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2015 Dietary Guidelines Should Be Based on Sound Science

October 6, 2015

By William Tatum, Director, Health and Nutrition Policy, Federal Affairs

One of the main principles of the Grocery Manufacturers Association (GMA) is that public policies must be based on sound science, and that’s why our organization is so interested in a House hearing Wednesday on the recommendations of the 2015 Dietary Guidelines Advisory Committee (DGAC).

The House Agriculture Committee hearing will review the process for developing the 2015 Dietary Guidelines for Americans (DGA) with U.S. Department of Agriculture (USDA) Secretary Tom Vilsack and U.S. Health and Human Services (HHS) Secretary Sylvia Burwell.

Here’s why this is important: The dietary guidelines, which are published every five years, play a critical role by serving as the scientific basis for federal nutrition policy development and are used by consumers, industry, nutrition educators, and health professionals. In light of their importance to all Americans and because they form the foundation for national nutrition policy, the guidelines should be based on sound nutritional science.

But GMA is concerned that wasn’t the case with some of the recommendations of the 2015 DGAC – a 14-member key advisory committee that provided the report that will be used by the USDA and HHS as the basis for policy recommendations for the DGA.

We believe that the 2015 DGAC overstepped the boundaries outlined in the National Nutrition Monitoring and Related Research Act of 1990. The advisory committee instead provided subjective policy recommendations on issues such as front-of-pack labeling, ingredient safety, food marketing, and federal feeding programs such as the Supplemental Nutrition Assistance Program – each of which is positioned well outside the statutory scope and beyond the collective expertise of advisory committee members.

Another concern is that while the advisory committee was expected to use the Nutrition Evidence Library (NEL) to support its systematic review of the current science on nutrition and health, it in fact only used this science resource for only 27 percent of its review. Instead, the advisory committee relied heavily on existing reports and meta-analyses as well as epidemiological and ecological modeling to answer research questions.  In the past, DGAC recommendations have been based on randomized clinical trial evidence as well as epidemiological and observational data to provide added support for policy recommendations.

Due to the highly controversial nature of the 2015 advisory committee recommendations, USDA and HHS received more than 29,000 comments on the DGAC report, compared to only 1,200 in 2010 – an increase by more than 1,350 percent.

Members of the House and Senate have sent numerous letters to USDA and HHS raising concerns and seeking clarification about the DGAC report, which was released in February 2015.

The final policy document is expected to be released by the end of the year by USDA and HHS.  GMA is concerned that recommendations based on insufficient science may reduce the credibility of the DGA’s and may discourage public action to follow the guidelines.  And in the end, what good are the government’s dietary guidelines if they aren’t practical, achievable and affordable?


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