-
    living populations. It is imperative that more realistic models be used
    for predicting outcomes for the reasons stated recently:

              ``. . . to establish a less controversial legacy for this
            important field, we should avoid past traps and be explicit
            about reasonable expectations. Implausible results that are
            `too good to be true' still threaten nutritional research on
            many fronts, including survey measurements, observational
            associations, treatment effects in randomized trials, and
            estimates of the impact on populations.'' \17\

        We therefore set out to build an empirically based model to predict
    weight change outcomes in free-living subjects, and to quantify the
    extent to which observed weight change in free-living subjects differs
    from that predicted under the assumption of no behavioral compensation.
    The approach we took was to use systematic review techniques to collect
    study data and conduct meta-regression on studies meeting a priori
    inclusion criteria. These criteria guided identification of high-
    fidelity interventions implemented in free-living adults. The subjects
    had some ability to behaviorally compensate for the intervention, yet
    the reported information about the intervention and compliance
    verification allowed for a high degree of confidence in treatment
    fidelity. For our main analysis, we compared the predictions from
    models that assume no active compensation 2, 18 with the
    observed outcomes as an estimate of the effects of behavioral
    compensation.
    Materials and Methods
    Systematic Review of the Literature and Study Selection
        Articles, abstracts and doctoral dissertations were retrieved using
    searches performed on the following electronic databases: PubMed,
    Cochrane Library, SCOPUS, PsycInfo, Cumulative Index to Nursing and
    Allied Health Literature (CINAHL) and Dissertation Abstracts. We
    searched PubMed without MeSH headings to identify publications for
    inclusion, using the following limits: dated 1 August 2012 back to
    earliest records of human studies. Detailed search methods are provided
    on the PROSPERO registry website (Registry #CRD42013002912). No ethics
    committee approval was required as the data used are published summary
    statistics.
        All studies were evaluated according to the following inclusion
    criteria: (1) the data were from adult human randomized controlled
    trials in free-living subjects, (2) the intervention was either a
    prescribed amount of over- or underfeeding given and reported (or could
    be converted) in kcal and/or supervised or monitored physical activity
    was prescribed and verified, (3) an objective verification method was
    used to verify the intervention at %80% (for example, observation,
    electronic monitoring and provision of food with returned unused
    portions), (4) the study had a total sample size of at least five
    participants at enrollment, (5) the study protocol included an
    intervention period of at least 7 days, (6) the publication was
    available in the English language and (7) the study was published and
    listed in the above databases on or before 1 August 2012.
        Our exclusion criteria are detailed in the online Supplementary
    Material. Briefly, we excluded studies on samples that were completely
    or predominantly made up of individuals younger than 18 years old or
    older than 60 years or having any health conditions that may affect
    weight. The filtering process of the initial search results is detailed
    in Figure 1 and also described in more detail in the online supplement.
    Statistical Analysis
        Quantifying the effect of behavioral compensation-comparison with
    metabolic compensation models. We entered sample demographic and
    intervention data into each of the metabolic compensation model
    calculators to most closely represent each intervention as described in
    the published papers to estimate weight changes that would occur if
    only metabolic compensation occurred. As we included data that had
    samples of both men and women where separate baseline data and results
    were not reported (only combined summaries), we entered the data for
    both genders and mathematically adjusted the outputs for the relative
    proportions of men and women. For the NIDDK simulator,\2\ we assumed a
    baseline value (when not otherwise reported) of sedentary activity
    level (1.4 metabolic equivalents). The difference between the observed
    weight change for each study and the weight change predicted by these
    models is indicative of the degree of behavioral compensation that is
    observed for the interventions in free-living adults included in our
    review and meta-analysis.
        All model data were analyzed with R routines \19\ and descriptive
    summaries were generated with Microsoft Excel version 2010. Further
    details of statistical approaches used for the predictive model
    building are on the online supplement. Risk of bias was assessed by two
    authors (EJD and KAK) independently and discrepancies were discussed
    until consensus was reached.
    Role of Funding Source
        The funding agency (International Life Science Institute--North
    America) had no role in the design, conduct, analysis, manuscript
    preparation or decision to publish the results of this study.
    Results
    Results of Publication Search
        We retrieved citations dated back to 1935, but more than \2/3\ of
    the initial publications retrieved were published after 2001. The final
    data set for building the predictive model consisted of 28 studies
    published between 1987 and 2012, including 15 exercise studies, nine
    studies with added energy, three dietary restriction studies and two
    studies that included both dietary restriction and exercise in the
    intervention (see Table 1 for a complete listing of included studies
    with selected summary data and intervention descriptions). The primary
    reasons for exclusion after full text review were studies not being
    truly randomized or not having a control group, followed by reliance
    only on self-report for EI or physical activity without any objective
    verification of compliance. Studies were all published journal
    articles, except for two dissertations.20-21 Eleven studies
    had samples that were either 100% men or 100% women. Three other
    studies reported results by gender separately if both males and females
    were included in the sample. Only six studies (21%) reported the racial
    makeup of the samples; therefore, this factor was excluded from further
    analysis. Mean ages of the samples ranged from 20.6 to 60 years. Mean
    baseline body mass index of the samples ranged from 22.6 to 35.1
    kgm^\2\.
    Figure 1

              PRISMA diagram-literature search and study selection process.

                   Table 1. Master List and Summary of Included Studies Grouped By Treatment Type and Sorted in Ascending Year of Publication
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                          Sample studied
                                         (mean age-years,      Adjusted daily       Study                        N  randomized,     Method of
      Reference(s)      Intervention       pct  female,        dose(s) (kcal:      duration     Intervention       completed,     missing data  Overall mean
                                           baseline BMI     treatment- control)    (weeks)          notes           analyzed        handling      compliance
                                             kgm^\2\)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Johnstone, et     Diet                    38, 0%, 35.1               ^167.2            4  High protein,           20, 17, 17  Completers             100
     al.\22\                                                                                   ketogenic diet
    Das, et al.\23\   Diet                 35, 76.3%, 27.6               ^285.6           26  Caloric                 46, 39, 39  Completers             100
                                                                                               restriction
    Zachwieja, et     Diet and             24, 45.8%, 24.1                 ^675            2  Caloric                 24, 24, 24  No drops                90
     al.\24\           exercise                                                                restriction and
                                                                                               daily treadmill
                                                                                               exercise
    Moreira, et       Diet and                 49, 68%, 30       ^556.0, ^753.3           11  25% caloric             36, 35, 36  ITT                     99
     al.\25\           exercise                                                                restriction
                       (separate                                                               (controlled
                       treatments)                                                             feeding) versus
                                                                                               aerobic
                                                                                               exercise
                                                                                               (individualized
                                                                                               and supervised
                                                                                               sessions 3 per
                                                                                               week)
    Leon, et al.\26\  Exercise                32.6, 0%, 26               ^245.6           12  Walking and             22, 16, 16  Completers              86
                                                                                               stair climbing
    Van Etten, et     Exercise              33.7, 0%, 23.7                ^31.6           18  Weight training         26, 26, 26  Completers              95
     al.\27\
    Murphy, et        Exercise           44.4, 100%, 25.76         ^81.6, ^84.5           10  Long versus             47, 34, 34  Completers            86.5
     al.\28\                                                                                   short bouts of
                                                                                               walking
    Crandall \21\     Exercise            51.75, 44%, 30.8                ^76.7           12  Recumbent cycle         13, 13, 13  No drops               100
                                                                                               ergometer
    Shaw and Shaw     Exercise               41, 92%, 32.6                ^13.7            8  Resistance              28, 28, 28  Completers            91.1
     \29\                                                                                      training
    Kirk, et al.\30\  Exercise              20.6, 0%, 28.2               ^104.7           24  High-intensity          25, 19, 19  Completers              96
                                                                                               resistance
                                                                                               training
    Whybrow, et       Exercise             27.2, 50%, 23.6      ^455.6, ^513.6,            2  Progressive             12, 12, 12  No drops               100
     al.\31\                                                             ^907.1                exercise on
                                                                                               cycle ergometer
                                                                                               or treadmill
    Guadalupe-Grau,   Exercise          23.7, 65.2%, 23.03                ^51.7            9  Strength                88, 72, 66  Completers              85
     et al.\32\                                                                                training and
                                                                                               plyometric
                                                                                               jumps
    Alves, et         Exercise              38.2, 100%, 30               ^106.1           26  Group exercises      156, 146, 156  ITT, BOCF               96
     al.\33\
    Turner, et        Exercise                  54, 0%, 28               ^187.3           24  Structured              54, 41, 29  Completers              94
     al.\34\                                                                                   exercise
    Bell, et al.\35\  Exercise              49, 100%, 34.7       ^399.0, ^395.1           24  Pedometer-based      211, 128, 128  Completers           84.77
                                                                                               walking program
    Vispute, et       Exercise          23.66, 41.7%, 24.6                ^41.9            6  Abdominal               24, 24, 24  No drops             95.71
     al.\36\                                                                                   exercises
    Hornbuckle, et    Exercise             28.5, 0%, 25.42                ^57.7           12  Resistance              44, 32, 44  ITT                     96
     al.\37\                                                                                   training
    Heydari, et       Exercise           37.7, 56.3%, 27.8               ^186.4           12  High-intensity          46, 38, 38  Completers             100
     al.\38\                                                                                   intermittent
                                                                                               exercise
    Thompson, et      Exercise           49.7, 72.8%, 31.8               ^174.8           16  Supervised           162, 137, 162  ITT                     91
     al.,\39\ and                                                                              aerobic
     Church, et                                                                                exercise
     al.\40\
    Addington \20\    Feeding                38.74, 63.8%,       2.9 (aspartame            4  Artificially         150, 111, 111  Completers             100
                                                     32.09   group), 142.9 (SSB                sweetened
                                                                         group)                beverage
                                                                                               (aspartame)
                                                                                               versus SSB
    Lammert, et       Feeding              22.4, 0%, 22.61                  191            3  Overfeeding             20, 20, 20  No drops               100
     al.\41\                                                                                   carbohydrate or
                                                                                               fat
    Martin, et        Feeding            37.7, 56.3%, 27.8                597.1            2  Low- versus high-       10, 10, 10  No drops               100
     al.\42\                                                                                   calorie
                                                                                               breakfast
    Sabate, et        Feeding            42.6, 45.2%, 23.7                  219           26  Walnuts                 90, 90, 90  No drops                95
     al.\43\
    Whybrow, et       Feeding              60, 26.7%, 27.7         122.8, 227.5            8  Added fruits and        90, 62, 62  Completers            92.6
     al.\44\                                                                                   vegetables
    Whybrow, et       Feeding            35.05, 50%, 25.35         343.9, 687.9            2  Added snacks           100, 87, 72  Completers              96
     al.\45\
    Sheridan, et      Feeding               24.9, 0%, 28.7                314.8            4  Pistachio nuts          15, 15, 15  No drops                99
     al.\46\
    Casas-Agustench,  Feeding            54.4, 56.3%, 26.5                176.9           12  Mixed nuts              52, 50, 50  Completers              94
     et al.\47\
    Maersk, et        Feeding                 28, 0%, 22.2    3.1, 365.2, 385.5           26  1 l per day of          60, 47, 47  Completers              85
     al.\48\                                                                                   diet soda, SSB
                                                                                               or milk versus
                                                                                               water
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Abbreviations: BOCF, baseline observation carried forward; ITT, intention-to-treat analysis reported; pct, percentage; SSB, sugar-sweetened beverage.

    Building a Predictive Model
        We expected to find enough studies to build a robust regression
    model, incorporating mean participant characteristics and evaluating
    any significant interactions. However, the relatively low number and
    sparsely distributed data prevented reliable estimates from our final
    model. Details of the model and its estimations can be found in the
    online supplement, Supplementary Figure S1 and Supplementary Tables S1a
    and S1b.
    Comparison with Metabolic Compensation Models--Estimating Behavioral
            Compensation
        To address our main research question (What is the effect of
    behavioral compensation that occurs in free-living subjects who receive
    an energy balance intervention on weight outcomes?), we generated
    output for each study using the NIDDK and Pennington weight change
    prediction calculators 2, 18 to estimate weight changes that
    would occur if only metabolic compensation occurred. The difference
    between the observed weight loss for each study and the weight change
    predicted by these models is indicative of behavioral compensation
    occurring during the intervention. The NIDDK and Pennington models are
    highly correlated (Pearson's r = 0.98, P<0.0001) in predicted weight
    change (Supplementary Figure S2). In general, the Pennington calculator
    is slightly more conservative than the predictions made by the NIDDK
    calculator.
        The overall degree of behavioral compensation estimated by the gap
    between the observed and metabolic compensation--only predicted values
    is illustrated in Supplementary Figure S3, panels A and B. Both slopes
    being less than 1 (that is, 0.344 and 0.399 for the NIDDK and
    Pennington Models, respectively) indicate that the observed weight
    change is less than predicted after accounting for metabolic
    compensation. This quantifies the degree of behavioral compensation
    that is occurring (that is, the compensation that is in addition to the
    metabolic compensation, resulting in less weight change than expected).
        The degree of behavioral compensation appears to differ depending
    on intervention type. As shown in Supplementary Figure S3, panels A and
    B, all types of interventions demonstrated less weight change than
    either the Pennington or NIDDK calculators predicted. The plot of
    overfeeding trials has a slope (95% confidence interval) of 0.06
    (^0.04, 0.16) and 0.07 (^0.05, 0.18), plotted against the NIDDK and
    Pennington calculators, respectively (Figure 2, panels a and b). A
    slope of 1 would indicate that, on average, the interventions produced
    exactly as much weight change as expected from the mathematical models,
    which assume no behavioral compensation. As such, this suggests that
    behavioral compensation may result in as much as 96% less weight gain
    than predicted by metabolic calculators when adding energy to the diet.
    The slopes of the plots for dietary restriction and exercise studies
    are more similar to each other. Specifically, slopes (95% confidence
    interval) of 0.56 (0.17, 0.96) and 0.88 (0.36, 1.40) were plotted
    against the NIDDK and Pennington calculators, respectively, for dietary
    restriction studies (Figure 2). For exercise intervention studies,
    slopes (confidence interval) of 0.38 (0.16, 0.60) and 0.46 (0.19, 0.72)
    were plotted against the NIDDK and Pennington calculators, respectively
    (Figure 3). Thus, behavioral compensation may result in up to 12-44%
    less weight loss than predicted for dietary restriction studies and 55-
    64% less weight loss than predicted for exercise intervention studies.
    Risk of Bias Assessment for Included Studies
        See online supplement for risk of bias summary and detailed rating
    figure (Supplementary Figure S4) for each included study. The greatest
    proportions of study aspects with high risk of bias were judged to be
    due to the lack of analysis for incomplete data (attrition bias--for
    example, use of intention-to-treat analysis) and lack of attention
    placebo for control groups. Four studies reported results using
    intention-to-treat analysis.
    Figure 2

              NIDDK and Pennington calculator predictions for caloric
            restriction (D, squares) and overfeeding (F, triangles)
            interventions. NIDDK (a) and Pennington (b) model predictions
            (x axis) versus actual observed weight changes for all studies
            (y axis). Each individual point represents a control versus
            treatment comparison; the solid lines are lines of best fit for
            slope and black dashed lines are 95% confidence intervals. Gray
            dashes lines are axes and lines of identity. Overall,
            predictions are an overestimate of observed weight change.
    Figure 3

              NIDDK and Pennington calculator predictions for exercise
            interventions (E). NIDDK (a) and Pennington (b) model
            predictions (x axis) versus actual observed weight changes for
            all studies (y axis). Each individual point represents a
            treatment versus control comparison; the solid lines are lines
            of best fit for slope and black dashed lines are 95% confidence
            intervals. Gray dashes lines are axes and lines of identity.
            Overall, predictions are an overestimate of observed weight
            change.
    Discussion
        We generated simple adjustment factors to predict weight change
    resulting from energy balance interventions in free-living adult
    populations, with the ability to compensate both behaviorally and
    metabolically, using 73 treatment and control arm group outcomes from
    28 studies. One of the notable findings was the small number of studies
    meeting our inclusion criteria (that is, where compliance was
    objectively measured), making it difficult to study the role of
    behavioral compensation in a free-living context beyond a very basic
    level. Although our estimates are the only ones for this purpose to
    date based on the currently available literature, this highlights a gap
    in the literature of studies designed to determine the impact of energy
    balance perturbations in humans in the context of a full range of
    compensation that prevents a more precise estimate. As these studies
    are crucial to understanding the effect of public health interventions,
    their limited quantity underscores a need for future research in this
    area.
        Perhaps, the most robust finding from our study most relevant to
    public health is that currently available predictions consistently
    overestimate weight change, which is evidence of significantly
    diminished weight change resulting from behavioral compensation. This
    is in spite of some instances where explicit instructions were given to
    make no other changes in routine habits, a form of compliance that is
    less commonly tracked or verified. In particular, the treatment effect
    of added calories was only, on average, 5% of the weight gain
    predicted from models assuming no behavioral compensation. Several
    included studies reported a mean weight loss effect from added energy.
    This indicates that even if a new food is introduced to the diet, for
    example, adding a daily snack or beverage, EI and/or EE can be adjusted
    reasonably well, resulting in very little weight gain relative to how
    much would be expected if this behavioral compensation did not occur.
    Behavioral compensation for negative energy balance interventions such
    as exercise or dietary restriction is also evident from our analysis,
    and results in 37-45% and 56-88% of the weight loss predicted from
    metabolic-only compensation models. In our initial example of reducing
    EI via snacks by 200 kcals per day for the hypothetical man, the
    adjusted estimate of weight change after 1 year would be closer to 3.2
    kg. This is lower than the 5.7 kg estimate given by the body weight
    simulator that predicts metabolic compensation only.
        Therefore, our results suggest that current public health
    interventions or clinical interventions that alter one aspect of energy
    balance, without holding other aspects constant, may result in more
    modest weight changes than predicted or desired. A similar approach has
    been reported in pediatric studies,\3\ but it did not attempt to
    account for both behavioral and metabolic compensation components. It
    is important to take all modes of compensation into consideration when
    planning an intervention with targeted amounts of weight change and
    when anticipating its outcomes. It is likely that increased doses of
    energy perturbations are required. Increased control over compliance
    and compensation is necessary to achieve target outcomes. Estimates of
    what is required to achieve a specific weight change may be made more
    accurate for the purposes of public health recommendations if the
    present estimations are considered.
        Our results suggest that there might be a differential effect of
    treatment type on the degree of behavioral compensation. However, an
    aspect of our data set needs to be considered in interpreting this
    result. Dietary restriction interventions are associated with greater
    treatment effects, and less behavioral compensation, than either
    exercise or overfeeding interventions. However, this finding may be
    because the dietary restriction interventions included in our analysis
    only allowed for behavioral compensation through EE changes, whereas
    all exercise and overfeeding interventions allowed for behavioral
    compensation through both dietary intake and EE changes.
        Our approach has strengths and limitations. First, our inclusion
    criteria were rigorous. All included studies have at least 80%
    compliance with the prescribed intervention, with compliance verified
    objectively (no reliance solely on self-report). In addition, the dose
    was corrected in our calculations for the level of compliance reported
    in the study. Further, included studies were randomized controlled
    trials, and our outcome for generating the predictive model and for
    comparing with metabolic compensation models was the control group-
    adjusted weight change. Therefore, our models are built to assess true
    treatment effect, and are corrected for any weight change due to
    factors such as regression to the mean, maturation, historical factors
    and behaviors that result from simply participating in a study, rather
    than from the treatment itself.
        Several limitations should also be considered when interpreting our
    analysis. Weight was not always the primary outcome in studies that met
    our inclusion criteria. This is particularly true for those with added
    EI in the form of nuts. Differences in stated outcomes of interest,
    time with researchers and other factors may affect weight outcomes for
    individual studies. In addition, body composition may be an important
    outcome that we were not able to adequately analyze because of the
    limited number of studies including body composition measurements such
    as changes in fat mass and fat-free mass. Because of our rigorous
    inclusion criteria, our data set is small (28 studies). The types of
    studies we selected are necessary for making definitive conclusions
    about the impact of perturbations in one aspect of energy balance on
    body weight. Studies also tended to be shorter in duration, thus it is
    difficult to make conclusions about long-term effects. This is a large
    gap in the literature, and a more systematic approach to large, well-
    controlled studies to answer these questions is warranted. In addition,
    16 of the 28 studies reported data only for those participants who
    completed the intervention period, and across all studies there was a
    17.8% dropout rate (Table 1), which may have biased our estimates of
    weight change toward overestimation. We used the intention to treat
    data when reported (four studies). Eight studies reported no dropouts.
        Future research is needed to understand potential differences in
    compensation between dietary interventions (added or reduced energy),
    different food forms and macronutrient compositions. Also, certain
    factors should be considered as potential confounders when quantifying
    the compensatory response to a specific intervention. For example,
    bioavailability of energy in food, efficiencies in physical activity
    and food utilization, seasonal effects and durations of interventions
    may all influence both the metabolic and behavioral compensatory
    response to an intervention. It is also unclear whether compensation
    would remain constant over time. Moreover, evaluating the influence of
    participant characteristics related to eating behavior (cognitive
    restraint, disinhibition and hunger) and compensation during
    interventions is needed as this may hold promise for optimizing
    treatment effectiveness.
        To conclude, we have presented the first empirically based,
    quantitative estimation for the range of behavioral compensation that
    may be observed for energy balance interventions. This information may
    assist in the estimation of weight outcomes of clinical health
    interventions. It may also inform public health projections for obesity
    interventions or public health initiatives.

    Conflict of Interest

        DBA has received consulting fees and his university has received
     gifts, grants and donations from multiple nonprofit and for-profit
     organizations with interests in obesity including publishers,
     litigators and food and pharmaceutical companies. KAK has received a
     speaker honorarium from Coca-Cola Iberia. The remaining authors declare
     no conflict of interest.

    Acknowledgements

        This project was sponsored by the International Life Sciences
     Institute--North America (EJD and KAK, co-PIs). We thank the following
     experts for their helpful comments on earlier versions of this
     manuscript: Steve Blair, Steve Heymsfield, Rick Mattes, Robert
     Matthews, Diana Thomas and Kevin Fontaine. Registry Information:
     PROSPERO (http://www.crd.york.ac.uk/prospero/search.asp)
     CRD42013002912.

    Author Contributions

        EJD, KAK and DBA conceived the study and developed the design and
     selection criteria. KAK performed the literature searches. KAK and EJD
     reviewed the literature, selected studies, extracted data, evaluated
     risk of bias and wrote significant portions of the manuscript. ASA
     assisted with literature selection, data extraction and summary
     calculations. JAD and KDK performed the statistical analysis and wrote
     some portions of the manuscript. DBA directed the statistical analysis
     and wrote some portions of the manuscript.

            Supplementary Information accompanies this paper on
         International Journal of Obesity website (http://www.nature.com/
         ijo).

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     nut consumption and serum lipid levels. J. Am. Coll. Nutr. 2007; 26:
     141-148.
        47. Casas-Agustench P., Lopez-Uriarte P., Bullo M., Ros E., Cabre-
     Vila J.J., Salas-Salvado J. Effects of one serving of mixed nuts on
     serum lipids, insulin resistance and inflammatory markers in patients
     with the metabolic syndrome. Nutr. Metab. Cardiovasc. Dis. 2011; 21:
     126-135.
        48. Maersk M., Belza A., Stodkilde-Jorgensen H., Ringgaard S.,
     Chabanova E., Thomsen H., et al. Sucrose-sweetened beverages increase
     fat storage in the liver, muscle, and visceral fat depot: a 6-mo
     randomized intervention study. Am. J. Clin. Nutr. 2012; 95: 283-289.

                                  attachment 3
    Myths, Presumptions, and Facts About Obesity *
    ---------------------------------------------------------------------------
        * This article was updated on June 6, 2013, at NEJM.org.
        N. Engl. J. Med. 2013;368:446-54.
        DOI: 10.1056/NEJMsa1208051.
        Copyright  13 Massachusetts Medical Society.
    ---------------------------------------------------------------------------
    Krista Casazza, Ph.D., R.D., Kevin R. Fontaine, Ph.D., Arne Astrup,
    M.D., Ph.D., Leann L. Birch, Ph.D., Andrew W. Brown, Ph.D., Michelle M.
    Bohan Brown, Ph.D., Nefertiti Durant, M.D., M.P.H., Gareth Dutton,
    Ph.D., E. Michael Foster, Ph.D., Steven B. Heymsfield, M.D., Kerry
    McIver, M.S., Tapan Mehta, M.S., Nir Menachemi, Ph.D., P.K. Newby,
    Sc.D., M.P.H., Russell Pate, Ph.D., Barbara J. Rolls, Ph.D., Bisakha
    Sen, Ph.D., Daniel L. Smith, Jr., Ph.D., Diana M. Thomas, Ph.D., and
    David B. Allison, Ph.D.**
    ---------------------------------------------------------------------------
        ** From the Departments of Nutrition Sciences (K.C., M.M.B.B.,
    D.L.S., D.B.A.), Health Behavior (K.R.F.), Pediatrics (N.D.), Medicine
    (G.D.), Health Care Organization and Policy (E.M.F., N.M., B.S.), and
    Biostatistics (T.M., D.B.A.) and the School of Public Health, Office of
    Energetics, Nutrition Obesity Research Center (A.W.B., D.B.A.),
    University of Alabama at Birmingham, Birmingham; the OPUS Center and
    the Department of Nutrition, Exercise, and Sports, University of
    Copenhagen, Copenhagen (A.A.); the Departments of Development and
    Family Studies (L.L.B.) and Nutritional Sciences (B.J.R.), Pennsylvania
    State University, University Park; Pennington Biomedical Research
    Center, Baton Rouge, LA (S.B.H.); Children's Physical Activity Research
    Group, Department of Exercise Science, Arnold School of Public Health,
    University of South Carolina, Columbia (K.M., R.P.); the Departments of
    Pediatrics and Epidemiology, Program in Graduate Medical Nutrition
    Sciences, and Program in Gastronomy, Culinary Arts, and Wine Studies,
    Boston University, Boston (P.K.N.); and the Center for Quantitative
    Obesity Research, Montclair State University, Montclair, NJ (D.M.T.).
    Address reprint requests to Dr. Allison at the University of Alabama at
    Birmingham, Department of Biostatistics, Birmingham, AL 35294, or at
    dallison@uab.edu.
    ---------------------------------------------------------------------------
    Abstract
      Background
              Many beliefs about obesity persist in the absence of
            supporting scientific evidence (presumptions); some persist
            despite contradicting evidence (myths). The promulgation of
            unsupported beliefs may yield poorly informed policy decisions,
            inaccurate clinical and public health recommendations, and an
            unproductive allocation of research resources and may divert
            attention away from useful, evidence-based information.
        Methods
              Using Internet searches of popular media and scientific
            literature, we identified, reviewed, and classified obesity-
            related myths and presumptions. We also examined facts that are
            well supported by evidence, with an emphasis on those that have
            practical implications for public health, policy, or clinical
            recommendations.
        Results
              We identified seven obesity-related myths concerning the
            effects of small sustained increases in energy intake or
            expenditure, establishment of realistic goals for weight loss,
            rapid weight loss, weight-loss readiness, physical-education
            classes, breast-feeding, and energy expended during sexual
            activity. We also identified six presumptions about the
            purported effects of regularly eating breakfast, early
            childhood experiences, eating fruits and vegetables, weight
            cycling, snacking, and the built (i.e., human-made)
            environment. Finally, we identified nine evidence-supported
            facts that are relevant for the formulation of sound public
            health, policy, or clinical recommendations.
        Conclusions
              False and scientifically unsupported beliefs about obesity
            are pervasive in both scientific literature and the popular
            press. (Funded by the National Institutes of Health.)

        Passionate interests, the human tendency to seek explanations for
    observed phenomena, and everyday experience appear to contribute to
    strong convictions about obesity, despite the absence of supporting
    data. When the public, mass media, government agencies, and even
    academic scientists espouse unsupported beliefs, the result may be
    ineffective policy, unhelpful or unsafe clinical and public health
    recommendations, and an unproductive allocation of resources. In this
    article, we review some common beliefs about obesity that are not
    supported by scientific evidence and also provide some useful evidence-
    based concepts. We define myths as beliefs held to be true despite
    substantial refuting evidence, presumptions as beliefs held to be true
    for which convincing evidence does not yet confirm or disprove their
    truth, and facts as propositions backed by sufficient evidence to
    consider them empirically proved for practical purposes.
        When standards for evidence are considered, it is critical to
    distinguish between drawing conclusions from scientific evidence and
    making decisions about prudent actions. Stakeholders must sometimes
    take action in the absence of strong scientific evidence. Yet this
    principle of action should not be mistaken as justification for drawing
    conclusions. Regardless of the urgency of public health issues,
    scientific principles remain unchanged. We find the language of the
    Federal Trade Commission to be apt: its standard for making claims is
    ``competent and reliable scientific evidence,'' defined as ``tests,
    analyses, research, studies, or other evidence . . . conducted and
    evaluated in an objective manner . . . using procedures generally
    accepted . . . to yield accurate and reliable results.'' \1\
        The scientific community recognizes that randomized experiments
    offer the strongest evidence for drawing causal inferences.
    Nevertheless, at least since the 1960s, when Sir Austin Bradford Hill
    spearheaded the scientific activities that led to the acceptance of the
    claim that smoking causes lung cancer and to his classic writing on
    association and causation,\2\ the scientific community has acknowledged
    that under some circumstances (i.e., when it is unethical or unfeasible
    to conduct a randomized study and when observed associations are not
    plausibly due to confounding), inferring causality in the absence of
    data from randomized, controlled trials is necessary and appropriate.
    However, the fact that the appropriateness of inferring causality holds
    only under certain circumstances is sometimes discounted by those who
    are eager to garner support for a proposal in the absence of strong
    data from randomized studies.
        Notably, the circumstances that justify drawing a conclusion of
    causation from nonexperimental data are rarely met in clinical and
    public proposals regarding obesity. It is possible to conduct
    randomized studies of even the most sensitive and invasive obesity
    procedures, as exemplified by recent articles in the Journal. Moreover,
    observational associations germane to the causes, treatment, and
    prevention of obesity are subject to substantial confounding, fraught
    with measurement problems, and typically small and inconsistent.\3\
    Such observational associations are often found to differ from those
    later obtained by more rigorously designed studies.\4\ Hence, in the
    present discussion, we generally conclude that a proposition has been
    shown to be true only when it has been supported by confirmatory
    randomized studies. References to published studies are used sparingly
    herein, with a more comprehensive listing provided in the Supplementary
    Appendix, available with the full text of this article at NEJM.org.
    Myths
        We review seven myths about obesity, along with the refuting
    evidence. Table 1 provides anecdotal support that the beliefs are
    widely held or stated, in addition to reasons that support conjecture.

                      Table 1. Seven Myths about Obesity *
    ------------------------------------------------------------------------
                   Myth                         Basis of Conjecture
    ------------------------------------------------------------------------
    Small sustained changes in energy  National health guidelines and
     intake or expenditure will         reputable websites advertise that
     produce large, long-term weight    large changes in weight accumulate
     changes                            indefinitely after small sustained
                                        daily lifestyle modifications (e.g.,
                                        walking for 20 minutes or eating two
                                        additional potato chips)
    Setting realistic goals in         According to goal-setting theory,
     obesity treatment is important     unattainable goals impair
     because otherwise patients will    performance and discourage goal-
     become frustrated and lose less    attaining behavior; in obesity
     weight                             treatment, incongruence between
                                        desired and actual weight loss is
                                        thought to undermine the patient's
                                        perceived ability to attain goals,
                                        which may lead to the
                                        discontinuation of behaviors
                                        necessary for weight loss
    Large, rapid weight loss is        This notion probably emerged in
     associated with poorer long-term   reaction to the adverse effects of
     weight outcomes than is slow,      nutritionally insufficient very-low-
     gradual weight loss                calorie diets (<800 kcal per day) in
                                        the 1960s; the belief has persisted,
                                        has been repeated in textbooks and
                                        recommendations from health
                                        authorities, and has been offered as
                                        a rule by dietitians
    Assessing the stage of change or   Many believe that patients who feel
     diet readiness is important in     ready to lose weight are more likely
     helping patients who seek weight-  to make the required lifestyle
     loss treatment                     changes
    Physical-education classes in      The health benefits of physical
     their current format play an       activity of sufficient duration,
     important role in preventing or    frequency, and intensity are well
     reducing childhood obesity         established and include reductions
                                        in adiposity
    Breast-feeding is protective       The belief that breast-fed children
     against obesity                    are less likely to become obese has
                                        persisted for more than a century
                                        and is passionately defended
    A bout of sexual activity burns    Many sources state that substantial
     100 to 300 kcal for each person    energy is expended in typical sexual
     involved                           activity between two adults
    ------------------------------------------------------------------------
    * We define myths as beliefs held true despite substantial evidence
      refuting them. A list of articles in which these myths are espoused is
      provided in the Supplementary Appendix.

    Small Sustained Changes in Energy Intake Or Expenditure
        Myth number 1: Small sustained changes in energy intake or
    expenditure will produce large, long-term weight changes.
        Predictions suggesting that large changes in weight will accumulate
    indefinitely in response to small sustained lifestyle modifications
    rely on the half-century-old 3,500-kcal rule, which equates a weight
    alteration of 1 lb (0.45 kg) to a 3,500-kcal cumulative deficit or
    increment.5-6 However, applying the 3,500-kcal rule to cases
    in which small modifications are made for long periods violates the
    assumptions of the original model, which were derived from short-term
    experiments predominantly performed in men on very-low-energy diets
    (<800 kcal per day).5, 7 Recent studies have shown that
    individual variability affects changes in body composition in response
    to changes in energy intake and expenditure,\7\ with analyses
    predicting substantially smaller changes in weight (often by an order
    of magnitude across extended periods) than the 3,500-kcal rule
    does.5, 7 For example, whereas the 3,500-kcal rule predicts
    that a person who increases daily energy expenditure by 100 kcal by
    walking 1 mile (1.6 km) per day will lose more than 50 lb (22.7 kg)
    over a period of 5 years, the true weight loss is only about 10 lb (4.5
    kg),\6\ assuming no compensatory increase in caloric intake, because
    changes in mass concomitantly alter the energy requirements of the
    body.
    Setting Realistic Weight-Loss Goals
        Myth number 2: Setting realistic goals for weight loss is
    important, because otherwise patients will become frustrated and lose
    less weight.
        Although this is a reasonable hypothesis, empirical data indicate
    no consistent negative association between ambitious goals and program
    completion or weight loss.\8\ Indeed, several studies have shown that
    more ambitious goals are sometimes associated with better weight-loss
    outcomes (see the Supplementary Appendix).\8\ Furthermore, two studies
    showed that interventions designed to improve weight-loss outcomes by
    altering unrealistic goals resulted in more realistic weight-loss
    expectations but did not improve outcomes.
    Rate of Weight Loss
        Myth number 3: Large, rapid weight loss is associated with poorer
    long-term weight-loss outcomes, as compared with slow, gradual weight
    loss.
        Within weight-loss trials, more rapid and greater initial weight
    loss has been associated with lower body weight at the end of long-term
    follow-up.9-10 A meta-analysis of randomized, controlled
    trials that compared rapid weight loss (achieved with very-low-energy
    diets) with slower weight loss (achieved with low-energy diets--i.e.,
    800 to 1200 kcal per day) at the end of short-term follow-up (<1 yr)
    and long-term follow-up (%1 year) showed that, despite the association
    of very-low-energy diets with significantly greater weight loss at the
    end of short-term follow-up (16.1% of body weight lost, vs. 9.7% with
    low-energy diets), there was no significant difference between the
    very-low-energy diets and low-energy diets with respect to weight loss
    at the end of long-term follow-up.\10\ Although it is not clear why
    some obese persons have a greater initial weight loss than others do, a
    recommendation to lose weight more slowly might interfere with the
    ultimate success of weight-loss efforts.
    Diet Readiness
        Myth number 4: It is important to assess the stage of change or
    diet readiness in order to help patients who request weight-loss
    treatment.
        Readiness does not predict the magnitude of weight loss or
    treatment adherence among persons who sign up for behavioral programs
    or who undergo obesity surgery.\11\ Five trials (involving 3,910
    participants; median study period, 9 months) specifically evaluated
    stages of change (not exclusively readiness) and showed an average
    weight loss of less than 1 kg and no conclusive evidence of sustained
    weight loss (see the Supplementary Appendix). The explanation may be
    simple--people voluntarily choosing to enter weight-loss programs are,
    by definition, at least minimally ready to engage in the behaviors
    required to lose weight.
    Importance of Physical Education
        Myth number 5: Physical-education classes, in their current form,
    play an important role in reducing or preventing childhood obesity.
        Physical education, as typically provided, has not been shown to
    reduce or prevent obesity. Findings in three studies that focused on
    expanded time in physical education \12\ indicated that even though
    there was an increase in the number of days children attended physical-
    education classes, the effects on body-mass index (BMI) were
    inconsistent across sexes and age groups. Two meta-analyses showed that
    even specialized school-based programs that promoted physical activity
    were ineffective in reducing BMI or the incidence or prevalence of
    obesity.\13\ There is almost certainly a level of physical activity (a
    specific combination of frequency, intensity, and duration) that would
    be effective in reducing or preventing obesity. Whether that level is
    plausibly achievable in conventional school settings is unknown,
    although the dose-response relationship between physical activity and
    weight warrants investigation in clinical trials.
    Breast-Feeding and Obesity
        Myth number 6: Breast-feeding is protective against obesity.
        A World Health Organization (WHO) report states that persons who
    were breast-fed as infants are less likely to be obese later in life
    and that the association is ``not likely to be due to publication bias
    or confounding.'' \14\ Yet the WHO, using Egger's test and funnel
    plots, found clear evidence of publication bias in the published
    literature it synthesized.\15\ Moreover, studies with better control
    for confounding (e.g., studies including within-family sibling
    analyses) and a randomized, controlled trial involving more than 13,000
    children who were followed for more than 6 years \16\ provided no
    compelling evidence of an effect of breast-feeding on obesity. On the
    basis of these findings, one long-term proponent of breast-feeding for
    the prevention of obesity wrote that breast-feeding status ``no longer
    appears to be a major determinant'' of obesity risk; \17\ however, he
    speculated that breast-feeding may yet be shown to be modestly
    protective, current evidence to the contrary. Although existing data
    indicate that breast-feeding does not have important antiobesity
    effects in children, it has other important potential benefits for the
    infant and mother and should therefore be encouraged.
    Sexual Activity and Energy Expenditure
        Myth number 7: A bout of sexual activity burns 100 to 300 kcal for
    each participant.
        The energy expenditure of sexual intercourse can be estimated by
    taking the product of activity intensity in metabolic equivalents
    (METs),\18\ the body weight in kilograms, and time spent. For example,
    a man weighing 154 lb (70 kg) would, at 3 METs, expend approximately
    3.5 kcal per minute (210 kcal per hour) during a stimulation and orgasm
    session. This level of expenditure is similar to that achieved by
    walking at a moderate pace (approximately 2.5 miles [4 km] per hour).
    Given that the average bout of sexual activity lasts about 6
    minutes,\19\ a man in his early-to-mid-30s might expend approximately
    21 kcal during sexual intercourse. Of course, he would have spent
    roughly \1/3\ that amount of energy just watching television, so the
    incremental benefit of one bout of sexual activity with respect to
    energy expended is plausibly on the order of 14 kcal.
    Presumptions
        Just as it is important to recognize that some widely held beliefs
    are myths so that we may move beyond them, it is important to recognize
    presumptions, which are widely accepted beliefs that have neither been
    proved nor disproved, so that we may move forward to collect solid data
    to support or refute them. Instead of attempting to comprehensively
    describe all the data peripherally related to each of the six
    presumptions shown in Table 2, we describe the best evidence.

                      Table 2. Presumptions about Obesity *
    ------------------------------------------------------------------------
                 Presumption                      Basis of Conjecture
    ------------------------------------------------------------------------
    Regularly eating (vs. skipping)       Skipping breakfast purportedly
     breakfast is protective against       leads to overeating later in the
     obesity                               day
    Early childhood is the period during  Weight-for-height indexes, eating
     which we learn exercise and eating    behaviors, and preferences that
     habits that influence our weight      are present in early childhood
     throughout life                       are correlated with those later
                                           in life
    Eating more fruits and vegetables     By eating more fruits and
     will result in weight loss or less    vegetables, a person presumably
     weight gain, regardless of whether    spontaneously eats less of other
     one intentionally makes any other     foods, and the resulting
     behavioral or environmental changes   reduction in calories is greater
                                           than the increase in calories
                                           from the fruit and vegetables
    Weight cycling (i.e., yo-yo dieting)  In observational studies,
     is associated with increased          mortality rates have been lower
     mortality                             among persons with stable weight
                                           than among those with unstable
                                           weight
    Snacking contributes to weight gain   Snack foods are presumed to be
     and obesity                           incompletely compensated for at
                                           subsequent meals, leading to
                                           weight gain
    The built environment, in terms of    Neighborhood-environment features
     sidewalk and park availability,       may promote or inhibit physical
     influences obesity                    activity, thereby affecting
                                           obesity
    ------------------------------------------------------------------------
    * We define presumptions as unproved yet commonly espoused propositions.
      A list of articles in which these presumptions are implied is provided
      in the Supplementary Appendix.

    Value of Breakfast
        Presumption number 1: Regularly eating (versus skipping) breakfast
    is protective against obesity.
        Two randomized, controlled trials that studied the outcome of
    eating versus skipping breakfast showed no effect on weight in the
    total sample.\20\ However, the findings in one study suggested that the
    effect on weight loss of being assigned to eat or skip breakfast was
    dependent on baseline breakfast habits.\20\
    Early Childhood Habits and Weight
        Presumption number 2: Early childhood is the period in which we
    learn exercise and eating habits that influence our weight throughout
    life.
        Although a person's BMI typically tracks over time (i.e., tends to
    be in a similar percentile range as the person ages), longitudinal
    genetic studies suggest that such tracking may be primarily a function
    of genotype rather than a persistent effect of early learning.\21\ No
    randomized, controlled clinical trials provide evidence to the
    contrary.
    Value of Fruits and Vegetables
        Presumption number 3: Eating more fruits and vegetables will result
    in weight loss or less weight gain, regardless of whether any other
    changes to one's behavior or environment are made.
        It is true that the consumption of fruits and vegetables has health
    benefits. However, when no other behavioral changes accompany increased
    consumption of fruits and vegetables, weight gain may occur or there
    may be no change in weight.\22\
    Weight Cycling and Mortality
        Presumption number 4: Weight cycling (i.e., yo-yo dieting) is
    associated with increased mortality.
        Although observational epidemiologic studies show that weight
    instability or cycling is associated with increased mortality, such
    findings are probably due to confounding by health status. Studies of
    animal models do not support this epidemiologic association.\23\
    Snacking and Weight Gain
        Presumption number 5: Snacking contributes to weight gain and
    obesity.
        Randomized, controlled trials do not support this presumption.\24\
    Even observational studies have not shown a consistent association
    between snacking and obesity or increased BMI.
    Built Environment and Obesity
        Presumption number 6: The built environment, in terms of sidewalk
    and park availability, influences the incidence or prevalence of
    obesity.
        According to a systematic review, virtually all studies showing
    associations between the risk of obesity and components of the built
    environment (e.g., parks, roads, and architecture) have been
    observational.\25\ Furthermore, these observational studies have not
    shown consistent associations, so no conclusions can be drawn.
    Facts
        Our proposal that myths and presumptions be seen for what they are
    should not be mistaken as a call for nihilism. There are things we do
    know with reasonable confidence. Table 3 lists nine such facts and
    their practical implications for public health, policy, or clinical
    recommendations. The first two facts help establish a framework in
    which intervention and preventive techniques may work. The next four
    facts are more prescriptive, offering tools that can be conveyed to the
    public as well established. The last three facts are suited to clinical
    settings.

                         Table 3. Facts about Obesity *
    ------------------------------------------------------------------------
                   Fact                             Implication
    ------------------------------------------------------------------------
    Although genetic factors play a    If we can identify key environmental
     large role, heritability is not    factors and successfully influence
     destiny; calculations show that    them, we can achieve clinically
     moderate environmental changes     significant reductions in obesity
     can promote as much weight loss
     as the most efficacious
     pharmaceutical agents available
     \26\
    Diets (i.e., reduced energy        This seemingly obvious distinction is
     intake) very effectively reduce    often missed, leading to erroneous
     weight, but trying to go on a      conceptions regarding possible
     diet or recommending that          treatments for obesity; recognizing
     someone go on a diet generally     this distinction helps our
     does not work well in the long-    understanding that energy reduction
     term \27\                          is the ultimate dietary intervention
                                        required and approaches such as
                                        eating more vegetables or eating
                                        breakfast daily are likely to help
                                        only if they are accompanied by an
                                        overall reduction in energy intake
    Regardless of body weight or       Exercise offers a way to mitigate the
     weight loss, an increased level    health-damaging effects of obesity,
     of exercise increases health       even without weight loss
     \28\
    Physical activity or exercise in   Physical-activity programs are
     a sufficient dose aids in long-    important, especially for children,
     term weight maintenance 28	29      but for physical activity to affect
                                        weight, there must be a substantial
                                        quantity of movement, not mere
                                        participation
    Continuation of conditions that    Obesity is best conceptualized as a
     promote weight loss promotes       chronic condition, requiring ongoing
     maintenance of lower weight \30\   management to maintain long-term
                                        weight loss
    For overweight children, programs  Programs provided only in schools or
     that involve the parents and the   other out-of-home structured
     home setting promote greater       settings may be convenient or
     weight loss or maintenance \31\    politically expedient, but programs
                                        including interventions that involve
                                        the parents and are provided at home
                                        are likely to yield better outcomes
    Provision of meals and use of      More structure regarding meals is
     meal-replacement products          associated with greater weight loss,
     promote greater weight loss \32\   as compared with seemingly holistic
                                        programs that are based on concepts
                                        of balance, variety, and moderation
    Some pharmaceutical agents can     While we learn how to alter the
     help patients achieve clinically   environment and individual behaviors
     meaningful weight loss and         to prevent obesity, we can offer
     maintain the reduction as long     moderately effective treatmentto
     as the agents continue to be       obese persons
     used \33\
    In appropriate patients,           For severely obese persons, bariatric
     bariatric surgery results in       surgery can offer a life-changing,
     long-term weight loss and          and in some cases lifesaving,
     reductions in the rate of          treatment
     incident diabetes and mortality
     \34\
    ------------------------------------------------------------------------
    * We classify the listed propositions as facts because there is
      sufficient evidence to consider them empirically proved.

    Implications
        Myths and presumptions about obesity are common. Several
    presumptions appear to be testable, and some of them (e.g., effects of
    eating breakfast daily, eating more fruits and vegetables, and
    snacking) can be tested with standard study designs. Despite enormous
    efforts promoting these ideas, research often seems mired in the
    accrual of observational data. Many of the trials that have been
    completed or are in progress do not isolate the effect of the presumed
    influence and the findings are therefore not definitive.
        Many of the myths and presumptions about obesity reflect a failure
    to consider the diverse aspects of energy balance,\35\ especially
    physiological compensation for changes in intake or expenditure.\36\
    Some myths and presumptions involve an implicit assumption that there
    is no physiological compensation whatsoever (i.e., the 3,500-kcal rule)
    or only minimal compensation (e.g., a reduction in snacking as a means
    of reducing weight). In other cases, there is an implicit assumption of
    overcompensation (e.g., eating breakfast daily or increasing the intake
    of fruits and vegetables as a means of reducing weight). Proponents of
    other unsupported ideas fail to consider that people burn some amount
    of energy even without engaging in the activity in question (e.g.,
    increased sexual activity). In addition, interested parties do not
    regularly request the results from randomized, long-term studies that
    measure weight or adiposity as an outcome. Therefore, the presented
    data are rife with circumstantial evidence, and people are not informed
    that the existing evidence is not compelling (e.g., breakfast
    consumption). Furthermore, some suggested treatment or prevention
    strategies may work well (e.g., increasing the consumption of fruits
    and vegetables) but only as part of a multifaceted program for weight
    reduction. Yet such a strategy is often presented as though it will
    have effects in isolation and even among persons not participating in
    weight-loss programs. We must recognize that evidence that a technique
    is beneficial for the treatment of obesity is not necessarily evidence
    that it will be helpful in population-based approaches to the
    prevention of obesity, and vice versa.
    Knowing and Not Knowing
        Why do we think or claim we know things that we actually do not
    know? Numerous cognitive biases lead to an unintentional retention of
    erroneous beliefs.37-38 When media coverage about obesity is
    extensive, many people appear to believe some myths (e.g., rapid weight
    loss facilitates weight regain) simply because of repeated exposure to
    the claims.\39\ Cognitive dissonance may prevent us from abandoning
    ideas that are important to us, despite contradictory evidence (e.g.,
    the idea that breast-feeding prevents obesity in children). Similarly,
    confirmation bias may prevent us from seeking data that might refute
    propositions we have already intuitively accepted as true because they
    seem obvious (e.g., the value of realistic weight-loss goals).
    Moreover, we may be swayed by persuasive yet fallacious arguments
    (Whately provides a classic catalogue) \40\ unless we are prepared to
    identify them as spurious.
        Fortunately, the scientific method and logical thinking offer ways
    to detect erroneous statements, acknowledge our uncertainty, and
    increase our knowledge. When presented with an alleged truth, we can
    pause to ask simple questions, such as, ``How could someone actually
    know that?'' Such a simple question allows one to easily recognize some
    beliefs as spurious (e.g., 300 kcal is burned during sexual
    intercourse). Moreover, we often settle for data generated with the use
    of inadequate methods in situations in which inferentially stronger
    study designs, including quasi-experiments and true randomized
    experiments, are possible, as recently illustrated (see the
    Supplementary Appendix). In addition, eliminating the distortions of
    scientific information that sometimes occur with public health advocacy
    would reduce the propagation of misinformation.
        The myths and presumptions about obesity that we have discussed are
    just a sampling of the numerous unsupported beliefs held by many
    people, including academics, regulators, and journalists, as well as
    the general public. Yet there are facts about obesity of which we may
    be reasonably certain--facts that are useful today. While we work to
    generate additional useful knowledge, we may in some cases justifiably
    move forward with hypothesized, but not proved, strategies. However, as
    a scientific community, we must always be open and honest with the
    public about the state of our knowledge and should rigorously evaluate
    unproved strategies.

        The views expressed in this article are those of the authors and do
     not necessarily represent the official views of the National Institutes
     of Health.
        Supported in part by a grant (P30DK056336) from the National
     Institutes of Health.
        Dr. Astrup reports receiving payment for board membership from the
     Global Dairy Platform, Kraft Foods, Knowledge Institute for Beer,
     McDonald's Global Advisory Council, Arena Pharmaceuticals, Basic
     Research, Novo Nordisk, Pathway Genomics, Jenny Craig, and Vivus;
     receiving lecture fees from the Global Dairy Platform, Novo Nordisk,
     Danish Brewers Association, GlaxoSmithKline, Danish Dairy Association,
     International Dairy Foundation, European Dairy Foundation, and
     AstraZeneca; owning stock in Mobile Fitness; holding patents regarding
     the use of flaxseed mucilage or its active component for suppression of
     hunger and reduction of prospective consumption (patents EP1744772,
     WO2009033483-A1, EP2190303-A1, US2010261661-A1, and priority
     applications DK001319, DK001320, S971798P, and US971827P); holding
     patents regarding the use of an alginate for the preparation of an
     aqueous dietary product for the treatment or prevention of overweight
     and obesity (patent WO2011063809-A1 and priority application DK070227);
     and holding a patent regarding a method for regulating energy balance
     for body-weight management (patent WO2007062663-A1 and priority
     application DK001710). Drs. Brown and Bohan Brown report receiving
     grant support from the Coca-Cola Foundation through their institution.
     Dr. Mehta reports receiving grant support from Kraft Foods. Dr. Newby
     reports receiving grant support from General Mills Bell Institute of
     Health and Nutrition. Dr. Pate reports receiving consulting fees from
     Kraft Foods. Dr. Rolls reports having a licensing agreement for the
     Volumetrics trademark with Jenny Craig. Dr. Thomas reports receiving
     consulting fees from Jenny Craig. Dr. Allison reports serving as an
     unpaid board member for the International Life Sciences Institute of
     North America; receiving payment for board membership from Kraft Foods;
     receiving consulting fees from Vivus, Ulmer and Berne, Paul, Weiss,
     Rifkind, Wharton, Garrison, Chandler Chicco, Arena Pharmaceuticals,
     Pfizer, National Cattlemen's Association, Mead Johnson Nutrition,
     Frontiers Foundation, Orexigen Therapeutics, and Jason Pharmaceuticals;
     receiving lecture fees from Porter Novelli and the Almond Board of
     California; receiving payment for manuscript preparation from Vivus;
     receiving travel reimbursement from International Life Sciences
     Institute of North America; receiving other support from the United
     Soybean Board and the Northarvest Bean Growers Association; receiving
     grant support through his institution from Wrigley, Kraft Foods, Coca-
     Cola, Vivus, Jason Pharmaceuticals, Aetna Foundation, and McNeil
     Nutritionals; and receiving other funding through his institution from
     the Coca-Cola Foundation, Coca-Cola, PepsiCo, Red Bull, World Sugar
     Research Organisation, Archer Daniels Midland, Mars, Eli Lilly and
     Company, and Merck. No other potential conflict of interest relevant to
     this article was reported.
        Disclosure forms provided by the authors are available with the full
     text of this article at NEJM.org.
        We thank Drs. Kyle Grimes and S. Louis Bridges for their suggestions
     on an earlier version of the manuscript.

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     body weight regulation. Am. J. Clin. Nutr. 2012; 95: 989-94.
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    Copyright 13 Massachusetts Medical Society.

                                  attachment 4
    Goals in Nutrition Science 2015-2020 *
    ---------------------------------------------------------------------------
        * Edited by: Steven H. Zeisel, University of North Carolina at
    Chapel Hill, USA; Reviewed by: Naima Moustaid-Moussa, Texas Tech
    University, USA Patrick John Stover, Cornell University, USA; Received:
    26 May 2015; Accepted: 14 August 2015; Published: 08 September 2015.
        Citation: Allison D.B., Bassaganya-Riera J., Burlingame B., Brown
    A.W., le Coutre J., Dickson S.L., van Eden W., Garssen J., Hontecillas
    R., Khoo C.S.H., Knorr D., Kussmann M., Magistretti P.J., Mehta T.,
    Meule A., Rychlik M., and Vogele C. (2015) Goals in nutrition science
    2015-2020. Front. Nutr. 2:26. doi: 10.3389/fnut.2015.00026
    ---------------------------------------------------------------------------
    David B. Allison,[1-4] Josep Bassaganya-Riera,[5]
    Barbara Burlingame,[6-7] Andrew W. Brown,[1]
    Johannes le Coutre,[8-10, *] Suzanne L.
    Dickson,[11] Willem van Eden,[12] Johan
    Garssen,[13] Raquel Hontecillas,[5] Chor San H.
    Khoo,[14] Dietrich Knorr,[15] Martin
    Kussmann,[10, 16] Pierre J. Magistretti,[17-18]
    Tapan Mehta,[19] Adrian Meule,[20] Michael
    Rychlik,[21] and Claus Vogele [22]
    ---------------------------------------------------------------------------
        \[1]\ Office of Energetics and Nutrition Obesity Research Center,
    School of Public Health, University of Alabama at Birmingham,
    Birmingham, AL, USA, [2] Section on Statistical Genetics,
    University of Alabama at Birmingham, Birmingham, AL, USA,
    [3] Department of Nutrition Sciences, University of Alabama
    at Birmingham, Birmingham, AL, USA, [4] Department of
    Biostatistics, University of Alabama at Birmingham, Birmingham, AL,
    USA, [5] Nutritional Immunology and Molecular Medicine
    Laboratory, Virginia Bioinformatics Institute, Virginia Tech,
    Blacksburg, VA, USA, [6] Deakin University, Melbourne, VIC,
    Australia, [7] American University of Rome, Rome, Italy,
    [8] Nestle Research Center, Lausanne, Switzerland,
    [9] Organization for Interdisciplinary Research Projects,
    The University of Tokyo, Tokyo, Japan, [10] Ecole
    Polytechnique Federale de Lausanne, Lausanne, Switzerland,
    [11] Institute of Neuroscience and Physiology, The
    Sahlgrenska Academy at the University of Gothenburg, Gothenburg,
    Sweden, [12] Department of Infectious Diseases and
    Immunology, Faculty of Veterinary Medicine, Utrecht University,
    Utrecht, Netherlands, [13] Faculty of Science, Utrecht
    Institute for Pharmaceutical Sciences, Utrecht University, Utrecht,
    Netherlands, [14] North American Branch of International
    Life Sciences Institute, Washington, D.C., USA, 15 Technische
    Universitat Berlin, Berlin, Germany, [16] Nestle Institute
    of Health Sciences SA, Lausanne, Switzerland, [17] Division
    of Biological and Environmental Sciences and Engineering, King Abdullah
    University of Science and Technology, Thuwal, Saudi Arabia,
    [18] Laboratory of Neuroenergetics and Cellular Dynamics,
    Brain Mind Institute, Ecole Polytechnique Federale de Lausanne,
    Lausanne, Switzerland, [19] Department of Health Services
    Administration, Nutrition Obesity Research Center, University of
    Alabama at Birmingham, Birmingham, AL, USA, [20] Department
    of Psychology, University of Salzburg, Salzburg, Austria,
    [21] Analytical Food Chemistry, Technische Universitat
    Munchen, Freising, Germany, [22] Research Unit INSIDE,
    Institute for Health and Behaviour, University of Luxembourg,
    Luxembourg, Luxembourg.
        * Correspondence: Johannes le Coutre
    johannes.lecoutre@frontiersin.org, johannes.le-coutre@rdls.nestle.com.
    ---------------------------------------------------------------------------
              With the definition of goals in Nutrition Science, we are
            taking a brave step and a leap of faith with regard to
            predicting the scope and direction of nutrition science over
            the next 5 years. The content of this editorial has been
            discussed, refined, and evaluated with great care by the
            Frontiers in Nutrition editorial board. We feel the topics
            described represent the key opportunities, but also the biggest
            challenges in our field. We took a clean-slate, bottom-up
            approach to identify and address these topics and present them
            in eight categories. For each category, the authors listed take
            responsibility, and deliberately therefore this document is a
            collection of thoughts from active minds, rather than a
            complete integration or consensus.
              At Frontiers in Nutrition, we are excited to develop and
            share a platform for this discussion. Healthy Nutrition for
            all--an ambition too important to be handled by
            detachedinterest groups.
            Johannes le Coutre, Field Chief Editor, Frontiers in Nutrition.
    Sustainable Development Goals for Food and Nutrition
    (Barbara Burlingame, Chor San H. Khoo, and Dietrich Knorr)

        To deliver successfully, nutrition research needs a bold dose of
    innovation. Moving forward from the Millennium Development Goals to the
    post-2015 sustainable development goals (SDG), global nutrition appears
    to require an improved model. Under current practices, feeding the
    exploding world population necessitates to close a gap of nearly 70%
    between the amount of food available today and the projected
    availability by 2050.(1) Today, globally, an estimated 805
    million people are undernourished or food-insecure,(2) yet 1
    out of 4 calories from food goes uneaten. Meanwhile, overweight and
    obesity affect approximately two billion people, including 42 million
    children under the age of 5. Human health notwithstanding environmental
    health is also at stake. Agriculture alone accounts for about 70% of
    our global water usage and 24% of our greenhouse gas emissions. As a
    result, our strategies to overcome issues of food sustainability, food
    waste, and food loss must be multifarious and include, at the very
    least: (i) Improving the global consumption of food. (ii) Increasing
    production efficiencies on existing agricultural land. (iii) Developing
    sustainable approaches that reduce the environmental impact of food
    production, and in particular greenhouse gas emissions. Certainly, the
    impact of agriculture on climate, ecosystems, and water will have to be
    reduced, while at the same time, we will need to ensure that it
    supports inclusive economic and social development.(1)
        Systems science, the interdisciplinary field that explores the
    nature of complex systems, is perhaps the best research model we have
    for addressing the urgent needs of a precariously unhealthy planet. For
    better or for worse, nutrition imparts a quintessential challenge,
    straddling many sectors and disciplines.
        In the past, at times, the agenda for mainstream nutrition has been
    pushing sectoral lines of reasoning by implementing policies that leave
    long-standing problems unresolved, while disrupting other sectors in
    the process. Of course, nutrition is not alone in this, but the history
    of unintended consequence is long and discouraging.(3-4)
        Agriculture and health have been the mainstay sectors at the United
    Nations level, in government ministries, and in academic departments.
    Increasingly, nutrition is being recognized as an important pillar for
    the environmental sector, with biodiversity for food and nutrition
    acknowledged by the Convention on Biological Diversity,(5)
    and the Commission on Genetic Resources for Food and Agriculture
    accepting whole diets, food, and nutrients for human nutrition as
    ecosystem services.(6)
        For all their embracing of nutrition, these sectors often work at
    cross-purposes, providing many useful illustrations of policies and
    programs that undermine each other's development efforts. We have
    policies and interventions in agriculture that contribute to diet-
    related chronic disease, environmental degradation, and food
    insecurity; (4, 7) conversely, in the health sector we have
    policies and interventions that compromise agricultural
    development;(8) and in the environmental sector that lead to
    micronutrient malnutrition.(9) Agriculture in particular,
    while solving some of its own sector problems, has been associated with
    many of the environmental and human health crises we now face, which
    directly impact upon nutrition, including chemical contamination of
    food supplies, loss of agrobiodiversity, and severe environmental
    degradation.(10)
        In spite of the clear need to develop innovation for the future,
    ``systematic attempts to explore existing methods and to develop new
    technologies of more sustainable food production systems have so far
    been scarce''.(11) Although this quote is from over 30 years
    ago, it still quite accurately describes the current situation
    regarding activities related to sustainable diets and sustainable food
    systems. A sustainable development lens with a systems science approach
    offers not only a new analytical model for nutrition, but also an
    ethical and inclusive framework. Within this framework, nutrition
    encompasses more than its traditional domains and takes on issues of
    climate change,(12) biodiversity and
    ecosystems,(13) water use/waste,(14) food losses
    and waste,(15-16) sustainable forests and
    seas,(17) chemical contamination of food and water
    supplies,(18) environmental regulatory issues and food law,
    risk and risk/benefit assessments,(19) and monitoring
    adherence to and compliance with a range of relevant treaties and
    signed declarations/commitments.(13)
        With this mindset of sensitive, cross-sectoral resolve, tangible
    and specific solutions will envisage a holistic food chain integration
    taking into account a total life cycle assessment. Food and nutrition
    security must be an intrinsic component of any solution for food
    sustainability. Forthcoming strategies will also have to explore the
    potential and utilization of new raw materials.
        Improvements of food safety, storage, packaging, and
    transportation--including the use of sensor technologies--can reduce
    food losses and waste. Innovation will have to equally encompass the
    re-evaluation of existing food processing, storage, and home
    preparation operations employing existing modern toolboxes. Moreover,
    low energy, waste-free or waste-reduced processing, and preparation
    operations need to be implemented to a larger extent, including
    alternative energy sources. In the same context, water decontamination,
    recycling, and preservation tools need to be applied.
        Unintended consequences must be considered with any sustainability
    program and global solutions are not necessarily applicable in local
    contexts. For example, reducing livestock production and consumption in
    one setting may benefit both human and environmental health, while in
    another setting it may reduce further already marginal intakes of high-
    quality protein and micronutrients and marginalize grazing lands that
    are self-renewing, sustainable repositories of biodiversity. Finally,
    young engineers and scientists need to be encouraged, trained, and
    involved to tackle the challenges of the future.
        We have a planet in crisis on so many fronts. Regardless of how the
    SDGs evolve, this multi-sectoral vision of nutrition research and
    action has the potential to make meaningful, and sustainable,
    contributions.
    Identifying and Mitigating Errors in Nutritional Science
    (David B. Allison, Andrew W. Brown, and Tapan Mehta)

        ``Science,'' as Adam Smith famously said, ``is the great antidote
    to the poison of enthusiasm and superstition''.(20)
    Complementarily, Stephen Hawking has called scientists, ``the bearers
    of the torch of discovery in our quest for knowledge''.(21)
    Thus, science can be seen as having two key complementary roles--
    dispelling false beliefs, and creating new knowledge. For science to
    fulfill this joint mission, its practice must be true to its principles
    and precepts, including objectivity, methodological rigor,
    transparency, and reproducibility. Yet, there are concerns that
    departures from these precepts are too common.(22-28) Some
    have speculated that deviations from good scientific practices have
    increased in recent years due to a number of social, institutional, and
    economic factors in science.(25, 29) Others have speculated
    that the problem may be especially severe in the related domains of
    nutrition research and obesity research, perhaps because of emotional,
    economic, and other factors involved in those topics or because the
    everyday familiarity with aspects of those topics is mistaken for
    expertise.(23, 26-28) It is difficult to quantify whether
    the situation is better or worse today than in the past, or whether
    this is especially true in nutrition and obesity research compared to
    other fields. Nevertheless, it is clear that the problem exists.

           Table 1: Common Errors Noted in the Published Literature a
    ------------------------------------------------------------------------
                  Error                         Example(s) of error
    ------------------------------------------------------------------------
    Errors involving or resulting       Self-reported energy intake
     from poor measurement              (33, 118, 119)b (34) c (32) d
                                        Self-reported weights (120)
                                        b (121, 122) d
    Errors involving inappropriate      Cluster randomized trials
     choice of or incorrect study       with no degrees of freedom (123) c
     design                             Lack of control for non-
                                        specific factors, i.e., failure to
                                        isolate the independent variable of
                                        interest (124) c
                                        Non-random assignment in
                                        self-described RCTs (125) b
    Errors involving replication        Not validating prediction
                                        models in fresh samples (126) d
                                        Gratuitous replication (35)
                                        d
    Errors in statistical analyses      Inappropriate baseline
                                        testing in parallel groups RCTs
                                        (127) c (128) d
                                        Failure to appropriately
                                        manage missing data (129) c (130,
                                        131) d
                                        Not accounting for
                                        clustering in cluster randomized
                                        trials (132, 133) b (134, 135) c
                                        (136) d
    Errors involving insufficient       Changing endpoints in a
     transparency in choices made       study (137) b (138) d
     about how to analyze and present   Excessive or unacknowledged
     the data                           multiple testing [called p-
                                        hacking,(139) d investigator degrees
                                        of freedom,(140) d or p-value
                                        fiddling,(141) d among other names]
                                        (142) c (143) b
    Errors of misleadingly describing   Selectively citing only the
     past literature                    part of a study that supports a
                                        hypothesis (35) d
                                        Perpetuating citations from
                                        previous researchwithout confirming
                                        the original source (144) b
    Errors that distort the             Publication bias (145) b
     scientific record by publishing    (23, 146) d
     studies as a function of study
     outcomes
    Errors of interpretation or         Inappropriate use of causal
     communication                      language (24, 35) d
                                        Exaggerating or mis-
                                        describing results (35) d
                                        Highlighting benefits of
                                        treatment when the effects were non-
                                        significant (i.e., spin) (147) d
                                        Issuing misleading press-
                                        releases (148) d
    Errors of logic and mathematics     Unreasonable linear
                                        extrapolations (e.g., 3,500 kcal
                                        rule) (149	150) b
    ------------------------------------------------------------------------
    a Errors, examples, and references were identified in a manner neither
      systematic nor comprehensive.
    b Denotes references correcting or commenting on specific errors.
    c references in which the error in question occurred.
    d Denotes references that provide tutorials on avoiding or overviews of
      the errors.

        Several initiatives are going to be important in the coming years
    to improve nutrition as a science. First is classifying errors that
    exist in the nutrition literature. Just as Mendeleev's Periodic Table
    of the Elements led to increased understanding of chemistry and
    Linnaeus' taxonomy of life led to a framework for the study of biology,
    if we can develop a ``pathology'' or classification of these errors, we
    may be better able to quantify the situation, identify patterns,
    develop an understanding of origins, and ultimately reduce the
    occurrence and severity of these errors. In our non-systematic study of
    these issues, we see a number of categories of common errors (Table 1).
    We refer to them as errors without making any inference that they are
    intentional or unintentional errors.
        Second, there is a general movement in science for ``Transparency
    and Openness Promotion,'' formalized in ``The TOP
    Guidelines''.(30) The guidelines recognize eight standards:
    citation, data transparency, analytic methods (code) transparency,
    research materials transparency, design and analysis transparency,
    preregistration of studies, preregistration of analysis plans, and
    replication. These standards aim to improve the communication of
    science, allowing improved understanding and replicability of results.
    Because the TOP Guidelines are being adopted across fields of science,
    the field of nutrition will not have to act in isolation to improve its
    scientific practices. Instead, we can build on and work with the minds
    and resources coming from a spectrum of scientific inquiry. Indeed,
    Frontiers in Nutrition was one of the initial signatories.
        Third, there is a need to develop sound methodology for evaluating
    nutrition and diet in free-living research participants. Issues are
    continually documented with self-report diet
    methodology,(31-33) and yet dietary recommendations depend
    heavily on dietary recall data.(34) Similarly, although
    existing nutrition-related health hypotheses can be investigated using
    randomized controlled trials (pragmatic or explanatory), the field
    often relies on ordinary association tests using observational data to
    quantify evidence (35-36) that policy-makers may then use to
    create policies or guidelines. The needs here are twofold: to develop
    and implement study designs that lie in the causality spectrum between
    ordinary association tests and randomized controlled trials
    (37-38) and to develop objective, reliable data on dietary
    patterns and nutrient status.(31-33)
        We believe that by recognizing and acknowledging these problems, we
    also recognize and acknowledge that our field can do better. This will
    pave the way toward constructive efforts to reduce such problems and to
    ultimately improve the scientific foundations of nutrition science.
    Building the Foundation: Procurement of Relevant Measures and Big Data
            Analysis
    (Martin Kussmann, Josep Bassaganya-Riera, Raquel Hontecillas, Tapan
    Mehta, and Chor San H. Khoo)

        Diet is considered a key environmental factor for maintaining
    health and preventing disease. As such, we need to better understand
    the interactions of nutrition and lifestyle with an individual's
    genetic makeup in order to delay or prevent metabolic and cognitive
    decline. Nutrition science is therefore undergoing a paradigm shift to
    better leverage the potential of nutrigenomics, a discipline that is
    already transforming the field.(39) To achieve this, the
    field will need to transform its current approach to research and
    implementation actions, and to take advantage of emerging advances in
    other disciplines--research designs, methods, new technologies, big
    data analysis, and bioinformation sharing.
        The conceptual basis of gene--environmental interactions require
    not only research and technology, but also the cross-fertilization of
    disciplines: genomics will encompass other-omics, and nutrition
    research will need to take on a holistic or system biology approach
    rather than just nutrients, ingredients, or genes. Nutrition science
    now encompasses more than the classic reductionist and descriptive
    approaches to more quantitative and systems-level
    approaches.(40) Translational research to maintain health
    and prevent or delay disease onset requires a transdisciplinary
    approach that embraces the complexity of human individuality in a
    rapidly changing environment. Nutrigenomics fuels this research by
    investigating how genomic and epigenomic individuality predisposes
    dietary, health, and disease responses. It also influences how an
    individual's genome expresses itself at different omic levels
    (proteomics, metabolomics, lipidomics) in response to environmental
    factors, including nutrition. Molecular phenotyping of humans over time
    and across healthy and safe exposures and challenges have thus been
    proposed.(41)
        Both the ongoing prevalence of malnutrition and the increasing
    incidence of nutrition- and lifestyle-related chronic diseases require
    comprehensive characterization of the complex interactions between
    environment and genetic makeup. Systems thinking in human nutrition,
    environment, and health requires improvement and translational thinking
    in three areas:

      (a)  In vitro and in vivo models: a systems approach to human health
                implies rethinking of in vitro and in vivo models with
                regard to their translatability into human phenotypes:
                natural human cell models and panels of rodent strains
                should complement cancer cell lines and single rodent
                strains.

      (b)  Human intervention study designs: classical case/control designs
                of human clinical/nutritional intervention studies should
                be complemented by longitudinal crossover studies, in which
                every subject is one's own case and control. Human clinical
                study subjects should not only be assessed at homeostasis,
                but also during a challenge to, and restoration of,
                homeostasis.

      (c)  Tools for molecular phenotyping and capturing of human diet and
                lifestyle: nutrigenomic studies have typically been
                technology-driven rather than technology-rooted. Normative
                science methods and approaches need to be complemented by
                more comprehensive systems biology-based investigations
                deploying a multitude of omic platforms in an integrated
                fashion.(41) While comprehensive and
                quantitative omics are rapidly progressing in terms of data
                generation, quantitative capture and monitoring of diet and
                lifestyle have lagged behind. Non-invasive technologies are
                now providing more attractive and precise image- and
                webbased or body-wearable consumer/research
                interfaces.(42) The bottleneck in knowledge
                generation has moved from (omics and clinical) data
                acquisition to processing, visualization, and
                interpretation. Innovative tools and methods for
                statistical treatment and biological network analysis are
                now at the forefront of nutritional and biomedical
                sciences.(43)

        To achieve this transformation and advancement of nutritional
    science, it is critical to connect researchers from all disciplines
    conducting direct or indirect research in the areas, e.g., (gen) omics,
    clinicals, dietetics, food science and technology, physiology,
    epidemiology, bioengineering, analytics, biomathematics. A
    transdisciplinary approach needs to be considered--enabling a spectrum
    of communicating and sharing from fundamental laboratory research,
    patient- and consumer-relevant outputs from personalized dietary/
    nutritional counseling to monitoring/diagnostics. Progress in advancing
    nutrigenomic interventions for consumers and patients can only be
    accelerated if nutrition research is broadened to include quantitative,
    holistic, and molecular sciences.(44)
        ``Let the food be your medicine, and medicine be your food,'' a
    statement attributed to Hippocrates, the father of Western Medicine,
    delineates the impact of nutrition in human health and disease. Indeed,
    several decades of research at the interface of nutrition and
    immunology demonstrate that infectious, immune-mediated and metabolic
    diseases are safely and effectively preventable through dietary
    interventions. Nonetheless, there is a major disconnect between the
    description of nutrition-based protection from disease and an
    insufficient mechanistic understanding at the systems-level of the
    complex network interactions by which nutrition mediates clinical
    protection. As a result, a comprehensive understanding of the
    mechanisms of action underlying the actions of nutritional
    interventions and the combinatorial effects of nutrients (i.e.,
    synergistic, antagonistic, or additive) at the systems-level remains
    largely unknown. As about 70% of the immune system is located in the
    gastrointestinal tract since the gut mucosa houses the largest
    repertoire of immune cells and commensal microbiota that symbiotically
    coexist to elicit protective immunity, studying nutritional immunology
    of the gut mucosa is incredibly important.(45) Coupling
    host-nutrient-microbiota actions, enabled through computational
    modeling of the gastrointestinal tract (46-50) with systems
    immunology frameworks has the potential to predict combinatorial
    outcomes of nutrient-microbiota-immune system interactions and advance
    toward a comprehensive systems-level mechanistic understanding of how
    nutrition and foods prevent disease. Computational models of
    nutritional immunology that funnel omics and cellular data judiciously,
    coupled with systems biology models of the underlying disease/organ,
    will bridge the connection between traditional methods of nutritional
    immunology research and their effect on the whole organism, which will
    enhance mechanistic insights and translational value. Over 163
    nutrition themed systems biology markup language models (SBML) are
    already available in the Biomodels database.(51) In summary,
    applying the iterative systems biology cycle of model building,
    calibration, refinement, and validation in nutritional immunology
    research has the potential to accelerate the discovery of novel network
    biomarkers and systems-level mechanistic understanding of the action of
    dietary components on immuneresponses.
        There has been an explosion in data collection and aggregation,
    some of which can be used for public health purposes, including obesity
    and nutrition-related research. Consequently, ample opportunities
    emerge to utilize ``big data'' in the pursuit of interesting outcomes
    and effectiveness studies related to nutrition and obesity using
    techniques such as quasi-experimental approaches. These approaches,
    when assumptions are satisfied, are intermediate between ordinary
    association tests and randomized controlled trials (37) in
    terms of presenting evidence for causality. In this article, the term
    ``big data,'' which is often used subjectively, refers to very large
    amounts of data: structured and unstructured that may also increase
    over time rapidly.(52) These types of data are collected by
    both the public and private sectors and increasingly require a
    distributed architecture to manage them efficiently. Big data analysis
    has generally referred to the confluence of statistical, machine
    learning and computational approaches to synthesize and analyze these
    large amounts of data. Administrative data, such as micro-level data
    aggregated by governments as well as private companies, can be used to
    evaluate the effectiveness of pharmacological and surgical
    interventions. In fact, private companies have started collecting
    unprecedented amounts of data with some companies specializing in data
    linkages. For example, companies such as Optum not only aggregate
    claims data from private insurance companies but are able to provide
    linked clinical data from the corresponding electronic health records
    (EHR). Data linkages are an extremely powerful tool since they allow
    researchers to answer questions that are otherwise not accessible using
    a single data source. For example, claims data do not provide
    information about the height and weight of an individual, but the
    linked clinical data do. Similarly, the increasing availability of EHR
    data and the initiatives to link these EHR data with genomic data can
    enable us to pursue a variety of studies, including pharmacogenetic and
    precision medicine studies. One of the challenges in accessing and
    leveraging ``big data'' is the resources, including the associated cost
    of purchasing the data, especially from private companies.
    Collaborations between industry and academic researchers are essential
    to fully exploit the data and to overcome logistical
    challenges.(53-54)
        So far, big data analysis has primarily focused on high-dimensional
    prediction models. The data mining and statistical toolkit for such
    approaches includes, but is not limited to, techniques such as
    boosting, random forests, classification and regression trees, and
    lasso-like penalized regression models.(53) While randomized
    control trials are considered gold standards, there are a variety of
    methods and designs that may allow us to generate evidence that may lie
    in the spectrum between purely association and definitively causal.
    Coupled with ``big data'' is an opportunity to estimate a degree of
    causality using techniques such as high-dimensional propensity score
    and differential comparison approaches to provide evidence that is
    indicative of causality.(55-56) There is also a potential to
    use instrument variable approaches, used commonly in health policy
    studies, by identifying appropriate instruments from ``big data.''
    Recent attempts to develop methods that enable to provide a degree of
    causal evidence are very encouraging and can allow us to maximize the
    potential of ``big data''.(57-58)
    Authenticity and Safety of Foods
    (Michael Rychlik)

        The authenticity of food is generally related to one or more of the
    following attributes: geographic origin, type of agricultural
    production, species and kind of raw materials, or certain process
    qualities such as sustainability or ecological foot print.
        Regularly uncovered crises of food adulteration underline the
    sensitivity of consumers to this issue. Apart from meat, foods that are
    often adulterated are olive oil, fish, organic foods, spices, tea,
    cocoa, coffee, and nuts.
        In recent years, there has been tremendous progress in high-
    resolution methods to elucidate the molecular fingerprint of food. On
    the genetic scale, apart from classical polymerase chain reaction, new
    developments of isothermal amplifications or next generation sequencing
    will enable more accurate identification of species.
        On the protein level, specific biomarker peptides can be used. For
    a fingerprint of metabolites, the new methods of non-targeted and
    targeted metabolomics already allow a specific authentication. In this
    field, the methods currently showing the best resolution are Fourier
    transform ion cyclotron mass spectrometry (FT/ICR-MS) or nuclear
    magnetic resonance (NMR) spectroscopy.(59) These new
    methodologies generate ``big data,'' from which the relevant
    information is only accessible when applying novel bioinformatics
    approaches.
        Regarding food safety, microbiological decay and foodborne
    infections still play an important role. However, contaminants also
    endanger the safety of all links in the whole food chain. The recent
    discoveries of process contaminants encompass simple molecules, such as
    acrylamide, furan, benzene, styrene, as well as more complex compounds
    such as 3-monochloropropane-1,2-diol (MCPD) esters. An end of new
    discoveries cannot be foreseen yet and we may assume that the sum of
    all these contaminants has a significant impact on life-style diseases
    such as cancer. Further new contaminants arise from packaging materials
    such as mineral oil saturated hydrocarbons (MOSH) or mineral oil
    aromatic hydrocarbons (MOAH), and pollutants from the environment such
    as the polyfluorinated alkyl substances (PFAS). Moreover, the historic
    toxin arsenic is more relevant than ever as rice and rice products are
    often contaminated and the mechanisms of arsenic carcinogenicity are
    still under controversial discussion.
        Generally, risk assessment of food contaminants or residues is
    predominantly performed on single compounds. However, almost completely
    missing is an assessment of the combined effects of toxins, be it
    within one group of compounds or spanning various structural groups.
    The current concept for assessing combinatorial effects is that of
    cumulative assessment groups (CAGs), which, e.g., assess the cumulative
    potency corrected dose of acute reference doses (ARfD) for pesticides
    showing the same mode of toxic action.(60) However, this
    approach is still preliminary and lacks comprehensive confirmation.
    The Science Behind Food-Related Behavior in Humans
    (Adrian Meule, Chor San H. Khoo, and Claus Vogele)

        Numerous environmental, social, and individual factors influence
    human food choice and intake.(61) In Western and Westernized
    societies, household expenditures and dietary energy availability
    decreased for unprocessed or minimally processed foods in the last
    decades while they increased for convenience foods and processed
    products.(62-63) An environment where there is easy and
    frequent accessibility to food, and where cues signaling food are
    ubiquitous, requires constant self-monitoring and -regulation in order
    to prevent or manage weight gain.(61) This, however, can be
    a highly effortful endeavor, leading many people to struggle with long-
    term weight maintenance. As evident from data from the last century,
    these self-regulatory efforts are made more difficult by increased
    consumption of energy-dense palatable foods and ingredients (e.g.,
    sugar, fat, and salt).(64) As a result, some have argued
    that these foods might have an addictive potential and that a subset of
    individuals who have difficulties in controlling consumption of these
    foods may be addicted to them.(65-68)
        In the scientific literature, the association between food and
    addiction and the actual use of the term food addiction has a long
    history, dating back to the 1950s and even earlier
    times.(69-70) Not until recently, however, have researchers
    tried to more precisely define what is meant by food addiction and to
    systematically investigate its validity, as a consequence of which the
    number of publications, including the term food addiction, increased
    substantially over the past 5-6 years.(65, 71) In humans,
    research on food addiction has been promoted by the Yale Food Addiction
    Scale (YFAS), a self-report questionnaire developed in 2009, which
    measures symptoms of addiction-like eating based on the diagnostic
    criteria for substance dependence as outlined in the fourth version of
    the Diagnostic and Statistical Manual of Mental Disorders (DSM-
    IV).(72) Since 2013, these diagnostic criteria have been
    revised in the fifth version of the DSM and a new version of the YFAS,
    which has been adapted accordingly, is currently under
    way.(73)
        Although research on food addiction is growing, it remains a
    controversial and debated topic with many researchers questioning the
    validity of the food addiction concept based on conceptual
    considerations or physiological mechanisms.(74-78) To
    address these issues, more and better human studies are needed to
    resolve questions related to, for example, whether animal models of
    food addiction are transferable to human eating
    behavior.(79-80) These controversies, in particular, lead us
    to argue that food addiction research in humans is still in its
    infancy, that it would be premature to conclude that some foods are
    addictive, and that research efforts to clarify this will further
    increase in the years to come.
        There are numerous avenues for future directions, which may
    include, but are not limited to: how do we define and harmonize
    definitions of food addiction? What are the implications of changes in
    the diagnostic criteria for substance dependence in the DSM-5 for food
    addiction? (73) Are all addiction criteria (as described in
    the DSM-5) equally applicable to human eating behavior? If not, does
    this obliterate the concept of food addiction? (81) How can
    food addiction be measured in humans other than using the YFAS and
    which methodological improvements need to be made to better design
    human behavior studies, including randomized controlled trials?
    (72) How relevant is the concept of food addiction for the
    treatment of obesity or binge eating and in public policy making? If it
    is relevant, how can it best be implemented? (70, 82) What
    are the disadvantages (if any) of the concept of food addiction?
    (83-85) How can animal models of addiction-like eating be
    improved to more specifically reflect relevant processes in humans?
    (86) Which foods are possibly addictive? (87) Can
    addiction-like eating actually be reduced to the addictive effects of
    substances or should the discussion about ``food addiction'' rather be
    replaced by a discussion on ``eating addiction''? (88)
    The Molecular and Physiological Science Underlying Nutrition and Brain
            Health
    (Pierre Magistretti, Johannes le Coutre, and Suzanne L. Dickson)

        Cognitive decline, dementia, Alzheimer's disease, and other age-
    related neurological diseases are on a rise in high income countries as
    well as in low and middle income countries.(89) Achieving
    and maintaining brain health is a lifelong endeavor with identifiable
    targets that are specific for each period in a lifetime. Thus,
    targeting cognitive development in the early phases of life and
    preventing cognitive decline during aging are priorities for any
    preventive or interventional approach. While pharmacological approaches
    can only be envisioned for brief periods of time and, for the most
    part, have been unsuccessful, nutritional approaches are implementable
    for extended periods of time. Initiatives on brain health should
    incorporate a nutrition-based approach that can be implemented
    throughout the different phases of life.
        In order to identify valid nutritional approaches for brain health,
    it is important to better understand the mechanisms that are at the
    basis of brain energy metabolism regulation. Key advances have been
    made in recent years in the identification of the molecular and
    cellular mechanisms that regulate the delivery of energy to active
    neurons. In particular, an active metabolic exchange has been
    characterized between neurons and astrocytes with specific molecular
    steps that can become targets for nutritional interventions.
        For the identification of the efficacy of such nutritional
    interventions, means for appropriate monitoring of markers need to be
    defined. This can be achieved by monitoring with brain imaging
    techniques, structural markers with morphometric approaches and
    myelination with MR as well as functional activation with fMRI, PET,
    EEG, and MRS, coupled with neuropsychological tests monitoring
    cognitive performance, motivation, and attention. The utility of these
    technologies goes beyond brain health and many of these approaches are
    being used to validate, in humans, the neuroscience of nutrition that,
    so far, has only been conducted in rodent models.(90-91)
        There is no doubt that targeting the molecular steps of brain
    metabolism with nutritional interventions and monitoring their
    structural and functional outcomes in vivo in humans, in particular
    regarding cognitive performance, represents a promising approach for
    developing nutritional interventions for achieving brain health that
    can be maintained on the long term. Meaningful nutrient intake and
    nutritional intervention likely has an impact on the development of
    cognitive and behavioral performance measures, thereby determining our
    health span throughout life. Brain imaging studies on infants
    demonstrate how breast milk promotes healthy neural growth and early
    white matter development.(92)
        Nutrients also engage brain pathways linked to metabolic control,
    appetite, and food-linked behaviors. There has been a general
    expectation that it must be possible to use food formulation/
    composition to control how much and what we eat by altering the
    satiating and/or reward value of food combinations.(93-94)
    Currently, we lack a sufficient scientific evidence base that certain
    ``unhealthy'' foods fall short of ``healthy'' foods in their ability to
    induce satiation, limit hunger, or reduce hedonic over-eating.
    Moreover, it has not yet been demonstrated that any food or combination
    of foods has beneficial effects on appetite and energy intake of
    sufficient duration or magnitude to impact on body weight or metabolic
    health.(95) This is a new and emerging field for which major
    advances are likely to progress through a better understanding of how
    nutrients communicate with the appetite-regulatory brain networks.
    Nutrient-brain communication could be direct but likely engages
    intrinsic physiological control systems. For example, when we eat,
    sensing mechanisms in the gut signal information about the amount and
    content of the food to the brain by nervous and endocrine afferent
    signals. Indeed, gut-derived hormones such as ghrelin and glucagon-like
    peptide 1 communicate with hypothalamic and brainstem areas linked to
    energy balance but also to brain areas processing the reward value of
    food and even brain areas linked to emotion and
    cognition.(96-97) Thus, while it seems clear that appetite-
    regulating hormones have a capacity to redirect behaviors important for
    governing how much and what we eat, the extent to which nutrients can
    control these behaviors through engaging intrinsic endocrine signals
    remains to be elucidated.
        A related question is whether specific nutrients or food
    combinations can act on the brain to reinforce their own intake,
    leading to addictive-like over-consumption. As reviewed recently
    (88) and as mentioned already in the previous section, it is
    very difficult to demonstrate in humans or rodents that foods act on
    the brain in a manner similar to addictive drugs, causing individuals
    to become addicted to them. It was suggested therefore that the term
    ``eating addiction'' rather than ``food addiction'' should be used to
    better describe addiction-like behavioral over-eating disorders. If it
    becomes possible to diagnose this patient group, e.g., through
    combining questionnaires about addictive-like behavior for food with
    brain imaging,(98-99) there will be a large public health
    impact on treatment and prevention strategies. Additionally, industrial
    stakeholders and politicians will need to find solutions to circumvent
    or treat eating addiction.(88)
    The Science of the Human Microbiome
    (Dietrich Knorr and Chor San H. Khoo)

        The human body harbors over eight million microbial genes, over
    10,000 species, and plays host to over a trillion microbes. Microbial
    cells outnumber human cells by a factor of 10.(100) As a
    result, there is considerable interest to better define and understand
    the microbial role in host physiology, health, and disease etiology. In
    the last decade, there has been a tremendous surge in microbiome
    research funded by programs such as the Human Microbiome Project (HMP)
    and the MetHIT Program. Advancing new and multiple technological
    approaches--whole genome sequencing, metagenomics, high-throughput-
    analysis, proteomics, transcriptomics, cultivation, metabolomics, and
    bioinformatics--has led to new insights into microbial variety and
    abundance in 15-18 body sites, including the oral cavity, skin, airway,
    gut, and vagina, from 242 healthy participants in the largest cohort
    study to date. Findings from this research were published in two
    seminal papers in 2012 by the Human Microbiome
    Consortium.(100-101) The HMP study has the largest
    collection of data on abundance and variety of the human microbiome,
    with 5,177 unique microbial taxonomic profiles from 16S ribosomal RNA
    genes, more than 3.5 terabases of metagenomic sequence, and 800
    reference strains isolated and sequenced.(100) Noteworthy
    observations from the HMP study are outlined in Table
    2.(102)

         Table 2: Variation in Microbial Ecology Among Individuals (102)
    ------------------------------------------------------------------------

    -------------------------------------------------------------------------
    Each person's microbiome is unique and no two individuals have the same
     microbiome (102) However, in spite of individual microbial differences,
     different individuals can still be considered healthy
    Microbial communities across varying body regions may predict some
     characteristics such as breast fed history and educational level
    Microbial communities from different body regions from an individual
     were predictive for others. For example, the oral community can be used
     to predict the gut community
    Overall, low relative numbers of pathogens have been observed
    Strong site specialization but considerable variation in diversity and
     abundance of each habitat's signature microbes among subjects
    Strong functional stability. This means that while the microbial
     compositions were widely different, the functionality is similar. This
     suggests flexibility to develop microbial communities that can provide
     similar performance
    Wide variation in patterns of alpha and beta diversity (alpha-diversity
     within a site; beta diversity among subjects)
    Correlations between ethnicity and microbiome composition across all
     body habitats
    A positive correlation of vaginal pH to microbial diversity (higher pH
     having higher diversity)
    An association of age with skin microbiome-associated metabolic pathways
     and oral microbiome composition
    ------------------------------------------------------------------------

        Translating learnings from emerging microbiome and health research
    presents exciting opportunities for future food and nutrition
    development. The use of microbes in food product development is not
    new. Fermented products are widespread and common in the marketplace.
    Food biotechnology has been in existence for more than 8,000
    years.(103) The potential health impact of gut microbiota
    has been postulated by Metchnikoff (104) and since then,
    numerous related research results have been
    provided.(105-107) Probiotics are supplied in starter
    cultures and thus need to be preserved for transportation and use. As
    the highest possible cell density is required, losses that occur during
    processing, transportation, and storage, including in products, are
    detrimental. Consequently, approaches to increase and retain
    physiological fitness have been explored.(108-109)
        Emerging capabilities to characterize microbial communities and
    their functions in the oral cavity present insights into the role
    microbes may play in taste and olfaction, and present new opportunities
    to further personalize and refine food products to better suit
    individual taste and palatability preferences. Oral pre- and probiotics
    may be an opportunity for innovation.
        These emerging advances in human microbiome structure, diversity,
    and function present exciting new opportunities for new food products,
    ingredients, or dietary approaches that can be used for supporting
    daily health, direct or adjunct intervention for risk reduction, or for
    new therapeutics for symptom reliefs (IBS). However, to advance these
    undertakings, several key questions need to be addressed. How easy is
    it to translate microbiome research to food and dietary applications?
    Limited well-designed studies have been performed that explore the
    impact of food and diet on microbial ecology and function. What
    biomarkers are available or need to be developed to understand how food
    and diet impact on the microbiome (gut, gut-brain, gut-kidney, etc.)?
    What microbial combination will be best suited for achieving specific
    outcomes? Of challenge is the ability to identify and separate the
    ``good'' from the ``bad'' microbes that can present foodborne illness
    or exacerbate disease risks. Gene sequencing and whole genome
    sequencing technologies have been used to diagnose and trace food
    contamination, and are now also applied in medicine. How can current
    microbiome research be easily translated for food and product
    applications? How easy is it to transfer available technologies and
    tools already developed for use in food and nutrition applications?
        In addition, there remains room for improvement when translating to
    innovative or tailor-made products. Needs and opportunities include
    process generated structures, which impact on food properties (process-
    structure-function relationship) as outlined in the European Technology
    Platform Strategic Research Agenda (ETP SRA) (2007; 2012; 2014) for
    designing tailor-made foods for the targeted release of essential food
    constituents at points of need to support human microbiota growth and
    metabolic fitness. This needs to include the entire human digestion
    system encompassing the chewing apparatus, mouth microbiota, and
    enzymes. Moreover, food can contain viable microbial cultures as well
    as active enzymes. Understanding their role in and during digestion as
    well as their impact on gut, mouth, and skin microbiota may lead to the
    development of new food design concepts with targeted nutritional
    benefits.
        Finally, emerging technologies are being introduced to the food
    processing area, including high hydrostatic pressure, pulsed electric
    fields, and atmospheric plasma. Little is known about their impact and
    function with regard to the human microbiota. These technologies could
    open new avenues for process-function-structure relationships as well
    as provide foods with metabolic properties not achieved via traditional
    processing.(36)
    Nourishing the Immune System and Preventing Disease
    (Johan Garssen, Willem van Eden, and Josep Bassaganya-Riera)

        Whereas the disciplines of pharmaceutical and nutritional sciences
    have evolved separately in the Western world, for Asia these two
    research areas have been connected for centuries. However, today, with
    the ever-growing burden of chronic diseases in modern societies, the
    high relevance of specialized nutrition in both prevention and
    therapeutic approaches receives increased attention and recognition.
    The gap between food and pharma is narrowing.(110) One
    reason might be that, scientifically, the evidence for the so-called
    multi-target or polypharmacology approaches aimed at disease management
    is growing. Medical nutrition is beginning to be recognized as a unique
    and potentially powerful area in Western societies at the interface
    between food and pharma.
        Medical nutrition targets innovative nutritional therapies,
    offering healthcare professionals solutions to effectively manage
    disease-related malnutrition and specific disease states. Medical
    nutrition is and will be increasingly understood as a useful and
    sometimes even essential component in the management of patient health.
    Many medical conditions can be managed better when patients are
    receiving a specialized diet adapted to their unique circumstances.
    Sometimes, the constraints to appetite may be physical, as in the case
    of stroke patients who may find it difficult or impossible to swallow,
    or of young children with neurological disabilities. Sometimes, the
    problem may simply be insufficient intake, caused by the loss of
    appetite. It is well known that many chronic diseases are associated
    with malnutrition, a phenomenon that is not solely based on body mass
    index or body weight. Many obese patients suffer from specific
    malnutrition. Examples of disease areas that might be associated with
    specific malnutrition are cancer, stroke, and COPD. However, frail or
    elderly people are treated and fed with this type of medical nutrition
    as well. Medical nutrition might bring solutions and support to these
    cases across a broad range of care settings--in the hospital, in the
    care home, or in the community. It contains unique compositions of
    specific nutrients that would be impossible or impractical to achieve
    through normal food intake alone. In most cases, it is administered via
    the gastrointestinal tract orally or with a feeding tube, utilizing the
    natural route for nutrient digestion and absorption. These cases are
    underpinned by a unique scientific rationale, preclinical and clinical
    research, and health economic evaluation making it very similar to the
    traditional pharma approach. By making medical nutrition an integral
    part of care, patient outcomes are significantly improved. Lower
    healthcare costs by shortening hospital stays and keeping patients
    independent for longer are key outcomes for medical nutrition
    intervention. The food for special medical purposes (FSMP) is the
    regulatory directive involved with the quality/safety and efficacy of
    medical foods.
        Another and unique medical area for which medical nutrition is
    aimed is disease-specific (the so-called disease targeted) medical
    nutrition. This type of medical nutrition is a unique, effective,
    therapeutic nutritional intervention for patients with, e.g., a
    clinical need to avoid certain nutrients due to specific diseases or
    conditions where normal food intake is harmful. Examples are inborn
    errors of metabolism such as phenylketonuria (PKU) or severe cow's milk
    allergy and childhood epilepsy. Ketogenic therapy during refractory
    epilepsy can reduce seizures significantly. Other examples for disease-
    specific medical nutrition are science-driven concepts containing
    different and uniquely selected nutrients that can act in an orchestra
    leading to a delay in disease progression. Validated examples have been
    described for Alzheimer's, HIV, diabetes, and
    cancer.(111-114)
        Disease-targeted medical nutrition can be aimed at conditions such
    as chronic inflammation. These inflammatory conditions are on the rise.
    This is caused by changes in life-style, food consumption patterns, and
    aging. Inflammation-associated conditions, such as atherosclerosis,
    type 1 and type 2 diabetes, obesity, Alzheimer's disease, and many
    others, are a growing burden to health budgets. Inflammatory conditions
    are thought to result from failing mechanisms of immunological
    tolerance. Of these mechanisms, deficient suppressive activities of a
    specialized subset of T cells, called regulatory T cells (Tregs), are
    being recognized as a major factor in the failure of immunological
    tolerance. A start has been made with the definition of antigen-
    specific Tregs with a broad anti-inflammatory effect, such as, for
    example, those that recognize inflammation-associated stress-
    proteins.(115) Herewith, the restoration of this regulation
    will be a widely sought goal, also for the field of nutrition. A
    telling example of what may be possible is the following. Wieten, et
    al., have shown that the up-regulation of stress-proteins, such as heat
    shock protein 70 (HSP70), in the cells lining the gut, leads to the
    local induction of Tregs.(116) Working with a model of
    chronic and relapsing arthritis, it was found that HSP70 was also
    induced in Peyer's patches and the induced HSP70-specific Tregs were
    having a systemic effect seen to fully control arthritis. This up-
    regulation was achieved by the oral administration in mice of
    carvacrol, an essential oil of Oregano species. It showed that our diet
    may contain effective coinducers of stress-proteins and that these co-
    induced proteins can elicit anti-inflammatory activity in the immune
    system. Similar activities have now been described for other food
    components.(117) Therefore, especially for the diets of the
    aging individual, substances with anti-inflammatory activities will be
    an attractive component. In the field of veterinary medicine and food
    animal production, restrictions are now being imposed on the use of
    antibiotics, certainly on the use of antibiotics as growth-enhancers.
    Also here, feed additives are searched with the purpose of controlling
    inflammation and thereby enhancing weight gain.
        In combination with drugs, medical devices and lifestyle
    modification, medical nutrition, and immune system targeted
    nutraceuticals can play an essential role in health care and precision
    medicine. Expectedly, it will lead to lower costs of care: fewer
    complications, shorter hospital stays and reduced mortality, and the
    reduction of disease manifestations.
        Over the coming years, Medical Nutrition and Nutraceuticals have
    the opportunity to be accepted as a bridge between food and traditional
    pharma approaches--not as isolated therapy but as part of integrated
    systems-wide health care. Additionally, pharma often is focusing on a
    monotherapeutic approach (one molecule one target) and medical
    nutrition will be recognized as the multi-target approach for disease
    management. Regulation and acceptance depends on national and
    international guidelines. Changes in regulation for medical nutrition
    are to be expected since medical nutrition is a relatively new
    therapeutic area that falls between different regulations and
    guidelines. For instance, in the USA, under section 5(b) of the Orphan
    Drug Act [21 U.S.C. 360ee(b)(3)], a medical food is formulated to be
    consumed or administered enterally under the supervision of a physician
    and which is intended for the specific dietary management of a disease
    or condition for which distinctive nutritional requirements, based on
    recognized scientific principles, are established by medical
    evaluation. Thus, from a regulatory perspective, medical foods are
    different than dietary supplements in that claims for medical foods can
    allude to disease management whereas dietary supplement claims cannot.
    Medical foods are exempted from the labeling requirements for health
    claims and nutrient content claims under the Nutrition Labeling and
    Education Act of 1990. In order to be a medical food, a product must
    meet the following criteria: to be a food for oral or tube feeding, the
    product must be labeled for the dietary management of a specific
    medical disorder, disease, or condition for which there are distinctive
    nutritional requirements, and the product must be intended to be used
    under medical supervision. Essentially, medical food comes into play
    when dietary management cannot be achieved by the modification of the
    normal diet alone. For instance, medical foods could be used to replete
    key metabolic components that might be depleted in diabetes or
    inflammation. Only translational research and randomized, placebo
    controlled double-blind clinical trials can validate these new
    concepts.

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        Conflict of Interest Statement: The authors declare that the
     research was conducted in the absence of any commercial or financial
     relationships that could be construed as a potential conflict of
     interest.
        Copyright 2015 Allison, Bassaganya-Riera, Burlingame, Brown, le
     Coutre, Dickson, van Eden, Garssen, Hontecillas, Khoo, Knorr, Kussmann,
     Magistretti, Mehta, Meule, Rychlik and Vogele. This is an open-access
     article distributed under the terms of the Creative Commons Attribution
     License (CC BY). The use, distribution or reproduction in other forums
     is permitted, provided the original author(s) or licensor are credited
     and that the original publication in this journal is cited, in
     accordance with accepted academic practice. No use, distribution or
     reproduction is permitted which does not comply with these terms.

                                  attachment 5
    Unintended Consequences of Obesity-Targeted Health Policy
      Virtual Mentor
      American Medical Association Journal of Ethics
      April 2013, Volume 15, Number 4: 339-346.
      Policy Forum
      Andrew W. Brown, Ph.D., and David B. Allison, Ph.D.

              L'enfer est plein de bonnes volontes et desirs. [Hell is full
            of good wishes and desires.]
                                  Saint Bernard of Clairvaux.[1]

        The conflict between individual freedom of choice and a
    government's obligation to protect its citizenry from threats to public
    health is often at the center of health policy debates. This has played
    out in New York City, for instance, with freedom of choice being the
    rallying cry of those opposed to a citywide ban on large containers of
    beverages,[2] while saving lives through health-motivated
    policies is offered as the justification for the
    regulations.[3] However, several other ethical concerns
    exist related to the creation or implementation of public policy.
    Herein, we will discuss a catalog of ethical concerns identified by M.
    ten Have, et al.[4] related to policies intended to prevent
    or treat obesity.
        We discuss these ethical concerns in light of two key issues: (1)
    Under which circumstances does obesity merit being considered a public,
    as opposed to simply a common, health concern? Whether or not obesity
    is considered a public health concern is important in deciding whether
    impinging on individuals' rights may be warranted. (2) How plausible is
    it that a given policy or program will have negative unintended
    consequences? These consequences are important to consider when
    deciding if a policy should be implemented. We then suggest strategies
    for minimizing ethical and other unintended adverse consequences of
    obesity-targeted health policies.
    Ethical Concerns in Obesity-Targeted Health Policies
        In ``Ethics and Prevention of Overweight and Obesity: An
    Inventory,'' Marieke ten Have and colleagues identify ethical concerns
    posed by 60 actual or proposed public policies, corporate initiatives,
    and behavior recommendations intended to prevent or treat
    obesity.[4] One group of ethical concerns comprises direct
    negative consequences of a program, including physical and psychosocial
    harm, dissemination of inadequate information, and creation or
    exacerbation of inequalities. The other group of ethical concerns
    encompasses disrespect for individuals and their rights and values,
    including transgressing personal and cultural values of eating,
    invading privacy, assigning fault for obesity, and abridging freedom of
    choice. Typically, more than one of these concerns exist with varying
    degrees of severity for any proposed policy or recommendation, but
    often the debate is dichotomized as a desire to promote health versus a
    desire to preserve individual liberty.
        The complexity of ethical considerations in obesity policymaking
    can be demonstrated by a policy that would allow the government to
    remove an obese child from his or her home (see Table 1). Note that the
    pros and cons listed in the table are not necessarily weighted by
    importance because importance is dependent on individual perspectives
    and specific situations. Here, the assumed benefit of the policy is
    that removing the child from the home will improve his or her weight
    and therefore health, though that assumption is itself
    contentious.[5] As the table shows, the ethical
    considerations are far more complex than health vs. freedom of choice.
    To add to the complexity, a given individual may consider one specific
    ethical concern more important than all others: for health advocates
    the physical health implications may outweigh all other concerns, while
    for the parents the sanctity of the parent-child relationship may be
    paramount.[6]

     Table 1. Ethical Concerns of an Example Policy in Which the Government
    Is Allowed To Remove Obese Children From Homes. The Ethical Concerns Are
      Not Necessarily Equally Prevalent and Do Not Necessarily Carry Equal
                                     Weight
    ------------------------------------------------------------------------
       Ethical concern [4]        Pro-policy view        Anti-policy view
    ------------------------------------------------------------------------
    Physical health            Improved health if    There may not be the
                                professionals can     resources or knowledge
                                affect weight.        to improve the health
                                                      of the removed child
                                                      in the long term.
    Psychosocial well-being    Obesity is            Removing children from
                                associated with       parents may be more
                                psychological         traumatic than the
                                disorders.            obesity.
    Equality                   All children have     Obesity affects the
                                the right to a        poor and minorities to
                                healthy childhood     a greater extent, so
                                and life.             this policy will
                                                      disproportionately
                                                      target these groups.
    Informed choice                                  Parents are no longer
                                                      able to make decisions
                                                      for their child.
    Social/cultural values     The social value      The social value placed
                                placed on fitness     on parent-child
                                and health is         relationships is
                                upheld.               violated.
    Privacy                                          The family's and
                                                      child's privacy may be
                                                      compromised.
    Attribution of             Responsibility for    The parents are
     responsibility             the child's obesity   directly or indirectly
                                is shared among       blamed for the obesity
                                society and medical   and stigmatized.
                                professionals.
    Liberty                                          The parent's and
                                                      child's liberties are
                                                      violated.
    ------------------------------------------------------------------------

    Under Which Circumstances Should Obesity Be Considered a Public Health
            Concern?
        The example in Table 1 has ramifications for specific individuals
    in specific circumstances and particularly focuses on minors, who are
    broadly considered not fully responsible for their own actions. The
    justifications and ramifications of broad health-targeted policies
    affecting ordinary adults are quite different.
        Before proceeding, we must distinguish between two distinct uses of
    the phrase ``public health'' as a prefix to terms such as ``problem,''
    ``concern,'' or ``issue.'' The phrase is often used merely to convey
    that the problem affects a large number of people. The term
    ``population health'' is emerging to express this idea.[7]
    But in debates about policies that may impinge on individual rights and
    values, the phrase is used more specifically to denote health problems
    in which individuals' actions may not be sufficient to protect them
    from ill health and collective action may offer such protection.
    Examples of the latter definition include certain infectious diseases
    from which protection can be afforded by mass vaccination and toxins in
    public drinking water supplies, which can be minimized by a variety of
    government policies.
        Using the more specific definition, it is not clear that obesity
    qualifies as a public health concern in all
    circumstances.[8] When considering some putative
    contributors to obesity, such as adenovirus 36 or environmental
    endocrine disruptors,[9] the definition does seem to apply:
    individuals generally cannot fully detect and protect themselves from
    exposure to these factors by their own action, and collective action at
    a societal level mandated by government policies might do so. However,
    when considering some other putative contributors to obesity such as
    ingesting excess energy or being insufficiently active, there generally
    are not external unavoidable constraints, as opposed to influences, on
    individuals. Thus, collective action to protect individuals from
    undetectable or unavoidable contributing factors is not required in
    such cases.
        At this point, we should address a related argument. This is
    perhaps the most commonly used argument to justify policies about
    obesity: obesity is costly to society, largely through the healthcare
    system, and this justifies collectively infringing upon individual
    liberty to decrease obesity. We do not agree with this argument.
    Regardless of the cost of obesity, that cost itself does not
    necessarily justify society's imposing such policies. The fact that one
    party (society in this case) voluntarily takes on an obligation to
    cover some costly benefit to a second party (individual citizens in
    this case) does not necessarily give the first party the right to
    dictate the behaviors of the second party. There are several
    alternatives which include society's not volunteering to take on the
    obligation, society's taking on the obligation but distributing the
    costs equitably to its members (e.g., charging obese persons more for
    health coverage), or society's voluntarily accepting the obligation and
    then simply agreeing to be ``magnanimous'' and bear the additional
    expense of costly behaviors in the interests of preserving individual
    liberty.
        This is not to say that obesity is not a problem. Obesity is
    associated with many chronic diseases, decreased productivity, and
    psychosocial difficulties. But if a health policy targeting a putative
    cause of obesity does not address an issue in which individuals'
    actions are insufficient to protect themselves from obesity, then the
    policy may be unwarranted regardless of cost.
    Good Intentions, Unintended Consequences
        Various policy advocates insist that obesity needs to be addressed
    by public policy, either because they reject the definition of public
    health provided above or because they believe action must be taken
    despite obesity's not specifically being a public health concern.
    Innumerable policy recommendations have been proposed or enacted in an
    effort to reduce obesity, from ``sin'' taxes [10] and
    ``psychic'' taxes [11] to information campaigns
    [12] and alterations to the built
    environment.[13] In some cases, the scientific evidence
    demonstrates fairly clearly that the recommendation will not
    substantially reduce obesity, which means these policies not only raise
    ethical concerns but may have no beneficial outcome; other
    recommendations are simply equivocal--the potential exists for benefits
    and harms--and the balance between ethical consequences and health
    benefits is thus uncertain.[14]
        When the outcomes of a particular proposal are uncertain,
    especially for interventions grounded in ``common sense,'' one could
    ask, ``How could it hurt to try?'' Some ways various policies could
    hurt, despite good intentions, were previously
    highlighted.[15] Such negative consequences include direct
    negative effects and encroachment on individual freedom like the list
    from ten Have, et al., but also include direct costs of resources,
    damage to scientific and political credibility, and distraction from
    more promising efforts and policies. In fact, direct, unintended
    negative consequences of some policy proposals have been demonstrated
    (Table 2).

     Table 2. Unintended Consequences of Actions Intended To Affect Obesity
    ------------------------------------------------------------------------
                                                      Documented unintended
             Action              Good intention            consequence
    ------------------------------------------------------------------------
    Tax sugar-sweetened      Decrease energy intake  Increased consumption
     beverages (SSBs).        to decrease weight.     of beer beyond the
                                                      decrease in sugar-
                                                      sweetened
                                                      beverages.[17]
    Alert patients to their  Make the patient aware  Patients may feel
     heavy weight status.     of a problem as a       stigmatized, become
                              first step in           depressed and eat
                              addressing it.          more, and avoid future
                                                      appointments.[16]
    Labeling calories on     Awareness of calories   Purchases of SSBs
     vending machine          will result in          increased in some
     beverages.               decreased               settings.[18]
                              consumption.
    Label ``unhealthful''    Increase ``healthful''  Increased selection of
     foods with messages      behaviors and           an ``unhealthful''
     that encourage           decrease                snack.[19]
     consuming fruits and     ``unhealthful''
     vegetables.              behaviors.
    Describe certain         Decrease caloric        Consumers consumed more
     restaurants and foods    consumption and shift   calories in side
     as more ``healthful''    consumption toward      dishes and beverages,
     and ``low-calorie.''     ``healthful'' foods.    and underestimated
                                                      total meal calories
                                                      when choosing
                                                      ``healthy''
                                                      restaurants or main
                                                      dishes.[20]
    Labeling calories and    Awareness of calories   Men ate more
     removing value pricing   and eliminating value   calories.[21]
     on menu items.           pricing will decrease
                              energy consumption.
    Discourage chocolate     Decrease caloric        Chocolate consumption
     consumption.             consumption.            increased for some
                                                      women in some
                                                      circumstances.[22]
    Encourage children to    Children prompted to    Children ate as many
     consume fruits by        eat fruits will         calories when prompted
     incorporating them       increase consumption    by fruit games as when
     into games.              of ``healthful''        prompted by energy-
                              foods and decrease      dense-snack games, did
                              caloric consumption     not increase fruit
                              overall.                consumption, and ate
                                                      more overall than when
                                                      not prompted by
                                                      food.[23]
    ------------------------------------------------------------------------

        For instance, the ``common sense'' impetus behind informing
    patients that they are obese may be the old maxim, ``the first step in
    solving a problem is admitting you have one.'' Yet, there is evidence
    that clinically relevant words to describe a patient's weight (e.g.,
    morbidly obese and obese) are considered stigmatizing, which patients
    state may make them avoid future appointments.[16]
        It is important to note that the good intentions and unintended
    consequences in the table represent hand-picked examples and these
    interventions may not be negative in all circumstances. For instance,
    there is some evidence that the effects of menu labeling on consumer
    choice can be inconsistent or even positive if delivered in specific
    ways, including whether or not educational information is included and
    whether the participants are male or female.[21, 24-25]
    Thus, the selected examples in Table 2 bring up yet another ethical
    concern: if a policy intervention benefits one subset of the population
    but harms another, what action should be taken? One could argue against
    implementing a policy so as to do no harm to one group, while another
    could argue that failing to act is tantamount to harming the group that
    stands to benefit.[26-27]
    Minimizing Negative Ethical Consequences in Reversing Obesity
        Marieke ten Have and colleagues raise an important complementary
    point to ethical concerns over policy recommendations: ``The fact that
    objections are raised does not automatically imply that a programme
    should not be implemented''.[4] When considering an obesity-
    targeted public health policy, we propose six recommendations:

      1.  Evaluate whether the proposed policy addresses an exposure that
                can truly be considered a public health
                concern.[8]

      2.  Be honest about the quality and quantity of evidence about the
                policy.[14]

      3.  Generate sufficient, high-quality evidence before implementing
                the policy and have plans in place to generate quality
                evidence about the effectiveness of the policy once
                instated.[28]

      4.  Do not assume there is negligible or no harm from the policy (see
                Table 2).

      5.  Do not assume that achieving a health benefit overrides respect
                for other values and ethical principles.[4, 29]

      6.  Given a choice between two or more plausible policies, choose the
                policy that least compromises ethical
                values.[29]

        These guidelines should help prevent us from paving the roads to
    health with good wishes but unintended consequences.

                                   References

        1. Shapiro F.R., ed. The Yale Book of Quotations. New Haven, CT:
     Yale University Press; 2006: 319.
        2. Grynbaum M.M.. New York plans to ban sale of big sizes of sugary
     drinks.New York Times. May 30, 2012. http://www.nytimes.com/2012/05/31/
     nyregion/bloomberg-plans-a-ban-onlarge-sugared-
     drinks.html?pagewanted=all&_r=0. Accessed January 3, 2013.
        3. Levine S. Supporters of Mayor Bloomberg's anti-obesity initiative
     [news release]. New York: City of New York; September 13, 2012. http://
     www.nyc.gov/html/om/html/2012b/support_for_soda_limits.html. Accessed
     January 8, 2013.
        4. ten Have M., de Beaufort I.D., Teixeira P.J., Mackenbach J.P.,
     van der Heide A. Ethics and prevention of overweight and obesity: an
     inventory. Obes. Rev. 2011; 12(9): 669-679.
        5. Summar P. Anamarie 4 years later: weight gain, size of child, 7,
     remain unexplained. Albuquerque Journal. March 13, 2005. http://
     www.abqjournal.com/news/metro/320825metro03-13-05.htm. Accessed January
     4, 2013.
        6. Parents visit overweight child. ABC News. August 31, 2000. http://
     abcnews.go.com/US/story?id=95940&page=1. Accessed January 4, 2013.
        7. Kindig D., Stoddart G. What is population health? Am. J. Public
     Health. 2003; 93(3): 380-383.
        8. Anomaly J. Is obesity a public health problem? Public Health
     Ethics. 2012; 5(3): 216-221.
        9. McAllister E.J., Dhurandhar N.V., Keith S.W., et al. Ten putative
     contributors to the obesity epidemic. Crit. Rev. Food. Sci. Nutr. 2009;
     49(10): 868-913.
        10. Chaufan C., Hong G.H., Fox P. Taxing ``sin foods''--obesity
     prevention and public health policy. N. Engl. J. Med. 2009; 361(24):
     e113.
        11. Lucas, Jr. G. Paternalism and psychic taxes: the government's
     use of negative emotions to save us from ourselves. http://
     papers.ssrn.com/sol3/papers.cfm?abstract_id=2150402. Accessed March 20,
     2013.
        12. Puhl R., Peterson J.L., Luedicke J. Fighting obesity or obese
     persons? Public perceptions of obesity-related health messages. Int. J.
     Obes. (Lond). 2012. [Epub ahead of print]
        13. White House Task Force on Childhood Obesity. Solving the Problem
     of Obesity Within a Generation: White House Task Force on Childhood
     Obesity Report to the President. 2010: 78-82. http://www.letsmove.gov/
     sites/letsmove.gov/files/
     TaskForce_on_Childhood_Obesity_May2010_FullReport.pdf. Accessed March
     20, 2013.
        14. Casazza K., Fontaine K.R., Astrup A., et al. Myths,
     presumptions, and facts about obesity. N. Engl. J. Med. 2013; 368(5):
     446-454.
        15. Allison D.B. Evidence, discourse and values in obesity-oriented
     policy: menu labeling as a conversation starter. Int. J. Obes. (Lond).
     2011; 35(4): 464-471.
        16. Puhl R., Peterson J.L., Luedicke J. Motivating or stigmatizing?
     Public perceptions of weight-related language used by health providers.
     Int. J. Obes. (Lond). 2012. [Epub ahead of print]
        17. Wansink B., Just D.R., Cawley J., et al. From Coke to Coors: a
     field study of a sugar-sweetened beverage tax and its unintended
     consequences. http://papers.ssrn.com/sol3/
     papers.cfm?abstract_id=2079840. Accessed March 20, 2013.
        18. Jue J.J., Press M.J., McDonald D., et al. The impact of price
     discounts and calorie messaging on beverage consumption: A multi-site
     field study. Prev. Med. 2012; 55(6): 629-633.
        19. Werle C.O.C., Cuny C. The boomerang effect of mandatory sanitary
     messages to prevent obesity. Marketing Letters. 2012; 23(3): 883-891.
        20. Chandon P., Wansink B. The biasing health halos of fast-food
     restaurant health claims: lower calorie estimates and higher side-dish
     consumption intentions. J. Consumer Res. 2007; 34(3): 301-314.
        21. Harnack L.J., French S.A., Oakes J.M., Story M.T., Jeffery R.W.,
     Rydell S.A. Effects of calorie labeling and value size pricing on fast
     food meal choices: results from an experimental trial. Int. J. Behav.
     Nutr. Phys. Act. 2008; 5: 63.
        22. Durkin K., Hendry A., Stritzke W.G. Mixed selection. Effects of
     body images, dietary restraint, and persuasive messages on females'
     orientations towards chocolate. Appetite. 2013; 60(1): 95-102.
        23. Folkvord F., Anschutz D.J., Buijzen M., Valkenburg P.M. The
     effect of playing advergames that promote energy-dense snacks or fruit
     on actual food intake among children. Am. J. Clin. Nutr. 2012; 97(2):
     239-245.
        24. Girz L., Polivy J., Herman C.P., Lee H. The effects of calorie
     information on food selection and intake. Int. J. Obes. (Lond). 2012;
     36(10): 1340-1345.
        25. Roberto C.A., Larsen P.D., Agnew H., Baik J., Brownell K.D.
     Evaluating the impact of menu labeling on food choices and intake. Am.
     J. Public Health. 2010; 100(2): 312-318.
        26. Vartanian L.R., Smyth J.M. Primum non nocere: obesity stigma and
     public health. J. Bioeth. Inq. 2013; 10(1): 49-57.
        27. Gill T.P. Key issues in the prevention of obesity. Br. Med.
     Bull. 1997; 53(2): 359-388.
        28. Landefeld C.S., Shojania K.G., Auerbach A.D. Should we use large
     scale healthcare interventions without clear evidence that benefits
     outweigh costs and harms? No. BMJ. 2008; 336(7656): 1277.
        29. Have M.T., van der Heide A., Mackenbach J.P., de Beaufort I.D.
     An ethical framework for the prevention of overweight and obesity: a
     tool for thinking through a programme's ethical aspects. Eur. J. Public
     Health. 2012. [Epub ahead of print]

        Andrew W. Brown, Ph.D., is a postdoctoral trainee in the Office of
     Energetics and Nutrition Obesity Research Center at the University of
     Alabama at Birmingham. Trained in nutritional biochemistry and
     statistics, Dr. Brown's research focuses on establishing an evidence
     base for common assumptions about nutrition and health on such topics
     as organic agriculture, artificial sweeteners, and dietary supplements.
     His recent work relates to research reporting fidelity and its
     implications for science and policy.
        David B. Allison, PhD, is distinguished professor, Quetelet Endowed
     Professor of Public Health, associate dean for science, director of the
     Office of Energetics, and director of the NIH-funded Nutrition Obesity
     Research Center at the University of Alabama at Birmingham. He has
     authored more than 450 scientific publications, received many awards
     for his research and mentoring, is an elected fellow of many academic
     societies, and in 2012 was elected to the Institute of Medicine of the
     National Academies.

    Disclosure

        Dr. Brown receives grant support from the Coca-Cola Foundation
     through his institution.
        Dr. Allison has served as an unpaid board member for the
     International Life Sciences Institute of North America. He has
     received: payment for board membership from Kraft Foods; consulting
     fees from Vivus, Ulmer and Berne, Paul, Weiss, Rifkind, Wharton,
     Garrison, Chandler Chicco, Arena Pharmaceuticals, Pfizer, National
     Cattlemen's Association, Mead Johnson Nutrition, Frontiers Foundation,
     Orexigen Therapeutics, and Jason Pharmaceuticals; lecture fees from
     Porter Novelli and the Almond Board of California; payment for
     manuscript preparation from Vivus; travel reimbursement from
     International Life Sciences Institute of North America; other support
     from the United Soybean Board and the Northarvest Bean Growers
     Association; grant support through his institution from Wrigley, Kraft
     Foods, Coca-Cola, Vivus, Jason Pharmaceuticals, Aetna Foundation, and
     McNeil Nutritionals; and other funding through his institution from the
     Coca-Cola Foundation, Coca-Cola, PepsiCo, Red Bull, World Sugar
     Research Organisation, Archer Daniels Midland, Mars, Eli Lilly and
     Company, and Merck. Dr. Allison has no financial interests in any of
     these companies.

    Acknowledgments

        We would like to thank Michelle M. Bohan Brown, Ph.D. (University of
     Alabama at Birmingham), for her valuable input.
        The viewpoints expressed on this site are those of the authors and
     do not necessarily reflect the views and policies of the AMA.
        Copyright 2013 American Medical Association. All rights reserved.

                                  attachment 6
    Evidence, Discourse, and Values in Obesity-Oriented Policy: Menu-
            Labeling as a Conversation Starter
    Commentary
    D.B. Allison.*
    ---------------------------------------------------------------------------
        * Correspondence: Dr. D.B. Allison, Department of Biostatistics,
    Ryals Public Health Building, 1665 University Boulevard, University of
    Alabama at Birmingham, UAB Station, Birmingham, AL 35294-0022, USA.
        E-mail: DAllison@uab.edu.
    ---------------------------------------------------------------------------
    Departments of Biostatistics and Nutrition Sciences, Nutrition Obesity
    Research Center, University of Alabama at Birmingham, Birmingham, AL,
    USA.
    International Journal of Obesity (2011) 35, 464-471; doi:10.1038/
    ijo.2011.28; published online 15 March 2011.

        The new study by Dr. Elbel and colleagues provides an opportunity
    to reflect on where we are with respect to menu labeling as a tool in
    our antiobesity arsenal and more generally to consider some issues
    surrounding policy-level proposals for stemming the obesity epidemic.
    By `menu labeling', I refer to listing the calories of menu items on
    the menu. In this commentary, I address two aspects: evidence on menu
    labeling per se; and, at least as important, several scientific,
    social/political and epistemological issues that generally apply when
    considering obesity-related policies.
        Elbel, et al.,\1\ deserve praise for this interesting paper. Dr
    Elbel previously offered that menu labeling is a good idea and should
    be implemented, stating `I see particular value in it when the options
    are this versus nothing at all . . . Given that the problem is so
    intense, I think we have to try things.' \2\ Yet, despite his previous
    favorable view, he does not mince words upon completing his latest
    study: `Our evaluation of New York City's labeling law suggests that .
    . . this public policy intervention had no significant effect on
    purchasing behavior within our study period for a low-income, racially
    and ethnically diverse population of parents and adolescents.' The
    authors' qualifying clauses are appropriate as their study cannot rule
    out any effect, in any period, for any population. Yet, it certainly is
    one more bit of evidence tipping the scales toward the conclusion that
    menu labeling does not have substantial or consistent beneficial
    effects on energy intake.
    Strengths and Limitations of the Study by Elbel, et al.
        The study had multiple strengths, including using Newark as a
    comparator city, acquisition of actual receipts, the real-world setting
    and a population of interest. There are also key limitations. First, it
    is an observational (non-experimental) study that, similar to all
    observational studies, is subjected to potential confounding and cannot
    alone justify conclusions about causation. Second, because no body mass
    index measurements were taken, we cannot discern whether a thinner or
    more obese clientele was buying food at these restaurants, which might
    affect our interpretation of the value of menu labeling or whether some
    body mass index categories increased and others decreased their
    calories purchased. Third, the statistical analyses did not account for
    potential clustering (potential non-independence) of observations
    within restaurants and families as it should have, although it seems
    unlikely that this would make the nonsignificant results significant.
    Finally, and importantly, the study only looks at calories purchased at
    a single eating occasion. It does not tell us about calories actually
    consumed at that occasion (except perhaps the upper limit), about
    whether the knowledge of the calories one purchased on that occasion or
    simply being `attuned to calories' might have affected energy intake
    throughout the day, nor about how menu labeling affected body weight or
    body fat over an extended time period, the ultimate goal of menu
    labeling. Although the fact that calories purchased did not differ
    before and after menu labeling makes a beneficial effect less
    plausible, one cannot rule out that, for example, patrons who realized
    how many calories were in their purchases chose to eat less of the
    total food they purchased or chose to indulge at the restaurant, but
    eat less later.
        If we are to understand the value of any macro-environmental
    manipulation intended to reduce obesity levels, we must eventually
    measure body weight, fat or obesity levels because we know that people
    often compensate for perturbations in energy intake or expenditure
    (c.f. 3). For example, Anderson and Matsa4 showed that `On average,
    when a given individual eats out, he consumes 238 more calories per
    meal than when he eats at home. . . . (However,) eating out increases
    intake over the entire day by only 35 calories . . . although
    individuals tend to eat more at restaurants, they compensate to a
    substantial degree by eating less throughout the rest of the day. Meal-
    level estimates therefore overestimate the net effect of restaurants on
    total caloric intake.'
    Empirical Issues
    What does the empirical literature show on the effects of menu
            labeling?
        Although it is impossible to comprehensively summarize this
    literature herein (for an extensive tabulation through mid 2009, see
    ref. 5), the study by Elbel, et al., accords with most literature in
    showing no clear and consistent benefit. Furthermore, to my knowledge,
    no study has assessed effects on weight, total energy balance or total
    energy intake for periods beyond 24 h. Thus, no studies are truly
    probative on the actual question of interest: whether menu labeling
    reduces obesity levels.
        Of the extant studies, many are observational 6-7 and
    those that are experimental are typically, if not exclusively, in
    laboratory analog settings (for example, see ref. 8). Some studies show
    that menu labeling is associated with or affects reduced calories
    purchased, although among men the association appears less than among
    women, or is absent entirely.9-10 Other studies show no
    association or effect,\7\ and some even show statistically significant
    increases (adverse effects) in calories purchased with menu labeling
    among young men.8, 11 One study suggests menu labeling may
    decrease calories that parents purchase for children, but not calories
    that they purchase for themselves.\12\ Another study suggests that,
    when ingested calories (measured by self-report) after the eating
    occasion on the same day in which menu labeling is used are considered,
    there is a reduction in total energy intake if the menu labeling is
    accompanied by a statement that `The recommended daily caloric intake
    for an average adult is 2,000 calories.' \13\ As treatment-induced
    biases in self-report measures are well documented (for example, see
    ref. 14), it is unclear whether this statement affected actual intake
    or merely reporting. Finally, yet another study shows that calorie
    labeling may either increase or decrease energy consumed, depending on
    the food item labeled.\15\ Thus, although under some circumstances
    there are hints of short-term (that is, within one eating occasion or
    day) benefits on energy purchased or consumed, overall the results do
    not offer compelling evidence for effectiveness. When we contrast these
    recent results with earlier literature offering statements such as `. .
    . we estimated that menu labeling would avert 40.6% of the 6.75 million
    pound average annual weight gain in the county population aged 5 years
    and older',\16\ it seems that some initial expectations were overly
    optimistic.
    Important Biases To Consider
        In reviewing this literature, it is also important to note biases
    that may be present. One type is what Cope and Allison \17\ called
    `white hat bias,' the tendency to distort research information in the
    service of seemingly righteous ends. Cope and Allison \18\ cited an
    example of the Food and Drug Administration in its proposed ruling on
    menu labeling, citing a study as supporting a favorable conclusion that
    its data did not actually support. As another example, consider an
    article that reported in the abstract `Results were similar in most
    analyses conducted stratified by factors such as age, race and
    education level'.\8\ Although not explicitly inaccurate, this seems to
    be a misleading statement given that in the article's body the authors
    report that `Average energy intake was higher among males in the . . .
    (menu labeling) conditions compared with those who selected their meal
    from the control menu' with a P-value of 0.01 and no such effect was
    observed among females. In a similar vein, a recent New York Times \19\
    article based on private e-mails from within the NY City Health
    Department shows that in their zeal to make consumers `fear' soda as
    adiposity promoting, they were willing to knowingly `oversimplify'
    messages and knowingly ignore some science.
        Another form of bias is publication bias, whereby the probability
    that a paper is published or perhaps where it is published, and the
    resulting attention it receives, depends on its outcome, which is often
    a bias toward studies showing positive effects.\20\ Notably, opinion
    pieces suggesting that policies, such as menu labeling, front-of-pack
    labeling and taxation of sugar-sweetened beverages, will be beneficial
    have appeared in the most prominent journals such as JAMA
    21-22 or New England Journal of Medicine.23-24
    Yet, subsequent empirical reports stating that menu labeling, programs
    designed to reduce consumption of sugar-sweetened beverages and front-
    of-pack labeling do not seem to be very effective have been published
    in respectable but far less prominent journals and may receive less
    attention. Moreover, several dissertations and theses that have found
    no beneficial effects do not appear to be published as yet (see Table
    below). If these studies are not published and considered, the
    published literature may offer a misleadingly favorable view.

    ------------------------------------------------------------------------
       Reference               Design                      Results
    ------------------------------------------------------------------------
              \15\   Randomized experiment      ` . . . provision of calorie
                                                 information does not alter
                                                 food choice but does
                                                 influence the amount people
                                                 eat. Although the salad and
                                                 pasta contained the same
                                                 number of calories, calorie
                                                 information decreased
                                                 consumption of pasta, but
                                                 increased consumption of
                                                 salad.'
              \25\   Randomized experiment      `There are no differences in
                                                 total calorie . . . chosen
                                                 across the three groups:
                                                 price only, nutrition info
                                                 only, and price + info
                                                 groups.'
              \26\   Randomized experiment      `No significant differences
                                                 were found in the foods
                                                 ordered among the various
                                                 menu conditions.'.
    ------------------------------------------------------------------------

    Reporting quality?
        The published research record should have the greatest precision
    possible and be reported in a way that helps readers understand the
    nature of the research, including its limitations, especially when the
    research has the potential to affect clinical care, public health
    practices or legislative policies. In part because of this, company-
    based clinical trials are held to rigorous scrutiny; hence, perhaps
    consequently, the reporting quality of industry-sponsored obesity
    trials seems to be at least as good as, and perhaps better than, non-
    industry-sponsored trials.\27\ These same rigorous standards of
    reporting quality should be applied to all articles in peer-reviewed
    journals, especially those that may influence policy. In this light,
    consider that, although the paper by Elbel, et al.,\1\ is subtitled `A
    Natural Experiment', the design is not an experiment as defined in the
    scientific literature (for example, see ref. 28, p. 1) but a type of
    observational study sometimes referred to as a quasi-experiment.\29\
    Such quasi-experiments do not permit the strong inferences to causation
    that true experiments do. Hence, when the conclusion by Elbel, et
    al.,\1\ states `This study examines the effects (emphasis added) of
    menu labeling . . .', causal language is used without justification.
    Although this is a common slip,\30\ it may nevertheless confuse
    readers, including mass media reporters or policy makers into thinking
    an effect (or lack thereof) has been shown when, in fact, only a lack
    of an association has been shown. Further, just as association does not
    necessarily imply causation, lack of association does not necessarily
    imply lack of causation. Similarly, Elbel, et al.,\1\ discuss `calories
    consumed', but the actual outcome of the study was calories purchased.
    This is an important distinction because the menu labeling could
    conceivably cause consumers to consume less of a perceived high-calorie
    item even if it is purchased. I state these points about precision,
    when I have made similar errors of imprecise language in my own papers,
    to point out that we should hold papers in the public health policy
    arena to every bit as rigorous a standard of reporting as we do big
    pharmaceutical randomized controlled trials (RCTs). Allowing ourselves
    to slip into imprecise language potentially creates misunderstandings
    among readers that can lead to erroneous public discourse about
    proposed policies.
    Social and Philosophical Issues
    Does it matter if it matters?
        At a presentation on menu labeling at the 2009 Obesity Society
    meeting, Professor K.D. Brownell asked `Does it matter if it matters?'
    That is, does it matter whether data show that menu labeling is
    beneficial in deciding whether to endorse it? He used the instructive
    analogy of tags that describe a garment's composition. We do not demand
    randomized experiments showing that such tags produce a benefit; we
    simply take as given that people have a `right' to know the composition
    of the fabrics they purchase. Can we extend this argument by analogy to
    menu labeling? Perhaps, but trying invites the question, who is `we' in
    the preceding sentence? Is it society at large? Or is it we members of
    the scientific community acting in our role as scientists per se rather
    than as member of the general public who just happen to be scientists
    by profession? This is an important distinction, because if we are not
    predicating our endorsement of a policy based on empirical evidence or
    even expert scientific opinion on the policy's effects, then this does
    not seem to be a scientific issue at all but rather one of politics,
    morality or taste, and it is not obvious that scientists qua scientists
    have anything special to add here. And if not, is this even a relevant
    topic of discussion for our scientific conferences and journals? In
    fact, because there are potential costs and harms of all interventions,
    balancing risks and benefits is important. By analogy, consider what
    Food and Drug Administration wrote in its final ruling banning ephedra
    as a weight loss supplement and in determining whether there was a
    `significant or unreasonable risk': `There is no requirement that there
    be evidence proving . . . harm to specific individuals, only that
    scientific evidence supports the existence of risk. . . . `Unreasonable
    risk,' thus, represents a relative weighing of . . . known and
    reasonably likely risks against its known and reasonably likely
    benefits.' \31\ In this light, it does matter if it matters.
    Choice-Limiting Versus Choice-Promoting Strategies
        Obesity-related legislation is mushrooming. Between 2003 and 2005,
    in the United States, at least 717 bills and 134 legislative
    resolutions were proposed, of which 17% of bills and 53% of resolutions
    were adopted.\32\ Proposals for policy-based approaches almost
    invariably meet resistance when the policies offend the moral or
    political sensibilities of some persons. This especially occurs when
    the proposed policy is seen as treading on the rights or autonomy of
    individuals in the interests of public health paternalism. Therefore,
    if we wish to minimize such resistance, we should aim to advance
    proposals that are freedom and choice promoting, rather than
    restricting. Consequently, many advocates of policy level approaches
    recognize the merit of `opt-out' versus `opt-in' approaches \33\ that
    can be effective in promoting desired behavioral changes without
    compromising individual liberty. Unfortunately, not all public health
    advocates are sensitive to this issue. For example, proposals for
    taxing certain foods, such as sugar-sweetened beverages, limit
    individual freedom to negotiate a price for a desired product with the
    purveyor. By way of contrast, consider the experiments by experiments
    by Sharpe, et al.,\34\ showing that consumers' extremity avoidance
    behavior (for example, not wanting to choose the smallest or largest
    item in a series) led to a potentially useful effect. Specifically,
    merely offering a smaller size drink in addition to (not instead of)
    the existing sizes led to an overall reduction in the amount of drink
    purchased. On the basis of these results, one could imagine a policy in
    which restaurants that offer multiple sizes of drinks would be required
    to offer an additional drink smaller than their current smallest size
    and, if effective, the principle might be extended to other foods that
    are sold in multiple distinct serving sizes. Such a policy would limit
    the freedom of corporations, but not of individuals, and hence
    presumably meet far less resistance from libertarians.
        How might libertarian concerns relate to menu labeling? One benefit
    of menu labeling is that it provides more information for consumers to
    make more informed choices. As someone with libertarian leanings, I
    generally favor more and accurate information being made available to
    citizens \35\ and, as an individual consumer, I enjoy learning about
    the foods I may choose to eat; therefore, in many settings such as
    fast-food restaurants, I would enjoy menus labeled with nutritional
    information. However, that is just a statement of my personal
    preferences and tastes, not a scientific statement, and other
    individuals may have other preferences and tastes. For example, in
    2008, `After students and parents raised concerns about displayed
    calorie counts leading to or worsening eating disorders, Harvard
    University Dining Services removed the index cards detailing
    nutritional information from dining halls'.\36\ Regardless of the
    empirical basis for the Harvard parents' concerns, their feelings and
    preferences are real, and if we seek policies that allow choice, we
    will respect such feelings.
        How might advocates of menu labeling minimize the resistance they
    receive if they try to move menu labeling into all restaurants, not
    just into fast-food chains? In this light, consider that this is not
    the first time in history that restaurant menu content has been subject
    to scrutiny and change. Years ago, it was common for restaurants to
    have `blind menus' without prices listed so patrons could take out
    their guests without the mood of the dinner being affected by the guest
    seeing the prices.\37\ Although such practice is now uncommon, many
    higher-end restaurants still provide such menus to patrons upon
    request. In this way, consumer choice is enhanced. The price
    information is there for all who want it and hidden for those who do
    not (in an `opt-out' manner). There is an analogy with respect to
    calorie information. In some circumstances, for example, when someone
    takes their special someone out for that romantic dinner to propose
    marriage or celebrate an anniversary, even the most health conscious
    among us may not wish to consider the calories in our food. This
    potential preference could be respected and choice enhanced if
    consumers had the option of viewing a menu with or without the calorie
    contents (in a `opt-out' manner). In a full-service restaurant with
    printed menus, this can be easily accomplished, and if menu labeling
    advocates propose such a choice-promoting approach, they are likely to
    meet applause instead of resistance from libertarians.
    Can we lead by example?
        Mohandas Gandhi said, `We must be the change we wish to see in the
    world. Change can only come from the roots upwards, never from the
    treetop down'.\38\ Our more modern guru, Michael Jackson, sang `I'm
    Starting With The Man In The Mirror. . . . If You Wanna Make The World
    A Better Place, Take A Look At Yourself And Then Make That Change!' In
    this light, an irony to the menu-labeling advocacy has occurred.
    According to Friedman,\39\ `Fast food is eaten disproportionately by
    low-income people, who are more likely to be overweight.' Further,
    meals eaten in full-service restaurants tend to be high in calories and
    fat as well,\40\ maybe even higher than those in fast-food restaurants,
    especially in the case of children's and adolescents'
    meals.41-42 Further, higher income people, who are more
    likely to patronize such restaurants, are not exempt from obesity. Yet,
    our early public health salvo at restaurants has not been aimed at
    those establishments likely frequented by the well-established senior
    academicians and high-ranking public health officials who propose the
    policies, but at those more frequented by people of lesser means. Other
    proposals that seem targeted more at persons of lesser means and that
    may seem restrictive or punitive have been made, such as restricting
    the provision of toys in children's fast-food meals, disallowing
    purchase of sugar-sweetened beverages with Supplemental Nutrition
    Assistance Program funds (food stamps), and restricting the location of
    fast-food outlets.
        I do not doubt that the intentions of most policy advocates are
    sincerely beneficent, nor that the greater uniformity of chain
    restaurants offers a rationale for starting there within the category
    of restaurants. Nevertheless, incarnations of public health paternalism
    aimed more at changing unhealthy behaviors among members of less-
    powerful social classes than the equally unhealthy behaviors of the
    social classes proposing the policies cannot be seen as Gandhian and
    has likely provoked some of the pushback that has occurred. This
    sentiment is well illustrated by the feminist writer, Anna Kirkland.

              `. . . this environmental approach to obesity has been sold
            as a progressive, structurally focused alternative to
            stigmatization, but it actually embeds and reproduces a
            persistent tension in feminist approaches to social problems:
            well-meant efforts to improve poor women's living conditions at
            a collective level often end up as intrusive, moralizing, and
            punitive direction of their lives . . . good choice dominated
            by elite norms of consumption and movement'.\43\

        As our field moves forward with the consideration of other public
    health policies that may have paternalistic aspects, perhaps we should
    start with the man in the mirror. Given the plausible weight-reducing
    effects of less heating and air conditioning and more sleep,\44\
    perhaps advocates of paternalistic public health policies should first
    demand that the use of heating and air conditioning be reduced in the
    buildings in which they and we work (which would also have an
    environmental and economic benefit) and take a pledge not to work on
    grant proposals, manuscripts or e-mail correspondence after 2200 hours.
    That would be leadership that walks the walk.
    Majority rules?
        An argument sometimes made in support of a proposed policy approach
    to obesity is that the general population desires the policy. Regarding
    menu labeling, a Robert Wood Johnson Foundation briefing states that
    survey and focus group research indicates that `males and females of
    diverse educational backgrounds reacted favorably to the idea of
    labeling menu items with just calorie information or identifying
    healthier options with a uniform, commonly defined symbol to help them
    make better choices'.\5\ Of course, public opinion should count. In the
    extreme case of a unanimous population opinion, the decision is easy.
        However, in cases in which there is a majority view favoring a new
    policy, but not unanimity, should majority rule? There are reasons to
    question `majority rules' as a justification for a new policy, and
    again we should be open in acknowledging that subjective values in
    addition to scientific evidence come into play. First, one should view
    opinion poll results about proposed policies with healthy scientific
    skepticism. Research on survey methodology has repeatedly shown that
    seemingly minor variations in question wording can have major
    influences on responses.\45\ For example, very different responses are
    obtained when people are asked whether the government should `forbid'
    something as opposed to whether the government should `allow'
    something, even though one question is just the complement of the
    other. Thus, we should perhaps only be persuaded by results of surveys
    purportedly showing popular support when such results are replicated
    with multiple differently worded questionnaires prepared by different
    parties.
        Second, sometimes the public may desire a policy based on an
    erroneous view of its likely effects. Those advocates who accept
    paternalistic public health approaches could argue that one should act
    in accordance with the public's interests, not necessarily on the basis
    of their expressed views.
        Finally, and most importantly from a libertarian view in which
    individual freedom is paramount, the desire of the majority is
    insufficient justification to tread upon the rights of the individual.
    Consider, for example, our response to a proposal that we have required
    prayer of a particular religious doctrine because the majority of the
    population thinks it is a desirable thing. The United States and many
    other democratic countries have already affirmed that, regardless of
    popular view, such a proposal is unacceptable. Clearly, most proposed
    obesity-related policies, including mandatory menu labeling, are not so
    extreme, and yet we should remember that multiple children in multiple
    countries (including the United States) have been removed from their
    parents' and homes by governmental actions on the basis of protecting
    them from their obesity-promoting environment,46-47 and that
    in 2008 three Mississippi legislators proposed `An Act To Prohibit
    Certain Food Establishments From Serving Food To Any Person Who Is
    Obese, Based On Criteria Prescribed By The State Department Of Health'
    (http://billstatus.ls.state.ms.us/documents/2008/pdf/HB/0200-0299/
    HB0282IN.pdf). Not surprisingly, the legislation was never enacted.
    Thus, we should be skeptical of majority public opinion as a
    justification for restrictive policies.
    Epistemological Issues
    What constitutes an adequate evidence base?
        Consider that, after analyzing 38 policy documents from five
    European countries, authors found that `Only 22% of the obesity
    statements were evidence based'.\48\ We seem to have a dearth of
    evidence in the obesity policy domain. There is little (although not
    zero) debate that randomized experiments offer the highest quality
    evidence we can obtain about the effects of interventions, including
    policies. There is also little debate that results obtained from well-
    done randomized experiments, especially on long-term outcomes on
    variables such as body weight or fat, will not always be available when
    we wish to make a statement, conclusion or decision about a proposed
    policy. In such situations, what should the standard of evidence be and
    who gets to decide that standard? At present, there is no obvious
    consensus. Importantly, answering the question of what constitutes
    adequate evidence depends on the context in which the question is
    called and will not be the academic community's alone (or in some cases
    at all) to decide. For example, in deciding whether a particular piece
    of litigation is justifiable, the level of scientific evidence required
    will be determined by applicable law as interpreted by the judiciary,
    not by academics.
        Second, in considering what constitutes adequate evidence, it is
    essential to distinguish between conclusion making and decision making.
    Scientists and public health advocates sometimes clash because they
    conflate this distinction. The advocate, who may be someone who is also
    sometimes a scientist, maligns the scientist qua scientist as trying to
    hold back progress and upholding an unreasonable standard, whereas the
    scientist maligns the advocate as playing `fast and loose with' or even
    ignoring scientific evidence. The problem is rarely that the two
    parties disagree on what evidence exists or what it shows, but rather
    they are answering two different types of questions and fail to realize
    or acknowledge this. The scientist is concerned with questions about
    the truth of propositions and addresses questions such as `By generally
    accepted scientific standards, can we reasonably conclude today to a
    reasonable degree of certainty that A causes B?' In contrast, the well-
    meaning public health advocate is concerned with questions about what
    we should do, such as `Given what we know today, however limited, is it
    prudent to implement A in the hopes that B will happen in response?' If
    we recognize this, there is no contradiction between the scientist
    saying that the evidence for the benefit of a proposed policy is weak,
    limited, inconclusive, or even non-existent and the advocate saying
    that, despite the fact that there is insufficient evidence to conclude
    that the policy will be effective, we should give it a try to determine
    whether it might plausibly work and whether the likely benefits
    outweigh the likely costs. Recognizing this, the honest advocate need
    not and should not try to inflate the evidence in support of a policy
    they wish to advance, as seems to be done now,18-19 but can
    honestly acknowledge the degree of uncertainty, respect scientists for
    contributing discussions of evidence to promote an informed decision-
    making process, and then advocate for prudential decision making.
    Are randomized studies needed and possible?
        Some advocates of policy approaches are dismissive of the role of
    randomized trials. In arguing this position, several valid points are
    commonly noted. These are listed in the first column of Table below.
    Unfortunately, gaining acceptance of these points is often followed by
    a rhetorical sleight of hand, whereby they are replaced with the far
    stronger and fundamentally different points listed in the second column
    of the table below. Writings that cogently show the fallacies of these
    points are listed in the third column.

    ------------------------------------------------------------------------
                                   Invalid points often
     Valid points about which    conflated with the valid       References
     there is  little if any       ones by advocates of       disputing the
              debate                 proposed  actions        invalid point
    ------------------------------------------------------------------------
    It is difficult to         It is impossible and perhaps             \49\
     conduct randomized         irrelevant to conduct
     experiments to test the    randomized experiments to
     effects of public          test the effects of public
     policies.                  policies.
    It is sometimes necessary  Once we decide to move                   \50\
     to move forward and take   forward, there is no need
     actions even in the        to do so in a manner in
     absence of the highest     which the highest quality
     quality evidence that is   evidence that is
     practically obtainable.    practically obtainable is
                                indeed obtained.
    In some situations (e.g.,  In general, it is                       51	52
     when considering smoking   appropriate to draw strong
     as a cause of lung         conclusions about causation
     cancer), the scientific    in the absence of
     community has judged       experimental evidence.
     that it is appropriate
     to draw strong
     conclusions about
     causation in the absence
     of experimental
     evidence.
    ------------------------------------------------------------------------

        In conversation, a colleague who is a strong advocate of public
    policy interventions such as menu labeling and taxation of selected
    foods said, `You know, David, we are never going to know for sure
    whether these policies work before we implement them.' I replied, `You
    may be right, but the way we are going about it, we will never know
    afterward either.' It is unfortunate that, to date, all the evidence we
    have on menu labeling is either from short-term laboratory analog
    experiments or from non-experimental observational studies. Although
    practical complexities undoubtedly exist, it is certainly possible that
    as the Federal Government proceeds with national menu labeling \53\
    they could randomly introduce it in \1/2\ of the states or counties in
    the United States and not in the other \1/2\ for a year in a valid
    cluster-randomized trial. At year's end, they might plausibly have
    unequivocal evidence on the effects of menu labeling on food purchases.
    Such data could offer guidance about whether to then implement the
    program in the remaining locations or discontinue the requirement.
    Similarly, many major national fast-food restaurant chains, were they
    inclined to conduct such a study, would easily have the financial
    resources and computer recording infrastructure of purchases to conduct
    such a trial by randomly assigning labeled menus to some of restaurants
    and unlabeled menus to others and then comparing the sales figures. If
    such studies were conducted at the state or county level, one could
    even solicit participation from and enroll specific subjects who are
    known to be high fast-food consumers at baseline and go beyond merely
    examining the effects on purchases at the cluster level; instead, one
    could study the actual end point of interest, body weight or fat in
    individual persons. Remarkably, for all the passion that public policy
    advocates bring to the table to push policies forward, they have not
    used that passion to demand that such studies be carried out. If they
    did so, perhaps they would help us learn how effective the policies
    they advocate are.
    Could it hurt?
        An argument sometimes made by advocates of policies that seem
    intuitively sound to them but are not supported by strong evidence is
    that, even if ineffective, such policies will be harmless. This is
    fallacious reasoning. There are at least five types of harm, or more
    generically cost, that may accrue. The first is direct negative effects
    of the policies on collateral outcomes (concerns about economic impacts
    and stigmatization are sometimes raised) or on the outcomes that are
    themselves the targets of policy, such as the increase in calories
    purchased by males seen in some menu-labeling studies.11, 35
    The second is encroachment on individual freedom that occurs with some
    policies as discussed earlier. The third is that if the scientific
    community advances a policy as very likely to be beneficial, which is
    then found not to be beneficial, our credibility may be damaged and,
    like the boy who cried wolf, our voices will carry less weight when we
    genuinely have important messages to convey. The fourth cost is
    distraction. When we focus our efforts on advocating and implementing
    methods that turn out to be ineffective, we are not spending those
    efforts on other approaches that might be better. Finally, there are
    direct resource costs. Every dollar our society spends implementing one
    policy is $1 less that we have available to support education, the
    arts, or any number of other things our citizens may find as equally
    deserving causes. This is not to say that these harms or costs will
    come to fruition in implementing any one policy, but they are
    plausible, should enter into society's decision analysis, and justify
    asking about evidence of benefit when considering proposed policy
    approaches to obesity.
    Conclusion
        The timely study by Elbel, et al.,\1\ adds to the growing body of
    evidence suggesting, but not demonstrating, that menu labeling has no
    important effect on reducing calories purchased at a single dining
    occasion. Moreover, it highlights the frustrating truth that, as such
    policies are implemented, they are not implemented in a manner that
    allows the most rigorous assessments of their effects to be conducted.
    Like all other studies to date, the study by Elbel, et al.,\1\ does not
    offer strong evidence about causation (or lack thereof), information
    about long-term effects, or effects on the variable that menu labeling
    is intended to affect, namely, obesity levels. As we move forward to
    consider this and other policy-level proposals for addressing obesity,
    as scientists we should hold high standards of discourse and of
    evidence and we should maintain a sense of humility about the accuracy
    of our predictions about the effects of our proposed policies. Society
    will sometimes be justified in moving forward even in the absence of
    strong evidence for the benefits of a proposed policy; yet, as
    scientists we should offer our most unbiased assessment of the current
    evidential base and ask that, as any new policies are implemented,
    rigorous evaluations of their effects should be conducted.

    Conflict of Interest

        Dr. Allison has received grants, honoraria, donations and consulting
     fees from numerous food, beverage, pharmaceutical companies and other
     commercial, government and nonprofit entities with interests in obesity
     and nutrition; receives royalties from obesity-related books; and in
     the past has received funds from litigators representing the restaurant
     industry in menu-labeling litigation.

    Acknowledgements

        I am grateful to Drs. Kevin Fontaine, Alexis Wood and Kyle Grimes
     for their helpful comments.

    Disclaimer

        The opinions expressed are the author's and not necessarily those of
     any organization with which he is affiliated.

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                                  attachment 7
    The Development of Scientific Evidence for Health Policies for Obesity:
            Why and How
    Molly B. Richardson,[1-2] Michelle S.
    Williams,[3] Kevin R. Fontaine,[2]-[3] David B.
    Allison.[2], *
    ---------------------------------------------------------------------------
        \[1]\ Department of Population Health Sciences, Virginia
    Polytechnic Institute and State University.
        \[2]\ Nutrition Obesity Research Center, University of Alabama at
    Birmingham (UAB).
        \[3]\ School of Nursing, Auburn University.
        * Corresponding Author: School of Public Health, University of
    Alabama at Birmingham, Ryals Building, Room 140J, 1665 University
    Boulevard, Birmingham, Alabama 35294, Phone: (205) 975-9167,
    dallison@uab.ed.
    ---------------------------------------------------------------------------
    Running title: Scientific process to develop obesity policy

        Acknowledgements: Supported in part by the NIH (T32HL105349) and
    the Nutrition Obesity Research Center (P30DK0563360). The opinions
    expressed are those of the authors and do not necessarily represent
    those of the NIH or any other organization. We gratefully acknowledge
    Gregory Pavela, Alexandra S. Allison, Ted Kyle, Jennifer Holmes, Olivia
    Affuso, Paula Chandler-Laney, and Daniel L. Smith, Jr. for input on
    this manuscript.
        Conflict of Interest: DBA has received financial support from
    numerous nonprofit and for profit organizations including government,
    litigators, food and beverage, pharmaceutical, and publishing
    companies.
    Abstract
        Potential obesity-related policy approaches have recently been
    receiving more attention. While some have been implemented and others
    only proposed, few have been formally evaluated. We discuss the
    relevance, and in some cases irrelevance, of some of the types of
    evidence that are often brought to bear in considering obesity-related
    policy decisions. We discuss major methods used to generate such
    evidence, emphasizing study design and the varying quality of the
    evidence obtained. Third, we consider what the standards of evidence
    should be in various contexts, who ought to set those standards, as
    well as the inherent subjectivity involved in making policy decisions.
    Finally, we suggest greater transparency from both academics and
    policymakers in the acknowledgment of subjectivities so they can
    distinguish and communicate the roles played by empirical evidence and
    subjective values in the formulation of policy.
    Introduction
        Proposals to use policy measures such as taxing persons with
    obesity as ways to raise revenue and discourage poor health behaviors,
    including high levels of consumption, existed at least as early as
    1904.\1\ However, it was largely in the mid-1990s that the academic and
    professional dialogue around obesity shifted from one dominated by
    basic science and clinical research to involve a third branch, namely,
    public health approaches. Inspired in part by the successful efforts to
    curtail cigarette smoking, potential obesity-related policy approaches
    began receiving more attention. A selection of such policies include,
    but are not limited to, providing information (e.g., labeling
    restaurant menus with nutritional facts), marketing ideas to inspire
    behavior change (e.g., placing public health posters in subway systems
    to discourage or encourage certain food or activity behaviors),
    mandating the measurement and reporting of the body mass index (BMI) of
    schoolchildren to parents, enacting worksite economic contingencies,
    changing food offerings for schoolchildren, zoning of allowable
    restaurants, banning the sale of certain portion sizes, taxing or
    subsidizing certain foods, and providing economic incentives and
    disincentives through insurance charges. Some of these have been
    implemented and some have only been proposed. Few have been rigorously
    evaluated and fewer still have unequivocal evidence demonstrating
    efficacy in stabilizing or reducing body weight.
        Because the implementation of such policies typically involves at
    least some of the following: money, limitations on the freedom of
    businesses to engage in certain types of commerce, limitations on
    personal freedom, and opportunity cost with regard to time and
    attention; it is not surprising that obesity-related policy proposals
    often provoke heated debate. Moreover, the debate frequently focuses on
    moral issues, sometimes involving the balance between autonomy and
    beneficence or individual fairness and societal benefits. Because these
    issues revolve around morals and values, they are difficult to
    reconcile. As such, they are repeatedly deferred while the dialogue
    jumps to questions of judging the quality of evidence. Yet even here,
    disagreements abound as to the strength of evidence and whether it
    supports a particular position on a proposed policy. Equally important
    and sometimes debated, but often simply glossed over, are questions
    such as, (1) What type of evidence is needed and appropriate for a
    particular situation? (2) How can such evidence be generated? and (3)
    Is evidence even needed at all to justify the implementation or
    rejection of a particular proposed policy?
        In this article, we address three macro-level questions. First,
    concerning evidence, we raise questions about the relevance of some
    types of evidence that are often brought to bear in policy dialogues.
    Second, we discuss the major methods used to generate such evidence,
    with particular focus on the fact that there are a range of study
    designs (i.e., ordinary association tests to pure randomized controlled
    trials [RCTs]) that yield evidence of varying quality and varying
    ability to support causality. Third, we consider what the standards of
    evidence should be in various contexts, as well as who ought to set
    those standards, and emphasize the inherent subjectivities involved in
    making policy decisions. We conclude by noting that it would be
    beneficial if both academics and policymakers were transparent in
    recognizing and conveying those subjectivities while taking care to
    both understand and distinguish the roles of empirical evidence and
    subjective values.
    What Do We Want Evidence About?
    Evidence Regarding Plausibility
        When considering a potential policy, the first evidence-oriented
    question we might ask is, ``Is there evidence that the policy will
    plausibly be effective?'' That is, is there reason to speculate that
    the policy will work? Of course, beyond simply saying we cannot prove
    the contrary, the plausibility of a proposition is subjective, but
    one's reasons for declaring something plausible or implausible can be
    specified. At the most superficial level, many obesity policies can be
    deemed plausible on the basis of the simple concept of energy imbalance
    as a cause of obesity. Any policy directed at either increasing energy
    expenditure or decreasing energy intake might thus be assessed as
    plausible by some. In some cases, this general plausibility is all that
    is needed to initiate a policy. For example, when considering calorie-
    labeling of restaurant menus, U.S. District Judge Richard J. Holwell
    ruled that:

              ``The Court agrees with Dr. Allison that one cannot conclude
            with scientific certainty from the available evidence that a
            regulation of this type will ultimately be successful in
            combating obesity. But even if there are no data demonstrating
            conclusively that Regulation 81.50 will be effective,
            conclusive proof is not required to establish a reasonable
            relationship between Regulation 81.50 and the City's interest
            in reducing obesity. Based on the evidence presented by the
            City, as well as common sense, it seems reasonable to expect
            that some consumers will use the information disclosed pursuant
            to Regulation 81.50 to select lower calorie meals when eating
            at covered restaurants and that these choices will lead to a
            lower incidence of obesity.'' \2\

        In contrast, empiricists (or Bayesians) might state that the
    existing evidence indicates that no proposed public health approach to
    obesity has been convincingly shown to work or, at best, that no
    approach has more than very modest effects when it has been applied or
    tested.3-4 Therefore, the a priori expectation is that the
    next proposed policy will have little to no effect. By analogy, this
    rationale is similar to the statistically minded high school guidance
    counselor who advises the basketball star to study academics because,
    while the counselor cannot rule out that this player will be the one to
    get drafted to the NBA or WNBA, it is unlikely.
        Plausibility may also be low in some people's minds for policies
    that aim to affect one component of energy balance in one context while
    leaving other components of energy balance untouched. Such policies,
    even if effective in altering the one component of energy balance in
    the desired direction, will only be effective if this alteration is not
    compensated (or is at least incompletely compensated) for by
    alterations in other components of energy balance. Empirical,
    experimental evidence indicates that such compensation does indeed
    occur, although the compensation is usually incomplete.\5\ This
    suggests that the plausible effects of policies that work through
    proposed alterations in one component of energy balance should not be
    based on models that assume no compensation (c.f., The Caloric
    Calculator, which estimates average caloric impact, which predicts
    effect sizes for childhood obesity interventions),\6\ as such models
    will likely markedly overestimate plausible effects.
        The plausible benefit of many proposed policy approaches also rests
    of the assumption of additivity--a small effect coupled with several
    other slight effects will collectively produce a larger response in the
    outcome. This is particularly applicable to the category of ``nudge,''
    a term introduced by Thaler and Sunstein to describe multiple, minor,
    likely unnoticeable changes to alter one's behavior.\7\ Rozin, et al.,
    showed that multiple modest changes, or nudges, affecting food
    accessibility (location of ingredients at a salad bar and size and type
    of serving utensils) in a cafeteria setting reduced the calories
    purchased during single meals without removing choices.\8\ They
    predicted that the reduced purchasing would translate to a cumulative
    benefit of weight loss over 1 year. Again, this type of study relies on
    several assumptions: that fewer calories purchased translates to fewer
    calories consumed; that ``all else is equal,'' i.e., that no
    compensation occurs; that short-term effects persist in the long term;
    that multiple interventions have additive effects; and that effects of
    interventions work equally well when subjects are fully aware of the
    interventions (as in ordinary commerce) as when the interventions are
    not disclosed (as in many studies). Such a study also brings up
    questions of whether patrons would purchase fewer calories in an
    ordinary setting such as a store and that would result in weight loss.
    For example, Wansink. et al., found that increasing the cost of soda
    resulted in reduced soda purchased but was associated with increased
    sales of beer.\9\ These nudges also may elicit a different response
    when persons are made aware of the interventions or with repeated long-
    term exposure (i.e., daily or weekly grocery shopping).\10\ The nudge
    approach has also been criticized on several other
    grounds,11-12 and such criticism highlights that what seems
    plausible to one person may not seem so to another.
    Evidence Regarding Postulated Intermediaries
        Evidence of the effectiveness of obesity policy may also rest on
    evidence regarding presumed mediating variables. An example is a
    proposed policy for an action intended to increase fruit and vegetable
    consumption, with the main assumption being that increased intake of
    fruits and vegetables (the mediating factor) will decrease adiposity or
    promote less weight gain. Empirical support for the policy may include
    a demonstration that the proposed action does indeed lead to increased
    fruit and vegetable consumption. However, such support can only be
    suggestive because it does not necessarily follow that increases in
    fruit and vegetable intake will actually decrease or prevent adiposity
    or lessen weight gain, and the same argument applies for other
    postulated intermediaries.13-14
    Evidence from Analogue Studies
        Analogue studies attempt to represent key aspects of ordinary life
    while controlling or limiting external factors, which increases
    internal validity and can yield key insights \15\ yet potentially
    decreases external validity.\16\ An example of an analogue study was
    conducted by Epstein, et al., to compare the effects of taxation versus
    subsidization on food purchases.\17\ They found that using taxes on
    foods with low nutrient density but also high caloric content was
    successful at reducing caloric intake, whereas subsidizing low-calorie
    foods increased caloric intake. This type of evidence supports the
    plausibility, but not necessarily the effectiveness, of a policy for
    decreasing obesity. One area of opportunity is the use of pragmatic
    RCTs, which emphasize rigorous methods in real-world contexts.\18\
    Direct Evidence Regarding Effectiveness
        Of course, the key evidence desired is evidence of a policy's
    effectiveness on the ultimate outcome: decreased levels of obesity.
    Although optimal, such evidence is often difficult to obtain.
    Ultimately, an ideal study would bear direct evidence of effectiveness,
    under actual conditions of use, during extended periods of time, and
    would be of a nature to allow strong inference of cause and effect.
    These would be randomized studies of actual policy or of extremely
    close proximity. There is no question that these studies would be
    difficult, expensive, time-consuming, and in some cases potentially
    unethical. We do not advocate a lack of action without this type of
    evidence; however, there should be a clear understanding that without
    such evidence, statements about the effects of a policy remain
    speculative.
    Evidence Regarding Unintended Consequences
        It is important to keep in mind that implementation of any policy
    often brings with it unintended and undesirable consequences. Many of
    these consequences have been previously highlighted.19-20
    Such consequences can include, but are not limited to, inequitable
    distribution of the costs to implement the policy, encroaching on
    individual freedoms, over-consumption or increased purchasing of
    certain foods, stigmatization, depression, and avoidance of doctor
    appointments.19-20 One author contends that the emphasis on
    body weight has led to weight-based bullying, increased disordered
    eating, body dissatisfaction, extreme dieting, and complications from
    obesity surgery, among others.\21\ While some evidence exists on
    potential unintended and undesirable consequences, it is fairly limited
    as this field has not been fully investigated. Again, fear of
    unintended negative consequences should not paralyze us into inaction,
    but should lead us to practice humility about the potential value of
    our proposals, to think things through carefully, and to vigilantly
    monitor implemented policies for any potential unintended consequences.
    Evidence Regarding Public Opinion
        Reports of the results of public opinion surveys on the
    desirability of particular obesity-related policies have proliferated
    in recent years.\22\ By implication, this suggests that if a large
    portion of the population supports a proposed policy, then implementing
    the proposal is merited. Is such a conclusion reasonable? Should
    evidence of public opinion about the desirability of policies be
    considered?
        Suh, et al., suggest that public opinion should be solicited to
    ``better understand the public mindset about relevant policy
    strategies, and to identify attitudes among different subsets of the
    population towards specific legal measures that can increase
    protections for individuals affected by obesity.'' \23\ Pollard, et
    al., also contend that it is important to survey public opinion or
    community perception, especially when the policy in question involves
    what may be thought of as government ``interference'' in issues
    concerning food (labeling, advertising, and supply of environmentally
    friendly food).\24\ But are such opinions always important? When
    assessing public opinion is warranted, which methodologic issues are
    involved? And, are there actually circumstances when assessing public
    opinion would be quite inappropriate? Because this article is primarily
    about evidence for effectiveness, we consider these questions only
    briefly here.
        Are scientific assessments of public opinions about policies always
    important? Throughout the history of the United States, political
    leaders have wrestled with the pursuit of what seems morally right
    based on fundamental principles and doing what is popular. One such
    example is the famous Lincoln-Douglas debates about slavery. In one of
    the debates, Lincoln famously said, ``In this and like communities,
    public sentiment is everything. With public sentiment, nothing can
    fail; without it nothing can succeed. Consequently he who moulds public
    sentiment, goes deeper than he who enacts statutes or pronounces
    decisions. He makes statutes and decisions possible or impossible to be
    executed.'' \25\ It is noteworthy that Lincoln, like some modern day
    authors interested in obesity policy,\26\ is talking about ``moulding''
    public opinion to enable what one has already determined is right and
    just, and not assessing public opinion to determine what is right and
    just.
        If Lincoln had conducted a public opinion poll and found that most
    pre-Civil War Americans favored retaining slavery in the United States,
    would he have judged that pertinent evidence as to whether the practice
    should be abolished? Would we? The answer is evidently no. When
    something is judged to be morally wrong, it is wrong and should be
    ``off the table'' for discussion regardless of its popularity. Consider
    the recent posting from Ted Kyle on a ``UK Proposal for Explicit Weight
    Discrimination in Healthcare.'' \27\ Kyle argues that a proposed policy
    was a grossly unjust form of discrimination against persons with
    obesity in terms of health care access. Or, consider proposed policies
    that entail institutionalized ``fat shaming'' \28\ or a failed/
    withdrawn Mississippi bill to limit access of persons with obesity to
    restaurants.\29\ Many, including the current authors, would consider
    such proposals morally indefensible, and if one adopts such a position,
    then no public opinion polls are needed. If moral opinion has superior
    authority relative to public opinion, this invites important questions
    of who or how many determine the moral authority and on what basis.
        When public opinion assessment is warranted, which methodologic
    issues are involved? The above notwithstanding, situations certainly
    exist where public opinion is important, such as to determine whether a
    policy which is neither morally indefensible nor a moral imperative is
    desired by the citizenry. In such situations, it will be important to
    rely on good principles of designing and interpreting opinion surveys
    and to keep in mind that who is surveyed \30\ and how questions are
    worded \31\ can both be used to manipulate the answers one receives.
    Extensive discussions on these and other methodologic points are
    covered in standard textbooks on survey and sampling methods.
        Are there actually circumstances when assessing public opinion
    would be quite inappropriate? Finally, we suggest that in some
    circumstances, assessing public opinion is not only unnecessary, but
    inappropriate. Specifically, in situations where a proposed approach is
    morally indefensible, to admit the value of public opinion surveys on
    determining whether a policy should be enacted invites a ``tyranny of
    the majority.'' 32-33 An interesting corollary of this is
    that empirical evidence on the harm or lack of benefit for some morally
    indefensible practice might also be seen as not only unnecessary, but
    counterproductive, because the very act of considering the empirical
    evidence implies that the practice under consideration might be worthy
    of adoption if the evidence came out a particular way. For example,
    consider this headline from an Internet posting: ``Science Says Fat
    Shaming Backfires--So Can We Finally Stop It?'' \34\ The article seems
    to be referencing an observational study \35\ that is interpreted to
    show that perceived weight discrimination leads to greater future
    obesity in the person experiencing the discrimination. The answer to
    the headline's rhetorical query, So Can We Finally Stop It?, in our
    opinion is that we unequivocally should stop fat shaming, but not
    because of this (or any other) study but rather because it is wrong.
    Even if one accepts our view that fat shaming is wrong a priori, might
    one ask where the harm is of buttressing the position with some
    empirical support. The harm is that the empirical support, like all
    empirical support, is subject to differential interpretation,
    criticism, and being overturned. In the observational study in this
    example, it would be easy to point out many limits, most notably that
    the study cannot show cause and effect. This may lead others to
    conclude, ``Well, if the wrongness of fat shaming depended in part on
    the empirical evidence and the empirical evidence has holes in it, I
    guess fat-shaming may not be wrong after all.'' If this example is not
    stark enough, we can ask ourselves would we take seriously the need for
    studies to show deleterious effects of policies that institutionalized
    racial or religious discrimination as justifications for eliminating
    such heinous policies?
    How Might Evidence for Obesity Policies Be Generated?
        We now turn from the question of what evidence we want to the
    question of how such evidence can be generated. In doing so, we
    emphasize that we are focusing in this section on questions regarding
    the effects of potential policies on outcomes and do not consider
    questions about assessing other things such as public opinion about
    policies. In considering the generation of evidence regarding the
    effects of potential policies, we are considering questions of cause
    and effect and readers may find the videos available from an annual
    short course on this topic of interest (see:
    http://www.norc.uab.edu/courses/shortcourse).
        Here, we divide the types of research to be considered into three
    categories: (1) research that can be determinative of the causal
    effects of policies; (2) research that can contribute to an overall
    assessment of the causal effects of policies, but cannot on its own
    determine causation; and (3) research that formally synthesizes
    multiple sources of information to estimate the causal effects of
    policies.
    Research That Can Be Determinative of the Causal Effects of Policies
    Role of Randomized Controlled Trials
        Empirical evidence derived from RCTs aimed at identifying factors
    that increase or decrease the risk or magnitude of obesity can provide
    the strongest evidence to guide the development of obesity
    policies.\36\ RCTs are regarded as the gold standard in the hierarchy
    of research designs because they are the most reliable method for
    determining causality.\37\ Evidence generated from RCTs has been used
    to guide the development of several types of obesity policies such as
    dietary recommendations, sugar-sweetened beverage taxes, and food
    pricing.38-40 Despite the acknowledgement that RCTs offer
    the strongest inferences about cause and effect, several arguments are
    commonly offered against reliance on RCTs for causal inference in
    policy research. We very briefly review these arguments here.

      1.  RCTs are imperfect. Some authors note that RCTs are imperfect.
                They can be designed and executed with flaws. Like all
                empirical studies, they are subject to stochastic
                variation. Finally, they often entail subject selection
                criteria and/or study conditions that limit
                generalizability of the results owing to the broader
                population and more ``real-life'' circumstances. These are
                all legitimate criticisms, but two things are noteworthy.
                First, these weaknesses are all surmountable. RCTs can be
                designed and executed well and can be executed in large
                enough samples and tested with small enough nominal type 1
                error levels to minimize stochastic errors. Finally,
                pragmatic controlled trials offer investigators the ability
                to conduct a study that examines the effectiveness and
                efficacy of an intervention in the real world by allowing
                for the inclusion of a diverse sample of the population and
                by enabling the intervention to be adapted to local
                settings.\41\ For example, the Moving to Opportunity study
                found that certain social programs involving housing
                vouchers providing the ``opportunity to move from a
                neighborhood with a high level of poverty to one with a
                lower level of poverty was associated with [caused] modest
                but potentially important reductions in the prevalence of
                extreme obesity and diabetes.'' \42\

      2.   RCTs are sometimes impractical or impossible. We agree that RCTs
                are sometimes impractical or impossible, but this has no
                bearing on the extent to which RCTs and other designs can
                or cannot provide strong inferences or causation. The
                argument that (a) RCTs are sometimes impractical or
                impossible, (b) such that if we relied on only them for
                strong causal inferences we would not be able to make
                strong causal inferences in some situations in which we
                wished to make strong causal inferences, and (c) therefore
                we should not make strong causal inferences solely from
                RCTs is simply a special case of Argumentum ad
                Consequentiam.\43\

      3.  There are no RCTs showing that parachutes work. It is sometimes
                noted that we accept many propositions as true on the basis
                of some evidence and intuitive obviousness such as that
                smoking causes lung cancer or that parachutes save lives
                among skydivers.\44\ This is an example of argument by
                analogy.\45\ Arguments by analogy can be useful foils to
                provoke thought, but in and of themselves prove or disprove
                nothing.

      4.  We cannot wait for perfect data. It is sometimes argued that we
                cannot (or more aptly should not) wait for perfect data to
                take certain actions, such as enact certain policies. We
                agree with this proposition. However, the statement ``we
                cannot (or more aptly should not) wait for perfect data to
                take certain actions'' is not equivalent to ``we cannot (or
                more aptly should not) wait for perfect data to draw strong
                conclusions about causation.'' Taking actions and drawing
                causal conclusions are distinct processes and the need and
                justification to take prudent action in the face of
                uncertainty is not a justification for denying that the
                uncertainty exists.19, 46-47

      5.  Inadvertently Promoting a False Dichotomy. Majumdar and Soumerai
                \48\ have cogently noted that ``some contend that only
                randomized controlled trials produce trustworthy evidence.
                Unfortunately, such a position discounts valid
                nonrandomized or quasi-experimental study designs, even
                though health policy randomized controlled trials are
                rarely feasible. Such a constrained view inappropriately
                lumps together valid evidence from strong nonrandomized
                designs (that is, before-after studies with concurrent
                controls or the interrupted time series study in which a
                policy causes a sudden, visible change in trend) with
                evidence from weak designs that permit little causal
                inference (that is, the commonly conducted cross-sectional
                analysis that looks at outcomes only after a policy has
                been implemented).'' We agree that there is a continuum of
                non-RCT designs that vary in the strength of causal
                inferences they justify. We also agree that the stronger
                designs are underutilized as we discuss later in this
                article. However, these recognitions do not affect the
                validity of propositions that randomization is key to valid
                causal inference.\49\ If we accepted otherwise, we would
                again be engaging in Argumentum ad Consequentiam.\43\
    Research That Can Contribute to an Overall Assessment of the Causal
            Effects of Policies
        Having emphasized the critical role of RCTs in humans on the policy
    under question and for the outcomes under question in drawing strong
    causal inference, we also note that with such information often
    unavailable and sometimes unattainable, it is frequently necessary to
    make decisions about actions without drawing firm conclusions about
    causation. In doing so, we must commonly integrate multiple sources of
    information, none of which alone is unequivocally dispositive about a
    conclusion of causation, to make informed decisions about what might
    reasonably be expected to work. Several sources of evidence can
    contribute to such decisions.
    Role of Model Organism Evidence
        Model organisms are used to generate information regarding casual
    relationships that cannot be derived through human studies. For
    example, exposure to environmental obesogens, such as endocrine-
    disrupting chemicals, has been identified as a possible factor that
    increases the risk of obesity.50-51 Such studies are vital
    in policy decisions, for example, to approve or disapprove use of a
    food additive, but cannot offer unequivocal conclusions about causation
    in humans because of the possible heterogeneity of effects across
    species.\52\
    Role of Observational Evidence: of Ordinary Association Tests (OATs)
            and Extended Assoc[i]ation Tests (EATs)
        Observational evidence generally plays a vital role in assessing
    the likely value of proposed policies. Observational studies are useful
    in generating hypotheses that can inform the conduct of more rigorous
    studies (i.e., randomized trials) to begin to establish causality. With
    regard to policies developed to address the obesity epidemic,
    observational studies have been used to investigate associations
    between the initiations of policies and relevant outcomes. That said,
    not all observational evidence is of equal value. Here we distinguish
    between two broad classes of observational evidence which we will call
    Ordinary Association Tests (OATs) and Extended Association Tests
    (EATs).
        Ordinary Association Tests. We define ordinary association tests
    (OATs) to be observational studies on samples of individuals in which
    the sole or primary means of controlling for potential confounding
    factors is inclusion of measures of some potential confounding factors
    as covariates in statistical models (or stratifying by measures of such
    factors). OATs are heavily relied upon in thinking about plausible
    effects of polices, but have also been heavily criticized in general
    53-54 and in the obesity and nutrition domains in particular
    55-57 for multiple reasons. We refer the reader to those
    references for details.
        Extended Association Tests. Most dialogue and research in obesity
    does not consider the evidence continuum between OATs, which do not
    offer strong assessments of causal effects, and RCTs, which do offer
    strong inferences, but cannot be done in all circumstances. In contrast
    to this polarized view, there are techniques that we refer to as
    extended association tests (EATs) that lie intermediary between
    ordinary association tests and RCTs, including but not limited to
    quasi-experimental studies and natural experiments. Such designs are
    increasingly used, especially in the disciplines of economics and
    genetics, but are rarely used in obesity research. However, the ability
    to draw causal inferences in obesity research could be strengthened by
    increased judicious use of such approaches. In-depth understanding and
    appropriate use of the full continuum of these methods requires input
    from disciplines including statistics, economics, psychology,
    epidemiology, mathematics, philosophy, and in some cases behavioral or
    statistical genetics. The application of these techniques, however,
    does not involve routine well-known ``cookbook'' approaches but
    requires understanding of underlying principles so the investigator can
    tailor approaches to specific and varying situations.
        Some of the key methods in use for situations where standard RCTs
    may not be available include natural experiments, quasi-experiments,
    and experiments in which true randomization is used but subjects are
    not randomized directly to levels of the independent variable, as
    described with examples in Table 1.
        Natural experiments are a useful type of observational study that
    can be used to investigate the impact of environmental changes on
    obesity, that is, changes that the investigator did not manipulate. In
    this case, investigators merely measure outcomes before and after the
    implementation of a new policy, regulation, or other factor that has
    changed. Within the context of efforts at obesity modification, natural
    experiments have been used to assess the effectiveness of new policies
    (e.g., inclusion of calorie information on menus, implementation of
    environmental elements thought to promote physical activity [i.e.,
    parks, bike lanes, walking trails], use of school-based obesity
    screening and BMI report cards).61, 68-70
        A prime example comes from the U.S. Food and Drug Administration,
    which implemented regulations requiring franchise restaurant chains
    with 20 or more locations to provide calorie information on their menus
    and menu boards. In a natural experiment conducted in New York City,
    receipts were collected from patrons of fast food restaurants before
    and after menu labeling was implemented. The investigators found that
    adding calorie information to the menus did not appear to influence the
    food choices of parents or adolescents.\61\ Natural experiments such as
    this are a cost-effective way to evaluate the effects of obesity
    policies, as well as provide information that might inform
    modifications to existing policies.
        The existence of EATs seems to be less well known to many
    investigators in public health, medicine, psychology, and related
    fields. We believe that many questions about behavioral, psychological,
    and economic influences on obesity-related variables and many applied
    questions about the effects of extant or proposed interventions can be
    addressed more informatively and more rigorously if more investigators
    availed themselves of these evolving methodologies related to causal
    inference from a basis of a sound understanding of fundamental
    principles.
    Research That Formally Synthesizes Multiple Sources of Information To
            Estimate The Causal Effects of Policies
        Apart from the need to embrace and use the range of potential
    design strategies available, it is also essential to ``step back'' and
    synthesize the multiple and varied sources of information to evaluate
    what they can tell us about the causal effects of policies.
    Role of Systematic Reviews and Meta-Analysis
        As a result of the growing rates of obesity around the world, the
    volume of evidence from obesity research has burgeoned. However, owing
    to variations in the quality and type of study design, implementation,
    and the outcomes measured, determining effects from various studies can
    be challenging. Debates on obesity policies are often fueled by the
    contradictory findings of empirical studies, such as those regarding
    the influence of sugar-sweetened beverage consumption on childhood
    obesity.\40\ As such, high-quality systematic reviews and meta-analyses
    can be useful when attempting to evaluate the state of the evidence
    related to a particular intervention or policy with objective
    approaches to identifying and integrating evidence.\71\ That said, as
    Ingram Olkin once wrote, ``Doing a meta-analysis is easy. Doing one
    well is hard,'' \72\ and we have found that errors in obesity-related
    meta-analyses abound.\73\ Hence, while meta-analyses are vital, our
    field needs to improve their execution, and meta-analyses should be as
    critically reviewed as are any other studies.
    Role of Modelling
        One drawback of RCTs, noted above, is that they often are not large
    enough to capture the entire spectrum of effects (both desired and
    undesired) that a policy may have.\74\ Mathematical and computational
    models of health policies are tools that can be used to predict the
    outcomes of an obesity policy and to identify implementation barriers
    before the policy is adopted.\75\ Moreover, the modelling of obesity
    policy enables policymakers to estimate the costs of implementing
    policies and to determine the resource allocation required to implement
    a given policy.76-78 For example, a dynamic weight loss
    model was used to estimate the effects of a tax on sugar-sweetened
    beverages on the prevalence of obesity in New York City.\79\ The model
    suggested that there would be decreases in obesity prevalence over a 10
    year period.\79\ The model also estimated the magnitude of the
    projected reductions in obesity prevalence, allowing readers to better
    judge the potential public health impact of such a policy.\79\
        Models are also valuable for monitoring the effects of policies
    over time. Evidence has shown that the effects of health policies can
    increase or diminish with the passage of time.\78\ Therefore, new data
    concerning the effects of a policy should be continually generated to
    estimate its effects in order to allow policymakers to revise or even
    discontinue implementation of the policy if it is shown to be
    ineffective.\74\
        Despite the benefits of using models in the development and
    refinement of health policies, some challenges and limitations must be
    recognized. For example, health policy modellers are not often
    integrated into the health policymaking process. Therefore, models are
    seen as ``one-offs'' rather than as tools that should be used during
    the lifecycle of the policy to ensure that it retains its value.
    Perhaps most importantly, models offer projections of effects, not
    demonstrations of effects. Such projections can be heavily dependent on
    the input parameters (i.e., assumptions) of the model, and some
    published modelling activities (e.g.,\80\) are so heavy on assumptions
    of efficacy of the policies considered that the modelling can be seen
    as an instance of petitio principii.\81\
    Standards for Evidence and Related Factors Influencing Policy Decisions
        According to Donaldson and colleagues, most obesity prevention
    bills enacted between 2010 and 2013 were based on initiating strategies
    (e.g., ``initiated farmer[s'] markets, increased access to walking
    trails, local menu labeling'') that had little to no evidence of
    benefit.\82\ But is this wrong? A vital consideration, often not made
    explicit a priori, concerns the standards for evidence that will used
    to both generate a policy decision and to evaluate its effect once
    implemented. In general, the standards of evidence for a scientific
    conclusion are thought to be far more rigorous, because they are based
    on long-established methodologies that are considered to be objective,
    repeatable, and relatively immune to biases of the individuals
    conducting the study. In contrast, the evidence (if any) needed to
    reach a policy decision (which is distinct from reaching a scientific
    conclusion) depends on many factors and is not constant across
    circumstances. Opinions can also vary. For example, the Society for
    Prevention Research states, ``To be ready for broad dissemination, a
    program must not only be of proven effectiveness, but it must also meet
    other criteria . . .'' (emphasis added).\83\ This stands in marked
    contrast to the statement of District Judge Richard J. Holwell quoted
    above that ``even if there are no data demonstrating conclusively that
    Regulation 81.50 will be effective, conclusive proof is not re-
    quired . . .'' and in the context of the legal proceedings, his
    interpretation of law is what determined the evidence standard. There
    are yet other standards in different contexts and so no universal rule
    about how much evidence is or is not needed for policymaking can be
    given. This stands in contrast to occasional statements from academics
    that seem to state from no formal basis of authority that a particular
    amount of evidence is or is not needed to enact a policy.
        The four quotations listed (see Box 1) are from discussions and
    presentations involving policies directed at curbing sugar intake in
    the public. They reflect the varying perspectives of differing
    standards of evidence among researchers. The first two 84-85
    put rigor of evidence aside and instead emphasize that the decision to
    develop policy is the priority based on a decision that seems to have
    already been committed to based upon some combination of suggestive
    evidence or intuition. In contrast, the third and fourth statements
    progress from needing ``a strong sense that it will be effective'' \86\
    to confidently requiring ``strong evidence'' prior to any public policy
    decision.\87\ Thus, disagreement on the amount and rigor or evidence
    needed to enact a policy exists even among researchers discussing a
    particular target (sugar) of public policy. They illustrate the
    subjectivity of the standards of evidence for decision making.
    In Summation
        In closing, our field will benefit from a greater emphasis on
    probative research. Probative research would meaningfully move us
    forward in our ability to state that a given treatment or prevention
    strategy does or does not have a particular effect.\88\ This is in
    contrast to studies that merely continue to draw attention to the
    plausibility of some treatment having some effect but do not increase
    our knowledge that such an effect actually exists.\88\ Finally, the
    quest for rigorous evidence and scrupulous truthfulness in reporting is
    fully compatible with the quest for beneficence and passionate pursuit
    of action for the betterment of others. Recognizing these
    comparabilities (see Box 2) may pave the way for public health dialogue
    in obesity that is both more honest and more collegial.

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        Table 1. Examples of Extended Association Tests (EATs) in Obesity
                                    Research
    ------------------------------------------------------------------------
      Topic Under Study          Design                Finding         Ref.
    ------------------------------------------------------------------------
    Effects of            Co-Sib Control        Mixed                  58	59
     Breastfeeding on
     Offspring Obesity
    Effects of            Adoption Study        Consistent with a       \60\
     Socioeconomic                               causal effect, but
     Status of Rearing                           only \1/2\ of
     Parents on Child                            ordinary
     BMI                                         association
    Effects of Menu       Quasi-Experiment      No support              \61\
     Labeling on
     Calories Purchased
    Effects of Migrating  Natural Experiment    Some evidence for       \62\
     from Tonga to New                           BMI increase in
     Zealand                                     some ages
    Effects of Roommate   Packet Randomized     Association             \63\
     Characteristics on    Experiment            suggesting that
     Freshman Weight                             being assigned to
     Gain                                        higher BMI roommate
                                                 leads to less
                                                 weight gain
    Effect of Education   Quasi-Experiment      No support              \64\
     on Food Choice
    Effect of Casinos     Quasi-Experiment      Association             \65\
     (as Economic                                suggestive of
     Boosters) on Child                          beneficial effect
     Obesity
    Effects of Altitude   Quasi-Packet-         Association             \66\
     of Residence on       Randomized            suggestive of
     Obesity               Experiment            beneficial effect
    Effects of            Co-Twin Control       No support              \67\
     Environmental
     Factors Influencing
     Birthweight on
     Adult BMI
    ------------------------------------------------------------------------

     Box 1: Contrasting Ideas on the Amount and Rigor of Evidence Regarding
                     Policies Targeted at Sugar Consumption
                             [emphases added below].
    ------------------------------------------------------------------------

    -------------------------------------------------------------------------
        ``It's a classic example. It's industry-funded authors saying that
     the dietary guidelines recommendations about sugar aren't based on
     science. I'm laughing because what kind of evidence do you need? Sugar
     is calories and no nutrients and everybody would be healthier eating
     less of it.''--Marion Nestel \84\
        ``I would be very surprised if any one pot policy had any effect on
     obesity. And in some ways I think it's a trap to expect it to do that
     because so many things are driving the problem. So many things are
     affecting the food supply, levels of physical activity, and [ . . . ]
     structural things like poverty, education, and access to healthcare. To
     expect any one policy to turn that around I think is wishful thinking.
     But it is certainly important that it be studied as much as it can so
     that you know at the end of the day, so that you know [ . . . ] where
     you get the biggest impact per dollar of policy change'' --Kelly
     Brownell \85\
        ``In public health, when someone is going to act, particularly for
     something that is a public policy my goodness, we have to have some
     pretty strong sense that it's going to be effective. Public policy
     cannot be enacted simply based on a good idea. There has to be reason
     that it's going to make a difference and a difference relative to
     public interest.''--Nancy E. Kass \86\
        ``But we should need very strong evidence before we made people burn
     a fuel in their homes that they do not like or stop smoking the
     cigarettes and eating the fats and sugar that they do like.''--Sir
     Austin Bradford Hill \87\
    ------------------------------------------------------------------------

        Box 2: Clarification Within Two Domains: Evidence for scientific
                conclusions and for Advocacy Of Policy Decisions
    ------------------------------------------------------------------------

    ------------------------------------------------------------------------
    Evidence for Scientific Conclusions   Greater candor in
                                          scientific presentations 89	92
                                          Acceptance by empirically
                                          minded scientists that action can
                                          sometimes legitimately precede
                                          without strong evidence
                                          Articulating distinctions
                                          between our values and our
                                          assessments of empirical evidence
                                          \91\
    Evidence for Advocacy of Policy       Eschewing fallacious
     Decisions                            rhetorical arguments
                                          Acceptance by advocates
                                          that advocacy neither requires nor
                                          justifies making evidence seem
                                          stronger than it is
    ------------------------------------------------------------------------

                                  attachment 8
    Will Reducing Sugar-Sweetened Beverage Consumption Reduce Obesity?
            Evidence Supporting Conjecture Is Strong, But Evidence When
            Testing Effect Is Weak
    Pro v. Con Debate: Role of Sugar Sweetened Beverages in Obesity
    K.A. Kaiser,[1] J.M. Shikany,[2] K.D.
    Keating,[1] and D.B. Allison [1]
    ---------------------------------------------------------------------------
        \[1]\ Office of Energetics, Dean's Office, School of Public Health,
    University of Alabama at Birmingham, Birmingham, Alabama, USA.
        \[2]\ Division of Preventive Medicine, School of Medicine,
    University of Alabama at Birmingham, Birmingham, Alabama, USA.
        Address for correspondence: Dr. D.B. Allison, Ryals Public Health
    Building, Rm 140J, University of Alabama at Birmingham, 1665 University
    Boulevard, Birmingham, AL 35294, USA. E-mail: Dallison@uab.edu.
    ---------------------------------------------------------------------------
    Received 12 February 2013; revised 25 April 2013; accepted 26 April
    2013.
    Obesity Reviews (2013) 14, 620-633.
    2013 The Authors
    Summary
        We provide arguments to the debate question and update a previous
    meta-analysis with recently published studies on effects of sugar-
    sweetened beverages (SSBs) on body weight/composition indices (BWIs).
    We abstracted data from randomized controlled trials examining effects
    of consumption of SSBs on BWIs. Six new studies met these criteria: (i)
    human trials, (ii) %3 weeks duration, (iii) random assignment to
    conditions differing only in consumption of SSBs and (iv) including a
    BWI outcome. Updated meta-analysis of a total of seven studies that
    added SSBs to persons' diets showed dose-dependent increases in weight.
    Updated meta-analysis of eight studies attempting to reduce SSB
    consumption showed an equivocal effect on BWIs in all randomized
    subjects. When limited to subjects overweight at baseline, meta-
    analysis showed a significant effect of roughly 0.25 standard
    deviations (more weight loss/less weight gain) relative to controls.
    Evidence to date is equivocal in showing that decreasing SSB
    consumption will reduce the prevalence of obesity. Although new
    evidence suggests that an effect may yet be demonstrable in some
    populations, the integrated effect size estimate remains very small and
    of equivocal statistical significance. Problems in this research area
    and suggestions for future research are highlighted.
    Introduction
        The proposition we have been asked to address and for which we
    evaluate the available evidence is as follows:

              `There is sufficient scientific evidence that decreasing
            sugar-sweetened beverage (SSB) consumption will reduce the
            prevalence of obesity and obesity-related diseases.'
    What We Are Debating
        In examining the proposition, it is useful to carefully consider
    several of its components as follows:
    Sufficient Evidence
        The word sufficient invites the question, sufficient for what? As
    the remainder of the proposition indicates, the answer is for drawing a
    conclusion that decreasing SSB consumption will reduce the prevalence
    of obesity and obesity-related diseases. This must be distinguished
    from the question of sufficiency for taking public health action or
    guiding public health policy. What constitutes sufficiency for actions
    (as opposed to drawing conclusions) is not a purely scientific question
    that can be answered objectively. Such decisions depend only in part on
    scientific evidence of the likely effects of those actions and also
    depend on other inputs including but not limited to legal authority,
    moral values and personal tastes, none of which are determined by
    empirical evidence. The question `Is there sufficient evidence for
    action?' is inherently subjective and depends on which action, in which
    regulatory context and according to whose tastes and moral values. As
    Sir Austin Bradford Hill wrote, `The evidence is there to be judged on
    its merits and the judgment . . . should be utterly independent of what
    hangs upon it--or who hangs because of it'.(1)
    Scientific Evidence
        We are not asked for conjecture, but rather whether empirical
    evidence exists showing that decreasing SSBs has the effects stated. We
    therefore examine the highest quality evidence available in the form of
    randomized controlled trials (RCTs). Because such trials are ethically
    possible and have been performed, we assert that this type of
    scientific evidence supersedes correlation or cohort
    studies.(2) When RCTs are not possible, other evidence must
    be amassed to attempt to inform causation. However, RCTs are possible
    to address this question and data are available. Hence, we rely on
    these results in the present case as they are probative (by probative,
    we mean studies which can generate evidence which settles questions by
    proving or disproving propositions, as opposed to simply influencing
    the strength of speculation) with respect to causation.(3)
    Decreasing
        We cannot assume that the effects of decreasing consumption are the
    opposite (direction and magnitude) of the effects of increasing
    consumption. Therefore, we provide examinations of available
    experimental reports that evaluate both interventions so as to quantify
    the observed effects in each case.
    Reduce the Prevalence of Obesity and Obesity-Related Diseases
        As to `obesity-related diseases,' one must first demonstrate an
    effect on obesity to suggest an effect on obesity-related diseases.
    Else in what way can the diseases be said to be obesity-related? We
    therefore focus our present meta-analysis on studies of the effect on
    body weight or body composition.
    What We Are Not Debating
        Just as we have clarified the proposition being debated, it is
    equally important to not be distracted by questions that we have not
    been asked to address. For example, we have not been asked to address
    whether obesity is a crisis, if fructose is toxic, are some sugars
    worse than others, are food company marketing budgets too large, have
    portion sizes increased to absurd levels, do SSBs affect dental caries,
    are pictures of an average American's sugar consumption dramatic, is
    liberty better than paternalism (or vice versa), is food marketing like
    tobacco marketing, or do we sometimes need to take public health
    actions in the absence of strong evidence. Although these are
    provocative questions, they are not germane to the necessary evaluation
    of evidence regarding the question we have been asked to debate. Yet we
    mention them because they and similar questions are often introduced
    into such discussions and serve as emotion-raising distractions to an
    evaluation of the pertinent evidence.
    There Is Evidence To Support Conjecture
        We freely concede that there is evidence to support the conjecture
    that reducing SSB consumption might reduce obesity and obesity-related
    diseases. However, many of these data are not probative in terms of
    causation. Specifically, there are three forms of human evidence
    supporting this conjecture.
        First, we address ecological correlation. SSB consumption has risen
    just as obesity rates have risen.(4) This is the weakest
    form of evidence available. Other beverage consumption patterns (e.g.,
    bottled water (5) depicted in Fig. 1) have also demonstrated
    a strong correlation with the obesity epidemic in the United
    States.(6-7)
        Second, we note an association in some observational
    studies.(8-10) Whereas there is an ever-growing body of
    epidemiologic studies, some of which demonstrate statistically
    significant associations, it is well known that association does not
    establish causation. Moreover, the association is weak,(11)
    inconsistent (12-13) and biased,(14) as we will
    discuss later. Again, as Dr. Hu (our debate opponent) wrote, `Although
    the overall results were not entirely consistent, the weight of
    epidemiologic and experimental evidence indicates greater consumption
    of sugar-sweetened beverages is associated with weight gain and obesity
    in children and adults. However, the existing studies suffer from many
    methodological limitations, including cross-sectional design, small
    sample size, short follow-up, inadequate dietary assessment, and a lack
    of repeated measures of diet and lifestyle. . . . any single dietary
    factor is unlikely to have a large effect on body
    weight'.(13)
        For the third and final point which supports conjecture, we
    acknowledge that lesser compensation with liquid versus solid calories
    has been found in some in short-term feeding studies.(15-17)
    By compensation, we refer to the definition provided by Mattes
    (18) whereby later energy intake may be reduced to
    compensate for preloads or added calories from some other intervention.
    It must also be acknowledged that compensation for added intake may
    also take the form of altered energy expenditure, which can offset the
    intake component of energy balance. Few feeding studies examine this
    component. Additionally, short-term feeding effects are by no means
    equivalent to long-term weight effects.(19) Moreover, the
    short-term effects are inconsistent, with some studies showing near
    perfect compensation for liquid calories (11, 20-21) and
    others showing imperfect but equivalent (between forms) compensation to
    solid calories.(22) Finally, there is far more than zero
    compensation as implied by common and exaggerated public statements
    such as, `When we drink sugary beverages, we simply do not compensate
    by eating less food' (23) or `Liquid calories don't register
    with our appetite controls'.(24)
    Figure 1

              Rise in obesity rates (6) (round markers) and
            bottled water consumption (5) (square markers),
            United States. BMI, body mass index, kg m^\2\.

        We agree with Dr. Pan and Dr. Hu's statement in 2011 that `. . .
    the isolated tests in the laboratory may not be directly reproduced in
    real life because the effect of any food or food component on satiety
    could be influenced by other dietary factors. Thus, results from short-
    term, well-controlled interventions may not be representative of a
    real-life setting, and long-term clinical trials on different physical
    forms of carbohydrates on energy intake and weight management are still
    lacking'.(25) Later in this article, we provide even more
    compelling evidence from longer-term trials on weight that some
    compensation for added liquid calories indeed occurs.
    Evaluation of Evidence To Draw Scientifically Supported Conclusions
        When randomized trials can be performed ethically and safely (which
    they have been), these study results are the strongest level of
    evidence of independent effects. Many scientists who have gone on
    record on the question we now debate have acknowledged the limitations
    of association studies and the need for well-designed randomized
    trials.(13, 26-28) If these same scientists are calling for
    well-designed trials, it is curious that strong statements are then
    made about weaker forms of evidence. Use of Hill's guidelines
    (1) is irrelevant in the instance of the effects of SSBs on
    weight because randomized trials can be done (and have been done). In
    such situations, the `totality' of the evidence, including evidence
    that is not probative, should not be relied upon for drawing
    conclusions of causation in favour of the probative studies. More
    recent trials have taken steps to reduce the level of bias
    (29-30) and future studies may advance this effort further.
    Specific Questions We Address By Use of the Best Available Evidence
      1.  Does an increase in SSB intake increase body weight or body mass
                index (BMI) in humans?

      2.  Does reduction of SSB intake reduce body weight or BMI in humans?

        We now evaluate and summarize the currently available evidence that
    could potentially be probative with respect to drawing conclusions
    about the effects of SSB reduction on weight or obesity.
    Methods
        See supporting information for details of the updated literature
    review, study selection and data extraction methods. As the present
    paper was in review, an additional study meeting our criteria became
    public as a conference abstract.(31) This trial tested the
    effects of home water delivery and an educational programme to reduce
    SSB consumption in overweight, adult, Mexican women as compared to the
    education-only control group. Based on the available information in the
    abstract, we were unable to formally include this study result in our
    meta-analysis, but we discuss the possible effects on our conclusions
    using estimates from data reported in the abstract in the next section
    on results.
    Results
    The Extent of the Data Available: Studies Included and Excluded
        Table 1 contains a brief listing and description of the six new
    studies (29-30, 32-36) added for meta-analysis. We provide
    more details of each study in the supporting information online.
    Supporting Information Figure S1 contains a flow chart of the screening
    and selection of recently published studies.
        In the three new studies in which SSBs were added [90 to 500 kcal
    day^\1\ to the diets of adults (30,34); 158 kcal day^\1\ in children
    (36)], statistically significant weight gain was observed in
    both adult trials, ranging from 0.39 to 1.14 kg (Supporting Information
    Table S1). No significant difference in weight gain was observed in the
    study in children between the treatment and control
    participants.(36) When we compared observed weight gain to
    theoretical weight gain from added SSBs in all RCTs published to date
    (Fig. 2), compensation appeared to occur in longer-term studies.
        In the one new study of adults (35) and the two new
    studies of children (29, 32-33) in which participants who
    drank some amount of SSBs at baseline were asked to eliminate or reduce
    their SSB consumption, standardized mean differences (SMDs) in
    percentage weight loss or BMI reduction ranged from 0.13 to 0.33
    (Supporting Information Table S2). The overall results for added SSBs
    (small but statistically significant weight gain; Fig. 3) or for
    reduced SSBs in subjects of all weight ranges (small and not
    statistically significant weight loss; Fig. 4) did not differ greatly
    from our earlier analysis.(37)
        In new studies in which all participants were overweight or obese
    at baseline, SMDs ranged from 0.13 to 0.73 (Supporting Information
    Table S3). In combination with earlier studies or subgroup analysis of
    the effects of reducing SSBs on overweight subjects (Fig. 5), the
    overall SMD was 0.25 (95% confidence interval [CI]: 0.13 to 0.38
    standard deviations, P <0.0001).
        In the newly published study by Hernandez-Cordero, et
    al.,(31) the authors reported no significant effect with a
    P-value of 0.50. Assuming this is a two-tailed P-value, the reported
    sample size yields an effect size of either ^0.086 or +0.086. The means
    were not reported so we cannot determine the direction. If the sample
    effect size were +0.086, then the summary statistic would not change at
    all from the summary estimate and CI shown in Fig. 4. Alternatively, if
    the sample effect size was ^0.086, the summary estimate would be
    reduced towards zero (from 0.06 to 0.05) and remain statistically non-
    significant. Similarly, for the analysis shown in Fig. 5 for subjects
    overweight at baseline, the addition of this study would shift the
    overall estimate from 0.25 to 0.21, or as low as 0.17 depending on
    direction of observed effect.
    Assessment of Study-Level Risk of Bias
        Supporting Information Figure S2 summarizes our cumulative
    assessment of potential areas of bias of the pertinent studies to date.
    The most important areas for risk of bias overall come from lack of
    participant blinding and selective reporting. Some study designs failed
    to adequately isolate treatment effects from the attention researchers
    paid to some groups. Additionally, only two studies' protocols
    (29, 34) had an objective measure of participant compliance
    (returned containers, urinary sucralose measures), making cross
    comparisons and estimates of true effects difficult. Failure to mention
    whether assessors were blinded was common (ten out of 15 studies),
    further clouding assessment of potential sources of bias.
    Assessment of Publication Bias
        Supporting Information Figures S3-S5 are funnel plots
    (38) for the assessment of potential publication bias from
    only the published studies and analyses for each of the three groups of
    designs or populations we analysed (excluding some analyses we
    performed on data not published but received upon request). We also
    evaluated potential publication bias by using the rank correlation
    test.(39) We found no present evidence of publication bias
    for studies on the effects of adding SSBs;
    (30, 34, 36, 40-42) P = 0.805), for studies on the effects
    of reducing SSBs in all weight categories;
    (29, 33, 35, 43-46) P = 0.976), or for studies on the
    effects of reducing SSBs in subjects who were overweight at baseline;
    (33, 35, 43, 44, 46) P = 0.858).
    Sensitivity Analysis
        Age differences. There was unequal representation of age groups
    among the types of trials. The added SSB studies were all on adults
    except one,(36) and the reducing studies were predominantly
    in children with two exceptions.(35, 47) Therefore, we
    evaluated the overall summary effects by excluding the studies
    referenced above. The overall SMD for the added SSB studies (adults
    only) increased by 0.06 (to 0.34; 95% CI: 0.15 to 0.54). The overall
    SMD for the reduction of SSBs in children of all weight categories was
    reduced by 0.01 (to 0.07; 95% CI: ^0.01 to 0.15). The overall SMD for
    the reduction studies in children only who were overweight or obese at
    baseline increased by 0.05 (to 0.30; 95% CI: 0.13 to 0.46). These
    results are not largely different from the combined analysis reported
    in Figs 3-5. Per the convention put forth by Cohen,(48)
    these standardized effects would all be categorized as `small.'

               Table 1  Studies Published Since January 2009 Meeting the Original Inclusion Criteria (37)
    ----------------------------------------------------------------------------------------------------------------
                           Question that can be
         Reference       addressed regarding the       How meta-analysed        Primary outcome(s) and analysis as
                        effects of SSBs on weight                               stated in trials registry and paper
    ----------------------------------------------------------------------------------------------------------------
    Njike, et al.,      Added two servings per     Meta-analysed all          Trial registry: NCT00538083
     2011 (30)           day of sugar-free cocoa,   response data for all     Primary--Endothelial function
                         sugared cocoa, or          phases (author provided   Secondary--Blood pressure, lipid
                         placebo cocoa in obese     raw data on request)--     profile, low-density lipoprotein
                         adults in a crossover      combined both caloric      (LDL) oxidation, lipid hydroperoxide,
                         trial, 6 weeks each        groups (sugared cocoa      C-reactive protein (CRP), glucose,
                         phase.                     and placebo cocoa) and     body weight, waist circumference,
                                                    subtracted sugar-free      endothelin
                                                    group.                    Paper:
                                                                              Primary--Endothelial function
                                                                              Secondary--Blood pressure, lipid
                                                                               profile and fasting glucose, food
                                                                               intake, endothelin, CRP, oxidized
                                                                               LDL, lipid hydroperoxide,
                                                                               anthropometric measures (body weight,
                                                                               body mass index (BMI), waist
                                                                               circumference)
                                                                              Missing data handling: Intention to
                                                                               treat analysis
    Vaz, et al., 2011   Added choco-malt beverage  Meta-analysed untreated    Trial registry: NCT00876018
     (36)                mix to water and gave      control group versus      Primary--Physical fitness and
                         one serving per day to     unfortified group.*        performance
                         children in a parallel                               Secondary--Nutritional status, muscle
                         trial.                                                strength and endurance
                                                                              Paper:
                                                                              Primary--Within participant change in
                                                                               physical performance: whole-body
                                                                               endurance, aerobic capacity, speed
                                                                               and visual reaction time
                                                                              Secondary--Nutritional status, muscle
                                                                               strength, endurance in forearm flexor
                                                                               muscle group
                                                                              Missing data handling: Complete case
                                                                               analysis
    Maersk, et al.,     Added 1 litre per day of   Meta-analysed regular      Trial registry: NCT00777647
     2012 (34)           milk, regular cola, diet   cola group versus diet    Primary--Body weight, magnetic
                         cola or water in           group.                     resonance spectroscopy, magnetic
                         overweight/obese adults                               resonance imaging, dual-energy x-ray
                         in a parallel trial for                               absorptiometry scan
                         6 months.                                            Secondary--Circulating metabolic
                                                                               parameters, blood pressure
                                                                              Paper:
                                                                              Primary--Intrahaepatic fat and
                                                                               intramyocellular fat
                                                                              Secondary--Fat mass, fat distribution,
                                                                               metabolic risk factors
                                                                              Missing data handling: Complete case
                                                                               analysis except for two cases who
                                                                               dropped out at 5 months, for whom
                                                                               last observation was carried forward
    Ebbeling, et al.,   Multicomponent programme   Meta-analysed weight       Trial registry: NCT00381160
     2012 (33)           to reduce/replace SSBs     change at end of 1 year   Primary--BMI change at 2 years
                         with non-caloric           intervention period.      Secondary--none stated
                         beverages in                                         Paper:
                         adolescents.                                         Primary--Change in mean BMI at 2 years
                                                                               (1 year post-intervention)
                                                                              Secondary--Differences between
                                                                               ethnicities, change in body fat as a
                                                                               percentage of total weight
                                                                              Missing data handling: Imputed--
                                                                               baseline and last observation carried
                                                                               forward in separate analyses
    de Ruyter, et al.,  Provided school children   Considered an SSB          Trial Registry: NCT00893529
     2012 (29)           identically labelled SSB   reduction study as        Primary--BMI Z-score at 6, 12 and 18
                         or non-caloric             inclusion criteria was     months
                         equivalent to consume      current SSB consumers.    Secondary--Body composition using
                         one can day^\1\.                                      skinfolds, bioelectrical impedance
                                                                               analysis (BIA), waist-to-height
                                                                               ratio, dental health, sensory
                                                                               evaluation (satiety and liking of
                                                                               study drink)
                                                                              Paper:
                                                                              Primary--Z-score of BMI for age at 18
                                                                               months.
                                                                              Secondary--(all pre-specified) waist-
                                                                               to-height ratio, sum of the four
                                                                               skinfold thickness measurements and
                                                                               fat mass (BIA). Additional outcomes
                                                                               were weight, height, z score for
                                                                               height, waist circumference and
                                                                               weight change adjusted for height
                                                                               change
                                                                              Missing data handling: Multiple
                                                                               imputation and complete case analysis
    Tate, et al., 2012  Substituted SSBs with      Meta-analysed water and    Trial registry: NCT01017783
     (35)                artificially sweetened     artificially sweetened    Primary--Weight change at 3 and 6
                         equivalent or water in     groups together versus     months
                         obese adults who drink     SSB group.                Secondary--Urine specific gravity,
                         two or more servings per                              fasting glucose
                         day at baseline.                                     Paper:
                                                                              Primary--Weight change at 6 months.
                                                                              Secondary--Compare the non-caloric
                                                                               beverage groups with the control
                                                                               group on criterion measures of weight
                                                                               loss, waist circumference, blood
                                                                               pressure, glucose, and urine
                                                                               osmolality from 0 to 3 and 0 to 6
                                                                               months
                                                                              Missing data handling: Multiple
                                                                               imputation for continuous variables,
                                                                               complete cases for 5% weight loss
                                                                               criterion analysis
    ----------------------------------------------------------------------------------------------------------------
    * We originally excluded any types of beverages that had growth promotion as a function, but the unfortified
      beverage met our original inclusion criteria and is included in this analysis. SSB, Sugar-sweetened Beverage.

    Figure 2

              Observed (30, 34, 40-42, 62) versus theoretical
            (63) weight gain effect of mandatory sugar-sweetened
            beverage (SSB) consumption.
              Notes: For observed values on the Y axis, weight change was
            determined by the change of those drinking more SSBs minus
            those drinking less. The X axis was determined by multiplying
            the added kcal per day times the duration of the study divided
            by 1,000. Fit lines were generated by setting the origin to
            zero and by using the linear regression (least squares) options
            in Microsoft' Excel. The theoretical values (round
            markers) were generated by entering mean baseline values for
            each study sample into the NIDDK body weight simulator
            (63) and adding the same number of calories per day
            for the same number of days as reported in the
            studies.(30, 34, 40-42, 62) Activity settings in the
            simulator were at the lowest level of sedentary and no activity
            or dietary changes over the study duration were entered into
            the simulator. Observed data represent an average energy
            compensation rate of 85% (range = 57-110% compensation).
    Figure 3

              Forest plot comparing studies of added sugar-sweetened
            beverage (SSB) consumption.
              Note: R square values were calculated from the overall
            standardized mean difference estimate (d) per the method found
            in.(64)

        Study heterogeneity in reduction studies. Because the heterogeneity
    statistic was significant (Fig. 4) in the reduction studies in both
    weight groups, we evaluated which study exerted the most influence for
    its effects on the overall SMD.(46) Exclusion of this study
    resulted in a non-significant heterogeneity statistic (x\2\
    (6) = 10.15, P = 0.12, I\2\ = 41%) and an increased overall
    SMD of 0.13 (95% CI: 0.04 to 0.22). These analyses shifted the overall
    statistics by relatively small amounts when considering the observed
    shifts in body weight among the analysis groups.
        Interpreting the magnitude of effects. At this juncture, it may be
    helpful to express the estimated effect sizes for SSB reduction on BMI
    in some additional metrics which may ease interpretation. One such
    metric is the probability that a randomly selected person from a
    hypothetical population in which SSB reduction was implemented will be
    better off (with respect to BMI) than a randomly selected person from a
    hypothetical population that is the same in all ways except that SSB
    reduction has not been implemented. Without intervention, the
    probability is 0.50 that a person from one population weighs more than
    a person from the other population. After the interventions included in
    our analysis, these probabilities would change slightly. The
    probability that a randomly selected person from the reduced SSB
    population will have lower BMI than a person randomly selected from the
    control population would be 0.52. The probability that a randomly
    selected overweight person from the reduced SSB population will have a
    lower BMI than an overweight person randomly selected from the control
    population would be 0.57.
    Figure 4

              Forest plot comparing studies of reduced sugar-sweetened
            beverage (SSB) consumption; subjects in all weight categories
            included.
              Note: R square values were calculated from the overall
            standardized mean difference estimate (d) per the method found
            in.(64)
    Figure 5

              Forest plot comparing studies of reduced sugar sweetened
            beverage (SSB) consumption; only subjects overweight/obese at
            baseline included.
               R square values were calculated from the overall
            standardized mean difference estimate (d) per the method found
            in.(64)

        Another way to place the effect sizes in perspective is to consider
    the g\2\ metric shown in Figs 3-5. Increasing consumption of SSBs
    explains 1.92% of the variance in body weight or BMI change. Reducing
    consumption of SSBs in persons of all weight categories explains 0.09%
    of the variance in body weight or BMI change. Among persons who are
    overweight or obese at baseline, reducing the consumption of SSBs
    explains 1.54% of the variance in body weight or BMI change. It is
    possible to apply other methods such as risk analysis for evaluating
    potential effects on population levels of obesity,(49) but
    that is beyond the scope of the present analysis.
    Additional Considerations
        Having demonstrated that, although the conjecture that decreasing
    SSB consumption will decrease obesity and obesity-related diseases is
    reasonable, the pertinent data testing the hypothesis are equivocal
    (i.e., the pooled results are nearly but not quite statistically
    significant), we now address several related questions.
    If the data are as weak as we have shown, why do some members of the
            public and the scientific community seem to perceive that the
            proposition has been proven?
        We suggest three major reasons for this confusion.
    Emotion-Raising Language
        Emotion-raising language has often been used in discussions of SSBs
    and obesity. Some authors have used words like `plague',(50)
    `toxic',(51-52) `hazardous' (4, 53) and `deadly'
    (4, 54) when describing SSBs or the sugars they contain and
    have tried to promote perceived connections between SSB marketers and
    the worst behaviour of tobacco marketers.(55) Although such
    words may help to advance an agenda,(56) they do not educate
    or inform the public. Moreover, they likely raise emotions and impair
    logical reasoning.(57) As Kersh and Morone (56)
    wrote, `Scientific findings never carry the same political weight as
    does a villain threatening American youth. If critics successfully cast
    portions of the industry in this way, far-reaching political
    interventions are possible, even likely. When an industry becomes
    demonized, plausible counter-arguments (privacy, civil liberties,
    property rights, and the observation that ``everyone does it'') begin
    to totter.'
    Figure 6

              Comparison of weight gain attributed to consumption of sugar-
            sweetened beverages for 1 year from various sources.
              Note: For the Haub study, the weight change shown above is
            adjusted by subtracting the control group weight change.
              * Body mass index of 27.8 kg m^\2\ (NHANES 2010 50th
            percentile for both men and women in the United States
            (65) entered into NIDDK body weight
            simulator.(63)
              + (66) # (67) $ (68).
    Distortion of Scientific Information
        A second factor that has likely contributed to misperceptions in
    this area is the distortion of scientific information by some authors
    and commentators. Table 2 lists some of the types of distortion that
    have occurred with quantitative or anecdotal documentation. Figure 6
    depicts disparities in projected versus actual outcomes of the effects
    of added SSBs over 1 year. Clearly, such practices mislead and have
    likely contributed to misperceptions in the scientific and lay
    communities about the strength of the evidence regarding the
    proposition debated here.
    The Mere Exposure Effect
        The final factor that we believe has led to the erroneous
    perception that the evidence showing that the proposition of this
    debate has been unequivocally proven is the `mere exposure effect.' The
    mere exposure effect is the label psychologists use for the phenomenon
    that the more a person is exposed to an idea, the more they come to
    like and accept it. As the Nobel Prize-winning economist Daniel
    Kahneman described, `A reliable way to make people believe in falsehood
    is frequent repetition, because familiarity is not easily distinguished
    from truth. Authoritarian institutions and marketers have always known
    this fact. But it was psychologists who discovered that you do not have
    to repeat the entire statement of a fact or idea to make it appear
    true'.(58)
        The number of articles on SSBs and obesity and the number of
    statements that SSBs are especially problematic in obesity are
    extraordinary, especially in comparison to the modest amount of
    probative data.(3) Thus, opinions about SSBs may have been
    offered so often that these opinions have become accepted as fact by
    many in the scientific community, media and lay public.

                   Table 2  Some types of Distortion of Information that Have Occurred Regarding Sugar-Sweetened Beverages (SSBs) and Obesity
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                Type of distortion                  Where it occurs                      Documentation of occurrence                         Comments
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Papers citing original randomized          In the scientific peer-   Cope and Allison (14) documented in a quantitative          This is not a criticism
     controlled trials (RCTs) that              reviewed literature       analysis of the literature that this exaggerated            of the original RCTs,
     investigated the effect of SSB reduction                             reporting was the norm rather than an exception.            but rather the manner
     on weight exaggerated the extent of the                                                                                          in which subsequent
     evidence supporting a beneficial effect                                                                                          authors cite them.
    Association studies are described by       In the scientific peer-   `A new study . . . suggests a key way to reduce childhood   `Cravings' were not
     using language that indicates a cause      reviewed literature       obesity could be to limit your child's salt intake. The     mentioned in the
     and effect relationship has been found     [e.g.,(69)], in           study looked at 4,000 children in Australia and found       published study,(74)
                                                government-sponsored      kids who ate more salt also had more cravings for sugary-   which did not
                                                newsletters               sweetened drinks like soda and juice.' (72)                 overstate the
                                                [e.g.,(70)], and in                                                                   findings, but were
                                                mass media articles                                                                   exaggerated in media
                                                (71	73)                                                                               coverage. This
                                                                                                                                      misleading practice is
                                                                                                                                      common in the obesity
                                                                                                                                      field overall.(75)
    Public statements that contradict          Communications from       In 2010, [T]he New York Times ran an article in which,      See Figure 6 for
     available evidence                         public health agencies    through e-mails obtained under the Freedom of Information   details and specific
                                                                          Act, they showed that the New York City (NYC) Department    references.
                                                                          of Health was knowingly making exaggerated statements
                                                                          about the amount of weight gain expected from drinking
                                                                          SSBs. Even after this expose (September 2012), the NYC
                                                                          Department of Health made even more exaggerated and
                                                                          evidence-contradicted statements about the amount of
                                                                          weight gain expected from drinking SSBs.
    Changing what is considered the primary    In the scientific peer-   An example (34) of this occurred in an RCT published in     This does not conform
     endpoint or analysis in an RCT             reviewed literature       the American Journal of Clinical Nutrition (AJCN). In the   to the CONSORT
                                                                          paper, the authors state `Our main aim was to test the      guidelines for
                                                                          hypothesis that sucrose-sweetened cola increases ectopic    publishing RCTs to
                                                                          fat including VAT4, total body fataccumulation, and         which authors
                                                                          metabolic risk factors . . . ,' whereas the registration    publishing in AJCN are
                                                                          in ClinicalTrials.gov states `Primary Outcome Measures:     expected to adhere.
                                                                          Body Weight; MR spectroscopy; MRI; DEXA scan.' Similarly,
                                                                          in ClinicalTrials.gov, the title of the trial is `Effect
                                                                          of Carbonated Soft Drinks on the Body Weight,' whereas in
                                                                          the article the title is `Sucrose-sweetened beverages
                                                                          increase fat storage in the liver, muscle, and visceral
                                                                          fat depot: a 6-mo randomized intervention study.' The
                                                                          fact that there was no significant effect on weight was
                                                                          not mentioned in the abstract of the paper.
    Conclusion statements from paper do not    In peer-reviewed papers,  An example from the peer-reviewed literature occurred in a  Although a trained
     match the results                          press releases, and       paper in AJCN (35) in which the results section of the      scientist carefully
                                                mass media interviews     abstract stated `Mean (RSEM) weight losses at 6 months      reading the original
                                                                          were ^2.5 R0.45% in the DB group, ^2.03 R0.40% in the       papers will understand
                                                                          Water group, and ^1.76 R0.35% in the AC group; there were   the results,
                                                                          no significant differences between groups.' Yet, the        journalists,
                                                                          conclusion section of the abstract stated `Replacement of   regulators, clinicians
                                                                          caloric beverages with non-caloric beverages as a weight-   and scientists who
                                                                          loss strategy resulted in average weight losses of 2% to    only rapidly read an
                                                                          2.5%.' Given the non-significant result, it does not seem   abstract are likely to
                                                                          justifiable to state there is any weight loss as a result   be misled.
                                                                          of the treatment. Even if point estimates were being
                                                                          provided in a merely descriptive manner, the unbiased
                                                                          estimates of treatment effects in an RCT are the control-
                                                                          subtracted means, not the raw means in the treatment
                                                                          group. Examples from press releases and media interviews
                                                                          can be found in (14, 76) and in these sources.(77,78)
    Publication bias                           In the scientific peer-   Cope and Allison (14) showed that in observational          This is why we wrote
                                                reviewed literature       epidemiologic studies of the association of SSB             earlier in this paper
                                                                          consumption and obesity, a standard test of publication     that the observed
                                                                          bias was significant, suggesting that investigators are     magnitude of
                                                                          more likely to publish positive statistically significant   association is likely
                                                                          findings than to publish null findings.                     biased upwards.
                                                                                                                                      Interestingly, Cope
                                                                                                                                      and Allison found that
                                                                                                                                      this publication bias
                                                                                                                                      seemed to occur among
                                                                                                                                      non-industry-funded
                                                                                                                                      authors and not among
                                                                                                                                      industry-funded
                                                                                                                                      authors.
    --------------------------------------------------------------------------------------------------------------------------------------------------------

        Table 3  Quotations Illustrating that Others Do Not Believe the Benefits of Interventions Aimed at SSB Reduction on Weight Have Been Established
    --------------------------------------------------------------------------------------------------------------------------------------------------------
            Person(s) or body offering statement                                              Statement                                          Reference
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    United States Department of Agriculture Dietary      `Thus, there are mixed results on this topic. RCTs report that added sugars are not            (12)
     Guidelines Advisory Committee                        different from other calories in increasing energy intake or body weight.
                                                          Prospective studies report some relationship with SSB and weight gain, but it is
                                                          not possible to determine if these relationships are merely linked to additional
                                                          calories, as opposed to added sugars per se. The systematic reviews in this area
                                                          are also inconsistent, probably based on different measures used to determine
                                                          added sugars intake or intake of SSB.' [We should] `Conduct well-controlled and
                                                          powered research studies testing interventions that are likely to improve energy
                                                          balance in children at increased risk of childhood obesity, including dietary
                                                          approaches that reduce . . . sugar-sweetened beverages' [because] `very few solid
                                                          data are available on interventions in children.'
    European Food Safety Authority                       `The Panel concludes that a cause and effect relationship has not been established             (79)
                                                          between total sugar intake and body weight gain, and that a cause and effect
                                                          relationship has not been established between the consumption of foods and
                                                          beverages in which sugars have been replaced by intense sweeteners and
                                                          contribution to the maintenance or achievement of a normal body weight.'
    Lisa Te Morenga, Simonette Mallard, Jim Mann         `Trials in children, which involved recommendations to reduce intake of sugar                  (80)
                                                          sweetened foods and beverages, had low participant compliance to dietary advice;
                                                          these trials showed no overall change in body weight.'
    German Nutrition Society                             `From two of the four available meta-analyses the conclusion is drawn that                     (81)
                                                          increased consumption of sugar-sweetened beverages in children and adolescents is
                                                          associated with a higher risk of obesity. In contrast, another meta-analysis
                                                          judges the effect as almost zero. The cohort studies published since then verify
                                                          this risk-increasing effect only in part. The most recent meta-analysis concludes
                                                          that the risk-increasing effect is limited to individuals with initially already
                                                          increased BMI or existing overweight, respectively.'
    Thomas Baranowski                                    `Another concern is the behavior or behaviors targeted for change. Many obesity                (82)
                                                          prevention interventions have targeted increasing fruit and vegetable intake and
                                                          decreasing sweetened beverage intake. Systematic reviews, however, showed no
                                                          consistent evidence that increased fruit and vegetable intake protected against
                                                          obesity or that sweetened beverage intake contributed to it.'
    Joint statement from American Heart Association and  `At this time, there are insufficient data to determine conclusively whether the               (83)
     the American Diabetes Association                    use of NNS [non-nutritive sweeteners] to displace caloric sweeteners in beverages
                                                          and foods reduces added sugars or carbohydrate intakes, or benefits appetite,
                                                          energy balance, body weight, or cardiometabolic risk factors.'
    --------------------------------------------------------------------------------------------------------------------------------------------------------

    Are we alone in the view that a beneficial effect of SSB reduction on
            obesity has not been demonstrated?
        In a word, no. As the quotations in Table 3 reveal, our views are
    concordant with those of other individual scientists and authoritative
    expert panels.
    What would it take to shift the balance of evidence?
        In a possibly apocryphal interchange, a devotee of Karl Popper's
    philosophy of science once challenged the great mathematical geneticist
    J.B.S. Haldane to specify what it would take to change his views about
    the validity of evolutionary theory. Haldane reportedly retorted
    `Fossil rabbits in the Precambrian!' Although a poetic retort, Haldane
    was effectively specifying objective empirical evidence that would be
    sufficient for him to change his view, something any scientist
    addressing empirical questions should be prepared to do.
        In the debate at The Obesity Society Meeting (September 20, 2012),
    the senior author [DBA] stated:

              `The day that multiple RCTs are published that

         are well designed, executed, and analyzed;

         show statistically significant outcomes in preplanned
                analyses of the total randomized sample on measures of
                total body weight, BMI, or total body fat and clearly
                support the value of reducing SSBs; and

         are sufficient in inferential weight to outweigh the
                existing RCT data;

              I will be delighted to modify my opinion.'

    The day after the debate (September 21, 2012), two new RCTs were
    published.(29, 33) These two publications together met some
    (but not all) of the criteria specified above as we discussed earlier.
    Most notably, their collective evidential weight moved the integrated
    meta-analytic estimate for the effects of SSB reduction very close to
    the border of the conventional 0.05 level of statistical significance.
    For this reason, we believe that these two new studies can be described
    as `tilting the needle' in the direction of demonstrating the obesity-
    reducing benefit of SSB reduction, but that the data remain equivocal.
    Nevertheless, we remain open-minded that future RCTs (and according to
    ClinicalTrials.gov some will be forthcoming) may fulfil the criteria
    above and offer unequivocal support for the proposition.
        We also suggest that the following approaches can increase the
    transparency of, and confidence in, RCTs in this area: (i) registering
    all RCTs in advance in ClinicalTrials.gov; (ii) making the raw data
    from all RCTs publicly available for common and open analyses,
    regardless of the source of funding; (iii) providing documentation via
    ClinicalTrials.gov as to which analyses are (were) pre-planned; and
    (iv) publishing all results regardless of outcome. These are laudable
    practices in all situations, but especially important in an area that
    has become so contentious.
    How does the strength of evidence for conclusions relate to support for
            actions?
        As we mentioned earlier, we are not addressing whether any
    particular policy or programme should or should not be implemented.
    Rather, our sole purpose has been to present a synthesis of the
    currently available literature that provides an estimate of the degree
    of evidence for the debate proposition. Moreover, it is important to
    note that our paper assessed the evidence for effect of reducing SSB
    consumption, which should not be conflated with the effects of
    particular policies (e.g., taxes, bans, advertising campaigns, etc.)
    intended to reduce SSB consumption. The effects of any such policies
    represent a different question and not one for which we have evaluated
    the evidence.
        The question of whether the available evidence is sufficiently
    strong to justify a particular action is a subjective one subject to
    societal perceptions, values, goals and the plausibility of unintended
    consequences.(59-60) This is illustrated by quotations from
    two authoritative sources on this point as food for thought:

              `Since taking office, the President has emphasized the need
            to use evidence and rigorous evaluation in budget, management,
            and policy decisions to make government work effectively. . . .
            Where evidence is strong, we should act on it. Where evidence
            is suggestive, we should consider it. Where evidence is weak,
            we should build the knowledge to support better decisions in
            the future.' (61)
              `On fair evidence we might take action on what appears to be
            an occupational hazard, e.g., we might change from probably
            carcinogenic oil to a non-carcinogenic oil in a limited
            environment and without too much injustice if we are wrong. But
            we should need very strong evidence before we made people burn
            a fuel in their homes that they do not like or stop smoking the
            cigarettes and eating the fats and sugar that they do like.'
            (1)
    Conclusions
        Our updated meta-analysis shows that the currently available
    randomized evidence for the effects of reducing SSB intake on obesity
    is equivocal. Even if statistical significance is ignored, the point
    estimates of effects on BMI reduction are small, accounting for only
    1.5% of the variance observed in those who were overweight at baseline.
    Therefore, we conclude that the debate proposition cannot be supported
    at this time. Of course, absence of evidence is not evidence of
    absence. The lower limit of the confidence interval around the
    estimated effect of SSB reduction is very close to the border of
    statistical significance. It is certainly possible that additional,
    larger or otherwise stronger studies will in the future provide clear
    and convincing evidence that lowering SSB consumption will reduce
    obesity and obesity-related disease prevalence. We are certainly not
    arguing against the common-sense recommendation that for individuals
    who wish to lose weight and who presently drink large amounts of SSBs,
    reducing intake of these and other sources of energy seems wise.
        We greatly respect our debate opponent, Dr. Hu, for addressing
    these issues in a manner that is both thoroughly scientific and equally
    collegial. We are hopeful that this debate may be seen not only as a
    careful consideration of the evidence regarding SSBs and obesity, but
    also as an exemplar of and call to a more informed, unexaggerated,
    open-minded, rational and civil dialogue on the many public health
    issues around obesity that, like SSB-related issues, have become so
    contentious.

    Author Contributions

        KAK performed an updated systematic review, reviewed papers for
     inclusion criteria, extracted data from papers, wrote summaries of new
     studies included in appendix, checked meta-analysis calculations,
     assessed risk of bias for newly included studies, generated tables,
     generated figures and wrote a significant portion of the text. KDK
     extracted data from papers, analysed supplemental data received from
     authors, generated new meta-analysis statistics and verified prior data
     reported. JMS reviewed papers for inclusion criteria, assessed risk of
     bias for newly included studies, wrote summaries of new studies
     included in appendix and reviewed and edited text. DBA conceived of the
     project scope, developed debate arguments, directed meta-analysis
     methods, reviewed papers for inclusion criteria, edited and wrote a
     significant portion of the text.

    Conflict of Interest Statement
        In the last 36 months, Dr. Allison has received consulting fees from
     Kraft Foods. The University of Alabama at Birmingham has received gifts
     and grants from multiple organizations including but not limited to The
     Coca-Cola Company, PepsiCo, Red Bull and Kraft Foods. Drs. Kaiser,
     Keating and Shikany have no competing interests to report.

    Ethical Approval

        Not required.

    Acknowledgements

        Supported in part by NIH grant P30DK056336. The opinions expressed
     are those of the authors and not necessarily those of the NIH or any
     other organization with which the authors are affiliated. This paper is
     based on a debate held at The Obesity Society 2012 Annual Meeting. The
     authors thank Sigrid Gibson; Drs. Michelle Bohan Brown, Richard
     Forshee, Richard Mattes and Douglas Weed for their suggestions on
     drafts of this manuscript. The authors also thank Dr. Marc Reitman for
     the use of Fig. 1. The authors are also grateful to those who kindly
     responded to our request for additional data about their studies: Dr.
     Valentine Njike, Dr. David Katz, Dr. Mario Vaz, Dr. Tinku Thompson, Ms.
     Janne de Ruyter, Dr. Sonia Hernandez-Cordero and Dr. Martijn Katan.

    Supporting Information

        Additional Supporting Information may be found in the online version
     of this article, http://dx.doi.org/10.1111/obr.12048.
        Figure S1. Study screening and selection process of new studies
     added since the original meta-analysis (21)
        Figure S2. Methodological quality summary; review authors' judgments
     about each methodological quality item for each included study (1	6,
     20, 25	32)
        Figure S3. Funnel plot of published studies of added sugar-sweetened
     beverage (SSB) consumption (3	4, 6, 27, 30, 32)
        Figure S4. Funnel plot of published studies on reduced sugar-
     sweetened beverage (SSB) consumption in subjects of all weight
     categories (1	2, 5, 20, 26, 28, 31)
        Figure S5. Funnel plot of published studies of reduced sugar-
     sweetened beverage (SSB) consumption in subjects overweight/obese at
     baseline (2, 5, 20, 26, 31)
        Table S1. Unstandardized effect sizes of new studies assessing the
     effects of adding mandatory SSB consumption to persons diets
        Table S2. Standardized effect sizes from new studies assessing the
     effect of attempting to get people to reduce or eliminate SSB
     consumption on body composition/adiposity indicators
        Table S3. Standardized effect sizes from new studies assessing the
     effect of attempting to get people to reduce or eliminate SSB
     consumption on body mass index (BMI) only for subjects overweight/obese
     at baseline or above the top of tertile of baseline BMI
        Appendix S1. Updated literature review, selection and data
     extraction methods

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     Consum. Res. 2008; 35: 406-422.
        60. Wansink B., Hanks D., Just D.R., et al. From Coke to Coors: A
     Field Study of a Sugar-Sweetened Beverage Tax and its Unintended
     Consequences. Posted: 5-26-2012. [WWW document]. URL http://dx.doi.org/
     10.2139/ssrn.2079840 (accessed December 2012).
        61. Zients J.D. Memorandum to the Heads of Executive Departments and
     Agencies. Posted: 2012. [WWW document]. URL http://www.whitehouse.gov/
     sites/default/files/omb/memoranda/2012/m-12-14.pdf (accessed December
     2012).
        62. Addington E.A. Aspartame- or sugar-sweetened beverages. Effects
     on food appetites and mood in young adults (Doctoral dissertation).
     Manhattan, Kansas: Kansas State University. 1998.
        63. Hall K.D. Body Weight Simulator. Posted: 4-4-2012. [WWW
     document]. URL http://bwsimulator.niddk.nih.gov/ (accessed December
     2012).
        64. Hedges L.V., Olkin I. Statistical Methods for Meta-Analysis.
     Academic Press: Orlando, FL, 1985.
        65. Flegal K.M., Carroll M.D., Kit B.K., Ogden C.L. Prevalence of
     obesity and trends in the distribution of body mass index among U.S.
     adults, 1999-2010. JAMA 2012; 307: 491-497.
        66. Hartocollis A. E-Mails Reveal Dispute Over City's Ad Against
     Sodas. Posted: 10-28-2010. [WWW document]. URL http://www.nytimes.com/
     2010/10/29/nyregion/29fat.html?pagewanted=all (accessed December 2012).
        67. New York City Department of Health and Mental Hygiene. Man
     Drinking Fat. NYC Health Anti-Soda Ad. Are You Pouring on the Pounds?
     Posted: 12-14-2009. [WWW document]. URL http://www.youtube.com/watch?v=-
     F4t8zL6F0c (accessed December 2012).
        68. Kansangra S. Maximum Size For Sugary Drinks: Proposed Amendment
     of Article 81--Response to Comments. Posted: 9-13-2012. [WWW document].
     URL http://www.nyc.gov/html/doh/downloads/pdf/boh/article81-response-to-
     comments-ppt.pdf (accessed December 2012).
        69. Davis J.N., Whaley S.E., Goran M.I. Effects of breastfeeding and
     low sugar-sweetened beverage intake on obesity prevalence in Hispanic
     toddlers. Am. J. Clin. Nutr. 2012; 95: 3-8.
        70. Norton A. Could Kids' Salt Intake Affect Their Weight? Posted:
     2012. [WWW document]. URL http://consumer.healthday.com/
     Article.asp?AID=671410 (accessed December 2012).
        71. Azuz C. Lots of salt means lots of soda. Posted: 12-10-2012.
     [WWW document]. URL http://www.cnn.com/video/?hpt=he_mid#/video/health/
     2012/12/10/hm-salt-and-soda.cnn (accessed December 2012).
        72. Mackey L. Lowering salt intake may be key to lowering childhood
     obesity rates. Posted: 12-10-2012. [WWW document]. URL http://wtvr.com/
     2012/12/10/lowering-salt-intake-may-be-key-tolowering-childhood-obesity-
     rates/ (accessed December 2012).
        73. McKenzie A. Study says salt may be a catalyst for childhood
     obesity. Posted: 12-13-2012. [WWW document]. URL http://
     triad.news14.com/content/top_stories/676361/study-says-salt-may-be-a-
     catalyst-for-childhood-obesity (accessed December 2012).
        74. Grimes C.A., Riddell L.J., Campbell K.J., Nowson C.A. Dietary
     Salt Intake, Sugar-Sweetened Beverage Consumption, and Obesity Risk.
     Pediatrics 2012; 13: 14-21. e-pub (DOI: 10.1542/peds.2012-1628).
        75. Cofield S.S., Corona R.V., Allison D.B. Use of causal language
     in observational studies of obesity and nutrition. Obes. Facts 2010; 3:
     353-356.
        76. Cope M.B., Allison D.B. White hat bias: a threat to the
     integrity of scientific reporting. Acta. Paediatr. 2010; 99: 1615-1617.
        77. James G. Are Diet Drinks The Key To Weight Loss? Posted: 2-15-
     2012. [WWW document]. URL http://www.huffingtonpost.co.uk/2012/02/15/
     diet-drinks-water-key-to-weightloss_n_1279488.html (accessed December
     2012).
        78. Lane P. Press Release: Weighing the difference: switching to
     water, diet beverages can tip the scales. Posted: 2012. [WWW document].
     URL http://uncnews.unc.edu/content/view/5088/71 (accessed December
     2012).
        79. European Food Safety Authority. Scientific Opinion on the
     substantiation of health claims related to intense sweeteners and
     contribution to the maintenance or achievement of a normal body weight.
     Posted: 2012. [WWW document]. URL http://www.efsa.europa.eu/en/
     efsajournal/doc/2229.pdf (accessed December 2012).
        80. Te Morenga L., Mallard S., Mann J. Dietary sugars and body
     weight: systematic review and meta-analyses of randomised controlled
     trials and cohort studies. BMJ 2013; 346: e7492.
        81. Hauner H., Bechthold A., Boeing H., et al. Evidence-based
     guideline of the German Nutrition Society: carbohydrate intake and
     prevention of nutrition-related diseases. Ann. Nutr. Metab. 2012; 60
     (Suppl. 1): 1-58.
        82. Baranowski T. School-based obesity-prevention interventions in
     low- and middle-income countries: do they really work? Am. J. Clin.
     Nutr. 2012; 96: 227-228.
        83. Gardner C., Wylie-Rosett J., Gidding S.S., et al. Nonnutritive
     sweeteners: current use and health perspectives: a scientific statement
     from the American Heart Association and the American Diabetes
     Association. Circulation 2012; 126: 509-519.

                                  attachment 9
    Liquid Calories, Energy Compensation, and Weight: What We Know and What
            We Still Need To Learn
    Invited Commentary
    David B. Allison *
    ---------------------------------------------------------------------------
        * Office of Energetics, Nutrition Obesity Research Center,
    University of Alabama at Birmingham, Birmingham, AL 35294-0022, USA, e-
    mail dallison@uab.edu.
        doi:10.1017/S0007114513003309.
    ---------------------------------------------------------------------------
    British Journal of Nutrition (2014), 111, 384-386
    ' The Author 2013
    (First published online 28 October 2013)

        Roughly 10,000 years ago, sugar was first domesticated in New
    Guinea. Roughly 8,000 years ago, it was transplanted to India. Sometime
    around the seventh century, cultivation and some industrial production
    began in southern Europe, and the crusades subsequently acquainted more
    Europeans with sugar imported from Arab lands. Until the sixteenth
    century, sugar was often viewed by Europeans as having medicinal
    properties. Colonisation of the New World led to mass production and
    distribution of sugar as a major foodstuff.(1-5) By 1713, a
    writer in a scholarly journal was extolling the health virtues of high
    levels of sugar consumption, including in beverages.(6) In
    1893, Harley (7) conducted self-experiments and concluded
    that consumption of 250 g (approximately 4184 kJ or approximately 1000
    kcal) of sugar greatly increased muscular work capacity. In 1899, a
    controlled trial involving soldiers reported that those given a ration
    of sugar were in better health, felt more vigorous and gained more
    weight (presumably judged to be a good thing at the
    time).(8) As the century turned, Gardner (9)
    described sugar as a nutritional necessity that increased the health
    and vigour of populations. Yet, the positive health halo of sugar could
    not last. A generation later, authors of scientific papers did write
    about `The social problem growing out of the overconsumption of sugar'
    and described school-based programmes to teach children to consume less
    sugar.(10)
        Sugar consumed in liquid form has come to be seen by some as
    especially deserving of scrutiny. In 1990, Tordoff & Alleva
    (11) published seminal trial results showing that persons
    required to consume additional sugar in the form of a beverage gained
    more weight than did a control group given a non-energetic beverage.
    After 13 years, suspicion was increasing that metabolisable energy,
    perhaps especially sugar, consumed as liquids promoted less satiety,
    less energy compensation and more weight gain than did the same energy
    consumed in solid form.(12) The topic has become
    controversial to say the least,(13) and there is substantial
    evidence that the strength of the supporting data has often been
    exaggerated and distorted.(14,15)
        Newspaper articles offer statements such as `People who drink
    sugary soft drinks do not appear to compensate by reducing calories
    somewhere else in their diets, so they tend to pack on extra pounds'
    (16) and `Study after study has shown that like experimental
    animals, people do not compensate for extra liquid calories by eating
    less food'.(17) This concept that people do not adjust their
    energy intake (or expenditure) to compensate for energy consumed as
    liquids is at the heart of the matter. Yet, is it true? Although
    opinions on matters of energy compensation in response to various forms
    of sugar intake and/or liquid energy have been offered for over 70
    years,(18,19) convincing data on these issues have been
    scarce.
        In this issue of the British Journal of Nutrition, Reid, et
    al.,(20) offer a new and valuable piece of evidence on this
    question. In a study of obese adult women, those consuming sugar in
    liquid form at a level of 1,800 kJ (approximately 430 kcal) per d
    gained far less weight than expected and no more weight than did women
    in a control group drinking zero-energy beverages. The study has
    several strengths. It was a controlled trial that was run for long
    enough to observe weight changes and that was at least partially
    conducted in a blinded fashion. It also has several limitations,
    including a modest sample size, incomplete blinding and the fact that
    it was not strictly randomised. I will not belabour those points here
    as Reid and colleagues discuss them in their article. It should also be
    noted that the study concerns only adult women and cannot necessarily
    tell us about the effects in men or children.
    What does the study show?
        The study's essential finding concerns the question of compensation
    for liquid energy. The sucrose group gained no appreciable weight. This
    shows that over an extended period, at least in conditions similar to
    those of this study, women do compensate for additional energy consumed
    in the form of a sugar-sweetened beverage (SSB). Moreover, that the
    weight gained in the sucrose group was significantly less than that
    predicted by an established mathematical model based on the amount of
    energy consumed in the form of SSB further indicates that the vast
    majority of the energy consumed was compensated for. Reid, et al.,
    state that `Obese women who received 1,800 kJ sucrose per day in soft
    drinks for 4 weeks gained a mean of 1.72 kg less than predicted by the
    model.' Interestingly, the model predicted a total weight gain for a
    woman with the average characteristics listed in Reid, et al.,'s Table
    1 of only about 1.8 kg.
    Are the findings consistent with those of other studies?
        Yes. Kaiser, et al.,(15) meta-analysed other studies in
    which adults were required to consume additional energy in SSB in
    randomised controlled trials (RCT), and found that, on average, such
    required SSB consumption did indeed cause weight gain, but that the
    amount of weight gained was far less than \1/2\ the amount one would
    have predicted to be gained by use of the same mathematical model used
    by Reid, et al. (see Kaiser, et al.,'s Fig. 2). This indicates that, as
    Reid, et al., found, over extended periods of time, the majority of the
    energy consumed as SSB is indeed compensated for.
    Do the findings inform us about the effects of reducing sugar-sweetened
            beverage consumption among adult women?
        No. Though tempting, we cannot necessarily infer the effects of
    reducing SSB consumption from studies of the effects of increasing SSB
    consumption. That said, as Kaiser, et al.,(15) reported, no
    RCT of adults reported to date has found a statistically significant
    effect of reducing SSB consumption on weight.
    Do the findings inform us about the differential effects (if any) of
            consuming liquid v. solid energy on weight?
        No. The results of Reid, et al., only show what happens with SSB.
    From these data alone, we have no way of knowing whether the same
    results would have been obtained if the women were required to consume
    1,800 kJ of food in some solid form. Returning to the literature at
    large, there is evidence from a recent meta-analysis that in short-term
    (typically single-day) studies with food intake as the outcome, liquid
    energy is less well compensated for than is solid
    energy.(21) Yet, we cannot assume that individuals will not
    adapt to dietary changes over time. Long-term effects on weight cannot
    be reliably inferred from short-term effects on food intake. Indeed, to
    my knowledge, there are only two human RCT comparing the effects of
    liquid v. solid foods on weight over an extended period of time, and
    neither found a statistically significant difference between the liquid
    and solid conditions when the entire samples were
    analysed.(22-23)
        In conclusion, what we know from the overall literature is that
    when adults are required to consume additional energy in the form of
    SSB, on average, they gain some weight. What we also know from the
    overall literature and this new study is that, on average, adults gain
    far less weight than they would be expected to gain if they did not
    compensate. Thus, people clearly do compensate for liquid energy,
    although they do so incompletely. What we do not know, despite all the
    drama and vituperation surrounding SSB, is whether, over extended
    periods of time, people compensate any differently for liquid v. solid
    energy. It is high time we learned.

    Acknowledgements

        The present work was supported in part by National Institutes of
     Health (NIH) grant P30DK056336. The opinions expressed are those of the
     author and not necessarily those of the NIH or any other organisation.
        The author received grants and gifts to his university and
     consulting fees from multiple for-profit and not-for-profit
     organisations with interests in obesity, sugar and SSB.

                                   References

        1. Anonymous (1853) History of sugar. The Illustrated Magazine of
     Art, vol. 2, no. 2, p. 147. http://www.jstor.org/stable/20538093
     (accessed August 2013).
        2. Baru S. (1987) Sugar in history: sweetness and power. Review of
     Sweetness and Power: The Place of Sugar in Modern History by Sidney W.
     Mintz. Economic and Political Weekly vol. 22, no. 33 (15 August 1987),
     pp. 1391-1393. http://www.jstor.org/stable/4377370 (accessed August
     2013).
        3. Levi L. (1864) On the Sugar Trade and Sugar Duties. A Lecture
     Delivered at King's College, London, February 29, 1864. London:
     Effingham Wilson, Royal Exchange. http://www.jstor.org/stable/60101270
     (accessed August 2013).
        4. U.S. Department of Agriculture, Economic Research Service (1971)
     A History of Sugar Marketing. Agriculture Economic Report No. 197.
     Washington, D.C.: U.S. Government Printing Office.
        5. Galloway J.H. (1977) The Mediterranean sugar industry. Geographic
     Rev. 67, 177-194. http://www.jstor.org/stable/214019 (accessed August
     2013).
        6. Slare F. (1713) Part of a letter from Dr. Fred Slare to Dr. Hans
     Sloane; concerning a person who had a new set of teeth after 80 years
     of age; with some observations upon the virtues and properties of
     sugar. Phil. Trans. R. Soc. (1683-1775) 28, 273-274.
        7. Harley V. (1893) Sugar as a food in the production of muscular
     work. Proc. R. Soc. Lond. 54, 480-487.
        8. Anonymous (1899) Sugar as a ration. Br. Med. J. 1, 105.
        9. Gardner H.W. (1901) The dietetic value of sugar. Br. Med. J. 1,
     1010-1013.
        10. Sollins I.V. (1930) Sugar in diet: an experiment in instruction
     in candy consumption. J. Educ. Sociol. 3, 546-555.
        11. Tordoff M.G. & Alleva A.M. (1990) Effect of drinking soda
     sweetened with aspartame or high-fructose corn syrup on food intake and
     body weight. Am. J. Clin. Nutr. 51, 963-969.
        12. Almiron-Roig E., Chen Y. & Drewnowski A. (2003) Liquid calories
     and the failure of satiety: how good is the evidence? Obes. Rev. 4, 201-
     212.
        13. Slavin J. (2012) Beverages and body weight: challenges in the
     evidence-based review process of the Carbohydrate Subcommittee from the
     2010 Dietary Guidelines Advisory Committee. Nutr. Rev. 70, Suppl. 2,
     S111-S120.
        14. Cope M.B. & Allison D.B. (2010) White hat bias: examples of its
     presence in obesity research and a call for renewed commitment to
     faithfulness in research reporting. Int. J. Obes. (Lond) 34, 84-88.
        15. Kaiser K.A., Shikany J.M., Keating K.D., et al. (2013) Will
     reducing sugar-sweetened beverage consumption reduce obesity? Evidence
     supporting conjecture is strong, but evidence when testing effect is
     weak. Obes. Rev. 14, 620-633.
        16. Hellmich N. (2007) Soda drinkers consume more calories. USA
     Today. http://usatoday30.usatoday.com/news/health/2007-03-25-soda-
     drinkers_N.htm (accessed August 2013).
        17. Brody J.E. (2010) A tax to combat America's sugary diet. New
     York Times. http://www.nytimes.com/2010/04/06/health/06brod.html?_r%0
     (accessed August 2013).
        18. Anonymous (1942) Sugar rationing called a ``Godsend'' to
     national health. Science News-Letter vol. 41, no. 11 (14 March 1942),
     p. 164. http://www.jstor.org/stable/3918542 (accessed August 2013).
        19. Anonymous (1944) Advice given to go easy on use of chocolate
     milk. Science News-Letter vol. 45, no. 25 (17 June 1944), p. 398.
        20. Reid M., Hammersley R., Duffy M., et al. (2014) Effects on obese
     women of the sugar sucrose added to the diet over 28 days, a quasi-
     randomised, single-blind, controlled trial. Br. J. Nutr. 111, 563-570.
        21. Almiron-Roig E., Palla L., Guest K., et al. (2013) Factors that
     determine energy compensation: a systematic review of preload studies.
     Nutr. Rev. 71, 458-473.
        22. DiMeglio D.P. & Mattes R.D. (2000) Liquid versus solid
     carbohydrate: effects on food intake and body weight. Int. J. Obes.
     Relat. Metab. Disord. 24, 794-800.
        23. Houchins J.A., Burgess J.R., Campbell W.W., et al. (2012)
     Beverage vs. solid fruits and vegetables: effects on energy intake and
     body weight. Obesity (Silver Spring) 20, 1844-1850.

                                 attachment 10
    Corporate Funding of Nutrition Research and Unjustified Conclusions
    JAMA Internal Medicine, May 2016, Volume 176, Number 5

        To the Editor In her Viewpoint about corporate funding of food and
    nutrition research, Dr Nestle criticizes the food industry and
    scientists who associate with it.\1\
        Dr. Nestle claims that scientists who receive industry-derived
    research grants ``often fail to realize that food-industry funding may
    affect their work.''.\1\ (p. 13) She cites newspaper
    articles that ``illustrate the concerns about biases introduced by
    industry funding.'' \1\ (p. 13) She also cites reports
    2-3 showing that there are relatively few studies funded by
    industry whose results are contrary to the funders' interest and
    discusses her work on the subject including reference to her Food
    Politics blog.\4\
        The study by Massougbodji, et al.,\2\ also determined that the
    quality of the methods of the studies reviewed did not explain the
    orientation of the authors' conclusions, nor was there any relationship
    between the source of funding and the overall quality of the studies
    examined. The study by Lesser, et al.,\3\ did not examine any aspect of
    the studies that were reviewed other than funding source. The newspaper
    stories did not describe any flaw in the research of the scientists
    profiled. In addition, the authors of a great number of the presumably
    tainted industry-sponsored studies discussed on the blog written by Dr.
    Nestle \4\ explicitly stated that the funding source was not involved
    in the design, conduct, data analysis and interpretation, or manuscript
    preparation. Although Dr. Nestle also states that the quality of
    dietary advice is adversely affected by the source of research funds,
    many believe that the real problem is the overall poor quality of
    nutrition research.\5\ Before guilt by association is established,
    criticisms by Dr. Nestle deserve much more analysis.
        It would certainly be helpful, if not essential, for Dr. Nestle or
    others to show that industry-funded studies have more design flaws,
    inappropriate analyses, or unjustified conclusions relative to similar
    studies funded by other sources. Furthermore, in addition to financial
    conflicts of interest, there are nonfinancial conflicts resulting from
    career self-interest or unbounded intellectual passion that can be just
    as worrisome. Conflicts of interest in science can affect anyone, and
    are relevant to proponents of any point of view.

    Richard Kahn, Ph.D.

        Author Affiliation: Department of Medicine, University of North
     Carolina, School of Medicine, Chapel Hill, North Carolina.
        Corresponding Author: Richard Kahn, PhD, Department of Medicine,
     University of North Carolina, School of Medicine, Chapel Hill, NC 27599-
     7005 (rak6200@gmail.com).
        Conflict of Interest Disclosures: None reported.
        Additional Information: Dr. Kahn served as the Chief Scientific and
     Medical Officer of the American Diabetes Association.

                                  [References]

        1. Nestle M. Corporate funding of food and nutrition research:
     science or marketing. JAMA Intern. Med. 2016; 176(1): 13-14.
        2. Massougbodji J., Le Bodo Y., Fratu R., DeWals P. Reviews
     examining sugar-sweetened beverages and body weight: correlates of
     their quality and conclusions. Am. J. Clin. Nutr. 2014; 99(5): 1096-
     1104.
        3. Lesser L.I., Ebbeling C.B., Goozner M., Wypij D., Ludwig D.S.
     Relationshipbetween funding source and conclusion among nutrition-
     related scientific articles. PLoS Med. 2007; 4(1): e5.
        4. Nestle M. Food Politics Blog. http://www.foodpolitics.com/.
     Accessed March 2, 2016.
        5. Ioannidis J.P. Implausible results in human nutrition research.
     BMJ. 2013; 347: f6698.

        In Reply: Dr. Kahn requests evidence that nutrition research funded
    by food companies is of lesser quality than studies funded by
    independent agencies or performed by investigators with nonfinancial
    conflicts of interest. Concerns about such issues are relatively
    recent; few published studies address them directly. Instead, concerns
    about industry sponsorship of nutrition research derive from
    comparisons with the results of studies of funding by tobacco,
    chemical, drug, or medical device companies. This research typically
    finds industry-sponsored studies to report results more favorable to
    the products of the sponsor than studies not funded by industry. It
    identifies subtle rather than substantive differences in the quality of
    this research; industry-funded studies are more likely to underreport
    unfavorable results and interpret neutral results more positively.\1\
    When results are negative, they are less likely to be published.\2\
        Between March 2015 and March 2016, I identified 166 industry-funded
    nutrition research studies and posted and discussed them on my blog.\3\
    Of these, 154 reported results favorable to the interest of the
    sponsor; only 12 reported contrary results. The few studies
    systematically examining the influence of industry funding on nutrition
    research tend to confirm results obtained from other industries. For
    example, a systematic review comparing industry-funded and nonindustry-
    funded trials of probiotics in infant formula reported no association
    of funding source with research quality. Industry-funded studies,
    however, seemed more likely to report favorable conclusions unsupported
    by the data.\4\
        Dr. Kahn states that sponsored studies often specify that the
    funder had no role in the study. Only recently have some journals
    required such statements, and I am unaware of research on the extent of
    this practice or authors' adherence to it. Among the 166 industry-
    funded studies that I reviewed, few disclosed involvement of a sponsor.
        Dr. Kahn asks whether industry funding is any more biasing than
    career self-interest or intellectual passion. Unlike industry funding,
    self-interest and passions are intrinsic to every scientist who
    conducts research, are a matter of public record, cannot be eliminated,
    and have not been shown to consistently bias research results in the
    same ways as industry funding.\5\ Fortunately, nutrition societies and
    research institutions are developing policies to manage financial
    relationships with industry.\6\ Such policies hold promise for
    preventing financial conflicts of research in nutrition research.

    Marion Nestle, Ph.D., M.P.H.

        Author Affiliation: New York University, Nutrition, Food Studies,
     and Public Health, New York, New York.
        Corresponding Author: Marion Nestle, PhD, MPH, New York University,
     Nutrition, Food Studies, and Public Health, 411 Lafayette, 5th Floor,
     New York, NY 10003-7035 (marion.nestle@nyu.edu).
        Conflict of Interest Disclosures: Dr. Nestle's salary from New York
     University supports her research, manuscript preparation, website, and
     blog at http://www.foodpolitics.com. She also earns royalties from
     books and honoraria from lectures to university and health professional
     groups about matters relevant to this letter and the Viewpoint to which
     it refers.

                                  [References]

        1. Lundh A., Sismondo S., Lexchin J., Busuioc O.A., Bero L. Industry
     sponsorship and research outcome. Cochrane Database Syst. Rev. 2012;
     12: MR000033.
        2. Rising K., Bacchetti P., Bero L. Reporting bias in drug trials
     submitted to the Food and Drug Administration: review of publication
     and presentation. PLoS Med. 2008; 5(11): e217.
        3. Nestle M. Food Politics Blog. http://www.foodpolitics.com/.
     Accessed March 2, 2016.
        4. Mugambi M.N., Musekiwa A., Lombard M., Young T., Blaauw R.
     Association between funding source, methodological quality and research
     outcomes in randomized controlled trials of synbiotics, probiotics and
     prebiotics added to infant formula: a systematic review. BMC Med. Res.
     Methodol. 2013; 13: 137.
        5. Bero L. What is in a name? Nonfinancial influences on the
     outcomes of systematic reviews and guidelines. J. Clin. Epidemiol.
     2014; 67(11): 1239-1241.
        6. Charles Perkins Centre. Engagement with Industry Guidelines 2015.
     University of Sydney, 2015. https://intranet.sydney.edu.au/perkins/
     research-support/engaging-with-industry.html. Accessed March 2, 2016.

                                 attachment 11
    The Limits of Sugar Guidelines
    Is there a danger in governments offering too-specific advice on sugar
            consumption?
    The Atlantic
    Nina Teicholz
    Jan. 17, 2017

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Sugary drinks on display in New York City in 2012, at a news
            conference about a proposed ban on all soft drinks over 16
            ounces in the city's restaurants and stores Andrew Burton/
            Reuters.

        A firestorm recently erupted over a paper in the Annals of Internal
    Medicine (https://www.ncbi.nlm.nih.gov/pubmed/27992898) that found
    official advice limiting sugar in diets to be based on ``low'' or
    ``very low'' quality evidence. Because a food-industry group had funded
    the study, a slew of critics accused the authors of distorting the
    science to undermine nutrition guidelines and make sugar seem less
    harmful than it actually is. One prominent nutrition professor called
    the paper (http://www.npr.org/sections/thesalt/2016/12/19/505867535/
    how-much-is-too-much-new-study-casts-doubts-on-sugar-guidelines)
    ``shameful.'' ``It was really an attempt to undermine the scientific
    process,'' said another (http://www.npr.org/sections/thesalt/2016/12/
    19/505867535/how-much-is-too-much-new-study-casts-doubts-on-sugar-
    guidelines).
        Lost in this torrent of criticism was any significant discussion of
    the science itself. Regardless of its funding source, was the paper
    correct in saying that there is insufficient evidence to recommend
    limiting sugar? And do official guidelines even matter, since we pretty
    much know that sugar is bad for us?
        The Annals paper examined a dozen guidelines on sugar passed by
    governments around the world since 2002, including the Dietary
    Guidelines for Americans, which last year recommended limiting sugar
    intake to ten percent of calories. One would assume that such advice is
    based on an ample body of rigorous research. But the Annals study,
    which included all the papers listed in the various guidelines'
    bibliographies themselves, claimed that reviews to date had overstated
    the evidence.
        In the most rigorous review on sugar and weight (http://
    www.bmj.com/content/bmj/346/bmj.e7492.full.pdf), for instance, only
    five trials lasting 6 months or longer could be found, on a total of
    just 1,245 people. According to the Annals authors, this review
    portrayed the data as more consistent than it actually was and failed
    to adequately account for evidence indicating that studies in which
    sugar was shown to have no detrimental effect may have been suppressed
    from publication.
        Moreover, less rigorous data from observational studies was widely
    found to be ``inconsistent.'' Sometimes sugar was associated with
    health problems--weight gain, Type 2 diabetes, and tooth decay--but
    sometimes it wasn't.
        ``Overall, I would say the guidelines are not trustworthy,''
    Bradley Johnston (http://ihpme.utoronto.ca/faculty/bradley-c-johnston/
    ), the study's lead author and an assistant professor of clinical
    epidemiology and biostatistics at McMasters University told me.
        The study's finding should come as a surprise to anyone who has
    been avoiding sugar for years already. Sugar is a potent source of
    glucose, which, over time, does appear to wreak havoc on one's
    metabolism and pave a direct path to obesity and diabetes. A large body
    of trial evidence has shown (http://www.nytimes.com/2016/09/11/opinion/
    sunday/before-you-spend-26000-on-weight-loss-surgery-do-this.html?_r=0)
    that when carbohydrate consumption is reduced, these diseases start to
    reverse themselves. Also, given all the recent headlines about sugar's
    ill effects, from Katie Couric's movie Fed Up to the passage of soda
    taxes in several cities, one could be forgiven for assuming that the
    evidence condemning sugar must be a done deal.
        Clinical trials on sugar are possible; it's just that very few have
    been done.
        Yet here were the Annals authors saying it's not. Reaction to the
    paper from nutrition experts and advocacy groups was swift, with
    criticism focused on the paper's Achilles heel: It had been paid for by
    the International Life Sciences Institute, which receives 60 percent of
    its funding from 400 industry members, including some, like Coca-Cola,
    PepsiCo, and Mars, that very much stand to benefit from a study
    questioning caps on sugar.
        ``This is a classic example of industry-funded research aimed at
    one purpose and one purpose only: to cast doubt on the science linking
    diets high in sugars to poor health,'' Marion Nestle, a prominent
    professor of nutrition at New York University, told National Public
    Radio (http://www.npr.org/sections/thesalt/2016/12/19/505867535/how-
    much-is-too-much-new-study-casts-doubts-on-sugar-guidelines). Dean
    Schillinger, the chief of the division of general internal medicine at
    San Francisco General Hospital, told the New York Times (http://
    www.nytimes.com/2016/12/19/well/eat/a-food-industry-study-tries-to-
    discredit-advice-about-sugar.html?_r=0): ``They're hijacking the
    scientific process in a disingenuous way to sow doubt and jeopardize
    public health.''
        Schillinger, with his colleague Cristin Kearns, also penned an
    editorial in Annals (https://www.ncbi.nlm.nih.gov/pubmed/27992900),
    which likened the sugar-review authors to lackeys hired by the tobacco
    industry to be ``merchants of doubt'' about the health hazards of
    smoking.
        Industry manipulation of the science is obviously an ongoing,
    serious concern. It was, in part, why the editor-in-chief of Annals,
    Christine Laine, invited this editorial. ``I wanted to show both sides
    of the issue,'' she told me, although she said that she considered the
    editorial to be unusually ``strident and hostile'' for an academic
    journal. Indeed, Schillinger and Kearns both part-time advocates
    against sugar; they write articles (http://www.sugarscience.org/sugar-
    papers-reveal-industry-role-in-shifting-focus.html#.WGdB-M6PTyA) and do
    other work for Sugar Science (http://www.sugarscience.org/), a group
    devoted to educating the public about sugar's health dangers. ``It's
    shown me that conflicts of interest are not only financial but also
    intellectual,'' said Laine, who added disclosures about the authors'
    Sugar Science affiliations to the editorial after a reader brought them
    to her attention, she says.
        Ironically, undercutting a scientific paper by focusing on its
    funding source has mainly been used in the past to shoot down sugar
    skeptics. For instance, when the British nutrition professor John
    Yudkin suggested sugar as a dietary culprit in the early 1970s, the
    University of Minnesota researcher Ancel Keys, a key defender of the
    competing hypothesis, that dietary fat was responsible for chronic
    health issues, accused Yudkin of issuing ``propaganda,'' linked to
    ``commercial backers [who] are not deterred by the facts.''
        Now that the nation's top nutrition authority, the U.S. Dietary
    Guidelines, has backed off caps on total fat and begun to condemn sugar
    instead, the public debate is also increasingly focusing on the sugar
    industry--indeed, so much so that other industry actors are escaping
    scrutiny. One has to ask, for instance, why there was no similar
    outrage over another recent paper (https://www.ncbi.nlm.nih.gov/pubmed/
    27881409), in The BMJ, with favorable findings for vegetable oils,
    nearly \1/2\ of whose authors were actual employees of the giant
    vegetable-oil manufacturer Unilever. This would be like workers at
    Mars, Inc. publishing a study on the health benefits of sugar. Yet this
    sizable conflict of interest largely got a pass by the many journalists
    covering the story (https://pubpeer.com/publications/DF70B2D23429
    0DF834A8F183BB6F8C#fb114267).
        To be clear, industry funding absolutely can deter good science;
    tobacco promotion will always be the epitome of that. But the influence
    of funding isn't invariable: While one meta-analysis found that funding
    sources do influence the conclusions of nutrition papers (https://
    www.ncbi.nlm.nih.gov/pubmed/17214504), another, by a fierce critic of
    industry (http://www.smh.com.au/technology/sci-tech/cocacolas-secret-
    plan-to-monitor-sydney-university-academic-lisa-bero-20161020-
    gs6m4a.html) funding, paradoxically did not (https://
    www.ncbi.nlm.nih.gov/pubmed/27802480). A healthy dose of skepticism
    over funding from all sources--including governments and other
    institutions, which may have their own pet hypotheses--is warranted, so
    long as it doesn't sideline the science or shut down legitimate debate.
        Schillinger and Kearns were right to raise doubts. Sugar defenders
    have, since the early part of the 20th century, worked diligently to
    promote their product, such that President Franklin Roosevelt, in the
    mid-1930s, was quoted as saying the sugar lobby was ``the most powerful
    pressure group that had descended on the national capitol'' during his
    lifetime. The extent of industry manipulation, through ad campaigns and
    efforts to twist the science are described by the journalist Gary
    Taubes in his new book, The Case Against Sugar.
        Yet Taubes believes that any industry with a PR budget has
    attempted pretty much the same. And he is up-front about the lack of
    rigorous evidence against sugar, stating in the introduction of his
    book, ``I'm going to concede in advance a key point that those who
    defend the role of sugar in our diet will invariably
    make. . . . [I]t cannot be established definitively, with the science
    as it now stands, that sugar is uniquely harmful.''
        Clinical trials on sugar are possible; it's just that very few have
    been done. Emerging evidence suggests (https://www.ncbi.nlm.nih.gov/
    pubmed/25756179) that the sugar industry may have stifled those
    inquiries (https://therussells.crossfit.com/2016/09/15/did-big-soda-
    derail-the-governments-cancer-research/), but Taubes believes more
    evidence supports the explanation that for decades, a monolith of
    nutrition scientists has just genuinely and obsessively had a
    preoccupation with fat and cholesterol which simply blotted out
    everything else. The National Institutes of Health (NIH) spent billions
    of dollars on large clinical trials, all trying to pin chronic disease
    on dietary fat and cholesterol. In fact, sugar was such a non-suspect
    for so many years that the major, NIH-funded observational studies took
    few pains even to measure it.
        While the evidence to date shows zero benefit from sugar and a
    clear signal of harm, there hasn't been enough time to fund and conduct
    definitive trials. Meanwhile, governments naturally feel they can't
    wait. Facing panic over the continued, relentless climb in obesity and
    diabetes rates with no solution in sight, they've gone ahead and passed
    sugar guidelines pinned to exact thresholds, of ten percent or five
    percent of calories. This advice is clearly well-intentioned. Yet if,
    as the Annals paper concludes, experts are skirting scientific norms by
    passing guidelines based on weak evidence, the whole process of
    guideline-making is effectively watered down. And the need for reliable
    guidance is no abstract question; indeed, everything from our
    waistlines to whether we might eat eggs for breakfast depends upon it.
        As Americans well know, there have been many reversals in our
    guidelines in recent years--on dietary cholesterol, on total fat, on
    whether to eat breakfast to maintain a healthy weight. These were all
    official guidelines based on weak evidence that, when actually tested
    in clinical trials, were found to be unjustified. It turned out that
    people had been avoiding egg yolks, lobster, and fat, generally, to no
    avail, and that skipping breakfast altogether might actually be the
    best option (https://www.washingtonpost.com/news/wonk/wp/2015/08/10/
    the-science-of-skipping-breakfast-how-government-nutritionists-may-
    have-gotten-it-wrong/?utm_term=.ca4
    bb87d6c30) for weight loss.
        It's worth at least considering criticism of the potentially
    ``low'' quality evidence behind existing nutrition advice.
        Instances of flip-flopping on nutritional advice not only erode the
    public trust, but make people think that the basic science itself is
    flawed--which, for the most part, it's not. Instead, the central
    problem has been that experts and policy makers have passed judgment
    before that good science was done. And once a judgment is codified as
    policy, it's hard to repeal. This was the case, for instance, with the
    low-fat diet, which although adopted as a U.S. guideline in 1980,
    wasn't actually studied in trials for another decade-plus. This kind of
    mistake, at its very worst, is potentially deadly: Indeed, the low-fat
    advice, by shifting consumption to carbohydrates such as grains and
    sugar, is now regarded as a probable cause of the obesity and diabetes
    epidemics.
        When the Senate first passed the government's warnings against fat
    and cholesterol in the late 1970s, officials argued that the urgency of
    responding to public-health crises overrode any concerns about
    insufficient scientific evidence. ``Undoubtedly there will be people
    who have said we have not proven our point,'' said Harvard's Mark
    Hegsted (https://naldc.nal.usda.gov/naldc/download.xhtml?id=1759
    572&content=PDF), an advisor to the report, at the time of its release.
    Yet, citing the epidemics of heart disease, cancer, diabetes, and
    hypertension, he stated, ``We cannot afford to temporize. We have an
    obligation to assist the public in making correct food choices. . . .
    To do less is to avoid our responsibility.''
        These are the same arguments being made today, on sugar. It makes
    sense to have a strong hunch that sugar is bad. Sugar has no
    nutritional value. It's a direct shot of glucose to the blood stream
    and fructose to the liver. The historical evidence against it presented
    by Taubes in his book is compelling. Personally, I try hard to avoid
    it. But I also tend to avoid refined carbohydrates, such as white bread
    and cereals. Based on the existing data, I suspect that too much
    fructose from today's highly sweetened fruit crops is bad, and that the
    40+ percent increase in our consumption of grains since 1970 (https://
    www.ers.usda.gov/publications/pub-details/?pubid=44220) have simply
    overloaded us in carbohydrates altogether (http://
    www.nutritionjrnl.com/article/S0899-9007%2815%2900077-5/abstract).
        The NIH should fund rigorous trials to sort out these issues.
    Meanwhile, in the absence of more definitive science, it's worth at
    least considering criticism of the potentially ``low'' quality evidence
    behind existing nutrition advice. Maybe the government should be
    issuing a strong cautionary note, based on the existing, emerging
    evidence, rather than a specific formal ``Guideline''--since basing
    guidelines on hunches that are probably right unavoidably opens up the
    possibility for guidelines based on hunches that are wrong.
        An educated guess is not enough, warned the late Senator Charles
    Percy, in objecting to the government's original dietary advice, 35
    years ago. He thought it paved over limitations in the data with
    excessive confidence. ``The best way to [provide dietary guidance] is
    to fully inform the public not only about what is known but also what
    remains controversial,'' he said.
        He was talking about fat and cholesterol; today's Annals paper is
    talking about sucrose, glucose, fructose. We've been down this road
    before, with experts, pressed into urgency on behalf of the public
    health, convincing themselves that insufficient evidence could suffice.
    Therefore, in the matter of national guidelines, it's worth being
    cautious--and not immediately dismissing those who send up cautionary
    flags.
                                 attachment 12
    Do Financial Conflicts of Interest Bias Research? An Inquiry into the
            ``Funding Effect'' Hypothesis
    Sheldon Krimsky [1]
    ---------------------------------------------------------------------------
        \[1]\ Department of Urban & Environmental Policy & Planning, Tufts
    University, Medford, MA, USA
        Corresponding Author:
        Sheldon Krimsky, Department of Urban & Environmental Policy &
    Planning, Tufts University, Medford, MA 02155, USA. E-mail:
    sheldon.krimsky@tufts.edu.
    ---------------------------------------------------------------------------
    Science, Technology, & Human Values, 38(4) 566-587
    The Author(s) 2012
    Reprints and permission: sagepub.com/journalsPermissions.nav
    DOI: 10.1177/0162243912456271
    sthv.sagepub.com
    Abstract
        In the mid-1980s, social scientists compared outcome measures of
    related drug studies, some funded by private companies and others by
    nonprofit organizations or government agencies. The concept of a
    ``funding effect'' was coined when it was discovered that study
    outcomes could be statistically correlated with funding sources,
    largely in drug safety and efficacy studies. Also identified in tobacco
    research and chemical toxicity studies, the ``funding effect'' is often
    attributed, implicitly or explicitly, to research bias. This article
    discusses the meaning of scientific bias in research, examines the
    strongest evidence for the ``funding effect,'' and explores the
    question of whether the ``funding effect'' is an indicator of biased
    research that is driven by the financial interests of the for-profit
    sponsor. This article argues that the ``funding effect'' is merely a
    symptom of the factors that could be responsible for outcome
    disparities in product assessment. Social scientists should not suspend
    their skepticism and choose as a default hypothesis that bias is always
    or typically the cause.
    Introduction
        The philosopher Charles Sanders Peirce claimed that of all ways of
    fixing our beliefs, science is the most dependable. He wrote in 1877,
    ``Scientific investigation has had the most wonderful triumphs in the
    way of settling opinion'' (Peirce, 1877). Not only have we come to
    believe in the ``dependability'' of scientific claims, we have come to
    depend upon them for making important life decisions. It is generally
    understood that the production of scientific knowledge is accompanied
    by quality controls that are designed to filter out errors and bias. By
    errors I shall mean those assertions or calculations in a study that
    are factually incorrect and which would be recognized as such by anyone
    trained in the discipline. These can include errors in statistical
    analysis, citations, recording of data, or the application of measuring
    devices. Bias, on the other, is a more complex term.
        As distinguished from error, bias is not as simple as an oversight
    or a mistake. Bias can be conscious or unconscious. It can be
    structural (by the choice of method) or nonstructural (by the
    interpretation of data). By ``structural bias,'' I mean the adoption of
    certain norms or methods that would distort (over- or underreport) the
    effects being studied. This term has been used in media studies where a
    structural bias is said to be the result of a preference of journalists
    for some type of story or frame that leads them to pay more attention
    to some events over others (van Dalen, 2011).
        Bias could involve proper or improper (scientific misconduct)
    behavior. In his book The Bias of Science, Brian Martin considers
    ``biased'' research as synonymous with ``value-laden'' research
    ``conditioned by social and political forces and dependent on judgments
    and human choices'' (Martin, 1979, 7). Under this definition, science,
    according to Martin, might never be unbiased or value-free. Resnik
    (1998, 85) argues that a bias is an invalid assumption: ``The person
    who conducts biased research is more like the person who defends a
    hypothesis that is later proven wrong than a person who makes a mistake
    or attempts to deceive his audience.''
        I am using ``bias'' in a different sense. By research bias, I shall
    mean the use of a method, data collection, data analysis, or
    interpretation of results that, in the consensus view of scientists of
    a discipline, tends to yield results that distort the truth of a
    hypothesis under consideration, diminishing or negating the reliability
    of the knowledge claim. Bias must be viewed in terms of the current
    operating norms of science. Since ``bias'' distorts the truth,
    scientists must be aware of its presence and where possible prevent or
    diminish it. I leave open the question of whether research considered
    unbiased in one time period could be viewed as biased by scientists
    during another time period.
        The function of our system of peer review is to identify error or
    bias before scientific studies are accepted for publication. After a
    study is published, it may still be criticized or corrected. Moreover,
    if an empirical finding cannot be replicated, the article may be
    withdrawn by the journal editors. Unlike other sources of establishing
    belief, science is considered to be a self-correcting enterprise where
    truth claims are kept open to new evidence. No one doubts, however,
    that bias can enter into published scientific work. While bias can be
    built into scientific methodology (structural), sometimes its subtlety
    can elude even the most careful reviewer and journal editor.
        Only recently have government and journals turned their attention
    to Conflict of Interest (COI) as a source of bias. The first Federal
    guidelines on scientific COI, issued simultaneously by the Department
    of Health and Human Services' (DHHS) Public Health Service (PHS) and
    the National Science Foundation were titled ``Objectivity in
    Research.'' The stated purpose of the regulation was ``to ensure that
    the design, conduct, or reporting of research funded under PHS grants,
    cooperative agreements or contracts will not be biased by any
    conflicting financial interest of those investigators responsible for
    the research'' (DHHS, 1995). And while the DHHS focused on financial
    COIs (FCOIs), it is generally recognized that interests other than
    direct financial interests can also play a potentially biasing role in
    science (Levinsky, 2002). Writing in the journal Cell Stem Cell about
    the ethics of stem cells, Jeremy Sugarman (2008, 532) noted: ``Both
    nonfinancial and financial conflicts of interest may adversely affect
    good judgment regarding stem cell research.'' But Sugarman also wrote
    that ``financial conflicts of interest in research may be easier to
    identify, simply because financial interests can be measured and more
    easily described than those associated with nonfinancial interests,
    such as the advancement of scientific and professional concerns''
    (Sugarman 2008, 532).
        Following the maxim ``study what you can measure,'' social
    scientists began investigating the relationship between FCOIs and bias
    in the mid-1980s, when author disclosures of author FCOIs were still in
    their infancy. Most of the studies investigating a link between author
    FCOIs and private funding of science were carried out in the field of
    medicine, specifically medical pharmacology. The concept of a ``funding
    effect'' was coined after a body of research revealed that study
    outcomes were significantly different in privately funded versus
    publicly funded drug studies (Krimsky, 2006 2010). The funding effect
    was also identified in tobacco, pharmacoeconomic, and chemical toxicity
    research (Als-Nielsen, et al., 2003). This article examines the
    strongest evidence for the ``funding effect,'' and explores the
    question of whether the ``funding effect'' is an indicator of
    scientific research bias, based on a previously stated criterion of
    ``bias.'' To begin, I shall discuss sources of evidence behind the
    ``funding effect.'' I shall argue that the ``funding effect'' is a
    symptom of the factors that are responsible for outcome disparities in
    product assessments and that social scientists should not, without
    further investigation and the elimination of other explanations, chose
    bias as the default hypothesis.
    Evidence of the ``Funding Effect'' in Science
        Beginning in the mid-1980s, scientists began testing the hypothesis
    that the source of funding from for-profit companies compared to
    nonprofit institutions and government can be correlated with the
    outcome of research, such as safety and efficacy in drug studies. This
    has been called ``the funding effect'' in science (Krimsky, 2005). The
    assumption has been that where there is a ``funding effect'' there must
    be bias. I shall begin with the evidence for the ``funding effect,''
    largely from a group of studies in drug trials, and then discuss the
    possible causes of the effect.
        Badil Als-Nielsen, et al. (2003) tested the hypothesis that
    industry-sponsored drug trials tend to draw pro-industry conclusions.
    The authors selected a random sample of 167 Cochrane reviews and found
    25 with meta-analyses that met their criteria. From the meta-analyses,
    they studied 370 drug trials. After coding and numerically scoring the
    trials' conclusions and applying a logistic regression analysis, the
    authors found that ``conclusions were significantly more likely to
    recommend the experimental drug as treatment of choice in trials funded
    by for-profit organizations alone compared with trials funded by
    nonprofit organizations'' (Als-Nielsen, et al., 2003, 925). The authors
    ruled out as an explanation of industry favored outcomes both the
    magnitude of the treatment effect and the occurrence of adverse events
    reported. They also noted that the clinical trial methods between for-
    profit and nonprofit organizations were not of the same quality.
    ``Trials funded by for-profit organizations had better methodological
    quality than trials funded by nonprofit organizations regarding
    allocation concealment and double blinding'' (Als-Nielsen, et al.,
    2003, 925). The authors do not report on the sponsor involvement and
    influence on the conduct and reporting of a trial. Such information
    could help us understand whether the external funder influences the
    scientist running the trial. The effects they observed between funding
    and outcome occurred whether the sponsor's contribution was minimal
    (provided the drug) or maximal (funded the study).
        The authors distinguish between potential biases in the empirical
    trial results (collection of data) and in the interpretation of those
    results, particularly in the recommendations they make about the
    experimental drug. As previously noted, bias can enter into any or all
    the stages of a study: the methodology, execution of the study,
    interpretation of results and recommendations (whether the experimental
    drug is better than the existing drug).
        It is also possible that industry-funded studies, having been
    identified as being of higher quality, have gone through more internal
    (company-sponsored) study and analyses, than one would expect of a
    nonprofit organization. This study found statistically significant
    outcome differences in a class of studies, but not necessarily bias--
    although systemic bias is one hypothesis.
        John Yaphe, et al. (2001) selected for their study randomized
    controlled trials (RCTs) published between 1992 and 1994 of drugs or
    food products with therapeutic properties appearing in five journals:
    Annals of Internal Medicine, BMJ, JAMA, Lancet, and NEJM. A total of
    314 articles met their inclusion criteria. Of the 209 industry-funded
    studies, 181 (87 percent) and 28 (13 percent) had positive and negative
    findings, respectively, while of 96 nonindustry-funded studies, 62 (65
    percent) and 34 (35 percent) had positive and negative findings,
    respectively. What can account for this disparity in the outcomes of
    industry and nonindustry trials? Clearly, the bias of an investigator
    internalizing the financial interests of the sponsor is one potential
    hypothesis.
        Paula Rochon, et al., investigated the relationship between
    reported drug performance and manufacturer association. They adopted a
    broad definition of ``manufacturer association,'' which included
    supplying the drug or sponsoring a journal supplement where the
    publication of the study appeared. The authors selected as their study
    sample randomized drug trials (identified in MEDLINE between 1997 and
    1990) of nonsteroidal anti-inflammatory drugs used in the treatment of
    arthritis (Rochon, et al., 1994). The authors found 1,008 articles
    published within that period but only 61 articles representing 69
    individuals met their inclusion criteria. All the trials in their study
    had a ``manufacturer association,'' because they reported there was a
    scarcity of nonmanufacturer-associated trials. Therefore, they could
    not compare trials funded/supported by private companies with those
    funded/supported by nonprofit organizations. The authors also used
    several rating systems to estimate drug efficacy. The critical outcome
    measure was whether the drug being tested was superior, the same, or
    inferior to a comparison drug.
        The results of the study showed the ``the manufacturer-associated
    drug is always reported as being either superior to or comparable with
    the comparison drug'' and that ``these claims of superiority,
    especially with regard to side-effect profiles, are often not supported
    by trial data'' (Rochon, et al., 1994, 158). It is logically possible
    that head-to-head testing of new versus old drugs always shows the new
    drug superior. After all, that is the impetus for developing new drugs.
    But in this case, the framing of the tests can bias the outcome. Marcia
    Angell explains the process with an illustration from statins--drugs
    that lower blood cholesterol levels. ``There is little reason to think
    one is any better than another at comparable doses. But to get a
    toehold in the market, me-too statins were sometimes tested for
    slightly different outcomes in slightly different kinds of patients,
    and then promoted as especially effective for those uses'' (Angell,
    2004, 81).
        In a study by Benjamin Djulbegovic, et al. (2000), the
    investigators explored whether the reports of pharmaceutical-industry
    sponsored randomized trials result in biased findings. They selected
    113 articles published from 1996 to 1998 that described 136 randomized
    trials on multiple myeloma (Djulbegovic, et al., 2000, 637). The
    authors compared the new therapy versus the standard therapy in the
    trials and then analyzed the outcome according to whether the sponsors
    were nonprofit or for-profit organizations. Nonprofit organizations
    showed a 53 percent versus 47 percent support for new therapies, but
    when the trials were sponsored by for-profit organizations the ratio
    was 74 percent to 26 percent, a statistically significant difference.
        Friedman and Richer (2004) investigated whether sources of funding
    could be correlated to reported findings. The authors analyzed original
    contributions in NEJM and JAMA published in 2001. They classified the
    presentation of results as positive (statistically significant clinical
    benefit from a treatment or absence of suspected side effects), mixed
    (clinical benefits but adverse side effects), negative (absence of
    clinical benefits), or other (unclear significance). They located 193
    original articles in NEJM, 76 (39.4 percent) with a COI and 205
    articles in JAMA, 76 (37.1 percent) with COI. The authors found 119
    studies that investigated drug treatments and 174 studies for all
    treatments. They observed a ``strong association between positive
    results and COI among all treatment studies'' with an odds ratio of
    2.35 and for drug studies alone an odds ratio of 2.64. The odds ratio
    is the ratio of probability of an event occurring in one group to the
    probability of it occurring in another group. An odds ratio of 2.35 for
    the drug studies is the probability of a positive result in a drug
    treatment study conducted by individuals with a FCOI divided by the
    probability of a positive result from a similar drug treatment
    conducted by individuals without a financial conflict of interest. In
    other words, an odds ratio of 2.35 means that investigators with an
    FCOI are more than twice as likely to produce positive results in a
    drug treatment study.
        Another interesting finding is that the probability of reporting
    negative results in cases where an author had a FCOI was very low. One
    negative study of the 60 drug studies with FCOIs versus 21 negative
    studies of the 59 drug studies without FCOIs were reported. The authors
    conclude that ``the odds are extremely small that negative results
    would be published by authors with COI'' (Friedman and Richter, 2004,
    53).
        The authors cannot provide an explanation for their observed
    association between FCOI and reported findings in medical treatments.
    They can only theorize about the cause. ``One could surmise that drug
    companies are selective and only want to invest in treatments proven to
    produce positive results and that early clinical trials filter out the
    most promising treatments, which could explain the small number of
    studies funded by private corporations presenting negative findings''
    (Friedman and Richter, 2004, 55). But they also consider the
    possibility of bias and ``spin.'' The question arises as to whether an
    investigator with a conflict of interest may be more inclined to
    present findings in order to gain favor with the sponsor or achieve any
    other extraneous objective--for example, to ``spin'' (Friedman and
    Richter, 2004, 55). Notwithstanding the fact that the cause of the
    association is not apparent in their data, they state that:

              The observation that negative findings are less commonly
            reported among studies funded by private corporations raises
            troublesome ethical questions. Researchers appear to be failing
            to promote both the benefits and negative side effects of
            commercial products they review or simply failing to submit
            negative studies for publication because they are viewed as
            uninteresting. (Friedman and Richter, 2004, 55)

        For social scientists studying the funding effect, the issue in
    this case is less a question of bias in the reported studies than it is
    an issue of bias in a failure of reporting negative studies, that is,
    in subverting the complete scientific record.
        Not all studies testing a hypothesis that there is an association
    between trial outcome or study quality and funding source reached
    positive findings. Tammy Clifford, Barrowman, and Moher (2002) selected
    a convenience sample of RCTs published between 1999 and 2000 by hand-
    searching five high impact general medical journals--Annals of Internal
    Medicine, BMJ, JAMA, The Lancet, and NEJM. The quality of the trial
    report was evaluated according to the Jadad scale, which included
    randomization, allocation concealment, and withdrawals. The authors
    classified the trials according to funding source in four categories:
    entirely industry, entirely no[t]-for-profit, mixed, and not reported.
    Sixty-six of the hundred trials reviewed were funded in whole or in
    part by industry; six did not disclose their source of funding. Of the
    100 trials, 67 favored the new therapy, six favored conventional
    treatments, 19 reported neutral findings, and for eight the outcome was
    unclear. Of the 67 trials that favored the new treatment, 30 came from
    ``industry only,'' 15 came from ``not-for-profit only,'' and 16 came
    from mixed sources; of the six trials that favored the conventional
    treatment, four came from ``industry only,'' one came from ``not-for-
    profit only,'' and one came from mixed sources.
        The numbers for ``favored conventional'' were so low that
    statistical findings were not relevant. Also, this study only focused
    on funding and not on the financial ties of individual faculty
    associated with the trials. The authors noted limitations of their
    results. ``Our failure to detect any significant association may result
    from a type 2 error that indicates inadequate statistical power.
    Although our results do not even hint at a trend . . . the potential
    for type 2 error is real'' (Clifford, Barrowman, and Moher, 2002, 21).
    Perhaps one conclusion can be drawn: of the 100 trials, 66 percent were
    funded in whole or in part by industry and 67 percent favored the new
    therapy. Thus, it appears that industry trials are dominant and driving
    the advocacy of new drugs over old treatments even without adding
    author FCOI.
        Finally, I shall summarize the first meta-analysis that explored
    the ``funding effect.'' Bekelman, et al., culled 1,664 original
    research articles and ended up with 37 studies that met their criteria.
    They concluded: ``Although only 37 articles met [our] inclusion
    criteria, evidence suggests that the financial ties that intertwine
    industry, investigators, and academic institutions can influence the
    research process. Strong and consistent evidence shows that industry
    sponsored-research tends to draw proindustry conclusions'' (Bekelman,
    Li, and Gross, 2003, 463). Bekelman, et al., were convinced that the
    ``funding effect'' is real.
        I shall now turn to the relationship between FCOI and
    pharmacoeconomics, defined as the discipline that evaluates the
    clinical, economic, and humanistic aspects of pharmaceutical products,
    services, and programs.
    Pharmacoeconomic Studies
        A few studies have examined whether the results of economic
    analyses of drugs are correlated with the funding source. Because there
    is greater discretion in developing the methodology for economic
    studies of drugs, any inferences of bias must be addressed through the
    modeling, the stakeholder interests, and the specific parameters used
    in cost-benefit analysis rather than the omission or manipulation of
    clinical data. Johnson and Coons (1995, 165) note that ``Many different
    guidelines have been proposed for conducting pharmacoeconomic studies.
    The differences among the various versions reflect the diverse and
    sometimes conflicting views of those who specialize in economic
    evaluations.''
        Mark Friedberg, et al. (2010) searched the Medline and Health Star
    databases for articles published between 1985 and 1998 on cost or cost-
    effectiveness analyses of six oncology drugs. The found forty-four
    eligible articles whose texts were analyzed for qualitative and
    quantitative conclusions and the funding source, based on predetermined
    criteria. Of the forty-four articles, twenty-four were funded by
    nonprofit organizations and twenty were funded by drug manufacturers.
    The authors found a statistically significant relationship between
    funding source and qualitative conclusions. Unfavorable conclusions
    were found in 38 percent (\9/24\) of the nonprofit-sponsored studies
    and five percent (\1/20\) of company-sponsored studies.
        Studies funded by pharmaceutical companies were almost eight times
    less likely to reach unfavorable qualitative conclusions than
    nonprofit-funded studies and 1.4 times more likely to reach favorable
    qualitative conclusions.
        C.M., Bell, et al. (2006) undertook a systematic review of
    published papers on cost-utility analyses. The authors found that
    industry-funded studies were more than twice as likely to report a
    cost-utility ratio below $20,000 per quality adjusted life year (QALY)
    as compared to studies sponsored by nonindustry sources. A similar
    study reported in the International Journal of Technology Assessment in
    Health Care assessed the relation between industry funding and findings
    of pharmacoeconomic analyses (Garattini, Rolova, and Casasdei, 2010).
    The authors searched Pub Med for articles on cost-effectiveness and
    cost utility, performed during 2004-2009 on single drug treatments.
    They found 200 articles that met their criteria. They divided the
    articles into two groups based on whether or not the authors had
    financial support from the pharmaceutical industry. ``Studies co-signed
    by at least one author affiliated to a pharmaceutical company and/or
    studies that declared any type of company funding were considered
    sponsored'' (Garattini, Rolova, and Casasdei, 2010, 331). The authors
    also classified the main conclusions as favorable, doubtful, or
    unfavorable toward the drug. Of the 200 articles, 138 (69 percent) were
    sponsored by a pharmaceutical company. Sponsored articles reported a
    favorable conclusion 95 percent of the time as against 50 percent of
    the time for nonsponsored articles. They claimed that ``the presence of
    a pharmaceutical sponsorship is highly predictive of a positive
    conclusion'' (Garattini, Rolova, and Casasdei, 2010, 331). According to
    Krimsky, 1999, 1475):

              The differences observed between [pharmacoeconomic] studies
            funded by industry and nonprofit organizations may be the
            result of methods chosen, prescreening, or bias due to the
            source of funding. By following the traditions of professional
            societies, such as those of engineering and psychiatry in
            setting guidelines of practice, pharmacoeconomists can attain a
            special role in the health care policy community in developing
            independent studies that are based on accepted canons that meet
            the highest standards of the profession. Canada and the United
            Kingdom have developed national guidelines for cost
            effectiveness studies.

        K.S. Knox, et al. (2000) reported on data collected in Friedberg,
    et al., in comparing practices of pharmaceutical-sponsored and
    nonprofit-sponsored pharmacoeconomic studies. They found that nonprofit
    studies more likely make an explicit statement of the significance of
    the findings (38 percent vs. 20 percent), provide a source of cost data
    (67 percent vs. 45 percent), and make a clear statement about the
    reproducibility of the findings in other settings (58 percent vs. 35
    percent). As in Friedberg, et al., Knox, et al., considered only one
    type of economic relationship between industry and researchers, namely,
    direct funding of a study and omitted many other types of financial
    relationships. Had they broadened their criteria, some of the 42
    pharmacoeconomic analyses they studied might be reclassified as
    ``pharmaceutical associated'' thus changing the statistical results.
        Some of the authors who found a ``funding effect'' were cautious
    about inferring a bias from the data, although it was included in the
    list of hypotheses they considered. The next section explores
    alternative explanations.
    Explanations of the ``Funding Effect'' Other than Bias
        In Yaphe, et al., the authors note that ``the higher frequency of
    good outcomes in industry supported trials may stem from a decision to
    fund the testing of drugs at a more advanced stage of development''
    (Yaphe, et al., 2001, 567). In other words, industry has already done a
    lot of internal studies weeding out ineffective drugs. Thus, by the
    time a private company funds a trial, it would likely do better than a
    drug has not gone through its internal review. To fully understand this
    process, we need to know the extent to which companies test and reject
    drugs internally before funding a study by an academic group and
    whether the outcome results of ``new drugs are always better'' would be
    found in trials of the same drugs but funded by nonprofit
    organizations.
        The methodologies of industry-funded as compared to nonprofit-
    funded trials may differ. For example, comparison of new drugs with a
    placebo may be more prevalent among industry-financed studies compared
    to nonindustry-financed studies. ``Comparison with placebo may produce
    more positive results than comparison with alternative active
    treatment'' (Yaphe, et al., 2001, 567). Unless we have a profit
    organization and nonprofit organization using the same or very similar
    methods to test the same drugs, drawing an inference about bias can
    yield false conclusions. The appearance of low negative outcomes from
    private sponsors could be the result of company screening for low
    probability drugs before they sponsor the trial or the ``reticence of
    investigators to submit negative findings for publication, fearing
    discontinuation of future funding'' (Yaphe, et al., 2001, 567). These
    caveats speak against a conclusion that bias can be inferred from the
    data that show outcome differences.
        Some tests use different doses of the new drugs and compare them to
    lower doses of the old drugs. This is corroborated by Rochon, et al.,
    in their study. ``When we evaluated the relative range of dosing of the
    manufacturer-associated drug and the comparison agents in the trials on
    the basis of the recommended dosage suggested in standard tests, there
    was a considerable mismatch. In the majority of cases where the doses
    were not equivalent, the drug given at the higher dose was that of the
    supporting manufacturer'' (Rochon, et al., 1994, 161).
        The authors surmise that higher doses ``bias the study results on
    efficacy in favor of the manufacturer-associated drug'' (Rochon, et
    al., 1994, 161). This illustrates that bias may enter into the
    ``funding effect'' in subtle and complex ways that deal with how the
    trial is organized.
        Some authors try to explain the ``funding effect'' by maintaining
    that most industry studies use a placebo and as a result are more
    likely to show a positive outcome. Also, the method of drug delivery
    used by companies may have been different than that used in nonprofit
    sponsor trials.
        Others have questioned whether industry trials are of lower quality
    and thus are likely to produce more favorable results. Djulbegovic, et
    al., rated the trial quality and concluded that ``trials funded solely
    or in part by commercial organizations had a trend toward higher
    quality . . . than those supported by the governmental or other
    nonprofit organizations'' (Djulbegovic, et al., 2000, 637). Thus, the
    outcome effect found in the industry-funded work of this group was not
    related to poor quality trials.
        In Frieberg's pharmacoeconomic study, the authors offer several
    possible explanations for the ``funding effect.'' First, for-profit
    companies are more likely than nonprofit companies to get ``early
    looks'' at the drugs, preliminary trial results, and economic data,
    weeding out those that would fail a cost-effectiveness standard.
    Companies might censor unfavorable studies by not funding them. Second,
    they surmise that funded studies with unfavorable results are less
    likely to be submitted for peer review and published. A third
    explanation for the disproportionate favorable results could arise from
    ``unconscious bias that could influence study conclusions'' from
    scientists who have a financial conflict of interest--such as being
    paid by the company or holding an equity interest in the drug. As
    previously noted, the economists engaged in the study may internalize
    the values of the study sponsor, which could translate into a
    methodology that is more likely to yield a positive economic analysis.
        And the final explanation suggested by the authors is that ``the
    pharmaceutical companies can collaborate directly with investigators in
    devising protocols for economic analyses and indirectly shape the
    economic evaluation criteria'' (Friedberg, et al., 2010, 1475). The
    assessment of bias requires a standard or norm for pharmacoeconomic
    analysis against which one can compare different outcomes (Krimsky,
    1999). Several studies have addressed the quality of pharmacoeconomic
    analysis of drugs (Sacristan, Soto, and Galende, 1993; Jefferson, et
    al., 1988). Currently, no standardization or best practice for
    pharmacoeconomic analyses exists. Because the choice of method can have
    a significant effect on outcome, a method that systematically yields
    outcomes consistent with the private sponsor's financialinterest may be
    biased.
    Single Product Assessment: Tobacco
        The studies of funding effects in pharmaceutical products include
    many types of drugs in order to develop aggregate statistics. Companies
    may do in-house studies before sponsoring extramural studies. The type
    of drug studied is generally considered not relevant to the findings of
    a funding effect. However, investigators may have different histories
    with the products they are testing. Nonprofit investigators may have
    seen the product for the first time. By eliminating product
    variability, investigators of the funding effect can more precisely
    judge the possible linkage between the source of funding and outcome
    findings such as product quality, safety, or economic efficiency. Two
    product studies for a funding effect meet these criteria: tobacco and
    the chemical bisphenol A (BPA). I shall begin with a discussion of
    tobacco research.
        Turner and Spilich (1997) investigated whether there was a
    relationship between tobacco industry support of basic research and the
    conclusions reached by authors of the study. They utilized a
    comprehensive review of the literature on tobacco and cognitive
    development and used that to obtain their reference studies. Beginning
    with 171 citations, the authors selected 91 studies fulfilling their
    selection criteria that investigated the effects of tobacco and
    nicotine upon cognitive performance. They coded the conclusions of the
    papers as positive, negative, or neutral on the question of whether
    tobacco enhances performance and segmented the papers into those that
    acknowledged corporate sponsorship and those that did not. When one or
    more of the authors was an employee of a tobacco company, the article
    was coded as industry-supported. All other articles were coded as
    ``noncorporate sponsorship,'' even in cases where one or more of the
    authors had previously received industry support.
        For those papers reporting a negative relationship between tobacco
    and cognitive performance, sixteen were coded ``nonindustry
    supported,'' and one was coded ``industry-supported.'' For those
    reporting a positive relationship, twenty-nine came from nonindustry
    supported papers and twenty-seven from tobacco industry-supported
    papers. Among those papers reporting a neutral effect, eleven were from
    nonindustry studies and seven from industry-supported studies. In this
    study, the industry/nonindustry demarcation in the papers shows a
    disparity in negative results compared to positive results. Why did so
    few studies funded by the tobacco industry report negative effects on
    performance from tobacco use? Because the study methodologies were
    different, we cannot say that investigator bias played a role. It may
    just be that the industry-funded studies used a method that yielded
    fewer negative outcomes compared with an alternative method(s) used by
    the nonindustry-funded studies. There is a phenomenon known as ``bias
    in the study design,'' but that was not examined in the study. As
    previously mentioned, systematic bias in a study design seeking to test
    the toxicity of a chemical would be introduced by animal models that
    are inherently insensitive to the chemical in question (Bailar, 2006).
        Deborah Barnes and Lisa Bero (1998) investigated whether review
    articles on the health effects of passive smoking reached conclusions
    that are correlated with the authors' affiliations with the tobacco
    companies. Since tobacco is a relatively homogenous product,
    differences in outcome cannot be attributed to product variability or
    company pre-testing. Just as in pharmacoeconomic studies, there is no
    canonical method in undertaking a review article. Authors make a
    selection of articles that become part of the review. Some reviewers
    make their selection algorithm transparent. Others may not. Any two
    studies may use a different selection algorithm and they may weigh
    studies differently. ``Ultimately, the conclusion of any review article
    must be based on the judgment and interpretation of the author''
    (Barnes and Bero, 1998, 1570).
        For this study, the authors adopted a search strategy use by the
    Cochrane Collaboration to select review articles from 1980 to 1995 on
    the health effects of passive smoking from the databases MEDLINE and
    EMBASE. They located additional review articles from a database of
    symposium articles on passive smoking. Articles were evaluated on
    quality and were classified as concluding that passive smoking was
    either harmful or not harmful. The authors found that 94 percent (\29/
    31\) of reviews by tobacco-industry affiliated authors concluded that
    passive smoking is not harmful compared with 13 percent (\10/75\) of
    reviews without tobacco industry affiliations. The influence of
    tobacco-industry affiliation on the finding of ``safety of passive
    smoking'' was very strong. ``The odds that a review article with
    tobacco with tobacco industry-affiliated authors would conclude that
    passive smoking is not harmful were 88.4 times higher than the odds for
    a review article with nontobacco affiliated authors, when controlling
    for article quality, peer review status, article topic, and year of
    publication'' (Barnes and Bero, 1998, 1569). The authors reported that
    the ``only factor that predicted a review article's conclusion was
    whether its author was affiliated with the tobacco industry'' (Barnes
    and Bero, 1998, 1570). In this study, the authors had no alternative
    hypotheses other than the inherent bias of authors with industry
    affiliation. Because there is a great deal of discrepancy among authors
    in how a review is carried out, including the selection and weighting
    of articles that form the basis of the review, there are a number of
    ways that the conclusion can be made to favor the funder's interests,
    not the least of which is to set a high bar for establishing evidence
    of causality. The authors impute conscious intentionality of bias to
    the funders in their statement that ``the tobacco industry may be
    attempting to influence scientific opinion by flooding the scientific
    literature with large numbers of review articles supporting its
    position [which they paid for] that passive smoking is not harmful to
    health'' (Barnes and Bero, 1998, 1569). From tobacco, I shall now turn
    to an industrial chemical used in many products--bisphenol A.
    Single Product Assessment: BPA
        While there are different variants of tobacco that depend on where
    the tobacco plant is grown, and even greater variation in cigarettes
    because of chemicals added to the tobacco and the paper, there is still
    greater homogeneity in studying tobacco than in studying different
    types of drugs. BPA, on the other hand, is a synthetic chemical that
    has a precise chemical structure. It was first reported synthesized in
    1905 by a German chemist. In 1953, scientists in Germany and the United
    States developed new manufacturing processes for a plastic material,
    polycarbonate, using BPA as the starting material. In the 1990s,
    scientists began studying the toxicological effects of BPA leaching
    from plastic food and water containers. Despite the fact that some
    scientists claimed there was extensive evidence that BPA can disrupt
    mouse, rat, and human cell function at low part per trillion doses and
    that disruption at the same low doses is also found in snails [and] has
    profound implications for human health (vom Saal, et al., 2005, 249),
    other scientists disagreed. Vom Saal and Welshons (2006, 61) divided
    the studies into those funded by industry and those funded by nonprofit
    organizations. Of the 119 studies funded by the Federal Government, 109
    showed harmful toxicological outcomes while ten had outcomes which
    showed no harm. Of the studies funded by the chemical companies, there
    were zero with outcomes showing harm and 11 with outcomes of no harm.
        The authors write: ``Evidence of bias in industry-funded research
    on BPA.'' Is it systematic bias and if so what form does it take? Is
    industry using a different methodology than most of the federally-
    supported studies? If so, is their methodology sound or is it designed
    to get a ``no harm'' outcome?
        vom Saal and Welshons argue that industry-funded studies have a
    built in bias [what I have referred to as structural bias] against
    finding positive effects of BPA. They maintain that ``To interpret
    whether there is a positive or negative effect of a test chemical, such
    as BPA, appropriate negative and positive controls also have to be
    examined'' (vom Saal and Welshons, 2006, 62). Vom Saal argues that the
    industry-supported tests omitted a positive control and without
    positive control findings, one cannot interpret a reason for purely
    negative results. The authors also noted that some industry-funded BPA
    studies used test animals that had very low sensitivity to exogenous
    estradiol and thus would not be expected to exhibit effects from BPA.
    Other industry-funded investigators used a type of animal feed, which
    because of its estrogenic activity, would give a false result.
    ``Inclusion of an appropriate positive control . . . would have allowed
    a determination of whether the failure to find effects of BPA was due
    to the lack of activity of BPA or to a lack of sensitivity of the
    animal model and/or estrogenic contamination of the feed that was
    used'' (vom Saal and Welshons, 2006, 63).
        In his classic work, The Logic of Scientific Discovery, Karl Popper
    (1968) developed the philosophical foundations of scientific
    methodology. Science, Popper argued, is not an inductivist enterprise,
    where truth is built up from data that are consistent with a
    hypothesis. Scientists must seek to falsify a hypothesis, and only when
    a hypothesis is recalcitrant against a rigorous attempt at
    falsification can it be accepted as truth. The critical point is that
    deduction and not induction is the logical grounding of empirical
    science. In the latter case, scientists would be given: A1
    is B, A2 is B . . . An is B therefore All A is B. In the
    former case, scientists seek to falsify ``All A is B'' by trying to
    find a disconfirming instance (Ax is not B).
        For example, one can reach the conclusion that ``all crows are
    black'' by observing crops in certain parts of Africa. Or you could
    imagine a geographical location that would most likely nurture a
    nonblack crow--such as the North or South Pole. If after all the
    seeking for a falsifying instance none appears, then, under the
    Popperian program, you can claim that the hypothesis ``all crows are
    black'' is confirmed. vom Saal and Welshons illustrate this point in
    the toxicology of BPA.

              . . . it is a common event in toxicological studies conducted
            by the chemical industry for purposes of reporting about
            chemical safety to regulatory agencies to provide only negative
            results from a study in which no positive control was included
            but from which positive conclusions of safety of the test
            chemical are drawn. (von Saal and Welshons 2006, 63)

        As Peirce noted, ``We are, doubtless, in the main logical animals,
    but are not perfectly so'' (Peirce, 1877). Both he and Popper
    understood that knowledge claims drawn inductively can be easily
    distorted by the social context of scientists. This is most notably the
    case in the field of toxicology, which is composed of academic
    scientists and contract toxicologists working on behalf of for-profit
    companies. These scientists are usually paid by chemical companies to
    fulfill the information needs of their regulatory requirements. The
    standards for doing toxicological research may vary, especially in new
    subfields like low-dose, endocrine toxicology. Thus, until the norms of
    good scientific practices are adopted across the subfield and by the
    government regulators, contract toxicologists may perform studies that
    have structural biases because they are more likely than not to produce
    false negatives. This is the take-home message from the criticism by
    vom Saal and Welshons of private-company-sponsored studies. They are
    looking to confirm the null (no effect) hypothesis rather than trying
    to falsify the null hypothesis, which would provide more confidence in
    the claim that the chemical is not harmful.
    Conclusion
        This analytical review of studies of studies that investigate an
    association between funding source and study conclusions has revealed
    several important results. First, there is sufficient evidence in drug
    efficacy and safety studies to conclude that the funding effect is
    real. Industry-sponsored trials are more likely than trials sponsored
    by nonprofit organizations, including government agencies, to yield
    results that are consistent with the sponsor's commercial interests.
    Second, there is some circumstantial evidence that this effect arises
    from two possible causes. Either the drugs sponsored by industry have
    gone through more internal testing and less-effective drugs are
    screened out, or the methods used in industry-sponsored drug testing
    have a structural bias that is more likely to yield positive outcomes.
        Third, a small number of pharmacoeconomic studies also show
    evidence of a funding effect. Without standardization of economic
    studies or the use of third-party ``economic auditors'' who have no
    economic ties to a company, it is difficult to account for the factors
    that explain this effect.
        A person who files his income tax is likely to use whatever
    discretionary decisions at his disposal to reduce his tax obligation.
    Similarly, a company that performs its own economic analysis of a new
    drug is likely to choose a model and use inputs that are advantageous
    to it. When a company hires an independent agent to undertake the
    economic analysis, little is known about what influence the company has
    in shaping the study. Also, little is known about drugs that are kept
    out of the testing pool by companies because they have already done the
    economic analysis.
        When we turn to studies of the funding effect on individualized
    commodities, the results are less ambiguous. There is an extensive body
    of research on tobacco, both primary (smokers) and secondary
    (secondhand smoke) exposures. This research shows a clear demarcation
    between studies funded by the cigarette industry and studies funded by
    nonprofit and governmental organizations. From this body of research,
    it is reasonable to conclude that the tobacco industry hired scientists
    to play a similar role as their contracted lawyers, namely, to develop
    a brief, in this case a scientific argument, that provides the best
    case or their interest. If that interpretation of tobacco-funded
    research is correct, it could explain the funding effect in tobacco
    studies.
        The second homogenous product discussed in this article is BPA.
    However, with only one study of this compound found that addresses the
    funding effect, a generalization cannot be drawn. But the scientists
    who published the study help the reader understand why a funding effect
    is a probable outcome. They show the systemic bias involved in the
    industry-funded studies that ordinarily do not appear in studies funded
    by nonprofit organizations.
        What I have argued in this article is that the ``funding effect,''
    namely the correlation between research outcome and funding source, is
    not definitive evidence of bias, but is prima facie evidence that bias
    may exist. Additional analyses of the methodology of the studies,
    interpretation of the data, interviews with investigators, and
    comparison of the products studied can resolve whether the existence of
    a funding effect is driven by scientific bias. Social scientists should
    follow Robert Merton's norm of ``organized skepticism'' when they frame
    an initial hypothesis about the cause behind the ``funding effect''
    phenomenon (Merton, 1968, 608). The notion of bias based on possessing
    a financial conflict of interest is certainly one viable hypothesis.
    But there are others. Social scientists must be equipped to compare the
    methods used across a cluster of studies funded by for-profit and not-
    for-profit companies to determine whether a particular method biases
    the results toward ``no detectable outcome'' while other more sensitive
    methods yield positive results. Certain chemical effects may show up in
    animal fetuses and not on the adult animals.
        In addition, social scientists must gain an understanding of the
    entities being tested across a series of studies to determine whether
    the differences in the entities can account for the ``funding effect.''
    Calcium channel blockers represent a class of drugs. It is important to
    understand whether the partition of studies between for-profit and not-
    for-profit funders coincides with a random distribution of the entities
    being studied. Drugs that have passed a prescreening test are more
    likely to show more favorable outcomes than similar drugs that have
    not. This potential confounder can be eliminated when the entities are
    relatively homogenous, like tobacco or a chemical like BPA.
        In some cases, ethnographic studies can determine whether for-
    profit companies have made internal decisions about drugs before they
    send them out to academic laboratories for study and how that compares
    with drug studies funded by not-for-profit organizations. Ethnography
    can also help social scientists ascertain when investigators reach
    beyond the data when they interpret results and whether the frequency
    of such overinterpretation (claiming benefits not found in the data) is
    more likely in studies funded by for-profit funders. Interviews with
    academic investigators, who are funded by private for-profit companies,
    and company executives, can reveal whether and how the funding
    organization helps frame the study, contributes to the interpretation
    of the data, and plays a role in deciding whether the results get sent
    for publication. The ``funding effect'' is merely a symptom of the
    factors that could be driving outcome disparities. Social scientists
    should not suspend skepticism and choose as the default hypothesis that
    ``bias'' is always the cause.

    Acknowledgment

        This research was supported in part by funding from the
     International Center forAlcohol Policies.

    Declaration of Conflicting Interests

        The author declared no potential conflicts of interest with respect
     to the research, authorship, and/or publication of this article.

    Funding

        The author received funding for an earlier version of this paper
     from the International Center for Alcohol Policies.

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        Djulbegovic, B., M. Lacevic, A. Cantor, K.K. Fields, C.L. Bennett,
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     Principle and Industry-sponsored Research.'' Lancet 356 (9230): 635-8.
        Friedberg, M., B. Saffran, T.J. Stinson, W. Nelson and C.L. Bennett.
     1999. ``Evaluation of Conflict of Interest in Economic Analyses of New
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     282 (15): 1453-7.
        Friedman, L.S., and E.D. Richter. 2004. ``Relationship between
     Conflict of Interest and Research Results.'' Journal of General
     Internal Medicine 19 (1): 51-56.
        Garattini, L., D. Rolova, and G. Casasdei. 2010. ``Modeling in
     Pharamacoeconomic Studies: Funding Sources and Outcomes.''
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     33.
        Jefferson, T., R. Smith, Y. Yee, M. Drummond, M. Pratt, and R. Gale
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        Johnson, J.A., and S.J. Coons. 1995. Evaluation in Published
     Pharmacoeconomic Studies. Journal of Pharmacy Practice 8 (8): 156-66.
        Knox, K.S., J.R. Adams, B. Djulbegovic, T.J. Stinson, C. Tomor, and
     C.L. Bennett. 2000. ``Reporting and Dissemination of Industry versus
     Non-profit Sponsored Economic Analyses of Six Novel Drugs used in
     Oncology.'' Annals of Oncology 11 (12): 1591-95.
        Krimsky, Sheldon. 1999. ``Conflict of Interest and Cost
     Effectiveness Analysis.'' The Journal of American Medical Association
     282 (10): 1474-75.
        ____. 2005. ``The Funding Effect in Science and its Implications for
     the Judiciary.'' Journal of Law and Policy 23 (1): 43-68.
        ____. 2006. ``Publication Bias, Data Ownership, and the Funding
     Effect in Science: Threats to the Integrity of Biomedical Research.''
     In Rescuing Science from Politics: Regulation and the Distortion of
     Scientific Research, edited by W. Wagner and R. Steinzor, 61-85. New
     York: Cambridge University Press.
        ____. 2010. ``Combating the Funding Effect in Science: What's Beyond
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     Monthly 12 (11): 1-15. Accessed October 1, 2010. http://www.peirce.org/
     writings/p.107.html.
        Popper, Karl. 1968. The Logic of Scientific Discovery. New York, NY:
     Harper &Row.
        Resnik, David B. 1998. The Ethics of Science. London, England:
     Routledge.
        Rochon, P.A., J.H. Gurwitz, R.W. Simms, P.R. Fortin, D.T. Felson,
     K.L. Minaker, and T.C. Chalmers. 1994. ``A Study of Manufacture-
     supported Trials of Nonsteroidal Anti-inflammatory Drugs in the
     Treatment of Arthritis.'' Archives of Internal Medicine 154 (2): 157-
     63.
        Sacristan, J.A., J. Soto, and I. Galende. 1988. ``Evaluation of
     Pharmacoeconomic Studies: Utilization of a Checklist.'' The Annals of
     Pharmacotherapy 27: 1126-33.
        Sugarman, Jeremy. 2008. ``Human Stem Cell Ethics: Beyond the
     Embryo.'' Cell Stem Cell 2 (7): 529-33.
        Turner, Christina, and George J. Spilich. 1997. ``Research into
     Smoking or Nicotine and Human Cognitive Performance: Does the Source of
     Funding make a Difference?'' Addiction 92 (11): 1423-426.
        Van Dalen, Arjen. 2012. ``Structural Bias in Cross-National
     Perspective: How Political Systems and Journalism Cultures Influence
     Government Dominance in the News.'' The International Journal of Press/
     Politics 17 (1): 32-55.
        vom Saal, F.S., S.C. Nagel, B.G. Timms, and W.V. Welshons. 2005.
     ``Implications for Human Health of the Extensive Bisphenol A Literature
     Showing Adverse Effects at Low Doses: A Response to Attempts to Mislead
     the Public.'' Toxicology 212 (2-3): 244-252.
        vom Saal, F.S., and W.V. Welshons. 2006. ``Large Effects from Small
     Exposures.'' Environmental Research 100 (1): 50-76.
        Yaphe, J., R. Edman, B. Knishkowy, and J. Herman. 2001. ``The
     Association Between Funding by Commercial Interests and Study Outcome
     in Randomized Controlled Drug Trials.'' Family Practice 18 (12): 565-
     68.

    Author Biography

        Sheldon Krimsky is the Lenore Stern Professor of Humanities and
     Social Sciences at Tufts University and the Carol Zicklin Visiting
     Professor at Brooklyn College. He is author of Science in the Private
     Interest.

                                 attachment 13
    Judge the Science, Not the Funding Source
    Editorial
    International Journal of Obesity (2014) 38, 625; doi:10.1038/
    ijo.2014.32; published online 18 March 2014
    2014 Macmillan Publishers Limited All rights
    reserved 0307-0565/14
    www.nature.com/ijo

        Medical research has long been engaged in debate over the
    influences of corporate sponsorship on research findings. These
    discussions are a necessary element of our scientific process. However,
    recently the issue of `funding source' has taken on a life of its own,
    particularly in the realm of obesity research. Discussions about the
    merit and objectivity of the underlying science frequently take a back
    seat to ad hominem attacks on researchers or accusations of malicious
    corporate intent in the absence of any objective scientific appraisal
    of the research.
        These discussions are based on the faulty logic that somehow direct
    corporate funding is inherently bias-producing in otherwise ethical
    researchers and that, by implication, public (for example, NIH, USDA)
    and/or philanthropic (for example, RWJ, AHA) funding, by way of the
    intervening agency, ensures objectivity. A recent controlled study of
    over 500 board-certified internists found that the participant's
    perception of methodological quality was lower if they believed a trial
    was corporate sponsored even when no actual methodological difference
    was present.\1\ This suggests a bias against scientifically valid
    studies based solely on funding source, which could in fact negatively
    impact public health through out-of-hand dismissal of relevant, high-
    quality research.
    ---------------------------------------------------------------------------
        \1\ Kesselheim A.S., Robertson C.T., Myers J.A., Rose S.L., Gillet
    V., Ross K.M., et al. A randomized study of how physicians interpret
    research funding disclosures. N. Engl. J. Med. 2012; 367: 1119-1127.
    ---------------------------------------------------------------------------
        Conversely, the implied bias favoring noncorporate trial
    objectivity is equally concerning as it may lead us to overlook very
    real potential bias from publicly funded trials. For example, it could
    be argued that a scientist who is funded by USDA is at similar risk for
    being biased in favor of sugar, corn and other agriculture-based
    products vs. artificial sweeteners. Moreover, an often overlooked
    threat to objectivity is the pressure to find statistically significant
    results. This has been found in both corporate- and noncorporate-
    sponsored research. A recent examination of over 4,600 scientific
    papers from all disciplines published internationally between 1990 and
    2007 found that the frequency of positive support for hypotheses has
    increased 22%. The author notes that this bias toward publishing
    positive results may influence the objectivity of the research
    literature both directly and also more subtly by discouraging more
    innovative (higher-risk) projects.\2\
    ---------------------------------------------------------------------------
        \2\ Fanelli D. Negative results are disappearing from most
    disciplines and countries. Scientometrics 2012; 90: 891-904.
    ---------------------------------------------------------------------------
        Assuming that the well-intentioned yet misguided goal of those
    leveling these ad hominem attacks is to keep scientists in check and to
    help us avoid moral and scientific pitfalls, there is a far better
    model available. When the model works, the public is protected,
    scientific discovery and rigor supported, and advances in our knowledge
    achieved. At the core of the model is a safe environment that allows
    for transparency. This includes full disclosure of all potential
    conflicts of interest without fear of judgment or reprisal and peer-
    reviewed publication of findings with appropriate methodological detail
    to allow for objective analysis and scientific scrutiny. Beyond these
    commonly and universally held practices, more consistent application of
    additional tools may be useful. For example, a requirement for all
    research to be preregistered in Clinicaltrials.gov or a similar
    database. Reviewers and journal editors can be encouraged to ensure
    that final manuscripts are consistent with the stated a priori
    objectives before final acceptance of manuscripts, which could further
    add to our protection of scientific integrity. Finally, we should all
    aspire to solve the intellectual property and other barriers that limit
    our ability to review and replicate studies on the basis of lack of
    access to primary data sources in some corporate trials. Although these
    barriers are complex and beyond the scope of this paper, we need to
    begin to find solutions that will enhance the ways scientific process
    can be used to be the judge of all science.
        In summary, what are the best practices for ensuring a strong,
    unbiased body of obesity research? Certainly not refusing funding from
    those who wish to collaborate with scientists in becoming part of the
    solution; absolutely not by launching unsubstantiated attacks on
    reputable scientists with longstanding records of ethical conduct and
    meaningful scientific contribution; rather, it is first by giving
    funding source its proper position among many possible and equally
    important threats to objectivity and implementing safeguards to protect
    against such bias (and worse yet malfeasance). Second, we need to
    redouble our efforts to adhere to the basic principles of good science
    like reproducibility, replicability and other core evaluative
    procedures that ensure objective and reliable scientific reporting.
    Finally, we need to work toward open access to data regardless of its
    source. This will require the cooperation of those in the scientific
    community and among potential sources of funding. Ultimately, this type
    of transparency regardless of funding source will deliver a more robust
    and complete body of evidence. In short, scientists need to practice
    good science, sponsors must commit to transparency and noninfluence,
    media needs to practice responsible scientific journalism, and we all
    need to base our evaluations on scientific data and not on
    predetermined opinions rooted in our own emotion-laden bias for or
    against specific funding sources.

    Conflict of Interest

        Dr. Martin Binks [1	2] reports the following potential conflicts of
     interest: Dr. Binks is sole proprietor of Binks Behavioral Health PLLC;
     he has also received financial compensation from: The Obesity Society
     (Communications & Social Media Consultant), 2011-present; Guidepoint
     Global Consulting, 2007-present; AbbVie Men's Health Initiative, 2012;
     Everyday Health Inc., 2006-2011; Evolution Health Systems, 2006-2011.
     Dr Binks also currently serves in the following volunteer roles: The
     Obesity Society, Secretary Treasurer & Development Chair. No funding
     from any source is directly associated with the development of this
     manuscript.
    [1] Department of Nutritional Sciences, Texas Tech University, Lubbock,
     TX, USA.
    [2] Binks Behavioral Health, PLLC, Hillsborough, NC, USA, E-mail:
     m.binks@ttu.edu.

                                 attachment 14
    The Obesity Society Encourages Science-Industry Collaborations to
            Support Obesity Science, Public Health
    New Position Statement Condemns Ad Hominem Attacks on Researchers
    Mar. 26, 2014, 11:00 ET from The Obesity Society

              The Obesity Society Logo. (PRNewsFoto/The Obesity Society)

        Silver Spring, Md., March 26, 2014--PRNewswire-USNewswire--
    Collaborations between scientists and industries, including food and
    pharmaceuticals, have a strong history of aiding in new scientific
    discoveries and supporting public health. For example, earlier this
    year, food industry corporations announced success in cutting 1.5
    trillion calories from food products, which The Obesity Society
    referred to (http://www.obesity.org/news-center/cutting-trillions-of-
    calories-from-food-products-can-have-a-significant-impact-on-the-
    nations-health.htm) as an effort that could ``make a significant
    difference in our nation's weight and health, helping to reverse the
    obesity epidemic.''
        ``It's clear, efforts to combat obesity cannot succeed without the
    engagement of the many industries that have the power to positively
    impact the health of billions of people,'' said TOS President Steven
    Smith, M.D.
        However, in recent years, nutrition and obesity researchers have
    frequently endured ad hominem attacks, or inappropriate criticisms of
    character and ethics on the sole basis of collaborative relationships
    and/or funding from Industry. Today, The Obesity Society (TOS) issued a
    position statement supporting and encouraging collaborative
    relationships between scientists and Industry in the interest of
    scientific discovery and public health. The position goes further to
    condemn these character attacks against credible and ethical
    professionals providing transparency and full disclosure about these
    collaborations.
        ``Many of our members are the obesity and nutrition scientists that
    offer valuable insight and spark meaningful dialogue with Industry
    leaders, and they deserve to be treated and recognized as the credible
    and ethical professionals that they are,'' said Dr. Smith.
    ``Discrediting the scientific opinions of these professionals based on
    their working relationships has no place in the scientific process.''
        The position statement, ``Acceptance of Financial Support from
    Industry for Research, Education and Consulting,'' authored by members
    of TOS leadership, including Advocacy Chair Emily Dhurandhar, Ph.D.,
    President-elect Nikhil Dhurandhar, Ph.D., Secretary-Treasurer Martin
    Binks, Ph.D., and Advocacy Advisor Ted Kyle, RPh, discourages the
    practice of ``dismissing the contributions of individual scientists and
    attempting to discredit individuals based on funding source.''
        ``We have seen too many scientists with long-standing records of
    scientific excellence and ethical conduct dragged into the spotlight of
    public criticism based solely on a funding source, and despite full
    disclosure and transparency,'' said Dr. Dhurandhar, who led the
    development of the statement. ``Scientists serve a clear role in these
    relationships and must operate with the ability to do their work to
    advance public health by engaging in free and open dialogue, offering
    expert opinion, and conducting meaningful research to support obesity
    treatment and prevention, and advance public health.''
        In the new position statement, TOS recognizes that individual
    motivations can sometimes create a risk of bias, which can come in many
    forms outside of funding source. However, from advisory panels to
    scientific publications, policies are in place to ensure transparency
    and disclosure of all potential sources of bias, which is common
    practice.
        ``Scientists are very familiar with the importance of making
    relevant disclosures and ensuring funding sources do not influence the
    design, analysis, interpretation, and publication of the scientific
    process,'' said Dr. Dhurandhar.
        The Obesity Society has a long-standing commitment to ensuring
    ethical and transparent relationships between science and Industry, and
    the organization hopes to advance the science behind obesity research,
    treatment and prevention through ongoing dialogue on this issue.
        Read the full position statement here (http://www.obesity.org/
    publications/acceptance-of-financial-support-from-industry-for-
    research-education-a-consulting.htm).
    About The Obesity Society (http://www.obesityweek.com/)
        The Obesity Society (TOS) is the leading professional society
    dedicated to better understanding, preventing and treating obesity.
    Through research, education and advocacy, TOS is committed to improving
    the lives of those affected by the disease. For more information visit:
    www.Obesity.org.
                                 attachment 15
    White Hat Bias: A Threat to the Integrity of Scientific Reporting
    A Different View
    Acta Pjdiatrica ISSN 0803-5253
    Mark B. Cope,[1] David B. Allison
    (dallison@uab.edu)[2]
    ---------------------------------------------------------------------------
        \[1]\ Solae LLC, St Louis, MO, USA.
        \[2]\ Biostatistics and Nutrition & Obesity Research Center,
    University of Alabama at Birmingham, Birmingham, AL, USA.
        Correspondence: David B. Allison, Biostatistics and Nutrition &
    Obesity Research Center, University of Alabama at Birmingham,
    Birmingham, AL, USA. Tel: 205-975-9169, Fax: 205-975-2540, E-mail:
    dallison@uab.edu

    Received: 26 August 2010; accepted 2 September 2010.
    DOI:10.1111/j.1651-2227.2010.02006.x

              Articles in the series A Different View are edited by Alan
            Leviton (alan.leviton@childrens.harvard.edu) We encourage you
            to offer your own different view either in response to A
            Different View you do not fully agree with, or on an unrelated
            topic.
    Background
        Like other people, scientific researchers have their own
    motivations. Such motivations include, but are not limited to, direct
    financial gain, interests in recruiting financial resources to their
    institutions, fame, social dominance, being perceived as righteous and
    upstanding, and a genuine interest in beneficence and improving the
    human condition. Pursuing these motivations may at times suggest
    behaviours on the part of scientists that accord with the behaviours
    that are generally accepted as sound and honest scientific practice.
    Yet in other situations, such motives may conflict with the precepts of
    scientific research.
        Although the potential for financial conflicts of interests (COIs)
    to bias research and research reporting is widely
    recognized,(1) far less attention has been devoted to other
    factors that may contribute to bias in research. Some people within the
    research and lay communities appear to think that direct financial COIs
    resulting from industry connections are the only factors of significant
    concern. For example, Lesser, et al., wrote `We agree that financial
    conflict is not the only cause of
    bias. . . . long-standing scientific viewpoints, career considerations,
    and even political opinions might color study design or interpretation.
    However, these types of individual bias tend to cancel themselves out
    among large groups of scientists over the long term. While one
    investigator's career may rise on a cherished theory, another's may
    rise by debunking that theory. We contend that financial conflict of
    interest is qualitatively different, producing selective bias that acts
    consistently in one direction over time'.(2)
        Another report, evaluating the possible financial competing
    interest among researchers who had published clinical studies in the
    British Medical Journal, concluded that `authors' conclusions were
    positively associated with financial competing interests. Other
    competing interests such as personal or academic were not significantly
    associated withauthors' conclusions'.(3) This study had low
    power--only 19 trial reports listed `other competing interests--for
    instance, personal, academic, or political.' Also, the reporting of
    nonfinancial interests is by no means standard or covered by most
    guidelines, so most nonfinancial interests probably go unreported.
        Recently, we published a paper describing `White hat bias (WHB),'
    which we defined as bias leading to distortion of information in the
    service of what may be perceived to be righteous ends.(4)
    Using quantitative evidence, we showed, at least in some areas of
    investigation, that WHBs that do not stem from financial connections to
    industry, clearly do not `cancel out' over the long run as Lesser, et
    al.,(2) hypothesized they would. Rather, WHB seemed to be
    consistently pushing conclusions in a single direction and
    systematically distorting the research record.
        In the remainder of this paper, we summarize the results of our
    previously reported investigation into WHB, offer a few additional
    examples of apparent WHB, often anecdotal, and finally close with some
    suggestions to reduce the influence of biases, including WHBs, in
    research.
    Summary of Our Previous Findings Related to Breastfeeding and Obesity
        Some reports that do not agree with main stream opinion (e.g., a
    report that sugar-sweetened beverages (SSBs) \1\ are not associated
    with obesity in children or a report that breastfeeding is not
    protective against childhood weight gain) may never be published. Other
    reports contain secondary references to support a current position, but
    incompletely or inaccurately describe the overall results from the
    secondary reference cited (4) [also labelled as `unbalanced
    citations' by Atkinson and Macdonald].(5)
    ---------------------------------------------------------------------------
        \1\ The term sugar-sweetened beverages (SSBs) is used for
    consistency with common use in the literature to denote any beverage,
    which has been sweetened by the addition of a substance containing a
    nontrivial amount of metabolizable energy. Thus, SSBs do not include
    beverages sweetened with high-intensity `noncaloric' sweeteners such as
    sucralose or aspartame, but may include beverages sweetened with
    substances not conventionally termed sugar.
    ---------------------------------------------------------------------------
        One area in which we documented WHB involved the question of the
    beneficial effect (or lack thereof) of breastfeeding on the development
    of obesity.(4) In a review commissioned and published by the
    World Health Organization (WHO) on the health benefits related to
    breastfeeding, specifically for obesity in the breastfed offspring, the
    authors presented evidence about whether breastfeeding protects against
    obesity and whether there is evidence of publication bias
    (PB).(6) PB occurs when the probability of publication
    depends on the results of the study.(7-8) For example,
    positive (statistically significant) results are much more likely to be
    reported than statistically insignificant (null)
    findings.(9)
        Within the WHO-commissioned report, the authors presented a graph
    showing clear evidence consistent with PB, suggesting that the
    probability a study was published was positively related to the degree
    it showed a statistically significant protective association of
    breastfeeding on obesity. To evaluate the impact of industry funding on
    such PB, we retrieved and reviewed the papers summarized in this graph.
    None of the papers reported any industry funding or were written by
    employees of the infant formula industry. Thus, the strong PB in the
    literature pertaining to breastfeeding and its relationship to obesity
    seems because of the behaviour of nonindustry funded scientists and
    does not appear to be fuelled by industry interests.
        Research can also be reported in a misleading manner when authors
    choose to include incorrect or questionable material and exclude
    otherwise pertinent information in their reviews or meta-analyses. In
    our review of the WHO report on breastfeeding,(4) we cited
    several examples where careful study of some of the original papers
    revealed that WHO authors selectively included some values from certain
    primary papers and thereby generated stronger associations of
    breastfeeding with reduced obesity risk and excluded less impressive
    values from the same papers without explanation. Misleading reports (or
    unexplained exclusion of data) can also occur in other areas of
    research.
    Some Additional Examples and Evidence
        `Spin,' defined as distorted presentation of data, was identified
    in reports of randomized clinical trials.(10) In each, the
    primary outcome was statistically nonsignificant, yet somewhere in the
    report (title, abstract, etc.), the experimental treatment was `spun'
    in a way to mislead the reader. In an evaluation of reports of 102
    randomized clinical trials (122 published journal articles), 62% of
    them added a new outcome, had at least one of the primary outcomes
    changed, or simply omitted the findings.(11)
        Recently, the Food and Drug Administration of the U.S. Government
    issued a docket describing how menu labelling in restaurants would give
    people the opportunity to make healthier diet choices when eating
    out.(12) The docket stated that `the availability of
    nutritional information through menu labeling would provide Americans
    the opportunity to exercise personal responsibility and make informed
    choices about their diets. Studies show that providing nutrition
    information at restaurants can help people make healthier choices
    [(13), Journal of Consumer Research 2009 36(3): 494-503]'
    (14) This cited study actually reported that parents will choose
    slightly lower calorie food options for their children in a restaurant
    setting; however, the parents did not choose lower calorie foods for
    themselves (13). This is an example of an unbalanced citation. Rather
    than stating `Studies show that providing nutrition information at
    restaurants can help people make healthier choices,' an accurate
    statement from that study would have been `A single study (but not all
    studies) showed that providing nutrition information at restaurants can
    help people make healthier choices when they choose food for other
    people, but not when they choose food for themselves.'
    What Can We Do?
        Faithful reporting, acknowledging study limitations and evaluating
    bodies of evidence without selectively excluding information on the
    basis of its desirability are a few examples of how paediatricians can
    become committed to scientific truthfulness. They are also encouraged
    to be sensitive to the possibility of WHB.
        Publication bias and exclusion of pertinent data for no apparent
    reason are examples of WHB and according to Atkinson and Macdonald
    (5) `all scientists should strive to have the `spin' stop
    with them'. `Science itself is the antidote to the poison of bias in
    research'.(15) We need to encourage, and perhaps require the
    publication of reports that minimize publication bias, and to require
    that trials and their protocols be registered to enable identification
    of omissions or distortions of any key procedures, which would affect
    interpretation of results. These and other ways of shoring up the
    integrity of the scientific process are not easy steps, will not solve
    all problems, will create some new challenges and cannot be implemented
    overnight. Yet we should not make the perfect the enemy of the good and
    should make the development and implementation of such procedures a
    priority.
    Conclusion
        To reduce the influence of bias in research and in general media
    reporting of scientific findings, there will need to be a concerted
    effort at all levels from scientist-authors to editors and journalists.
    We do not yet know how much of WHB is inadvertent and how much it
    results from an anti-industry sentiment, feelings of righteous
    indignation, a passionate interest in justifying public health actions,
    or yet other factors. Yet regardless of the root of the WHB, medical
    professionals, reporters, government policy makers and the public
    should be aware of such biases and view scientific literature with a
    critical eye.
        Drs. Allison and Cope have received grants, book royalties,
    honoraria, donations and consulting fees from numerous food, beverage,
    dietary supplement, pharmaceutical companies, litigators and other
    commercial, government and nonprofit entities with interests in obesity
    and nutrition, including interests in breastfeeding and SSBs. Dr. Cope
    recently accepted a position with Solae LLC (St Louis, MO, USA).

                                   References

        1. Friedman L.S., Richter E.D. Relationship between conflicts of
     interest and research results. J. Gen. Intern. Med. 2004; 19: 51-6.
        2. Lesser L.I., Ebbeling C.B., Goozner M., Wypij D., Ludwig D.S.
     Relationship between funding source and conclusion among nutrition-
     related scientific articles. PLoS Med. 2007; 4: e5.
        3. Kjaergard L.L., Als-Nielsen B. Association between competing
     interests and authors' conclusions: epidemiological study of randomised
     clinical trials published in the BMJ. BMJ 2002; 325: 249.
        4. Cope M.B., Allison D.B. White hat bias: examples of its presence
     in obesity research and a call for renewed commitment to faithfulness
     in research reporting. Int. J. Obes. (Lond) 2010; 34: 84-8; discussion
     3.
        5. Atkinson R.L., Macdonald I. White hat bias: the need for authors
     to have the spin stop with them. Int. J. Obes. (Lond) 2010; 34: 83.
        6. Horta B., Bahl R., Martines J., Victora C. Evidence of the Long-
     Term Effects of Breastfeeding: Systematic Reviews and Meta-Analysis.
     WHO, Geneva, Switzerland, 2007.
        7. Riechelmann R.P., Wang L., O'Carroll A., Krzyzanowska M.K.
     Disclosure of conflicts of interest by authors of clinical trials and
     editorials in oncology. J. Clin. Oncol. 2007; 25: 4642-7.
        8. Friedman C.P., Wyatt J.C. Publication bias in medical
     informatics. J. Am. Med. Inform. Assoc. 2001; 8: 189-91.
        9. Rosenthal R.H. The ``File Drawer Problem'' and Tolerance for Null
     Results. Psychol. Bull. 1979; 86: 638-41.
        10. Boutron I., Dutton S., Ravaud P., Altman D.G. Reporting and
     interpretation of randomized controlled trials with statistically
     nonsignificant results for primary outcomes. JAMA 2010; 303: 2058-64.
        11. Chan A.W., Hrobjartsson A., Haahr M.T., Gotzsche P.C., Altman
     D.G. Empirical evidence for selective reporting of outcomes in
     randomized trials: comparison of protocols to published articles. JAMA
     2004; 291: 2457-65.
        12. Registry F. FDA Docket. 2010; 75: 39026-8.
        13. Tandon P.S., Wright J., Zhou C., Rogers C.B., Christakis D.A.
     Nutrition menu labeling may lead to lower-calorie restaurant meal
     choices for children. Pediatrics 2010; 125: 244-8.
        14. Howlett E.A., Burton S., Bates K. and Huggins K. Coming to a
     Restaurant Near You? Potential Consumer Responses to Nutrition
     Information Disclosure on Menus. Journal of Consumer Research 2009; 36:
     494-503.
        15. Allison D.B. The antidote to bias in research. Science 2009;
     326: 522-3.

                                 attachment 16
    White Hat Bias: Examples of Its Presence in Obesity Research and a Call
            for Renewed Commitment to Faithfulness in Research Reporting
    Commentary
    International Journal of Obesity (2010) 34, 84-88; doi:10.1038/
    ijo.2009.239; published online 1 December 2009
    M.B. Cope [1] and D.B. Allison [2]
    ---------------------------------------------------------------------------
        \[1]\ Department of Pharmacology and Toxicology, School of
    Medicine, University of Alabama at Birmingham, Birmingham, AL, USA.
        \[2]\ Section of Statistical Genetics, Department of Biostatistics,
    School of Public Health, and Clinical Nutrition Research Center,
    University of Alabama at Birmingham, Birmingham, AL, USA.
        Correspondence: Professor D.B. Allison, Section of Statistical
    Genetics, Department of Biostatistics, School of Public Health,
    University of Alabama at Birmingham, Ryals Public Health Building, 1530
    3rd Avenue S, RPHB 327, Birmingham, AL 35294-0022, USA. E-mail:
    Dallison@uab.edu.

              `White hat bias' (WHB) (bias leading to distortion of
            information in the service of what may be perceived to be
            righteous ends) is documented through quantitative data and
            anecdotal evidence from the research record regarding the
            postulated predisposing and protective effects of nutritively
            sweetened beverages and breastfeeding, respectively, on
            obesity. Evidence of an apparent WHB is found in a degree
            sufficient to mislead readers. WHB bias may be conjectured to
            be fuelled by feelings of righteous zeal, indignation toward
            certain aspects of industry or other factors. Readers should
            beware of WHB, and our field should seek methods to minimize
            it.
    Introduction
        Scientific dialogue is dependent on fair and open presentation of
    data and evidence, yet concerns have been raised in recent years about
    bias in research practice. We present data and examples pertinent to a
    particular bias, a `white hat bias' (WHB), which we define to be bias
    leading to distortion of research-based information in the service of
    what may be perceived as righteous ends. We evaluate WHB in the context
    of two illustrative obesity topics, nutritively sweetened beverage
    (NSB) consumption as a postulated risk factor \1\and breastfeeding as a
    postulated protective factor.\2\
    Example 1--Data on citation bias
        If secondary reportings of original research misleadingly cite
    papers with statements that inaccurately describe available evidence,
    then inaccurate beliefs may inappropriately influence clinical
    practice, public policy or future research. Previously,\3\ we observed
    that two papers 4-5 had both statistically and non-
    statistically significant results on body weight, body mass index (BMI)
    or overweight/obesity status, which allowed future writers to
    potentially choose which results to cite, and were also widely cited,
    permitting a quantitative analysis of citations.
    Cited Versus Citing Papers
        A Web of Science search (through to October 2008) yielded 195 and
    45 papers citing James, et al.,\4\ and Ebbeling, et al.,\5\
    respectively. We analyzed those in English (165 and 41, respectively).
        James, et al.,\4\ studied an intervention to decrease NSB
    consumption and adiposity among children. Dichotomized (overweight or
    obese versus neither overweight nor obese) and continuous (change in
    BMI) data were analyzed for statistical significance. The authors
    wrote:

              `After 12 months there was no significant change in the
            difference in body mass index (mean difference 0.13, ^0.08-
            0.34) or z score (0.04, ^0.04-0.12). At 12 months the mean
            percentage of overweight and obese children increased in the
            control clusters by 7.5%, compared with a decrease in the
            intervention group of 0.2% (mean difference 7.7%, 2.2-13.1%).'

        Ebbeling, et al.,\5\ described a randomized controlled trial of a
    25 week NSB reduction program in adolescents and wrote:

              `The net difference (in BMI), 0.14R0.21 kg/m\2\, was not
            significant overall.'

        They then report a subgroup finding:

              `Among the subjects in the upper baseline--BMI tertile, BMI
            change differed significantly between the intervention . . .
            and control . . . groups, a net effect of 0.75R0.34 kg/m\2\.'

        Ebbeling, et al. (p. 676) label the analysis in the total sample as
    the `primary analysis.'

                                                  Table 1  Categorization of 165 Papers Citing James, et al.\2\
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                          Score                            A            B            C            D            E            F            G            H
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    No. of references in each category                         14           74            2           21            2            1            1           50
    Proportion (exact CIs) a                                0.127        0.644        0.017        0.183        0.017        0.009        0.009
                                                      (0.071-0.19  (0.548-0.72  (0.003-0.06  (0.119-0.26  (0.003-0.06  (0.001-0.05  (0.001-0.05
                                                               9)           9)           8)           8)           8)           5)           5)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Abbreviations: BMI, body mass index; CI, confidence interval.
    a Proportions and CIs are calculated with only categories A through to G in the denominator. Scoring key: (A) Accurate--described the non-significant
      result on continuous outcome (change in BMI) and described the significant result on the dichotomous outcome (overweight versus non-overweight). (B)
      Mildly misleading (positively)--Described the result of the intervention study as showing efficacy, benefit or statistical significance for the
      dichotomous outcome of overweight status, without mentioning the non-significant result on the continuous outcome. (C) Moderately misleading
      (positively)--Described the result of the intervention study as showing efficacy, benefit or statistical significance on some weight-related outcome
      without explicitly stating that it was on the proportion overweight per se. (D) Explicitly misleading (positively)--Described, with a factually
      incorrect statement, that the result of the intervention for a continuous weight-related outcome was significant or showed effectiveness. (E) Mildly
      misleading (negatively)--Described the result of the intervention study as not showing efficacy, benefit or statistical significance on the continuous
      measure of BMI, without mentioning the significant result on the dichotomous outcome. (F) Moderately misleading (negatively)--Described the result of
      the intervention study as not showing efficacy, benefit or statistical significance on some weight-related outcome without explicitly stating that it
      was on the continuous measure of BMI. (G) Explicitly misleading (negatively)--Described, with a factually incorrect statement, that the result for the
      dichotomous outcome was not significant or that a lack of effectiveness was shown for the dichotomous outcome. (H) Unscorable--Did not make explicit
      statements about the effects of the study, made statements that were too ambiguous to code or made statements that were self-contradictory.

    Data Coding and Analysis
        Each paper citing either James, et al.,\4\ or Ebbeling, et al.,\5\
    was categorized (see Tables 1 and 2) on the basis of how authors cited
    results related to body weight, BMI or overweight/obesity outcomes from
    these two papers in their report. Papers citing James, et al., were
    independently coded by the authors of this paper (DBA or MBC). Any
    discrepancies were resolved by discussion. Papers citing Ebbeling, et
    al., were scored by DBA and cross-checked by MBC. Proportions (with
    confidence intervals) were calculated (Tables 1 and 2). Exact binomial
    calculation tested the null hypothesis that the proportion citing
    papers in a misleading manner that exaggerated the strength of evidence
    was equal to the proportion citing papers in a misleading manner that
    diminished the strength of evidence; as such an equal proportion would
    suggest a lack of bias in the overall literature, even if not in any
    one paper.
    Citation Analysis Results
        Results were quite consistent across papers citing either James, et
    al.,\4\ or Ebbeling, et al.,\5\ The majority, 84.3% for James, et
    al.,\4\ and 66.7% for Ebbeling, et al.,\5\ described results in a
    misleadingly positive manner to varying degrees (that is, exaggerating
    the strength of the evidence that NSB reduction showed beneficial
    effects on obesity outcomes). Some were blatantly factually incorrect
    in their misleading statements, describing the result as showing an
    effect for a continuous obesity outcome, when no statistically
    significant effect for continuous obesity outcomes was observed. In
    contrast, only four papers (3.5%) were negatively misleading (that is,
    underplayed the strength of evidence) for James, et al.,\4\ and none
    were negatively misleading for Ebbeling, et al.\5\ Only 12.7 and 33% of
    papers accurately described complete overall findings related to
    obesity outcomes from James, et al.,\4\ and Ebbeling, et al.,\5\
    respectively.
        To test whether the proportion of misleading reporting in the
    positive direction was equal to the proportion in the negative
    direction, we calculated the confidence interval on the proportion of
    misleading reportings in either direction that was positively
    misleading. This yields a proportion of 0.96 (95% CI: 0.903-0.985) for
    those citing James, et al.,\4\ and 1.00 (95% CI: .832-1.000) for those
    citing Ebbeling, et al.,\5\ and is significantly different from 1/2 for
    each (P<0.0001), indicating a clear bias and potential for readers of
    the secondary literature to be deceived.
    Example 2--Data on publication bias
    NSB Consumption
        A meta-analysis on NSB consumption and obesity \6\ found that
    estimated adverse associations were significantly smaller (that is,
    less adverse) among industry-funded than among non-industry-funded
    studies. One troubling conceivable explanation for this is that
    industry does something to bias results to make NSBs seem less harmful,
    but this is not the only conceivable explanation.
        To examine this further, we requested, and Dr. Vartanian \6\
    graciously provided, his meta-analysis data file. Focusing on cross-
    sectional studies, because a large number had adiposity indicators as
    outcomes, we conducted publication bias (PB) detection analyses.\7\ PB
    causes the sample of studies published to not constitute a
    representative sample of the relevant studies that hypothetically could
    have been published. With PB, the probability of a study being
    published depends on its outcome. Typically, PB involves statistically
    significant studies having a higher likelihood of being published than
    non-statistically significant ones. Our analysis (Figure 1) shows a
    clear inverse association between study precision and association
    magnitude. This PB hallmark suggests that studies with statistically
    significant NSB findings are more likely to be published than are
    nonstatistically significant ones. Interestingly, this bias seems to be
    present only for non-industry-funded research, suggesting that non-
    industry-funded scientists tend not to publish their non-significant
    associations in this area. Contrarily, all industry-funded studies seem
    to exceed a minimal level of precision. Thus, much of the reason for
    the smaller associations detected by Vartanian, et al.,\6\ for
    industry-funded research seems to be because of PB in non-industry-
    funded research. However, even after accounting for precision, the mean
    difference between the association magnitudes of industry and non-
    industry-funded studies is reduced by 33%, but not eliminated,
    suggesting that there may be competing biases operating in industry-
    funded research.

                                                 Table 2  Categorization of 41 Papers Citing Ebbeling, et al.\3\
    --------------------------------------------------------------------------------------------------------------------------------------------------------
                                Score                                   A            B            C            D            E            F            G
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    No. of references in each category                                      10            9           11            0            0            7            4
    Proportion (exact CIs) a                                             0.333        0.300        0.367        0.000        0.000
                                                                   (0.173-0.52  (0.147-0.49  (0.199-0.56  (0.000-0.11  (0.000-0.11
                                                                            8)           4)           1)           6)           6)
    --------------------------------------------------------------------------------------------------------------------------------------------------------
    Abbreviations: BMI, body mass index; CI, confidence interval.
    a Proportions and CIs are calculated with only categories A through to E in the denominator. Scoring key: (A) Accurate--Described both the non-
      significant result in the total sample and the significant result in the heaviest subgroup. (B) Patently misleading overpositive--Described as
      positive on weight without mentioning anything about the result only being in heaviest children. (C) Mildly misleading overpositive--Described as
      positive among the heaviest children without explicitly mentioning that there was no significant result in the total sample. (D) Mildly misleading
      over-negative--Described the null result in the total sample without explicitly mentioning the significant result in the heaviest subgroup. (E)
      Patently misleading over-negative--Described as negative in a way that explicitly indicated that there were no significant effects even in sub-groups.
      (F) Not directly relevant--Did not make clear and explicit statements about the effects of the study. (G) Ambiguous as to whether category A or E
      applies.

    Figure 1

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Plot of sample effect sizes from cross-sectional studies of
            the association between sugar-sweetened beverage consumption
            and obesity indexes indicating publication bias among non-
            industry-funded studies (Blue diamonds--industry funded; Red
            diamonds--non-industry funded).
    Breastfeeding
        The World Health Organization (WHO; \8\) published a meta-analysis
    on whether breastfeeding protects against obesity and also found
    evidence of PB. Figure 2 indicates this strikingly. We retrieved all
    papers from which data were obtained for Figure 2 to evaluate the
    impact of industry funding on this PB. None of the papers reported any
    industry funding or were obviously authored by authors employed by the
    infant formula industry. Thus, as with the NSB literature, there seems
    to be a strong PB that is not apparently fueled by industry interests.
    Figure 2

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]

              Plot of the relationship between association magnitude and
            study precision indicating publication bias in studies of
            breastfeeding and obesity (from Horta, et al.\8\).
    Example 3--Anecdotal Examples of Miscommunications in Press Releases
        Evidence suggests that `Press releases from academic medical
    centers often promote research that has uncertain relevance to human
    health and do not provide key facts or acknowledge important
    limitations'.\9\ This is also occurring in the obesity field. For
    example, the paper by Ebbeling, et al.,\5\ states, `change in body mass
    index (BMI) was the primary end point. The net difference, 0.14R0.21
    kg/m\2\, was not significant overall,' and then reports the subgroup
    finding, `Among the subjects in the upper baseline-BMI tertile, BMI
    change differed significantly between the intervention . . . and
    control . . . groups.' Contrast this modest finding in a sample subset
    and the circumspect presentation in the original paper with the
    presentation in the press release issued by the authors' institution
    (http://www.childrenshospital.org/newsroom/Site1339/
    mainpageS1339P1sublevel192.html (accessed on 31 October 2008)), which
    states `In randomized trial, a simple beverage-focused intervention led
    to weight loss' and never states that the primary analysis was not
    statistically significant.
        When the paper by James, et al.,\4\ was released, the press release
    issued on the BMJ website (http://www.bmj.com/content/vol328/issue7446/
    press_release.shtml (accessed on 20 September 2009)) stated
    `Discouraging children from drinking fizzy drinks can prevent excessive
    weight gain, according to new research available on bmj.com,' despite
    the facts that no analysis of weight change per se was reported and
    that there was no significant effect on BMI change. Neither of these
    facts was mentioned in the press release.
        Finally, in 2009, describing an observational epidemiological
    study, UCLA issued a press release (http://www.healthpolicy.ucla.edu/
    NewsReleaseDetails.aspx?id%35 (accessed on 20 September 2009)) stating
    `. . . research released today provides the first scientific evidence
    of the potent role soda and other sugar-sweetened beverages play in
    fueling California's expanding girth' One of the study authors was
    quoted in a subsequent news story stating `For the first time, we have
    strong scientific evidence that soda is one of the--if not the
    largest--contributors to the obesity epidemic' (http://
    www.drcutler.com/poor-diet/study-soda-making-californians-fat-19373657/
    (accessed on 25 September 2009)). These statements are inaccurate and
    also unfair to all authors of observational studies who published such
    research years before. The press release further stated `The science is
    clear and conclusive [emphasis added],' despite the fact that this was
    a correlational research, and offered no statement to the reader to
    interpret the results as indicative of correlation and not necessarily
    causation.
    Example 4--Inappropriate Or Questionable Inclusion of Information
        Research may also be misleadingly presented by inclusion of
    incorrect or questionable material in reviews. In our critical review
    of the WHO report on breastfeeding, we noted several examples (see,
    Cope and Allison,\2\ p. 597) in which an inspection of the original
    papers reviewed revealed that the authors of the WHO report selectively
    included some values from certain primary papers that led to stronger
    associations of breastfeeding with reduced obesity risk and excluded
    less impressive values from the same papers without explanation.
        Similarly, Mattes, et al.,\3\ noted that several reviews of NSB
    consumption and obesity inappropriately included a study \10\ that was
    actually neither a test of nutritive sweetener-containing solid food
    versus beverage nor of NSB consumption versus non-NSB consumption.
    Sweeteners were presented in both solid and beverage food forms. The
    original authors \10\ wrote, `. . . subjects who were given
    supplemental drinks and foods [emphasis added] containing sucrose for
    10 wk experienced increases in . . . body weight', and thus the study
    should never have been considered as evaluative of NSB effects. Mattes,
    et al.,\3\ provide other examples of papers being inappropriately
    included in past reviews of NSB consumption and obesity.
    Conclusion
        Finding effective methods to reduce obesity is an important goal,
    and appropriate evaluations of the strength of the evidence supporting
    the procedures under consideration are vital. Sound evaluations
    critically depend on evidence being presented in non-misleading ways.
    Alarms have been sounded about dramatic rises in obesity levels, not
    without justification. And yet, these alarms may also have aroused
    passions. Certain postulated causes have come to be demonized (for
    example, fast food, NSBs, formula feeding of infants) and certain
    postulated palliatives (for example, consumption of fruits and
    vegetables, building of sidewalks and walking trails) seem to have been
    sanctified. Such demonization and sanctification may come at a cost.
    Such casting may ignite feelings of righteous zeal.
        Some authors compare NSBs, fast foods and other food and restaurant
    industry offerings to the tobacco industry (for example, see Browne
    \11\ and Warner \11\), suggesting, for example, comparisons between
    `Joe Camel' and `Ronald McDonald' (http://www.time.com/time/magazine/
    article/0,9171,1187241,00.html). To the extent that such comparisons
    inform us about important causes of obesity and how to reduce them,
    this is all to the good. But to the extent that such comparisons and
    other appeals to passions inflame rather than inform, they may cloud
    judgment and decrease inhibitions against breaching ordinary rules of
    conduct. Historians indicate that during times of war, propagandists
    demonize (that is, dehumanize) the enemy to inflame spirits and this
    facilitates some breaches of codes of conduct such as massacres.\12\
    Although inflaming the passions of scientists interested in public
    health is unlikely to provoke bloodshed, we scientists have, as a
    discipline, our own code of conduct. Central to it is a commitment to
    faithful reporting, to acknowledging our study limitations, to
    evaluating bodies of evidence without selectively excluding information
    on the basis of its desirability--in short, a commitment to
    truthfulness. The demonization of some aspects and sanctification of
    others, although perhaps helpful in spurring social action, may be more
    harmful to us in the long run by giving unconscious permission to
    breach that code, thereby eroding the foundation of scientific
    discipline.
        Evidence presented herein suggests that at least one aspect has
    been demonized (NSB consumption) and another sanctified
    (breastfeeding), leading to bias in the presentation of research
    literature to other scientists and to the public at large, a bias
    sufficient to misguide readers. Interestingly, although many papers
    point out what seem to be biases resulting from industry funding, we
    have identified here, perhaps for the first time, clear evidence that
    WHBs can also exist in opposition to industry interests.
        Whether WHB is intentional or unintentional, and whether it stems
    from a bias toward anti-industry results, significant findings,
    feelings of righteous indignation, results that may justify public
    health actions, or yet other factors, is unclear. Future research
    should study approaches to minimize such distortions in the research
    record. We suggest that authors be more attentive to reporting primary
    results from earlier studies rather than selectively including only a
    part of the results, to avoiding PB, as well as to ensuring that their
    institutional press releases are commensurate with the studies
    described. Journal editors and peer reviewers should also be vigilant
    and seek to minimize WHB. Clinicians, media, public health policy
    makers and the public should also be cognizant of such biases and view
    the literature on NSBs, breastfeeding and other obesity-related topics
    more critically.

    Conflict of Interest

        Drs. Allison and Cope have received grants, honoraria, donations and
     consulting fees from numerous food, beverage, dietary supplement,
     pharmaceutical companies, litigators and other commercial, government
     and nonprofit entities with interests in obesity and nutrition,
     including interests in breastfeeding and NSBs. Dr Cope has recently
     accepted a position with The Solae Company (St. Louis, MO, USA).

    Acknowledgements

        We gratefully acknowledge Dr. Alfred A. Bartolucci for his comments
     on our data analysis and Dr. Lenny Vartanian for sharing his data file.
     Supported in part by the NIH grant P30DK056336. The opinions expressed
     are those of the authors and not necessarily those of the NIH or any
     other organization with which the authors are affiliated.

                                   References

        1. Allison D.B., Mattes R.D. Nutritively sweetened beverage
     consumption and obesity: the need for solid evidence on a fluid issue.
     JAMA 2009; 301: 318-320.
        2. Cope M.B., Allison D.B. Critical review of the World Health
     Organization's (WHO) 2007 report on `evidence of the long-term effects
     of breastfeeding: systematic reviews and meta-analysis' with respect to
     obesity. Obes. Rev. 2008; 9: 594-605.
        3. Mattes R.D., Shikany J.M., Allison B.D. What is the demonstrated
     value of moderating nutritively sweetened beverage consumption in
     reducing weight gain or promoting weight loss? An evidence-based review
     and meta-analysis of randomized studies. (Submitted for publication).
        4. James J., Thomas J.T., Cavan D., Kerr D. Preventing childhood
     obesity by reducing consumption of carbonated drinks: cluster
     randomised controlled trial. BMJ 2004; 328: 123743.
        5. Ebbeling C.B., Feldman H.A., Osganian S.K., Chomitz V.R.,
     Ellenbogen S.J., Ludwig D.S. Effects of decreasing sugar-sweetened
     beverage consumption on body weight in adolescents: a randomized,
     controlled pilot study. Pediatrics 2006; 117: 673-680.
        6. Vartanian L.R., Schwartz M.B., Brownell K.D. Effects of soft
     drink consumption on nutrition and health: a systematic review and meta-
     analysis. Am. J. Public Health 2007; 97: 667-675.
        7. Sterne J.A.C., Egger M. Regression methods to detect publication
     and other bias in meta-analysis. In: Rothstein H.R., Sutton A.J.,
     Borenstein M. (eds). Publication Bias in Meta-Analysis. John Wiley &
     Sons Ltd: West Sussex, UK, 2005.
        8. Horta B., Bahl R., Martines J., Victora C. Evidence of the Long-
     Term Effects of Breastfeeding: Systematic Reviews and Meta-Analysis.
     World Health Organization Publication: Geneva, Switzerland, 2007.
        9. Woloshin S., Schwartz L.M., Casella S.L., Kennedy A.T., Larson
     R.J. Press releases by academic medical centers: not so academic? Ann.
     Intern. Med. 2009; 150: 613-618.
        10. Raben A., Vasilaras T.H., Moller A.C., Astrup A. Sucrose
     compared with artificial sweeteners: different effects on ad libitum
     food intake and body weight after 10 wk of supplementation in
     overweight subjects. Am. J. Clin. Nutr. 2002; 76: 721-729.
        11. Brownell K.D., Warner K.E. The perils of ignoring history: big
     tobacco played dirty and millions died. How similar is Big Food?
     Milbank Q. 2009; 87: 259-294.
        12. Levene M., Roberts P. (eds). The Massacre in History (Studies on
     War and Genocide). Berghahn Books: Oxford, UK, 1999.

                                     ______

                               Submitted Question
    Response from Diane Whitmore Schanzenbach, Ph.D., Director and Senior
            Fellow, Economic Studies, Brookings Institution; Professor of
            Social Policy, and of Economics, The Hamilton Project,
            Northwestern University *
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        * There was no response from the witness by the time this hearing
    was published.
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    Question Submitted by Hon. David Scott, a Representative in Congress
            from Georgia
        Question. I have a question for you about the potential effects of
    adopting WIC restrictions as SNAP restrictions. As you know, WIC is
    meant to ensure low-income women have access to foods that meet the
    nutrient needs of pregnancy, infancy and developing young children. The
    purpose of SNAP, however, is meant to ensure that our low-income people
    are not hungry. WIC food packages are extremely restrictive, even when
    it comes to healthy foods, and vary widely by state. For example,
    currently only $10 is allowed per month on fruits and vegetables. In
    some states, frozen and canned fruits and vegetables are not allowed to
    be purchased with WIC benefits. Many states don't even offer yogurt,
    and when they do, they offer only the large size, certain brands and
    certain flavors. Many of us, no matter the income level, have dealt
    with a picky eater in our family, and we've had to find little
    solutions to getting them to eat healthy foods. Maybe they hate
    strawberry yogurt, but they'll eat blueberry! Maybe they won't eat raw
    broccoli, but they'll eat steamed frozen broccoli with a little cheese
    on top. It begs the question, are we trying to make it harder or easier
    for Americans to feed our families?
        Some states are considering asking for a waiver from USDA to
    restrict SNAP purchases to the preexisting and restrictive list of
    foods under WIC. Could you please describe what implementation would
    look like, health outcomes and any unintended negative consequences of
    states restricting SNAP benefits to those foods offered through the WIC
    program? Would it further the program's goal of reducing hunger?
        Answer.

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