In comments submitted to the docket before the March 30 deadline, for example, the American Beverage Association urged The Departments of Agriculture (USDA) and Health and Human Services (HHS) to ignore issues that are “not pertinent to a discussion of science-based nutrition advice,” while the Food Law and Policy Clinic of Harvard Law School wants the government to consider questions such as:
“What is the relationship between specific dietary patterns and environmental sustainability? How can a person achieve nutrient and food group recommendations while consuming a sustainable diet?”
Here is just a small selection of comments from some key stakeholders in the debate:
The American Beverage Association: Focus on nutrition, not nutrition policy
“The agencies should ensure the guidelines stay true to their charter and take care not venture into areas and issues that fall outside the guidelines’ intended scope and that are not pertinent to a discussion of science-based nutrition advice. Such ‘out-of-scope’ issues include, for example: policy recommendations on sustainability, social policies such as marketing restrictions and taxation, ingredient safety, and the setting of dietary reference intakes (DRIs) for nutrients.”
Food Law and Policy Clinic of Harvard Law School: Encourage whole fruit, not juice; probe meat and disease risk
“The 2020 DGA should consider the important distinction between whole fruit and 100% juice, examine current evidence on the different health outcomes associated with these food forms, and incorporate this information into the recommendations on how children should meet daily recommendations for fruit.
“[The DGAC should ask] What is the relationship between sugar-sweetened beverage consumption during adulthood and 1) body weight or obesity; 2) risk of cardiovascular disease; 3) risk of type 2 diabetes and metabolic disease; and 4) risk of tooth decay?
"What is the relationship between red and processed meat consumption and 1) risk of cardiovascular disease; 2) risk of cancer; 3) body weight and obesity; and 4) type 2 diabetes?”
The Nutrition Coalition (TNC): Low carb diets should be one of USDA's dietary patterns
"On the subject of the low-carb diet, TNC believes that this diet is supported by a large body of scientific evidence and should be included as one of the USDA's Dietary Patterns...The cumulative evidence shows that low-carb diets are safe and effective for combating obesity, highly promising for the treatment of Type 2 diabetes, and they improve most cardiovascular risk factors."
Animal Legal Defense Fund: Animal protein and dairy are not essential components of a healthy diet
"USDA and HHS should develop a Healthy Vegan Pattern separate from a Healthy Vegetarian Pattern. Vegetarian and vegan diets are not equivalent and should not be treated as such.
"USDA/HHS should further ensure that information about plant-based options and meal planning is readily available to the public on the health.gov website and other Dietary Guidelines educational materials. Merely recognizing the benefits of vegan and plant-forward diets is insufficient without educational outreach and suggestions for ways to transition to plant-based alternatives.
"MyPlate should accurately reflect scientific findings and provide clear guidance on the healthiest dietary choices. The current MyPlate misleadingly represents that animal protein and dairy are essential components of a healthy diet."
National Milk Producers Federation: Look again at saturated fat
“The emerging science which calls into question the received wisdom on saturated fat should be examined objectively and thoroughly. While the response of the nutrition establishment has been generally dismissive, this is a legitimate topic where it is not clear that the past demonization of saturated fat has been justified.
“The new science suggests that longstanding advice to consume low-fat and fat-free dairy may be unnecessarily restrictive and, if overall caloric intake remains appropriate, there is room for including whole milk and other full-fat dairy foods in the diet."
United States Cattleman’s Association: Focus on nutrition
“USCA requests that the dietary guidelines remain within the scope of nutrition and diet, and reflect that red meat is an essential part of a healthy whole food diet, as stated in previous and recent research.”
Plant Based Foods Association: Spell out what a healthy plant-based diet looks like
“The current guidelines already support the need for increased consumption of plant-based foods. To help Americans make healthier food and beverage choices, we suggest drafting an additional appendix focused on a vegan/plant-based pattern to include plant-based meat and dairy alternatives to fit into a Healthy U.S.-Style Pattern. This will encourage the public to choose from a variety of healthier food and beverage choices that can be used throughout the lifespan.
“The Dietary Guidelines provide critical health and nutrition information and advice. Unfortunately, that advice is not adequately supported by policies that ensure availability of fresh fruits, vegetables and other healthy, plant-based options… We propose … exploring questions such as: What are effective behavioral, food environment, and policy interventions that can encourage and support increased consumption of plant-based foods such as fruits, vegetables, plant-based meat and dairy alternatives, whole grains, nuts, and seeds as part of a healthy diet?”
Animal Welfare Institute: Place more emphasis on plant-based foods for health
“We strongly recommend a greater emphasis on plant-based foods for disease prevention and better overall health.”
The Grain Chain: Look at total sugars, not added sugars
“While several of the proposed 2020 DGA review topics and questions focus on added sugar's impact on the health impact for various life stages, The Grain Chain believes a more appropriate approach, based on existing scientific evidence, would be to review total sugars with consideration of carbohydrate and overall dietary quality as related to the overall dietary pattern.”
The Juice Products Association: Juice is misunderstood
“There is a considerable amount of confusion around 100% juice and its role in health and the diet…. More than 90% of Americans are not consuming enough fruits and vegetables. Research shows that intake of 100% juice as part of a healthy diet can have a significantly positive impact on total fruit and fruit food group consumption”
Peanut Institute: Peanuts are protein foods!
“There is an opportunity for more clarification of the different foods included in the protein group to benefit the public’s understanding of why one might choose vegetarian sources of protein instead of or in addition to animal sources…. If MyPlate explicitly named or depicted items that did qualify [as proteins] it would likely increase awareness that many non-meat products such as peanuts fall into the protein group.”
Atkins Nutritionals: Add low carb-guidance to the guidelines
“Lower carbohydrate guidance must be included into the recommendations as an option for those with metabolic syndrome and insulin resistance. Today there are more than 80 published, peer-reviewed clinical studies, including many well-designed NIH-funded studies, demonstrating the safety and efficacy of a lower carbohydrate eating pattern.”
Read all of the comments in the docket HERE.