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The Humane Society of the United States (HSUS) Sustainability Comments for the 2015 Dietary Guidelines The U.S. Department of Health and Human Services 2015 Dietary Guidelines have the potential to positively influence health outcomes for millions of Americans. Incorporating sustainability into the Guidelines presents an additional opportunity to educate, reach more people, and to effectively address multiple issues simultaneously, including public health and good stewardship of our nation’s agricultural resources. This is also reflective in the fact that such issues do not exist in a vacuum—how we choose to approach each pressing issue can have serious consequences for the other. Thus, we are very appreciative of the Dietary Guidelines Advisory Committee (DGAC) for exploring ways to incorporate sustainability into the 2015 Dietary Guidelines (Request 5-2). As is increasingly evident, we can and should address both health and sustainability issues simultaneously. Climate Change and The EnvironmentA reduction of animal product intake may be the most important recommendation that can be made. The Food and Agriculture Organization of the United Nations (FAO) has said that animal agriculture sector is “one of the top two or three most significant contributors to the most serious environmental problems, at every scale from local to global.” Indeed, raising enormous numbers of land animals for food inefficiently consumes natural resources, contributes to deforestation, and produces immense quantities of animal waste, threatening water and air quality. Further, farm animal production alone accounts for 14.5% of the world’s greenhouse gas emissions (GHG). Even assuming efficient sectoral growth, by 2050 emissions from animal production is predicted to grow 39% over year-2000 levels and to account for 70% of the sustainable level of global GHG emissions. A shift toward more plant-based diets will reduce GHG emissions. , , , , Dietary changes towards less meat-heavy diets have also been increasingly shown to be essential to meeting global climate change mitigation goals, as well as to reduce other negative environmental impacts. , , And recent studies indicate that decreases in animal source food consumption can reduce emissions from the farm animal sector more than supply-side solutions. Non-climate-related improvements include water pollution and water use. According to the FAO, “The livestock sector…is probably the largest sectoral source of water pollution, contributing to eutrophication, ‘dead’ zones in coastal areas, degradation of coral reefs, human health problems, emergence of antibiotic resistance and many others.” Industrial farm animal production (IFAP), in particular, is a key culprit in the degradation of water supplies. At IFAP facilities, where tens of thousands of animals are confined indoors, the amount of manure typically exceeds the ability of the surrounding land to absorb it. When this happens, it can contaminate water supplies and emit harmful gases into the atmosphere. Farm animals confined on IFAP facilities in the United States produce three times more waste (manure) than humans, and regulations relating to the treatment of farm animal manure are lax relative to the regulations mandating the treatment of human waste. According to the U.S. Department of Agriculture’s Economic Research Service, IFAP operations spread 1.23 million tons of nitrogen on fields (in the form of manure) in the United States in 2007; however, cropland and pasture owned by these operations only had the capacity to assimilate 38% of this nitrogen. Nitrogen deposition, largely from agriculture, is expected to increase significantly in the coming years, with the resulting nitrogen oxide and ammonia leading to eutrophication and soil acidification. In terms of water use, raising animals for food requires substantially greater quantities of water than raising plants for human consumption. According to the International Water Management Institute and the Stockholm International Water Institute, an average of 6000 liters of water is required to produce 1 kg (2.2 lbs) of chicken, whereas less than half of that is needed to produce 1 kg (2.2 lbs) of cereals. This is particularly relevant to the United States, where recent drought has been extensive, for example with the 2012 drought hitting 80% of agricultural land and the current “exceptional” (meaning greater than “severe” or “extreme”) drought in California. For this and other environmental reasons, addressing sustainability by recommending a decrease in meat consumption in the 2015 Dietary Guidelines is crucial.Public HealthReductions in meat, egg, and milk consumption can simultaneously improve food security and public health. . .*SEE ATTACHMENT FOR FULL PUBLIC COMMENT*
Request 5-2 Food Systems SustainabilityThe Center for Biological Diversity is encouraged to see the USDA and HHS incorporating sustainability concerns into the 2015 Dietary Guidelines. As one of the world’s largest consumers of natural resources, the U.S. can no longer ignore the impact of our choices on the planet and wildlife, particularly when it comes to our diets. Livestock production is one of the most environmentally destructive industries on the planet, and any recommendation on a sustainable American diet must include a call for reduced meat and dairy consumption. We’ve included recent studies and additional information in the attached document to address the advisory committee’s special request on sustainable food systems.As the leading national source for nutritional guidance, the 2015 Dietary Guidelines plays a critical role in moving the U.S. toward a more sustainable food system. The Center for Biological Diversity urges the advisory committee to include reduced meat and dairy consumption in the 2015 Dietary Guidelines as a critical part of achieving a sustainable diet. With 37% of pesticides used in the U.S. going toward raising animals for food, reducing meat consumption is an important part of choosing organic foods. Reducing meat consumption is also an effective way to address food waste due to its inefficient conversion of crops into food. Due to the extreme amount of resources it takes to produce meat and dairy products, in addition to the livestock industry’s significant impact on climate change, pollution and wildlife extinction, the 2015 Dietary Guidelines will have little impact on the sustainability of the U.S. food system unless it strongly urges Americans to replace more meat and dairy with plant-based alternatives.
Please require inclusion of levels of residual pesticides and herbicides on food packaging. Perhaps they could also be listed as ingredients.
TOPIC: Encouraging the consumption of protein from plants can be an important way to improve the health and diet of Americans through increased accessibility of nutrition for consumers both safely and economically, in a sustainable manner while helping to feed the future population. For full comment details, please see attachment: KelloggCompanyPlantProteinCommentstoDGACThe Kellogg Company respectfully submits comments to the U.S. Department of Health and Human Services (DHHS) and the U.S. Department of Agriculture (USDA) for consideration by the Dietary Guidelines Advisory Committee (DGAC) and more specifically, Subcommittee 2 (SC2): Dietary Patterns, Foods and Nutrients, and Health Outcomes. At Kellogg Company, we are driven to enrich and delight the world through foods and brands that matter. We have a long history of developing and marketing great-tasting, nutritious products that fit within the Dietary Guidelines for Americans (DGA), offering brands that nourish families so they can flourish and thrive. We also recognize that health extends beyond the table to the environment in which we live, and we are committed to creating more sustainable practices to help serve the expanding population. We appreciate the opportunity to demonstrate how a variety of plant-based proteins can help consumers meet the U.S. Dietary Guidelines recommendations in a sustainable way. We recognize the importance of vegetarian diets, as did the Dietary Guidelines for Americans, 2010; however, with only 5% of Americans following a vegetarian diet, we ask the DGAC to consider a new way of presenting plant-based eating to consumers by recommending plant-based protein one or more times a week as a choice within mainstream eating patterns. This recommendation could lead to an increase in consumption of plant-based protein while still recognizing the role of animal protein consumption. Such a diet, now being called a flexitarian lifestyle, results in the ultimate goal of increasing vegetables, legumes, whole grains and key nutrients that are missing in the diet today. Our detailed comments provide research on the following areas: • Nutrition: Plant-based protein recommendations can help lead to a diet with more variety and balance by encouraging foods that fall short in today’s diet, such as grains, legumes, and vegetables. Sources of plant-based protein can provide key nutrients of concerns, including dietary fiber and potassium. Furthermore, consumption of a more plant-based diet has been associated with a healthy weight, reduced risk of certain chronic diseases and greater longevity.• Accessibility: Plant-based protein sources can be more accessible to consumers due to affordability, convenience of taking food on the go and ease of storage.• Sustainability: Plant-based protein sources can help feed our expanding population while utilizing resources in a way that helps protect the environment.• Grains: Grains are recognized by many organizations as a source of plant-based protein, including the Dietary Reference Intakes report on Protein ; however, they are often overlooked in dietary guidance.We believe obtaining protein from plant sources: 1) is an important way to improve the health and diet of Americans, 2) increases accessibility of nutrition for consumers both safely and economically, and 3) supports the health of the planet while helping feed the future global population predicted at 9 billion by 2050. • We encourage the DGAC to continue to recommend a shift towards a more plant-based diet by encouraging consumers to choose plant-based proteins more often. Plant-based proteins provide numerous health and nutrition benefits many Americans are currently lacking. o Suggested DG Key Recommendation: “Consume plant-based protein one or more times a week.”• We also recommend that the DGAC note the importance of grains as a plant-based protein option. In addition to protein, grains help consumers meet vitamin and mineral requirements, increase fiber consumption and gain access to important phytonutrients. o Suggested DG Key Recommendation and MyPlate Recommendation: “Vary your protein routine – choose beans, peas, nuts, seeds and grains one or more times a week.”Thank you for the opportunity to comment on recommendations for the Dietary Guidelines for Americans, 2015. As viewed on 8/28/14 at http://www.nal.usda.gov/fnic/DRI/DRI_Energy/589-768.pdf, page 691. As viewed on 9/18/14 at https://www.un.org/en/development/desa/news/population/un-report-world-population-projected-to-reach-9-6-billion-by-2050.html
These comments are submitted on behalf of the Egg Nutrition Center (ENC). Funded by the American Egg Board, ENC monitors scientific findings and regulatory developments for the U.S. egg industry, and serves as a resource for health practitioners in need of current nutrition information to share with their patients and clients.In its public sessions, the 2015 Dietary Guidelines Advisory Committee (DGAC) has discussed not only the scientific evidence behind potential dietary guidance, but also issues arising from the need to communicate this guidance to all Americans in ways that are easily understandable, inclusive and actionable. Communicating the 2015 DGA to consumers, health professionals and other audiences will involve the presentation of recommendations about particular food groups or categories of foods. These comments center around one such communication category, solid fats.Executive Summary• Although there are several definitions for solid fats provided in various editions of the Dietary Guidelines for Americans (DGA) and related documents, most of these definitions refer to solid fats as those that are usually solid at room temperature, and may also state that solid fats are high in saturated fats or comprise primarily saturated fats.• Eggs are considered a solid fat, although eggs are not solid at room temperature.• Solid fats are described as being high in saturated fats, although eggs have only 1.5 grams of saturated fat out of 5 grams of total fat, and the saturated fat in eggs constitutes only 8% of the Daily Value (DV) for saturated fat.• The 2010 DGA present the solid fats label as a means of communicating a message about excess calories, not a message about adverse health associations. One egg contains only 70 calories.• The methodology for converting various protein foods into ounce equivalents, in which an ounce equivalent of eggs is not 28.35 grams (the metric equivalent of one ounce) but rather 50 grams, makes eggs appear to have a greater amount of saturated fat per ounce equivalent than meat, whereas if the comparison were made on the basis of Reference Amounts Customarily Consumed (RACCs), eggs would appear substantially lower in saturated fat.• A definition of solid fats that utilizes either or both (1) solidity at room temperature and (2) high level of saturated fat, might exclude eggs depending on the exact meaning of the term “high,” which is not currently defined with precision.
I feel that that 2015 Dietary guidelines should specify what foods have different nutrients that are needed daily. The average American know that one can get potassium from a banana, however that is not the only food that gives a good source of potassium. A reference sheet that has little known fruits and vegetables would be a good addition.
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As a Undergraduate Human Nutrition and Foods student at West Virginia University, I believe that changes to the US Dietary Guidelines regarding sustainability are vital to the overall environmental impact of society. While working with Barbara Hartman, chief of Nutrition and Food Service at the Martinsburg, WV VAMC, I composed the attached public comment regarding sustainability. The comment is supported through peer reviewed research and documents produced by government agencies supporting sustainability within the US food system. Please review the attachment for my complete public comment. 1. Comments for elements of a whole food system:• Change this verbiage, to “Elements of sustainable, resilient, and healthy food and water systems.” • Already national and state food policies support access to sustainable, resilient, and healthy food and water systems, the U.S. Dietary Guidelines should also.2. Comments for specific food groups and commodities:• Increase consumption of whole, unprocessed foods by emphasizing the importance of cooking in the home.• Increase local and seasonal food procurement and consumption.• Procure and consume seafood that is sustainability raised or harvested.• Increase consumption of plant based protein.• Reduce household food waste by following the EPA food waste hierarchy.• Increase consumption of water from a tap (decreasing the use of bottled water).
With each generation we have become more accustomed to immediate gratification in many aspects of society, and, food certainly is part of this equation. Even for those of us with a general knowledge of healthy eating, it takes a greater understanding to really know how food affects the body. Although I certainly am guilty of turning a blind eye when I want to indulge, I have found that a greater awareness, i.e. calorie counting with a phone app has helped me to make better food choices and maintain a healthier lifestyle, while holding myself accountable for what I eat. I don't know that the advertisers would be too fond of it; however, it would be interesting if right on the food label there was something, besides the calories, to increase awareness, not just for the healthy foods; but, particularly for the unhealthy ones.
Dietary guidelines has numerous applications. Across the board, however, it should focus/direct consumers back to real, sustainable foods. That means making strong efforts to change the cultural norms of eating highly processed foods, and transitioning to real, whole foods. This in itself though involves multiple aspects; that is addressing it at the individual/consumer level, as well as at the agricultural/provider level. Such problems are highly complex and must be approached through an ecological perspective addressing it from numerous angles. Thus, we not only need to change the way we think about food, but we also need to structure local/national communities in such a way that supports this shift in thinking as well as providing the ability for sustainable food practices. Additionally, action is needed at the policy/government level to support these shifts as well. Current policies do not support sustainable, real food. Additionally, in order to support real, sustainable food, we have to reshape agricultural practice to not rely so heavily on chemicals, antibiotics, growth hormones, etc. Though some of these may have there place sparingly, they have become norms for agricultural practice. And research (with a healthy dose of common sense), shows that the increase of all these agents in our foods and various products has a strong correlation with our increase in various health problems, most of which are lifestyle related (nutrition, exercise, environmental exposure). Again, this needs to be addressed at the individual level to reshape norms/perspectives, and this must also be addressed at agricultural/provider level. Government policy is needed to expel these harmful/outdated methods of food production. By making these shifts to encourage, support, and educate the nation towards such an end would address a number of goals at once. Eating real, whole foods primarily that are sustainably grown/raised will help them consume more nutrient dense foods that are more proportional in their energy/nutrient make up, while avoiding many toxins; thus, addressing issues of food groups, eating-patterns, energy balance, carbohydrates, protein, fats, micronutrients, sustainability, food industry approaches, food environment, and behavior.
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Last updated: 10/1/2014