By the Healthy Nation Coalition, Well Being Journal, Vol. 24, No. 2.
Dear Secretary Burwell and Secretary Vilsack,
At the conclusion of the sixth meeting of the 2015 Dietary Guidelines Advisory Committee (DGAC), we write to express concern about the state of federal nutrition policy and its long history of failure in preventing the increase of chronic disease in America. The tone, tenor, and content of the DGAC’s public meetings to date suggest that the 2015 Dietary Guidelines for Americans (DGAs) will perpetuate the same ineffective federal nutrition guidance that has persisted for nearly four decades but has not achieved positive health outcomes for the American public.
We urge you to adhere to the initial Congressional mandate that the DGAs act as “nutritional and dietary information and guidelines for the general public” and are “based on the preponderance of the scientific and medical knowledge which is current at the time the report is prepared.”
Below we lay out specific objections to the DGAs:
• They have contributed to the increase of chronic diseases.
• They have not provided guidance compatible with adequate essential nutrition.
• They represent a narrow approach to food and nutrition inconsistent with the nation’s diverse cultures, ethnicities, and socioeconomic classes.
• They are based on weak and inconclusive scientific data.
• They have expanded their purpose to issues outside their original mandate.
As you prepare to consider the 2015 DGAC’s recommendations next year, we urge you to fulfill your duty to create the dietary foundation for good health for all Americans by focusing on adequate essential nutrition from whole, nourishing foods, rather than replicating guidance that is clearly failing.
The DGAs Have Contributed to the Rapid Rise of Chronic Disease in America
In 1977, dietary recommendations (called Dietary Goals) created by George McGovern’s Senate Select Committee advised that, in order to reduce risk of chronic disease, Americans should decrease their intake of saturated fat and cholesterol from animal products and increase their consumption of grains, cereal products, and vegetable oils. These Goals were institutionalized as the DGAs in 1980, and all DGAs since then have asserted this same guidance. During this time period, the prevalence of heart failure and stroke has increased dramatically. Rates of new cases of all cancers have risen. Most notably, rates of diabetes have tripled. In addition, although body weight is not itself a measure of health, rates of overweight and obesity have increased dramatically.
While some argue that Americans have not followed the DGAs, all available data show Americans have shifted their diets in the direction of the recommendations: consuming more grains, cereals, and vegetable oils, while consuming less saturated fat and cholesterol from whole foods such as meat, butter, eggs, and full-fat milk. Whether or not the public has followed all aspects of the DGAC’s guidance does not absolve the U.S. Departments of Agriculture (USDA) and Health and Human Services (DHHS) from ensuring that the dietary guidance provided to Americans first and foremost does no harm.
The DGAs Fail to Provide Guidance Compatible with Essential Nutrition Needs
The 1977 Dietary Goals marked a radical shift in federal dietary guidance. Before then, federal dietary recommendations focused on foods Americans were encouraged to eat in order to acquire adequate nutrition; the DGAs focus on specific food components to limit or avoid in order to prevent chronic disease. The DGAs have not only failed to prevent chronic disease, but in some cases, they have also failed to provide basic guidance consistent with nutritionally adequate diets.
Maillot, Monsivais, and Drewnowski (2013) showed that the 2010 DGAs for sodium were incompatible with potassium guidelines and with nutritionally adequate diets in general.
Choline was recognized as an essential nutrient in 1998, after the DGAs were first created. It is crucial for healthy prenatal brain development. Current choline intakes are far below adequate levels, and choline deficiency is thought to contribute to liver disease, atherosclerosis, and neurological disorders. Eggs and meat, two foods restricted by current DGAC recommendations, are important sources of choline. Guidance that limits their consumption thus restricts intake of adequate choline.
In young children, the reduced fat diet recommended by the DGAC has also been linked to lower intakes of a number of important essential nutrients, including calcium, zinc, and iron.
Following USDA and DHHS guidance should not put the most vulnerable members of the population at risk for nutritional inadequacy. DGAC recommendations should be emphasizing whole foods that provide essential nutrition, rather than employing a reductionist approach based on single food components to exclude these foods from the diet.
The DGAC’s Narrow Approach to Food and Health Is Inappropriate for a Diverse Population
McGovern’s 1977 recommendations were based on research and food patterns from middle class Caucasian American populations. Since then, diversity in America has increased, while the DGAs have remained unchanged. DGAC recommendations based on majority-white, high socioeconomic status datasets have been especially inappropriate for minority and low-income populations. When following DGAC recommendations, African American adults gain more weight than their Caucasian counterparts, and low-income individuals have increased rates of diabetes, hypertension, and high cholesterol. Long-standing differences in environmental, genetic, and metabolic characteristics may mean recommendations that are merely ineffective in preventing chronic disease in white, middle class Americans are downright detrimental to the long-term health of black and low-income Americans.
The DGAC plant-based diet not only ignores human biological diversity, it ignores the diversity of American foodways. DGAC guidance rejects foods that are part of the cultural heritage of many Americans and indicates that traditional foods long considered to be important to a nourishing diet should be modified, restricted, or eliminated altogether: ghee (clarified butter) for Indian Americans; chorizo and eggs for Latino Americans; greens with fatback for Southern and African Americans; liver pâtés for Jewish and Eastern European Americans.
Furthermore, recommendations to prevent chronic disease that focus solely on plant-based diets is a blatant misuse of public health authority that has stymied efforts of researchers, academics, healthcare professionals, and insurance companies to pursue other dietary approaches adapted to specific individuals and diverse populations, specifically, the treatment of diabetes with reduced-carbohydrate diets that do not restrict saturated fat. In contradiction of federal law, the DGAs have had the effect of limiting the scope of medical nutrition research sponsored by the federal government to protocols in line with DGAC guidance.
The DGAs Are Not Based on the Preponderance of Current Scientific and Medical Knowledge
The science behind the current DGAC recommendations is untested and inconsistent. Scientific disagreements over the weakness of the evidence used to create the 1977 Dietary Goals have never been settled. Recent published accounts have raised questions about whether the scientific process has been undermined by politics, bias, institutional inertia, and the influence of interested industries.
Significant scientific controversy continues to surround specific recommendations that:
1. Dietary saturated fat increases the risk of heart disease: Two recent meta-analyses concluded there is no strong scientific support for dietary recommendations that restrict saturated fat. Studies cited by the 2010 DGAC Report demonstrate that in some populations, lowering dietary saturated fat actually worsens some biomarkers related to heart disease.
2. Dietary cholesterol increases the risk of heart disease: Due to a lack of evidence, nearly all other Western nations have dropped their limits on dietary cholesterol. In 2013, a joint panel of the American Heart Association and the American College of Cardiology did the same.
3. Polyunsaturated vegetable oils reduce the risk of heart disease and should be consumed as the primary source of dietary fat: Recent research renews concerns raised in response to the 1977 Dietary Goals that diets high in the omega-6 fatty acids present in vegetable oils may actually increase risk of chronic disease or death.
4. A diet high in carbohydrate, including whole grains, reduces risk of chronic disease: Clinical trials have demonstrated that diets with lower carbohydrate content improve risk factors related to heart disease and diabetes. Janet King, chair of the 2005 DGAC, has stated that “evidence has begun to accumulate suggesting that a lower intake of carbohydrate may be better for cardiovascular health.”
5. A low-sodium diet reduces risk of chronic disease: A 2013 Institute of Medicine report concludes there is insufficient evidence to recommend reducing sodium intake to the very low levels set by the DGAC for African-Americans of any age and adults over 50.
In all of these cases, contradictory evidence has been ignored in favor of maintaining outdated recommendations that have failed to prevent chronic disease.
More generally, “intervention studies, where diets following the Dietary Guidelines are fed long-term to human volunteers, do not exist,” and food patterns recommended by the DGAC “have not been specifically tested for health benefits.” The observational research being used for much of the current DGAC activities may suggest possible associations between diet and disease, but such hypotheses must then be evaluated through rigorous testing. Applying premature findings to public health policy without adequate testing may have resulted in unintended negative health consequences for many Americans.…