August 3, 2010
by L. Joshua Sosland
In comments submitted in response to the Dietary Guidelines Advisory Committee report, several leading food industry groups expressed strong concerns about various recommendations made in the report. A diverse collection of groups ranging from the Salt Institute and The Sugar Association to the Organic Trade Association delivered stinging criticisms of the D.G.A.C. report. Groups representing the meat and grain-based foods industries expressed serious concerns about aspects of the report but also found large parts of the report to support.
The comments were submitted in response to a June 15 Federal Register notice soliciting feedback about the report. The U.S. Department of Agriculture and the Department of Health and Human Services will use the report and the comments to finalize the Dietary Guidelines for Americans 2010, set to be published toward the end of the year. In addition to written comments, oral comments were presented in Washington July 8 by several groups.
Not surprisingly, criticisms tended to be most strident from groups representing foods the report suggested are over-consumed by the public. Still, the comments and the criticisms were varied, and suggestions tended to be considerably more nuanced than each group simply arguing for sustained or increased intake.
Certain groups suggested that the committee, while claiming an unprecedented reliance on rigorous science in drafting the report, played loosely with science for some of the D.G.A.C.’s strongest recommendations.
Taking issue with SoFAS
Drawing particular ire from The Sugar Association was a subsection of the D.G.A.C. report dealing with energy from Solid Fats and Added Sugars (SoFAS) in the Nutrient Density section of the report.
“SoFAS contribute little or nothing to overall nutrient adequacy of the diet but add from 500 calories to 1,050 calories to total energy intake each day for many Americans,” the D.G.A.C. report said. “This is excessive.”
The Sugar Association objected to the observations and conclusions that intake of SoFAS be reduced sharply. The group objected to the very concept of SoFAS as the basis for dietary recommendations and challenged how data on intake of the macronutrients were gathered.
At a base level, the association made a point that was made by members of the guidelines committee when they acknowledged during the public meetings — sugar does not cause obesity.
“Every comprehensive review of the scientific literature concludes that, with the exception of dental caries, no causal link can be established between the intake of sugars and lifestyle diseases, including obesity,” the group said.
The association was highly critical of the report’s data for SoFAS intake, noting that rather than being based on surveys, the estimates were generated using “statistical modeling derived from one source provided by the National Cancer Institute.”
The group went on to note science does not support an inverse relationship between sugar intake and micronutrient intake because “sugars make many health foods palatable.”
Discussing the SoFAS concept, the group questioned the “scientific validity of lumping two distinct dietary components, added sugars and solid fats, with different biological impacts and health outcomes.”
In its conclusions, the association urged the committee to place emphasis on consumers reducing overall food and beverage intake. Such an emphasis would help consumers understand “their actual caloric needs and proper portions whether eating a salad, a hamburger or dessert.”
In its oral comments, the Salt Institute cast as radical, dangerous and counterproductive, the recommendation to reduce sodium intake to 1,500 mg.
“Available data confirm that there is no modern society that consumes so little salt, thus making the Dietary Guidelines recommendation a trial on more than 300 million Americans,” said Morton Satin, the group’s vice-president of science and research. “Population-wide interventions to reduce health risks can only work when there are no negative health consequences, which is clearly not the case with salt reduction.”
Urged by the Centers for Disease Control and Prevention, the Dietary Guidelines Advisory Committee suggested a reduction to 1,500 mg from 2,300 mg in the 2005 edition of the guidelines. Current average consumption is about 3,400 mg.
The Salt Institute said such a shift would result in confusion and unintended consequences.
“Reduced salt in food will fuel the obesity epidemic as individuals will consume more to satisfy their natural sodium appetite and their hunger for taste satisfaction,” the group said. “It will also lead to other serious unintended health risks.”
Elaborating on those risks, Mr. Satin cited peer-reviewed evidence that suggests the possibility of cognitive impairment, adverse infant neurodevelopment and increased attention deficits, and falls in the elderly, resulting from inadequate salt intake.
Mr. Satin characterized the proposal to slash sodium intake as reflective of activist ideology rather than sound science.
“The purpose of the 5-year review process is to objectively examine all the new evidence before making recommendations, yet, before the process began, key committee members openly stated the expected outcomes regarding salt, thereby compromising the process and making any final recommendations a foregone conclusion,” he said.
The Report of the Dietary Guidelines Advisory Committee addressed questions about organic food for the first time, but the report’s conclusions were not satisfactory to the Organic Trade Association, a group with 1,300 members across various parts of the supply chain from farming to retail.
“O.T.A. has grave concerns and strongly disputes the conclusions” reached in the report, the group said.
Of particular concern is a reference in Resource 3 of the report.
“Evidence suggests that it is premature to conclude that the nutritional value and purported health benefits of organic foods are better than those produced through conventional agricultural practices,” the D.G.A.C. report said.
The O.T.A. also objected to the report’s conclusion that, “Our current understanding of conventional and organically produced foods indicate that their nutritional value and contributions to human health are similar.”
The O.T.A. criticized the observation on two grounds. The O.T.A. challenged the report’s conclusion that organically grown fruits, vegetables and grains are no more nutrient dense than conventional counterparts.
More importantly, the group said the health benefits of organics extend beyond nutrient density.
“The conclusions of the draft Dietary Guidelines are in direct conflict with the advice put forth by the recent President’s Cancer Panel report regarding ways to reduce environmental cancer risk,” the O.T.A. said.
The group asked the conclusions likening the healthfulness of conventional and organic foods be rewritten or stricken from the 2010 guidelines.
Lost in translation
Objections from two principal protein groups, the American Meat Institute and the United Egg Producers, were more nuanced. Stating that Americans are not over consuming meat or eggs, the groups were anxious that language in the report not be construed as encouraging cutbacks in intake.
“Many consumers are under the mistaken impression that Americans over-eat meat, poultry and beans,” the A.M.I. said. “This is supported by the A.M.I.’s polling data from 2010 indicating consumers believe they need to cut back their consumption of meat and poultry products.”
Against that backdrop, the A.M.I. said it is “critically important” that the guidelines are worded in a way that does not lead to reduced consumption.
“In particular, language in the report recommending that Americans consume ‘only moderate’ amounts of meat and poultry may be perceived as advice to ‘reduce’ their consumption,’ the A.M.I. said.
The U.E.P. also was troubled by the “only moderate” comment, which extends to eggs, as well as meat and poultry.
“This statement is inherently confusing and not based on the scientific evidence presented by the D.G.A.C. in its discussion of nutrient density,” the egg producers said. “No one can quarrel with the concept of moderation whether for eggs or any other food. However, the somewhat pejorative modifier ‘only’ appears to imply that most Americans should consume less of these foods than they presently do.”
Noting that meat and poultry fit well into the committee’s recommendations toward foods that contain high quality protein and are excellent sources of micronutrients, the group expressed the hope the guidelines would be “based in sound science, not social policy opinion as outlined by the Total Diet and Translating and Integrating the Evidence chapters which fall outside the scope of the committee.”
Both the A.M.I. and the egg producers expressed concern about language in the report advising people to “shift food intake patterns to a more plant-based diet…”
While the groups agreed that that fruit and vegetable consumption needs to be higher, “the phrase ‘plant-based diet’ may cause many people to think the federal government is telling them to become vegetarians or vegans,” the U.E.P. said. “We urge U.S.D.A. and H.H.S. to find a phrase other than ‘plant-based foods’ to convey the importance of eating more fruits and
vegetables. We believe the potential of this phrase to confuse and even mislead makes it unhelpful as part of the Dietary Guidelines.”
Shifting from refined to enriched
Issues with terminology also were of great concern to a consortium of grain-based foods groups. The consortium, while supporting the D.G.A.C. report’s phrase “make half your grains whole” encouraged the committee to use the term “enriched” grains rather than “refined” grains for milled products such as white flour that are not whole grain products.
The group warned that use of the term “refined” would cause confusion.
“The term ‘enriched’ is more accurate than the term ‘refined’ or milled grains because approximately 95% of all refined/milled grains are enriched with niacin, thiamine, riboflavin and iron in equal amounts found in whole grains and folic acid is fortified in twice the amount found in whole grain products,” the group said. The group noted the Food and Drug Administration’s Standards of Identity used the term enriched when these nutrients have been added.
The group also voiced its opposition to the committee’s “blanket recommendation to limit ‘refined’ carbohydrates,” which the industry groups said placed flour in a combination with added sugars and fats.
“The recommendation unjustly conflates enriched flour with added fat and sugar,” the group said. “(This recommendation could be likened to telling consumers to consume fewer almonds merely because they are a popular ingredient in chocolate bars.)”