Dear Dr. Olson, Dr. Casavale, Ms. Rihane, and Dr. Bowman:
The National Center for Health Research presents these comments on the expert report prepared for the eighth edition of the Dietary Guidelines for Americans (DGA) by the Dietary Guidelines for Americans Committee (DGAC). Overall, we strongly support the conclusions and policy recommendations in the report. Our research center scrutinizes scientific and medical data and provides objective health information to patients, providers and policy makers. We do not accept funding from any agricultural or food manufacturing industries, and have no conflicts of interest in making our recommendations.
We strongly agree with the Dietary Guidelines Advisory Committee’s assessment that the overall body of evidence identifies a healthy dietary pattern as one that is:
- higher in fruits, vegetables, whole grains, low or non-fat dairy, seafood, legumes, and nuts;
- lower in red and processed meats
- low in sugar-sweetened foods and drinks and refined grains; and
- lower in sodium.
We commend the DGAC for emphasizing overall dietary patterns, and suggest that the final recommendations give several examples of healthful patterns. This is not only educational but may improve participation, as some people may find one pattern more appealing or easy to follow than another.
We urge USDA and HHS to:
- Strengthen their efforts to encourage all Americans to make half their plates fruits and vegetables at every meal;
- Promote policies that increase children’s access to more fruits and vegetables in school meals and the school food environment;
- Promulgate guidelines that increase access to more fruits and vegetables in all federal nutrition programs, including financial incentives for people to buy more fruits and vegetables.
We have several specific comments below:
The DGAC notes the importance of implementing comprehensive nutrition standards to increase fruits and vegetables in school meals. School-based changes that include nutrition education and parent involvement are especially effective in increasing children’s fruit and vegetable consumption.
We support the DGAC’s proposal to change language regarding meat from “choose lean meat and poultry” to “limit red and processed meats.” That is an important change, based on clear, consistent, and still-mounting evidence of the link between regular consumption of red and processed meats and certain types of cancer, including colorectal cancer. This recommendation has a significant potential to improve the country’s health and is already supported by experts in the field.
We support the DGAC’s recommendations to reduce consumption of added sugars. Also there should be a line on added sugars on the Nutrition Facts label that includes a percentage of a Daily Value of added sugar and the total amount of sugar in both grams and teaspoons. We support the DGAC’s conclusions on the need for policies that address over-consumption of added sugars including:
- Economic and pricing approaches;
- Continued efforts to reduce added sugars in foods and beverages in school meals and snacks;
- Limiting the advertising of foods and beverages high in added sugars to young children, youth, and adolescents;
- Health promotion policies to reduce the availability of sugar-sweetened beverages in post-secondary institutions and worksites;
A recent prospective study of more than 11,000 people found higher risks of cardiovascular mortality with increasing consumption of added sugar. Those who consumed between 10 and 25 percent of their calories from added sugars had a 30 percent higher risk of dying of a heart attack, stroke, or other cardiovascular event than those who consumed less than 10 percent. The risk was nearly three times higher for those who consumed more than 25 percent of their calories from added sugars.[1]
Added sugars should be reduced in the diet, not just replaced with low-calorie sweeteners. Instead, they should be replaced with healthy options, such as water in place of sugar-sweetened beverages. We also support the DGAC’s emphasis on water as the primary recommended beverage.
The Dietary Guidelines for Americans should continue to recommend that consumers replace foods made with refined grains with 100% whole grains. The Guidelinesshould warn consumers that foods with labels such as “8 grams whole grain” or “made with whole grains” may be mostly refined grain, and should advise instead to look for products that are “100% whole grain.” Many consumers don’t realize that products with less than 100% whole grain have been refined. The guidelines should also give examples of healthy portion sizes for grains. These practical statements would help people follow the Guidelines by avoiding foods with high amounts of refined grains.
Reducing sodium intake is important. However, we recognize that more evidence is needed to define the optimum sodium intake for many people, and we encourage the DGAC to revisit these specific recommendations as more data become available. Meanwhile, Americans will continue to have difficulty reducing their sodium intake unless there are changes to the food available. Prepared frozen meals, which many families rely on for inexpensive and easy-to-prepare meals, are often extremely high in sodium. Fast food and restaurant foods are often even higher in sodium. Reducing sodium in the foods purchased or made available through schools, government programs, and workplaces is also essential to achieving the enormous health benefits of sodium reduction across the population. As the Committee advised, HHS and USDA should work with the food and restaurant industry to lower the amount of sodium in food by modifying the GRAS status of salt and establishing sodium limits for foods.
These changes will be difficult to make and the government needs to make it easier by working with restaurants and food manufacturers to reduce salt and sugar and increase fruits and vegetables in frozen foods and other convenience foods that families rely on.
We support the DGAC’s recommendations that most Americans should rely on healthy diets, not vitamin or mineral supplements, to lower their risk of cancer, heart disease, and other illness. Most research does not support claims that dietary supplements prevent of cancer or cardiovascular disease.[2]
We ask that the DGAC clarify their recommendations on egg consumption. Given the controversy over the significance of dietary cholesterol, the DGAC should place egg consumption in the context of the overall dietary patterns that have been shown to confer health benefits.
We commend the DGAC’s recognition of sustainability as an essential component of federal dietary guidance. Consistent with current scientific literature, the DGAC notes that diets high in animal-based foods, particularly red and processed meats, are associated with an increased risk of heart disease, diabetes, and cancer, and worse environmental outcomes.
In summary, we support many of the recommendations in the DGAC and hope to work towards healthier eating habits to ensure a healthy future. Please let us know if we can be of any further assistance in these efforts.
Sincerely,
The National Center for Health Research
- Yang, Q., Zhang, Z., Gregg, E. W., Flanders, W. D., Merritt, R., & Hu, F. B. (2014). Added sugar intake and cardiovascular diseases mortality among US adults. JAMA Internal Medicine, 174(4), 516-524. (We note that the findings were remarkably robust, as they were “largely consistent across age group, sex, race/ethnicity (except among non-Hispanic blacks), educational attainment, physical activity, health eating index, and body mass index.”)
- Fortmann, S. P., Burda, B. U., Senger, C. A., Lin, J. S., Beil, T. L., O’Connor, E., & Whitlock, E. P. (2013). Vitamin, mineral, and multivitamin supplements for the primary prevention of cardiovascular disease and cancer: A systematic evidence review for the US preventive services task force. Evidence Syntheses (108).