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Dietary Guidelines for Americans, 2015

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Anonymous Comment ID #800


Committee should address the valid concern about the wide distribution of (GMO) roundup ready soy and corn in the food supply. The pesticide residue has been detected in cord blood meaning that the potential harm from herbicide and insecticide exposure begins at birth. The 2015 US Dietary Guidelines need to provide valid and reliable information on this health concern. The funding of studies on this cannot come from Monsanto as it has in the past. Labeling of GMO ingredients in food products is the very least the public can make use of in selecting the foods they consume.

Affiliation: Individual/Professional Organization:
  • Food Safety

Edward Groth PhD Comment ID #799


October 29, 2014

TO: Dietary Guidelines Advisory Committee
FROM: Edward Groth III, PhD
RE: Thoughts About Seafood Consumption Advice

Dear DGAC:

Early this year, I and a dozen co-signers submitted a review and analysis of epidemiological evidence on issues of seafood consumption, methylmercury exposure, and the associated health benefits and risks. Included in our submission as attachments were 34 published studies. Last week, I submitted three additional studies. I hope the Committee has found that literature useful as it deliberates on how to update dietary guidance for Americans on this crucial food group.

Today, I am submitting my thoughts, as an individual with long experience analyzing and communicating about these issues, on what scientifically sound, helpful seafood consumption advice might look like. I will include a biosketch in my attached materials, but in brief, I specialize in environmental health, food safety and the interactions between science and values in policymaking. I worked at Consumers Union for 25 years (I retired a decade ago), where my role was analyzing risk/benefit issues, explaining those issues to the editors of CONSUMER REPORTS, and often, communicating directly with policymakers and consumers about such topics.

I have worked, usually with teams of colleagues, to craft scientifically sound, helpful advice on fish consumption—in particular, advice to manage the risks associated with methylmercury exposure—for about 35 years. Without question, this is one of the most difficult “risk communication” tasks I have ever been involved in. Not only are both benefits and risks associated with fish consumption, but the benefits and risks of different seafood choices vary enormously; i.e., one cannot advise about “fish” generically when, for example, salmon and tuna have very different benefit/risk profiles. In order to be useful, advice must delve into details, and draw meaningful distinctions. This complexity challenges both those offering advice and those trying to use it.

Nevertheless, the public health community collectively has an enormous amount of experience now both with iteratively trying to improve seafood consumption advice, and with communicating with the public about it. A lot is known today about what kinds of advice are needed to protect public health, and what works well and not so well in getting messages across.

The 2015 Dietary Guidelines for Americans present a wonderful opportunity to take seafood consumption advice to the next level: That is, to use the best available emerging science, and the experience of the past decade or so in communicating such advice, to make this next iteration the best it can possibly be. With your indulgence, I will now share my ideas on how to do that.

Also attached here, one more relevant recent study, which is discussed in the attached Word document.

Thank you,

Edward Groth III, PhD

Affiliation: Individual/Professional Organization: Retired
  • Food Safety
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)

Anonymous Comment ID #798


Food will always be personal thing. No amount of science can quantify a perfect diet for everyone. A diet cannot be pigeonholed into one idea. A wide variety of fresh and wholesome food available locally constitutes a healthy food matrix from the ground up. The food pyramid that the government designs should only be a reference based on sound reasoning taking into consideration the adverse health and environmental impacts of processed food. The more we can attune to balance with nature..the sooner we can return to a cleaner world and healthier diets.

Affiliation: Individual/Professional Organization: Ms.
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)

Anonymous Comment ID #797


See attached document.

Affiliation: Other Organization: National Consumers League
  • Food Safety

Anonymous Comment ID #796


Further emphasize that eating lower on the food chain can be a healthy diet-- we don't need to all be vegan, but getting Americans to feel more comfortable with flexitarian diets is key to the future of food.

Affiliation: Individual/Professional Organization: Stanford University
  • Food Groups (Fruits, Vegetables, Grains, Dairy, Protein Foods)

Anonymous Comment ID #795


Given the complexity in our food supply, defining superiority in food selection is an impossible task, and a risky one. Particularly in these stressful economic times, endorsing one food or dietary philosophy over another can be tantamount to telling parents they are giving their children inferior food. Instead of letting yourselves be bogged down by micro-managing food selection, think in broader and more inclusive terms. Support positive eating attitudes and behaviors as defined by the Satter Eating Competence Model (ecSatter).
According to research published in the Fall 2007 supplement to the Journal of Nutrition Education and Behavior, the ecSatter is being positive, comfortable and flexible with eating as well as matter-of-fact and reliable about getting enough to eat of enjoyable and nourishing food. ecSatter is predicated on the utility and effectiveness of biopsychosocial processes: hunger and the drive to survive, appetite and the need for pleasure, the social reward of sharing food, and the biological propensity to maintain preferred and stable body weight.
According to the original research and over 20 studies conducted since then, adults who score high on the Satter Eating Competence Inventory (ecSI) have nutritionally superior diets, weights that tend toward the average, and better health indicators: Activity, sleep, biological parameters.
To support eating competence, go back to supporting nutritional adequacy, and leave medical nutrition therapy to the clinical dietitians. Give basic information, then trust consumers, and the process, to bring themselves along.

Affiliation: Individual/Professional Organization: Ellyn Satter Associates
  • Behavior

Eric Goplerud Ph.D. Comment ID #794


In 2007, I led an interdisciplinary team of health services researchers, physicians, government leaders to successfully convince the American Medical Association that screening primary care patients for risky alcohol use and providing brief interventions is a medical procedure warranting separate medical procedure codes, the Common Procedure and Terminology (CPT) codes. We presented evidence that alcohol misuse is the third leading preventable cause of death in the United States. In 2001, this illness was associated with 75,000 deaths and 2.3 million years of potential life lost (30 years per premature death) (Stahre et al, 2004). Among adults in the United States, approximately 30 percent of current drinkers exceed recommended daily or weekly limits; and more than 90 percent of these excessive drinkers binge drink (Naimi et al, 2003). Among those who drink excessively, approximately 15 percent meet criteria for alcohol abuse. Approximately 10 percent of those who drink excessively are alcohol dependent (Dawson et al, 2005). Other types of alcohol misuse include any alcohol consumption among high-risk populations (e.g., pregnant women, youth) and drinking in association with certain activities (e.g., driving a motor vehicle, operating heavy equipment).
Alcohol misuse, measured as more than one drink per day for women and two drinks per day for men, and only by adults of legal drinking age, is linked to increased risk for unintentional injuries (e.g., motor vehicle crashes and falls), violence (e.g., homicide and suicide), liver disease, diseases of the central nervous system (e.g., stoke and dementia), hypertension and various cancers (e.g., breast, head and neck, stomach, colon and liver). Alcohol misuse is also associated with a variety of adverse reproductive health outcomes including unintended pregnancy, sexual assault, sexually transmitted infections (STIs), fetal alcohol spectrum disorders including fetal alcohol syndrome, low birth weight and sudden infant death syndrome. Finally, alcohol misuse often coexists with mental health problems and/or other substance abuse (NIAAA, 2000; Corrao et al, 2004; Thun et al, 1997; Naimi et al, 2003; Gladstone et al, 1996; Iyasu et al, 2002). We felt it critical that a standard drink be defined, equating distilled spirits, wine and beer.

In the years since that time, we have made great strides nationally introducing screening and brief intervention into routine medical care. The standard, internationally normed screening instruments such as the AUDIT and ASSIST specify the 2 drinks for men, 1 drink for women and equivalence between alcohol content of beer, wine and distilled spirits.

It is essential that these descriptions of moderate drinking and unhealthy drinking by maintained, and that the equivalence of a standard drinkg in the Dietary Guidelines be very clearly specified.

Affiliation: Individual/Professional Organization: George Washington University
  • Alcoholic Beverages

Anonymous Comment ID #793


October 24, 2014

FR Docket # 2014-02939

Dietary Guidelines Advisory Committee,

The Juice Products Association (JPA) would like to submit the attached comments on 100% fruit juice for your review and consideration. We reviewed comments and slides presented by Subcommittee 1 and the Added Sugars Working Group during Meeting #5 and though we recognize the value of the information presented, we noticed two points related to fruit and vegetable juice that need to be addressed:

1. Fruit Juice Concentrate which is Reconstituted to Single-Strength Fruit Juice Should Not Be Considered An “Added Sugar”
2. Fruit Juice Is An Important Part of A Quality Diet

The attached comments specifically address these two points.

JPA is a trade association whose international membership consists of major processors, growers, packers, brokers and distributors of a wide variety of 100% fruit and vegetable juices, juice beverages, drinks, jams, jellies, fruit spreads and other fruit products.

JPA would like to thank you for your consideration in this matter.


Diane Welland M.S., R.D.
Nutrition Communication Manager
Juice Products Association
Washington, DC

Affiliation: Industry/Industry Association Organization: Juice Products Association
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)
  • Water & Beverages (Non-alcoholic)

Anonymous Comment ID #792


On behalf of the Life Sciences Research Organization (LSRO), thank you for the opportunity to submit comments to the 2015 Dietary Guidelines Advisory Committee (DGAC).

I am submitting for the committee’s consideration the LSRO report chronicling our recently conducted independent review of the literature to evaluate the relationship between meals prepared away from home and the prevalence of childhood and adolescent obesity. This report was conducted in conjunction with an expert advisory committee which provided scientific oversight and direction for all aspects of this project.

Eighty-five observational and two interventional studies were included in the review from the 2798 studies identified in the literature search. MPAH prepared at schools were evaluated separately from those prepared at commercial food establishments (CFE) and studies from western countries evaluated separately from non-western countries. The analysis included evaluation of the impact of study design, study publication year, study publication year for U.S. studies only, study population size, study quality (internal validity, external validity, neither, or both), age of study participants (children, adolescents, or both children and adolescents), reporter of weight, measure of exposure, measure of body weight, study quality combined with indexed measures of body weight, type of school meal, and U.S. school meals,. For CFE studies, the type of CFE that was the source of the MPAH was also analyzed.

The two published intervention studies reported no association between MPAH and body weight. While there were more direct associations than inverse associations for the relationship between MPAH and body weight, more than 50% of the reported associations did not attain statistical significance. Even when observational studies were limited to higher quality studies on U.S. populations, the proportion of non-significant results continued to predominate. This was also the case when the data were analyzed on the basis of study size and other factors. These results casts doubt that methodological considerations are the major cause of the high proportion of non-significant findings, and if there is a direct relationship between MPAH and increased weight in children and adolescents, the relationship is a weak one at best. Thus, no firm conclusions can be drawn regarding the relationship between MPAH and weight in children and adolescents from this analysis. A meta-analysis of these studies addressing the methodological considerations and low statistical power of some studies might provide greater clarity to these discrepant results and allow more definitive conclusions.

This study was sponsored by the McDonald’s Corporation; LSRO retained full control over the appointment of the expert advisory committee and all aspects of data selection, collection, analysis, summary, and conclusions.

Thank you again for allowing me the opportunity to submit comments. I look forward to publication of the 2015 Dietary Guidelines for Americans.

LSRO is a non-profit organization providing expert, objective scientific opinions and evaluations to governmental agencies and leading corporations in food, health and bioscience sectors. As a non-profit organization, LSRO provides independent, science-based analysis and advice to help inform the development of policies and regulations, including the original GRAS reviews for the U.S. Food and Drug Administration. We commend the efforts undertaken by the Department of Agriculture, the Department of Health and Human Services, and members of the DGAC to conduct an evidence-based review and update the current Guidelines.

Affiliation: Individual/Professional Organization: LSRO
  • Energy Balance (Weight Loss, Weight Maintenance, Calorie Intake, Physical Activity)
  • Food Environment

Anonymous Comment ID #791


Hi, thank you for your work. Please be objective when deciding recommendations on sodium. I am still learning myself, but I question the roll of sodium on risk of death. Is it possible we might be going the wrong direction focusing on sodium reduction?

Affiliation: Individual/Professional Organization:
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)
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