Goodbye Dietary Guidelines?

There is an old saying that goes: if you don't like something, change it. 

While I am generally supportive of the basic tenant of this statement, I also like the saying: you can have your own opinions, but you can't have your own facts. 

During dinner with a friend in Washington, DC I learned of identical language found in both the House Agriculture (pg. 80; Sec. 734) and Labor an Human Services (pg. 98; Sec. 232) 2016 appropriation bills that will all but paralyze the release of the Dietary Guidelines for Americans. You heard right; the Dietary Guidelines for Americans have joined the Supplemental Nutrition Assistance Program (SNAP- also known as Food Stamps) and the Healthy, Hunger Free Kids Act (the school lunch program) as the new politicized hotbed.

The language bars funding to the Guidelines unless the agencies comply with patronizing requirements:

"None of the funds made available by this Act may be used to release or implement the final version of the eighth edition of the Dietary Guidelines for Americans, revised pursuant to section 301 of the National Nutrition Monitoring and Related Research Act of 1990, unless the Secretary of Agriculture and the Secretary of Health and Human Services comply with each of the following requirements:

1. Each revision to any nutritional or dietary information or guideline contained in the 2010 edition of the Dietary Guidelines for Americans and any new nutritional or dietary information or guideline to be included in the eight edition of the Dietary Guidelines for Americans-

A) shall be based on scientific evidence that have been rated "grade 1: Strong" by the grading rubric developed by the Nutrition Evidence Library of the Department of Agriculture; and 

B) shall be limited in scope to only matters of diet and nutrition intake.

2. The Secretaries shall release a preliminary draft of the eight edition of the Dietary Guidelines for Americans, including a list of the scientific studies and evidence supporting each revised or new nutritional or dietary information or guidelines, for a period of public comment of at least 90 days

3. Following the end of the public comment period, the Secretaries shall provide a period for agency review of public comment of at least 60 days."

But what is at the heart of this debate? According to Philip Brasher at Agripulse, it's all about "protecting meat." He states that the House appropriators are seeking to ensure the Obama administration doesn't use environmental factors in writing the federal dietary guidelines for meat consumption and that the 2015 recommendations are strictly limited to “matters of diet and nutrient intake”, an effort to thwart the inclusion of environmental considerations in the guidelines.

Those that work in food and nutrition know the complexity of nutritional science, food politics and healthy food environments. A bit of science training of legislators may do us all good. "Grade 1 strong" research would require the use of methods that should be barred by any respectable Institutional Review Board. It would also throw out the new language that supports dietary patterns (not Grade 1 strong) AND any recommendations about physical activity (not Grade 1 strong OR "in the scope of diet and nutrition"). See these examples of recommendations that don't make the "strong" grade. Since a tenant of the food industry's health messaging is centered around personal responsibility and physical activity, this may have some critics outside of the meat lobby.


Implications of the Language

§  USDA and HHS complete a revised DGA every five years. The public has already had approximately 24 months to weigh in on the development of the 2015 DGAs – in addition to 75 days to comment on the DGAC report. The list of scientific studies that will be used to inform the DGAs is completed. Any additional public comment would significantly delay the release of the 2015 DGA, which is set to be released by the end of the calendar year.

§  The language undercuts the whole development process for the Dietary Guidelines; the Advisory Committee conducts an exhaustive, systematic review of the evidence, including a bias assessment. The recommendations have to be based on the best evidence available, but unfortunately not all of that evidence can be “strong.” Studies of strong design with minor methodological concerns are included in Level II (Moderate) Evidence Grade. It is not just the quality of evidence that we need to take into account, but also the preponderance of evidence. There are very important studies that may have minor flaws, but contribute to the preponderance of evidence that we want to take into account for the DGACs.

§  The implication of the language would be that the 2015 Dietary Guidelines would be prohibited from taking into consideration the totality of the scientific evidence reviewed by the Dietary Guidelines Advisory Committee report, including the evidence linking diet and cancer risk.

§  Here are some examples of recommendations with a moderate grade that would be cut if we used only a Level I Strong Evidence Grade:

• Recommended dietary patterns that are higher in vegetables, fruits, and whole grains; include seafood and legumes; are moderate in dairy products (particularly low and non-fat dairy) and alcohol; lower in meats, and low in sugar-sweetened foods and beverages, and refined grains are associated with favorable outcomes related to healthy body weight or risk of obesity. 

• Higher intake of added sugars, especially in the form of sugar-sweetened beverages and the link with increased risk of hypertension, stroke, and coronary heart disease in adults.

• The relationship between higher sodium intake and risk of cardiovascular disease and high blood pressure. 

• Replacing sugar-containing sweeteners with low-calorie sweeteners to reduce calorie intake, body weight, and body fat.

• The relationship between dietary patterns and colorectal cancer and post-menopausal breast cancer risk. 

• Moderate evidence indicates that dietary patterns rich in vegetables, fruit, and whole grains, and lower in animal products and refined carbohydrate, are associated with reduced risk of post-menopausal breast cancer.

Some of the current 2010 DGA recommendations (including sodium) are based on “moderate” evidence. The way bill language is written, we would not be able to change those without “strong” evidence, but anything already in the 2010 DGA’s could remain, which is inconsistent.  The scientific evidence in support of lean meat is also not “strong”, so that might cause some concern.

This language will exclude the important recommendations in the DGAs on physical activity. It is very important for Americans to understand the holistic approach they should be taken to prevent chronic disease and maintain a healthy lifestyle including both diet and physical activity.

The Dietary Guidelines Advisory Committee report, which serves as the basis for the DGAs already went through a public review and comment period so requiring another comment period would be duplicative and wasteful of government resources. 

Taking Action (Updated)


You can take action, demand that the Committees let the Secretaries of Agriculture and Health do their jobs. If you are represented by one of these representatives (see below), call with or e-mail this message...

"I urge you to let the Secretaries of Agriculture and Health do their jobs and consider the recommendations of the expert committee on the Dietary Guidelines for Americans regarding the impact of diet on both human and environmental health."

If your Representative is not on one of the Committees, everyone can contact the Agriculture Appropriation Committee Chair, Robert Aderholt (Alabama) and Labor and Health Appropriations Chair Tom Cole (Oklahoma).

If you bave a representative on either committee, please contact them as well.

House Agriculture Appropriations Subcommittee
Republicans

• Robert Aderholt, Alabama, Chairman
• Kevin Yoder, Kansas
• Tom Rooney, Florida
• David Valadao, California, Vice Chair
• Andy Harris, Maryland
• David Young, Iowa
• Steven Palazzo, Mississippi

Democrats

• Sam Farr, California, Ranking Member
• Rosa DeLauro, Connecticut
• Sanford Bishop, Jr., Georgia
• Chellie Pingree, Maine

House Labor & Human Services Appropriations Subcommittee

Republicans

• Tom Cole, Oklahoma, Chairman
• Mike Simpson, Idaho
• Steve Womack, Arkansas, Vice Chair
• Chuck Fleischmann, Tennessee
• Andy Harris, MD, Maryland
• Martha Roby, Alabama
• Charlie Dent, Pennsylvania
• Scott Rigell, Virginia

Democrats

• Rosa DeLauro, Connecticut, Ranking Member
• Lucille Roybal-Allard, California
• Barbara Lee, California
• Chaka Fattah, Pennsylvania

Dietary Guidelines Background

The Dietary Guidelines provide a crucial basis for federal nutrition policy, nutrition programs and education, and in identifying research needs. Currently the Guidelines provide science-based advice for persons aged two and over that will promote health and also prevent chronic disease. Guidelines that provide consistent messages help consumers make healthy choices for themselves and their families. These areas will impact Americans’ awareness of healthy eating for many years.
The Dietary Guidelines help direct the course of developing effective, quality nutrition policy and guiding the regulatory process. It is also important for consumers to understand the Dietary Guidelines to help make help healthy food choices for their families. Public health nutritionist found that the Dietary Guidelines:

1. Are grounded in strong and emerging science.

2. Are focused on food patterns – how and what actual foods we eat – more than individual nutrients.

3. Look at food beyond just what's on your plate – from how it's produced to where itis sold and consumed and more.

The Dietary Guidelines Advisory Committee (DGAC) is a 14-member committee of independent experts, convened by the Departments of Agriculture and Health and Human Services. The DGAC spent 20 months reviewing the latest scientific evidence on nutrition and physical activity. Their advice is mostly unchanged from a report issued by the 2004 expert panel, prior to publication of the 2005 Dietary Guidelines. The recommendations include: Americans need to eat more fruit, vegetables, whole grains and fiber; Americans should consume more plant-based foods and eat less foods with solid fat and added sugars; and Americans should consume dairy products that are low-fat or non-fat.


The DGAC Scientific Report makes the following recommendations:

1. Reduce consumption of added sugars, by setting a maximum limit to 10 percent of calories (50 grams or 12 teaspoons) 

2. Reduce daily sodium intake to 2,300 milligrams per day for the general population.

3. Limit red meat and processed meats high in saturated fat and sodium to reduce the risk of cancer and other adverse health outcomes. 

4. Reduce foods high in saturated fats and replace saturated fats with monounsaturated or polyunsaturated fats. 

5. Include strong recommendations regarding measures to encourage consumption of fruits and vegetables.

6. Provide clear recommendations to help people identify and consume whole grains in place of refined grains.

7. Develop policies to promote water as the primary beverage of choice and reduce consumption of sugar sweetened beverages.

8. Recognize sustainability as an essential component of federal dietary guidance.

The report has already been sent to the Secretaries of Agriculture and Health and Human Services to be used as they and their staffs write the 2015 Dietary Guidelines. HHS and USDA accepted public comments on the scientific report until May 8, 2015.

The consensus from a large coalition within the public health community is that these guidelines will help consumers be able to choose healthy safe foods for their families which is an overarching goal of the Guidelines.