U.S. Department of Health and Human Services

Nutrition and Your Health:
Dietary Guidelines for Americans

U.S. Department of Agriculture
 
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select topic:Alcoholic Beverages    Carbohydrates    Discretionary Calories    Energy Balance/Weight Management     Fats    Fluids and Electrolytes    Food Groups    Food Safety    General/Overarching issues    Nutrient Intake    Physical Activity   

Number of Comments Found:272

Alcoholic Beverages
   General
Summary We think that the information provided to consumers on the alcohol content of various types of alcoholic beverages could be clearer, and suggest additional information to include.
Comments In general, we find that the science base section (D8) on ethanol is clearly written and provides consumers with easily accessible, scientifically valid information on the health effects of ethanol consumption. We suggest some relatively minor changes to the definition of a standard drink in order to provide consumers with the clearest possible information on the size of various alcoholic beverages and the relation to the amount of ethanol they contain. The current information in the proposed Guideline is: “One drink is defined as 12 oz of regular beer, 5 oz. of wine (12 percent alcohol), or 1.5 oz of 80-proof distilled spirits.” In our opinion, this definition would be clearer and more consistent if the percent alcohol were included with each type of beverage, and if the definition also stated that each of these standard drinks contains 0.6 fl oz of alcohol. In addition, the term “fl oz” (or fluid ounce) should be used. and the percent alcohol should be given for each type of beverage so that consumers of each understand that if they drink, for example, 60 proof distilled spirits, they will be consuming less than one standard drink. We suggest the following formulation: A standard drink, which contains 0.6 fluid ounces of alcohol, consists of: • 12 fluid ounces of regular beer (5 percent alcohol) • 5 fluid ounces of wine (12 percent alcohol) • 1.5 fluid ounces of 80-proof distilled spirits (40 percent alcohol). Thank you for the opportunity to comment on the proposed Guidelines. We hope that our suggestions will help improve communication with consumers. Sincerely, Ruth Kava, Ph.D., R.D. Director of Nutrition, ACSH Elizabeth M. Whelan, D.Sc., M.P.H. President, ACSH
Submission Date 9/22/2004 2:33:00 PM
Author American Council on Science and Health

Summary Recommend you revise the definition of "moderate" to the equivalent of 3 or 4 beers per week. This sends a much better signal to people on what is "healthy."
Comments By defining "moderation" as the equivalent of 2 beers per day, you are endorsing this quantity as acceptable. Inclusion of the words "or less" does not change this endorsement. Two beers a day may be what many Americans consume, but it is clear that the effects of this much alcohol for most people is just plain unhealthy.
Submission Date 9/23/2004 10:19:00 PM
Author from Canal Winchester, OH

Summary The Committee report states: One drink is defined as 12 oz of regular beer, 5 oz. of wine (12 percent alcohol), or 1.5 oz of 80-proof distilled spirits. It would be more useful to consumers if it included the information that defined each drink in terms of 0.6 fluid ounces of alcohol.
Comments Clearly written consumer guidance on ethanol, with a comprehendible and consistent definition of a standard drink will assist dietitians and other health professionals in giving guidance about moderate and responsible consumption of alcohol for those adults who choose to drink. Given the importance of the definition of a drink in giving guidance for following the ethanol guideline, I propose two recommendations to make this statement more clear. First, the addition of the percent alcohol for wine that was added in the 2005 draft is extremely helpful, but propose that the percent alcohol should be stated for each type of beverage. Second, an additional important piece of information is that each of these standard drinks contains 0.6 fl oz of alcohol. There is a wide variety of alcohol beverages that have different percents of alcohol. Knowing that a ˇ§standard drinkˇ¨ contains 0.6 fl oz of alcohol would allow the individual who consumes alcohol drinks to easily determine the amount of alcohol they are consuming so that they can follow the moderation guideline.
Submission Date 9/24/2004 4:05:00 PM
Author from boston, ma

Summary Standard drink definition should include amount of alcohol in each drink (0.6 fl ounces). Suggestion: 12 fl ounces of regular beer (5% alcohol); 5 fl ounces of wine (12% alcohol); 1.5 fl ounces of 80-proof distilled spirits (40% alcohol). Each standard drink contains 0.6 fl ounces of alcohol.
Comments September 24, 2004 Ms. Kathryn McMurry HHS Office of Disease Prevention and Health Promotion Office of Public Health and Science STE LL100 1101 Wootton Parkway Rockville, MD 20852 FR Docket No. 04-19563, Department of Health and Human Services, Announcement of the Availability of the Final Report of the Dietary Guidelines Advisory Committee, a Public Comment Period, and a Public Meeting Dear Ms. McMurry: Thank you for providing the opportunity to comment on the Advisory Committee’s draft report of the 2005 Dietary Guidelines for Americans. These Guidelines are an important tool for consumers and the dietitians and other health professionals who advise them. As a professor in the Department of Family Medicine in the Graduate School of Medicine at the University of Tennessee, and past-president of the American Dietetic Association, I would like to thank the Committee for its efforts to provide useful and clear guidance on alcohol consumption. In general, the alcohol guideline provides evidence based information that will be helpful to dietitians and all health professionals in providing guidance to their patients. In counseling with patients, I am often asked, “What does moderation mean?” and “How much is a drink?” To effectively explain moderation, I need to be able to clearly communicate the meaning of a standard drink. The current definition in the proposed guideline is helpful. However, a clearer and more complete definition would better assist the dietitian in communicating the guidance on moderate and responsible consumption as defined in the alcohol guideline to their adult patients who choose to drink. The proposed 2005 guideline defines a standard drink as: One drink is defined as 12 oz of regular beer, 5 oz. of wine (12 percent alcohol), or 1.5 oz of 80-proof distilled spirits. The addition in the current draft of the percent alcohol for a serving of wine is an excellent revision to past Guidelines. However, to make this definition more complete and consistent, information on percent of alcohol by volume for each type of alcohol beverage (beer, wine and distilled spirits) should be included. Additionally, in counseling patients, dietitians address the fact that the alcohol content in different types of alcohol drinks may vary. Thus, the drink definition should also include information on the amount of alcohol in each standard drink (0.6 fl ounces). This information will provide a benchmark for quantification and assist consumers to better determine the number of standard drinks they are consuming. The additional clarifications I have suggested, as illustrated below, will provide consumers with the necessary information to most easily follow the recommendations set forth in the alcohol guideline. A standard drink is defined as: • 12 fluid ounces of regular beer (5 percent alcohol) • 5 fluid ounces of wine (12 percent alcohol) • 1.5 fluid ounces of 80-proof distilled spirits (40 percent alcohol). Each standard drink contains 0.6 fl ounces of alcohol. Once again I appreciate the opportunity to comment on the proposed 2005 Dietary Guideline’s guideline on alcohol. As a dietitian, I am committed to providing accurate and meaningful information to my patients regarding their diet and lifestyle. I think the suggested revisions will provide useful information to all health professionals in communicating their messages to their patients. Sincerely, Jane White, PhD, RD, FADA Professor, Department of Family Medicine Graduate School of Medicine University of Tennessee – Knoxville Knoxville, TN
Submission Date 9/24/2004 6:00:00 PM
Author University of Tennessee – Knoxville

Summary While we support the majority of the findings in the Committee Report, we would like to provide additional comment in two important areas: • There should be no changes to the Drinking In Moderation Definition, especially with the “Count as a Drink” language regarding expressions of alcohol content f
Comments Wine Institute is the public policy association of California wineries representing over 800 California wineries and affiliated businesses. These companies are responsible for 80 percent of the nation’s wine production. On behalf or our members, we are pleased to submit comments in response to the request for public input on the 2005 Dietary Guidelines Advisory Committee Report to the Departments of Health and Human Services and Agriculture. We agree that the 2005 Dietary Guidelines for Americans should represent a balanced approach to recommendations on the full range of nutrition, lifestyle and health issues. In particular, we support the Ethanol Subcommittee’s continued recommended advice to discourage excessive consumption and indicate that, even in moderation, there are individuals who should not drink. We are pleased that the main alcohol message has been maintained from the 2000 Dietary Guidelines: “If you drink alcoholic beverages, do so in moderation” and that the Committee has maintained the recommendation (advice) that, “For those who choose to drink an alcoholic beverage, it is advisable to consume it with meals to slow absorption. Data suggest that the presence of food in the stomach can slow the absorption of alcohol and thereby mitigate the associated rise in blood alcohol concentration.” While we support the majority of the findings in the Committee Report, we would like to provide additional comment in two important areas: • There should be no changes to the Drinking In Moderation Definition, especially with the “Count as a Drink” language regarding expressions of alcohol content for wine, because there will be extensive rulemaking by the Treasury Department’s Tax and Trade Bureau (TTB) in 2005 that will address several significant issues that are based on the language of the Dietary Guidelines. Language in the Dietary Guidelines should not be misused or misconstrued in any future regulatory action or rulemaking. • Messages relating to moderate drinking and weight gain and obesity for the public should clearly state that the scientific findings in this area are inconclusive and that alcohol, as well as other sources of discretionary calories, should be monitored closely for optimal health. I. MODERATE DRINKING DEFINITION In the 2000 version of the Dietary Guidelines for Americans, drinking in moderation is defined in Box 26 on page 36 - What is Drinking in Moderation?: The Advice For Today on page 37 goes one step further and recommends “Limit intake to one drink per day for women and two per day for men, and take with meals to slow alcohol absorption.” The Advisory Committee found this definition of moderate drinking as optimal for adults who choose to drink as a means to provide both beneficial effects on heart disease and allcause mortality as well as reduce risks caused by heavy drinking. However, the Advisory Committee also states that, “The definition of moderation, including the size of one drink, requires emphasis. (Some investigators and apparently many individuals interpret ‘moderate drinking’ to cover higher levels of intake than shown in Table E-25. Many mixed drinks actually provide several servings of alcohol per drink.” (DG Advisory Committee Report, Part D, Section 8, page 3). In an apparent response to further define a moderate serving of each beverage, the Advisory Committee has added a “12 percent alcohol” qualifier to the definition of a serving of wine. Throughout the text of the Advisory Committee Report, one serving of wine is defined as “a 5-ounce glass of 12 percent alcohol.” (See Table E-25, below). Wine Institute believes that providing the public a frame of reference by including serving size information in ounces will assist wine, beer, and distilled spirits consumers in their awareness of alcohol consumption levels. We believe that direct serving size information in ounces about the product being consumed is relevant and, if truthful, accurate and specific, should be able to be included. However, within each category of drinks (wine, beer and distilled spirits) there is a range of products with different alcohol percent values. Unlike distilled spirits, wine is not a “mixed” drink. Consumers discriminate among the various wine products more by their broad product categories, and producers of wine do not target a particular alcohol level but a sensory style and taste. Even from a regulatory standpoint, the standards of identity for wine differ significantly from distilled spirits product standards. Table wine, for example, is defined as still wine between 7 and 14 percent alcohol by volume.1 While from a scientific or clinical standpoint it may make 1 27 USC 5041 states, in part, as follows: (a) Imposition There is hereby imposed on all wines (including imitation, substandard, or artificial wine, and compounds sold as wine) having not in excess of 24 percent of alcohol by volume, in bond in, produced in, or imported into, the United States, taxes at the rates shown in subsection (b), such taxes to be determined as of the time of removal for consumption or sale. All wines containing more than 24 percent of alcohol by volume shall be classed as distilled spirits and taxed accordingly. Still wines shall include those wines containing not more than 0.392 gram of carbon dioxide per hundred milliliters of wine; except that the Secretary may by regulations prescribe such tolerances to this maximum limitation as may be reasonably necessary in good commercial practice. (b) Rates of tax (1) On still wines containing not more than 14 percent of alcohol by volume, $1.07 per wine gallon; (2) On still wines containing more than 14 percent and not exceeding 21 percent of alcohol by volume, $1.57 per wine gallon; (3) On still wines containing more than 21 percent and not exceeding 24 percent of alcohol by volume, $3.15 per wine gallon; (4) On champagne and other sparkling wines, $3.40 per wine gallon; (5) On artificially carbonated wines, $3.30 per wine gallon; and (6) On hard cider which is a still wine derived primarily from apples or apple concentrate and water, containing no other fruit product, and containing at least one-half of 1 percent and less than 7 percent alcohol by volume, 22.6 cents per wine gallon. sense to qualify wine with a specific alcohol content, we do not believe that assigning an arbitrary value of 12 percent alcohol to wine provides the consumer with any additional useful information from which to make an informed decision. As the alcohol percent value of table wine varies between 7 percent and 14 percent and that for dessert wine is 14 percent and above, such a listing would not necessarily be truthful or accurate and could be misleading. We believe that the addition of a “12% alcohol” qualifier in the “Count as a Drink” language will be misinterpreted by some as the establishment of a “standard drink” size, which will eventually lead to a distortion and/or omission of the important moderation message. The Guidelines represent great efforts to explain moderate consumption to U.S. consumers, but they have also been misunderstood. We are seeing the moderation message giving way to a much broader interpretation that the Guidelines themselves have established the size of a “standard drink,” and there have been several regulatory actions that have been based on this contention. We have seen the “count as a drink” language stripped of its accompanying moderation context, with what remains being repackaged as a definition for a “standard drink.” We do not believe that this is what was intended by the authors of the Guidelines, and we are concerned that this misinterpretation and misuse, all pending the safeguards of future rulemaking, will raise serious social as well as political implications. While adding a “12% alcohol” qualifier to wine may appear to be minor and consistent with the “80 proof distilled spirits” language, we are concerned that such changes will result in an argument that these sizes equate to “standard drink” sizes and will become the basis for untruthful and misleading information on wine, beer, and spirits labels. Changes such as this will tend to bolster an argument that all alcoholic beverages are “equal,” a notion that Wine Institute disagrees with. It is an oversimplification to single out the ethyl alcohol property that all alcoholic beverages have in common, and then to conveniently boot strap this commonality into a graphic equation that all alcoholic beverages are equal but only in specific but differing quantities. There are three separate regulatory actions that are pending administrative rulemaking, all based in large part on the contention that the U.S. Dietary Guidelines have established standard serving sizes. Carbohydrate Labeling of Alcoholic Beverages Awaits Rulemaking On April 7, 2004, without the benefit and safeguards of the rulemaking process, the TTB published an Industry Circular that authorized the voluntary labeling of carbohydrate information for wine, beer, and distilled spirits2. Citing the 2000 Dietary Guidelines3, TTB in its Industry Circular uses the Dietary Guidelines “Count as a drink” language as a measure of a serving size: 2 TTB Ruling Number 2004-1, dated April 7, 2004, entitled “Caloric and Carbohydrate Representations in the Labeling and Advertising of Wine, Distilled Spirits and Malt Beverages, is currently available on the TTB web site at http://www.ttb.gov/alcohol/info/revrule/rules/2004-1.pdf Accordingly, this ruling holds that the statement of average analysis must apply to a serving of the product, and that the serving must be 12 fl. oz. for malt beverages, 5 fl. oz. for wine, and 1.5 fl. oz. for distilled spirits. TTB indicates in this ruling that it will conduct a rulemaking on this issue in the future.4 To date, almost six months since the publication of this interim policy, Wine Institute still awaits the promised publication of a Notice of Proposed Rulemaking by TTB on this matter. The significance of this action, however, should not be lost. This is an instance where an administrative agency has taken information from the Dietary Guidelines, eliminated the notion of moderate consumption, and concludes that the “Count as a drink” volumes for alcoholic beverages are “standard drink” sizes. “Serving Facts Panel” Labeling of Alcoholic Beverages Awaits Rulemaking The issue of whether the Dietary Guidelines established a definition of a “standard drink” came to light again with TTB in early August, 2004. On August 5, 2004, and again without the benefit of rulemaking, TTB released what it referred to as a “Serving Facts White Paper” where the identical drink volume values were being used by TTB to permit not simply additional nutritional information, but a comparative “equivalency” graphic” showing illustrations of a beer, wine and spirits container: 3 In TTB Ruling Number 2004-1, it is stated: It should be noted that we are setting serving sizes for these products in ounces, even though existing regulations require the use of metric terms in labeling the net contents of wine and distilled spirits containers. It is our belief that consumers are used to seeing serving sizes set forth in ounces, in the U.S. "Dietary Guidelines" and elsewhere. 4 In TTB Ruling Number 2004-1, it is stated that “TTB plans to engage in rulemaking, in the near future, on the issue of labeling and advertising statements regarding calorie and carbohydrate content. We believe that public comment on these issues will be useful in developing a more comprehensive policy on the mandatory or voluntary use of nutritional information on alcohol beverage labels.” The beer and wine sectors of the alcoholic beverage industry, strenuously objected to both the process and the content of the “White Paper.” Wine Institute opposed the “White Paper” for many reasons, but we point out that the term “standard drink” used by TTB and attributed to the Dietary Guidelines does not appear anywhere within the 2000 version of the Dietary Guidelines. It should be noted that TTB did not move ahead on this version of the “Serving Facts Panel” white paper, but revised and reissued a second white paper on September 21, 2004. While this white paper removes the more onerous provisions embodied in the first version and is careful not to use the term “standard drink,” this second white paper maintains, without benefit of rulemaking, serving size information that is identical to the Guidelines’ “Count as a Drink” sizes. TTB states in this version of the white paper that it will be conducting a rulemaking in the future.5 National Consumer League / Center for Science in the Public Interest Rulemaking Petition Awaits Rulemaking Submitted to TTB in December of 2003, the rulemaking petition of the National Consumer League and the Center for Science in the Public Interest calls for uniform information on several label items: • Alcohol content • Standard serving size • Amount of alcohol in ounces and number of calories per serving • Number of standard drinks per container • Ingredient declaration • U.S. Dietary Guideline recommendations for moderate drinking 5 TTB states in its document entitled: “Nutrient Claims in the Labeling and Advertising of Wine, Distilled Spirits and Malt Beverages – “Serving Facts” Panel” as follows: “The ruling would provide guidance to industry members on what TTB will allow as optional serving facts information on labels and in advertising until we develop final regulations concerning such panels. It is possible that the results of the rulemaking will differ from the guidance in the ruling.” The petitioners contend that more uniform alcohol information should be conveyed to consumers in a context where consumers can more easily understand how much alcohol they are consuming. They suggest that the serving sizes “prescribed” by the U.S. Dietary Guidelines should be used as the “standard serving size.” Additionally, the petitioners suggest that a consistent graphic, such as a beer mug or a glass of wine, be used to alert consumers to the statement. The sample label proposed in that petition looks like this: We urge the authors of the Dietary Guidelines 2005 version to allow for the completion of rulemaking before considering any changes to that portion of the Guidelines. II. CALORIES AND WEIGHT The issue of caloric content and association of alcohol with added sugar and solid fats in relation to discretionary calories and maintaining a healthy weight/weight gain is addressed both in Part A: Executive Summary and Part E: Translating the Science into Dietary Guidance. In the section “Control Calorie Intake to Manage Body Weight” (Part E page 7), the Advisory Committee states that, “Calories come from fat, carbohydrate, protein, and alcohol. The healthiest way to reduce calorie intake is to reduce one’s intake of added sugars, solid fat, and alcohol – they all provide calories, but they do not provide essential nutrients.” … “Table E-3 gives examples of how calories can be decreased by decreasing alcoholic beverage intake.” As we stated in our May 2003 submission to the Advisory Committee, “Given the current lack of consensus on the issue of moderate wine, beer and spirits consumption and its relationship to weight gain, Wine Institute recommends that the Committee provide more detailed discussion on the issue of moderate consumption of wine, beer and distilled spirits and its relationship to weight gain.” (WI Comment 2003, pages 6-7) The NIAAA review, State of the Science Report on the Effects of Moderate Drinking, concluded that the current scientific literature suggests that, “The data on the relationship between moderate alcohol consumption and weight gain/obesity are inconclusive. However, there is some evidence for reduced risk of diabetes and metabolic syndrome, which often co-exist with or develop from obesity.” (NIAAA 2003, page 29) An independent review commissioned by Wine Institute to review wine and alcohol and its effects on calories and body weight control since 1985 stated that, “At least 90 papers were published that have dealt directly or indirectly with alcohol consumption and body weight regulation. This renewed interest in how alcohol influences body weight stems, in part, from concern over dietary elements that may underlie the world-wide obesity epidemic. Although no universal consensus has been reached, a number of lines of evidence increasingly suggest that moderate alcohol consumption does not represent a dietary risk for developing obesity and may in fact promote certain metabolic changes which reduce the risk for overweight and obesity.” (Cordain 2003, page 2) In response to the scientific evidence presented, the Ethanol Subcommittee concluded that the relationship between consuming four or fewer alcoholic beverages daily and obesity was an “Unresolved Issue.” They state that, “The available data on the relationship between alcohol consumption and weight gain/obesity are sparse and inconclusive. There are contradictory findings at the higher end of the spectrum (i.e. 3 to 4 drinks per day) that may relate to fundamental limitations of the cross-sectional study design. At moderate drinking levels (i.e. up to one drink per day for women, up to one (sic?) drink per day for men), there is no apparent association between alcohol intake and obesity.” The Subcommittee concludes, “In summary, although prospective data are limited, there is no apparent association between consuming one or two alcoholic beverages daily and obesity.” Dietary Guidelines Advisory Committee Report, (Part 6, Section 8, page 6) Based on the Ethanol Subcommittee conclusion, we would like to recommend the statement made in Part E: Translating the Science into Dietary Guidelines be revised to read: “Calories come from fat, carbohydrate, protein, and alcohol. The healthiest way to reduce calorie intake is to reduce one’s intake of added sugars and solid fats. The findings on the relationship between moderate alcohol consumption and weight gain/obesity are inconclusive, however, it may be prudent to monitor consumption as it relates to the intake of discretionary calories.” CLOSING STATEMENTS We would like to commend the members of the Advisory Committee for their thorough review of the scientific literature and overall balanced recommendations on moderate alcohol consumption by healthy adults. On the issue of the Drinking In Moderation Definition, we strongly support the current definition of moderation (no more than 1 drink per day for women and no more than 2 drinks per day for men). We recommend the definition of one drink of wine be retained as stated in the 2000 version of the Guidelines in Box 26 – What is Drinking in Moderation? We believe that any changes made to the current definition would lead to inaccurate and misleading representations of the Guidelines’ moderation message to the public. Therefore, we recommend the addition of a clear and unambiguous statement in the guidelines that the “Count as a Drink” statements should not be interpreted as the establishment of a “standard drink,” and that the information is being provided to further explain the moderation message. As stated, there will be full and extensive industry and regulatory agency review accompanied by public comment for both serving size and serving facts labeling at the start of 2005. We would ask that any messages relating to moderate drinking and weight gain and obesity for the public clearly state that the scientific findings in this area are inconclusive and that alcohol, as well as other sources of discretionary calories, should be monitored closely for optimal health. We thank you for the opportunity to present additional information and recommendations on the Dietary Guidelines Advisory Committee Report.
Submission Date 9/27/2004
Author Wine Institute

Summary If you drink alcoholic beverages, do so in moderation. • Supporting text should include alcohol consumption as a risk factor for breast cancer, as well as for high blood pressure and congestive heart failure if drinking is prolonged. Written by: Ralph B. Vance, Karmeen Kulkarni, Alice K. Jacobs
Comments If you drink alcoholic beverages, do so in moderation. • Supporting text should include alcohol consumption as a risk factor for breast cancer, as well as for high blood pressure and congestive heart failure if drinking is prolonged.
Submission Date 9/27/2004
Author American Cancer Society, American Diabetes Association, American Heart Association

Carbohydrates
   Sugars
Summary Choose carbohydrates wisely for good health. • Suggest changing key message to “Choose carbohydrates wisely for good health, including to help manage body weight”. • Supporting text should provide explicit recommendations on those carbohydrate-rich food and beverage sources that should be limited an
Comments Choose carbohydrates wisely for good health. • Suggest changing key message to “Choose carbohydrates wisely for good health, including to help manage body weight”. • Supporting text should provide explicit recommendations on those carbohydrate-rich food and beverage sources that should be limited and which should be consumed more frequently as part of a healthy diet.
Submission Date 9/27/2004
Author American Cancer Society, American Diabetes Association, American Heart Association

Summary Executive Summary Should Reflect the Order of Priority of the Guidelines Written by: Maureen Storey & Richard Forshee
Comments The Center for Food and Nutrition Policy (“Center” or CFNP) at Virginia Tech—National Capital Region located in Alexandria is an independent, non-profit research and education organization that is dedicated to advancing rational, science-based food and nutrition policy. It is recognized as a Center of Excellence on such matters by the Food and Agriculture Organization of the United Nations (FAO). The Center uniquely operates like an independent “think-tank,” while maintaining its academic affiliation with Virginia Tech, a major land-grant university. The research, education, outreach, and communications activities of the faculty are conducted in a relevant, time-sensitive manner that helps inform the public policy process on food and nutrition issues. Encompassed in the Center’s activities on nutrition policy are its interests in policy and regulatory issues involving dietary guidance. The Center respectfully submits the following comments in response to the solicitation for written comments regarding the proposed 2005 Dietary Guidelines for Americans as published in the Federal Register.1 The comments contained herein urge the final guidelines to 1) reflect the priorities or order of importance in producing desirable health outcomes; 2) delete the section on the role of the environment as speculative rather than substantive; and 3) re-draft certain segments of the carbohydrates chapter to accurately reflect the results of publications used to justify the recommendations of the DGAC. Choose Carbohydrates Wisely for Good Health The following comments pertain to Part D Science Base, Section 5 Carbohydrates. The Center agrees that the message to “choose carbohydrates wisely for good health” is scientifically sound advice. Yet the language of the Conclusion and the Rationale of the guideline suggesting that added sugars may uniquely contribute to certain undesirable health outcomes such as poorer nutrient intake, unhealthy body weight, and increased risk of dental caries, is overstated. What is the relationship between intake of carbohydrates and dental health? The DGAC draft report suggests a possible relationship between added sugars and dental health. Question 1 asked: “What is the relationship between intake of carbohydrates and dental health?” Enclosed is a recent paper published by Forshee and Storey examining the association between dental caries and soft drink consumption.4 The study showed that for most age groups, soft drink consumption was not linked to an increase in dental caries. Our examination generally agrees with the findings of Heller and coworkers, but our interpretation of the policy implications of the results differs from theirs.5 The Center agrees that good dental hygiene, drinking fluoridated water, and using fluoridated dentifrices are the most effective ways to reduce dental caries. A secondary consideration is intake of fermentable carbohydrates that stick to the teeth and are not removed by brushing or rinsing the mouth. The Center therefore urges the draft report to reflect the priority of behaviors that will lead to better oral health by re-stating the final sentence in the conclusion to read: “A combined approach of optimizing oral hygiene practices and reducing the frequency and duration of exposure to fermentable carbohydrate intake is the most effective way to reduce caries incidence.” 4 Forshee RA, Storey ML. Evaluation of the association of demographics and beverage consumption with dental caries. Food Chem Toxicol. 2004; 42:1805-1816. 5 Heller KE, Burt BA, Eklund SA. Sugared soda consumption and dental caries in the United States. Journal of Dental Research 2001; 80: 1949-1953. 4 Does intake of added sugars have a negative impact on achieving recommended nutrient intake? The sentence in the Conclusion—“A reduced intake of added sugars (especially sugarsweetened beverages) may be helpful in achieving recommended intakes of nutrients and in weight control”—overstates the evidence presented. The evidence in fact shows that focusing on added sugars intake as a way to control or lose weight or improve micronutrient intake is unlikely to have any effect on these outcomes. The Center is pleased that the DGAC considered our research during its deliberations, however, we object to the manner in which our research is characterized in the draft report. For example, the draft report notes that most cross-sectional studies have found that “an increased intake of added sugars is associated with increased total energy intake” and the study by Storey et al, 20036 is cited as support for this statement. Our study in fact showed that less than 10% of children’s BMI and less than 15% of adolescents’ BMI could be explained by the parameters of our models. Of the variance that was explained by the models we developed, the largest predictors of BMI among children and adolescents were factors that can not be modified, such as age, gender, and race-ethnicity. Of the lifestyle factors that can be modified, sedentary behavior was far more predictive of BMI than was dietary intake; and within dietary intake, added sugars did not predict BMI. The conclusions we reached therefore do not support the statement made in the draft DGAC report. The Center also objects to how another one of our studies is represented in the draft report. The DGAC asked the sub-question: “Does intake of added sugars have a negative impact on achieving recommended nutrient intake?” The sentence in the draft report—“each of these papers shows a decreased intake of at least one micronutrient with higher levels of added sugar intake”—is true on its face, but it misrepresents the intent and overall conclusion of at least the study conducted by the Center. While again the Center is pleased that the DGAC cited our study (Forshee and Storey, 2001),7 we in fact showed that added sugars intake had an inconsistent association with micronutrient intake and that the association was always small. In addition, whether the association was positive or negative, it was probably small enough to be biologically insignificant. The DGAC also relied heavily on the Institute of Medicine of the National Academies draft report—specifically Appendix J—that examined the relationship between added sugars intake and micronutrient intake. Unfortunately, the NAS report used a ratio variable (percent energy from added sugars [%EAS]) that introduced a statistical and mathematical complexity that certainly affected the results of the study. In a study to be published by Forshee and Storey and that was provided to the DGAC carbohydrate subcommittee, we found that the relationship between total energy intake and 6 Storey ML, Forshee RA, Weaver AR, Sansalone WR. Demographic and lifestyle factors associated with BMI among children and adolescents. International Journal of Food Science and Nutrition 2003; 54: 491- 503. 7 Forshee RA, Storey ML. The role of added sugars in the diet quality of children and adolescents. Journal of the American College of Nutrition 2001; 20: 32-43. 5 micronutrient intake is far stronger than the one between energy from added sugars and micronutrients.8 Does intake of added sugars contribute to excess intake of energy? This question is irrelevant because one could just as easily ask if intake of any macronutrient contributes to excess intake of energy. Of course, the answer is yes; intake of any macronutrient, including added sugars, can contribute to excess intake of energy. In addition, the first two sentences in this section should be deleted because the statements address a different scientific question of underreporting food intake.9 The language in the draft report alludes to “prospective studies” that suggest a positive association between consumption of sugar-sweetened beverages and weight gain. At least one DGAC member argued that prospective studies are more important than cross-sectional studies in providing evidence regarding relationships between health behaviors and health outcomes. The Center agrees that prospective studies allow the testing of certain hypotheses that cannot be tested in cross-sectional studies. We therefore encourage the principal investigators of existing prospective studies to make the data widely available so that the scientific and policy communities can benefit from the work of many independent research teams. In order to better understand the importance of these studies, we critically reviewed five of the prospective studies cited by the DGAC 10, 11, 12, 13, 14 and one prospective study published since the release of the draft report.15 8 Forshee RA, Storey ML. Controversy and statistical issues in the use of nutrient density in assessing diet quality. Journal of Nutrition 2004; in press. 9 “The analysis of dietary data on added sugars may underestimate intake because of the underreporting of food intake, which is more pervasive among obese adolescents and adults than among their lean counterparts (Johnson, 2000). It appears that foods high in added sugars are selectively underreported (Krebs-Smith et al., 2000).” 10 Ludwig DS, Peterson KE, Gortmaker SL. Relation between consumption of sugar-sweetened drinks and childhood obesity: a prospective, observational analysis. The Lancet 2001; 357: 505-508. 11 Berkey CS, Rockett HR, Field AE, Gillman MW, Colditz GA. Sugar-added beverages and adolescent weight change. Obesity Research 2004; 12: 778-788. 12 Newby PK, Peterson KE, Berkey CS, Leppert J, Willett WC, Colditz GA. Beverage consumption is not associated with changes in weight and body mass index among low-income preschool children in North Dakota. J Am Diet Assoc. 2004; 104: 1086-94. 13 James J, Thomas P, Cavan D, Kerr D. Preventing childhood obesity by reducing the consumption of carbonated soft drinks: cluster randomised controlled trial. British Medical Journal 2004; 328:1237-1242. 14 Schulze MB, Manson JE, Ludwig DS, Colditz GA, Stampfer MJ, Willett WC, Hu FB. Sugarsweetened beverages, weight gain, and incidence of type 2 diabetes in young and middle-aged women. Journal of the American Medical Association 2004; 292: 927-934. 15 Field AE, Austin SB, Gillman MW, Rosner B, Rockett HR, Colditz GA. Snack food intake does not predict weight change among children and adolescents. Int J Obes Relat Metab Disord. 2004; 28:1210- 1216. 6 Each of these studies was conducted with the primary purpose of linking sweetened beverages with weight gain in children, adolescents, or adults. We believe the studies, as a body of evidence, show inconsistent results. The relationship between sugarsweetened beverages and BMI ranges from not statistically significant to a weak relationship affecting a small percentage of the population. A critique of each study is shown below. Ludwig et al., Relation between consumption of sugar-sweetened drinks and childhood obesity: a prospective, observational analysis. The Lancet 2001; 357: 505-508. This 19-month prospective observational study examined dietary habits and weight gain among 548 11-12 year old school children living in Massachusetts. Separate multivariate regression analyses were performed to estimate BMI and the probability of a child becoming overweight as a result of consuming calorie-containing carbonated soft drinks. At the end of the study, the authors found that only 6.8% of the study population of growing children, or 37 previously normal-weight, growing children, moved to the overweight category. At the same time, 35 (6.4% of the study population) previously overweight, growing children moved to the normal-weight category. Therefore, a net of two more children out of 548 (or 0.36% of the population) were classified as overweight at the end of the study. The regression analysis in Table 2 reports a relation of 0.24 kg/m2 increase in BMI for a one serving per day increase in sugar-sweetened drink consumption (controlling for other covariates). According to Table 1, baseline sugar-sweetened drink consumption was 1.22 servings per day and increased by 0.22 to 1.44 servings per day at followup. Therefore, the model predicts that for the average participant sugar-sweetened drink consumption contributed to a 0.05 kg/m2 increase in BMI over 19 months. While statistically significant, it does not appear that sugar-sweetened drinks made a large contribution to BMI for the average child in this study. Moreover, the authors did not report the coefficients of the other independent variables in the regression analyses. This prevents readers from determining the relative strength of the evidence upon which the authors made their conclusions regarding any possible unique contribution of soft drink consumption and weight gain among growing children. Berkey et al., Sugar-added beverages and adolescent weight gain. Obes Res 2004; 12: 778-788. This prospective, observational study (U.S. Growing Up Today Study) uses a powerful dataset, and the statistical modeling is generally good. However, the interpretation of the results does not appear to reflect the findings. Many of the reported p-values for the sweetened beverage variables were greater than (not statistically significant) or barely below 0.05. This is particularly surprising for such a large sample (>10,000 after exclusion criteria). 7 For example, in this sample of more than 10,000 boys and girls ages 9-14 years (y), the largest increase in BMI was 0.14 kg/m2 for boys who increased their consumption of caloric beverages by more than two servings per day. This small increase in BMI was attributed to a very large increase in calorically sweetened beverages. On average, there was an increase of 0.03 kg/m2 per serving/day for males, which was significant at p = 0.04. For females, there was a non-significant increase of 0.02 kg/m2 per serving/day (p = 0.096). Sugar-added beverages were defined as soda pop, sweetened iced tea, and non-carbonated fruit drinks. For boys, the average soda pop consumption in this study ranged form 0.34 (for 9 y) to 0.77 (for 14 y); iced tea ranged from 0.69 (for 9 y) to 0.20 (for 14 y), and non-carbonated fruit drinks ranged from 0.69 (for 9 y) to 0.78 (for 14 y). An increase of two servings per day is very large relative to the average consumer; indeed it is larger than the mean servings for the highest consuming age group. Even if we reduced consumption by more than the mean of the highest consumers, we would reduce average BMI by 0.14 kg/m2 at most. The coefficients and p-values for milk, sweetened beverages, and fruit juices are all very similar. Furthermore, the coefficients are much smaller and not statistically significant once total energy is introduced as a control variable. This suggests, as the authors report, that energy explains the relationships observed rather than any special property of sweetened beverages. Given the small magnitude of the reported relationships and the borderline p-values, the impact of sweetened beverages on BMI appears to be small. The authors also collected data on physical activity and sedentary behavior. Although these variables were included in the analysis, the authors did not report the results. Other research has shown that these variables have a stronger relationship with BMI than does added sugars. Since the results for physical activity and sedentary behavior were not reported, there is no context or basis for comparison in the interpretation of the reported relationship between sugar-added beverages and BMI. Despite these weak relationships and the lack of context, the authors still call for limiting the consumption of soft drinks and claim that this approach may prevent excessive weight gain. However, their results do not support the claim that limiting consumption of soft drinks may play a meaningful role in preventing weight gain. Based on these results, it is difficult to see how discouraging sweetened drink consumption could have a meaningful impact on average adolescent BMI. 8 James et al., Preventing childhood obesity by reducing the consumption of carbonated soft drinks: cluster randomised controlled trial. BMJ 2004; 328:1237-1242. This cluster, randomized controlled trial was designed to discourage consumption of “fizzy” drinks among 7-11 year old British school children. The so-called “Ditch the Fizz” campaign told the children that reducing calorie-containing soft drink consumption would improve well-being and dental health. The original published version of the paper noted that consumption of carbonated drinks decreased by 0.6 glasses per day. It was amended to show that consumption decreased by 0.6 servings over three days, or 0.2 servings per day. These results indicated that few children changed their dietary habits as a result of the campaign. The results also showed that consumption of carbonated drinks with sugar was unchanged in the control group and decreased by 0.3 of a (250ml) serving over a 3-day period in the intervention group. Neither change was statistically significant, and there was no statistically significant difference between the control and intervention groups. Furthermore, the mean change in BMI was 0.8 kg/m2 for the control group and 0.7 kg/m2 for the intervention group. This difference was not statistically significant. Newby et al. Beverage consumption is not associated with changes in weight and body mass index among low-income preschool children in North Dakota. J Am Diet Assoc. 2004; 104:1086-94. Newby et al. analyzed data from a prospective cohort study of 1,345 children 2-5y who were participating in the North Dakota Special Supplemental Nutrition Program for Women, Infants, and Children (WIC). Their models found no statistically significant association between beverage consumption and change in either weight or BMI. Specifically with regard to soda consumption, the estimated coefficient in the multivariate adjusted model for weight was -0.00 ± 0.04 (p=.95) and for BMI was -0.01 ± 0.02 (p=.58). Moreover, zero was in the middle of the confidence interval and the estimate was negative, not positive, which was the hypothesis being tested. As the authors note, average consumption of soda in this study is only a little over one ounce per day, but this is very close to the national average of 1.75 oz/day for children under 5y as reported by the CSFII 1994-96, 1998 Table Set 17, Table 15A.16 This prospective study of a group of young, low-income children consuming nearly the national average of 16 U.S. Department of Agriculture, Agricultural Research Service. 1999. Food and Nutrient Intakes by Children 1994-96, 1998. Online. ARS Food Surveys Research Group, available on the "Products" page at [accessed September 23, 2004]. 9 soda showed no association between soda consumption and either weight or BMI. Schulze et al., Sugar-sweetened beverages, weight gain, and incidence of type 2 diabetes in young and middle-aged women. JAMA 2004; 292: 927- 934. This article addresses important nutrition, public health, and public policy issues using an extraordinarily rich and important dataset. Unfortunately, some of the commentary in the study does not accurately reflect the data presented. This prospective cohort analysis used data from the Nurses’ Health Study II. This non-representative sample of women had a full sample of 116,671 women, but the authors excluded nearly half of the respondents (n=51,603). It is important to note that the average weight increased in all sugar-sweetened beverage consumption categories during the four-year periods 1991-1995 and 1995-1999. Even the category that sharply reduced consumption of sugar-sweetened beverages had an average weight gain of 1.34 kg from 1991-1995. Percent of Population Affected by Sugar-sweetened Beverage Consumption 1991-1995 Consumption Category Percentage of the Population ?kg/4years ?lb/year Consistent =1/wk 75 3.21 1.8 Consistent =1/day 5 3.12 1.7 =1/wk to =1/day 2 4.69 2.6 =1/day to =1/wk 2 1.34 0.7 Other 16 3.04 1.7 Source: Adapted from data presented in Schulze et al. As shown in the table above, 75% of the participants were already in the lowest category of sweetened beverage consumption, consistently drinking one or fewer soft drinks per week (Consistent =1/wk). Only 2% of the participants increased sweetened beverage consumption from =1/wk to =1/day, and these participants gained about 1.5 kg more than those in the lowest consumption category. Similarly, only 2% of the participants reduced their sweetened beverage from =1/day to =1/wk, and those 10 participants gained 1.9 kg less than participants in the lowest consumption category. Percent of Population Affected by Sugar-sweetened Beverage Consumption 1995-1999 Consumption Category Percentage of the Population1 ?kg/4years ?lb/year Consistent =1/wk 76 2.04 1.1 Consistent =1/day 5 2.21 1.2 =1/wk to =1/day 1.5 4.20 2.3 =1/day to =1/wk 2 0.15 0.1 Other 16 2.10 1.2 Source: Adapted from data presented in Schulze et al. 1 Does not sum to 100 due to rounding. Slightly more than 96% of the women in this study had the same average weight gain between 1995 and 1999. Three out of four women in this study already consumed soft drinks once a week or less and can not be expected to reduce their consumption much further. Of the four percent of women who went from one extreme category to another (i.e., dramatically decreased or increased consumption), their weight gain changed by about one pound per year compared with the 96% of the rest of the population. This association was somewhat smaller after controlling for total energy. If less than a two kilogram change over a four-year period for less than four percent of the population is the best single opportunity we have to curb the obesity epidemic, then we have a serious challenge ahead for all of us, including the 96 percent of the population who are low or very modest consumers of sweetened beverages. Field et al. Snack food intake does not predict weight change among children and adolescents. Int J Obes Relat Metab Disord. 2004;28:1210- 1216. Using the same prospective, observational study as Berkey et al. (U.S. Growing Up Today Study), Field et al. report no association between consumption of snack foods and annual change in BMI z-score among the nearly 15,000 girls and boys who were 9-14y in 1996. The estimated coefficients were negative, small, and not significant for both boys and 11 girls. Adding sugar-sweetened beverages to the snack food category “did not meaningfully change the results” (p. 1214). Body of Evidence Does Not Support a Public Health Strategy Targeting Sweetened Beverages Overall risk from any substance depends on the level of exposure and the degree to which the substance is considered a hazard. The table below illustrates that seven studies using a variety of designs show a very slight difference in BMI that is often not significant. “Hazard” estimates in this set of data range from not significant to about 0.20 (kg/m2)/year per serving/day. It is therefore difficult to justify public health strategies that would focus on reducing sweetened beverages as a unique risk for obesity and Type 2 diabetes. Summary of Findings from Selected Major Papers Study Magnitude ?BMI/year/(serving/day) Significance Forshee & Storey17 (cross-sectional) 0.11 (males) 0.26 (females) Not Significant Not Significant Ludwig et al. (prospective) 0.15 (0.24 over 19 months) p=0.03 Berkey et al. (prospective) 0.03 (boys) 0.02 (girls) p=0.04 p=0.096 Not Significant James et al. (intervention) 0.1 difference between treatment and control Not Significant Newby et al. (prospective) -0.01 (children) Not Significant Schulze et al. (prospective) 0.20 (women) (applies to 4% of participants) p<0.05 Field et al. (prospective) ~0 (not directly reported) Not Significant Source: Compiled by CFNP from data presented in published studies. Several approaches have been developed to evaluate the overall strength of a body of scientific evidence. One recent example is the U.S. Food and Drug Administration’s Interim Evidence-based Ranking System for Scientific Data18 that is part of the Interim 17 Forshee RA, Anderson PA, Storey ML. The role of beverage consumption, physical activity, sedentary behavior, and demographics on body mass index of adolescents. Int J Food Sci Nutr. In press. 18 U.S. Department of Health and Human Services, Food and Drug Administration, Center for Food Safety and Applied Nutrition. Interim Evidence-based Ranking System for Scientific Data. July 2003. last accessed September 21, 2004. 12 Procedures for Qualified Health Claims in the Labeling of Conventional Human Food and Human Dietary Supplements.19 The guidance describes an approach to evaluate how strongly the totality of scientific evidence supports a claim in the form of “consuming more X reduces the risk of Y,” with its counterpart claim being, “consuming less X reduces the risk of Y.” Based on the type and quality of the evidence, a proposed claim will be placed in one of four categories (First-level is the existing standard of Significant Scientific Agreement): Scientific Ranking FDA Category Appropriate Qualifying Language Second Level B ... "although there is scientific evidence supporting the claim, the evidence is not conclusive." Third Level C "Some scientific evidence suggests ... however, FDA has determined that this evidence is limited and not conclusive." Fourth Level D "Very limited and preliminary scientific research suggests... FDA concludes that there is little scientific evidence supporting this claim." Source: FDA Interim Procedures for Qualified Health Claims Using this approach, we believe that the claim “Consuming less sugar-sweetened beverages may reduce body mass index” would be a Third-level or Fourth-Level claim. There are no large clinical trials testing this claim. One small randomized control trial (James et al.) showed no difference in the change in BMI between treatment and control groups. The evidence from prospective observational studies is inconsistent. The Newby et al. and Field et al. studies found no relationship between sugarsweetened beverages and BMI. The Berkey et al. study found only a weak relationship between sugar-sweetened beverages and BMI, and that relationship disappeared after controlling for total energy. Ludwig et al. found a statistically significant relationship (p=0.03) that predicted an increase of 0.05 kg/m2 over 19 months for the average respondent in their study. Schulze et al. found statistically significant differences of about one pound/year that affected the approximately four percent of the participants who went from one extreme consumption category to the opposite extreme category. The other ninety-six percent of the participants had indistinguishable weight gains regardless of their sugar-sweetened beverage consumption. The prospective studies therefore have not confirmed a relationship between calorically sweetened beverages and BMI and cross-sectional studies generally have not found a relationship between sugar-sweetened beverage consumption and BMI either. 19 U.S. Department of Health and Human Services, Food and Drug Administration, Center for Food Safety and Applied Nutrition. Interim Procedures for Qualified Health Claims in the Labeling of Conventional Human Food and Human Dietary Supplements. July 2003. last accessed September 21, 2004. 13 Broad policies promoting the reduction of caloric-sweetened beverage consumption in order to decrease overweight/obesity in the U.S. population are not supported by the existing evidence. Summary of Comments In summary, the Center for Food and Nutrition Policy urges the following: 1) Prioritize the executive summary of the report to reflect the order of priority of the guidelines; 2) Delete the section on the role of the environment in implementing the guidelines as speculative and not supported by a science base; 3) Re-write the sentence on dental health as shown in these comments, which reflect the priority and relative importance of the factors that contribute the most to dental caries. 4) Re-write the section on added sugars and micronutrient intake to reflect the inconsistency and size of the relationship; 5) Re-write the section on added sugars and weight gain to reflect the actual findings in the scientific literature; that is, the relationship is small, weak, or not statistically significant. Furthermore, only a small percentage of the population appears to be affected by excessive intake of added sugars and/or sweetened beverages. Respectfully submitted, Maureen Storey, PhD Richard A. Forshee, PhD Director, CFNP Associate Director, CFNP Director, Research
Submission Date 9/27/2004
Author Center for Food and Nutrition Policy

Summary The advice to choose carbohydrates wisely doesn’t provide clear enough advice.
Comments The advice to choose carbohydrates wisely doesn’t provide clear enough advice. The two main messages in that section are about increasing whole grains and reducing the consumption of refined sugars. And since the whole grain recommendation is in this section of increasing daily intake of fruits and vegetables, whole grains, and low-fat and nonfat milk products, this section should avoid redundancy and convey the important dietary advice about refined sugars in a way that is easier for the public to understand and more available, and read, drink fewer soft drinks and limit cakes, cookies, and other foods rich in refined sugars
Submission Date 9/21/2004
Author Center for Science in the Public Interest

Summary We support the science-based conclusions on dental caries, diabetes, glycemic index and load and dietary fiber. There are, however, two areas related to the Added Sugars conclusive statements that require further consideration of the evidence. We are concerned that the Report suggests that a high
Comments The Committee’s conclusions concerning carbohydrates closely align with the DRI Macronutrient Report (Institute of Medicine, 2003). We support the science-based conclusions on dental caries, diabetes, glycemic index and load and dietary fiber. There are, however, two areas related to the Added Sugars conclusive statements that require further consideration of the evidence. • Added Sugars We are pleased that the Committee recognized the important nutrient contributions made by sweetened, flavored milks and presweetened cereals. We are concerned that the Report suggests that a high intake of added sugars is associated with reduced nutrient intakes. The DRI Macronutrient Report, however, indicates that association is not significant until added sugars intake reaches 25% or more of caloric intake. It is not clear why the Dietary Guidelines Report fails to use this number to more specifically describe the level at which this shift occurs. In fact, the Dietary Guidelines Report indicates that individuals with moderate intakes of added sugars (5-10% of calories) have better nutrient status than those at higher or lower intake levels. The Advisory Report lists that 10% of added sugars intake comes from breakfast cereals and other grains such as breakfast bars. We recommend that this category be split due to the different usage and consumption patterns of cereals (predominantly breakfast occasions) versus the bar category (snacks and sometimes breakfast occasions). We would also like to clarify that ready to eat cereals contribute approximately 4% of added sugars intake.
Submission Date 9/27/2004
Author General Mills

   Glycemic Response
Summary We concur with the committee’s finding that the glycemic index and/or glycemic load are of little utility for providing dietary guidance for Americans.
Comments We concur with the committee’s finding that the glycemic index and/or glycemic load are of little utility for providing dietary guidance for Americans.
Submission Date 9/27/2004
Author U.S. Rice Federal

   Sugars
Summary Overview of the Sugar Association position on sugars • People eat foods, not individual nutrients. • Sugar is valued as a food ingredient not only for its flavor enhancement but also for its uniqueness to meet the myriad of fundamental and essential functional requirements, particularly safety. •
Comments The Sugar Association, Inc. (Association) is pleased to provide comments to the Department of Health and Human Services and the United States Department of Agriculture (Agencies) relating to sugars intake advice in the final report of the Dietary Guidelines Advisory Committee (Committee.) The Association acknowledges the dedication of those in the Federal Government working hard to provide the best possible advice to assist the American public in making choices that will improve overall health and well being. The Association believes today’s public health challenges require innovative strategies and contemporary initiatives when educating the American public about healthful eating and active lifestyles. The Association was founded in 1943 by the US sugar industry to monitor nutrition science and educate consumers about sugar’s role in a healthy diet. We ask the Agencies to consider the Association’s scientific expertise and years of experience in consumer education when evaluating these comments as part of the process of establishing federal nutrition advice about sugar. While the Association submitted written comments to the Dietary Guidelines Advisory Committee throughout its deliberative process, the Association would like to provide the Agencies with the following bulleted overview of specific issues provided to the Committee regarding sugars and a detailed response on the issues: discretionary calories, added sugars and nutrient displacement, and terminology. Overview of the Sugar Association position on sugars • People eat foods, not individual nutrients. • Sugar is valued as a food ingredient not only for its flavor enhancement but also for its uniqueness to meet the myriad of fundamental and essential functional requirements, particularly safety. • There is no scientifically verifiable body of evidence persistently documenting negative health impacts ascribable to sugar intake, including obesity and nutrient displacement, at current consumption levels. • Every major scientific review completely exonerates the direct involvement of sugars in the etiology of lifestyle diseases. , , , • The National Academy of Sciences, Institute of Medicine Macronutrient Report (IOM Report) concludes that current scientific data are insufficient to support evidence of any major health impact from sugars intake, including obesity. • The IOM Report did not establish a UL (Upper Level) for total or added sugars intake, only a suggested threshold for added sugars. • In the matter of added sugars and nutrient displacement, the IOM Report stated unequivocally that the suggested intake threshold applied to only some micronutrients within some subpopulation groups. The suggested intake threshold is well above the current average consumption level of sugars in the US population. • The US Food and Drug Administration has ruled that “added” and “naturally occurring” sugars are indistinguishable, and therefore concludes that consumers could be misled into believing that food containing no refined sugar is superior to food containing refined sugar. • Inordinate emphasis on added sugars could create a public health outcome similar to the one resulting from the simplistic focus on low-fat. The importance of energy balance is obscured by such one-dimensional approaches. • We ask the Agencies to consider the potential long-term repercussions the current trend of increasing use of sugar replacers may exert on satiety, metabolism and taste preference, especially among children.Recommended daily nutrient intake values are established to meet the dietary needs of healthy individuals. Micronutrient intake recommendations are established such that 98% of a normally distributed population receives adequate micronutrients. Consequently, micronutrient intake values provide a tool to evaluate the dietary adequacy of the general population. Although a single study might show that the intake of one or more selected vitamins or minerals is less than 100% of its established intake recommendation, this observation has little to do with a single food or a particular food ingredient. In any given short-term dietary sampling, it is highly unusual if the recorded intake of every micronutrient equals its recommended intake value.xi In fact, dietary intake expert committees “tend to err on the side of generosity.”xi There are always sectors that lie beyond the lower and upper boundaries of a normal distribution. It is no different with micronutrient intakes. Accordingly, small fractions of a population exhibiting dietary habits and eating patterns outside the norm are to be expected. Unless micronutrient intakes consistently fall below two-thirds of the recommended intake level, there is no long-term harm to health.xi Dietary guidance must be focused on the foods and beverages not consumed by a minority of individuals, not on a dietary component like added sugars. It is indefensible to construct dietary guidance systems, intended for 98% of the population, on the micronutrient intakes of the select few individuals requiring highly specialized dietary advice. There is no validated body of irrefutable evidence that corroborates the popular theory that added sugars reduce the nutrient adequacy of the American diet. Thorough examination of the data in the stable of articles cited repeatedly as substantiating this theory points out the fallacy of this hypothesis. For example, the data in the article emphasized by the Committee as supporting the added sugars and nutrient displacement hypothesis say the opposite. As listed in Table 3 of the cited article, micronutrient intakes range between 78% (zinc) and 237% (vitamin B12) of dietary recommendations for those Americans consuming more than 18% of their daily energy as added sugars. These intake levels are not nutritionally inadequate. While it is true that added sugars can be mathematically associated with the intake of a micronutrient like calcium, , critical analysis points out the ineffectiveness of using the nutrient displacement theory to explain low calcium intakes.xiv, However, the Committee continued to perpetuate the flawed nutrient displacement hypothesis by its treatment of the recently published IOM Report data of the comparative added sugars and calcium intake levels. As seen in Figure 1, the ‘inverted U-shaped’ response between the comparative calcium and added sugars intakes argue against the nutrient displacement hypothesis. Legitimate nutrient displacement requires that highest calcium intakes occur at the lowest level of added sugars intake. The fact that genuine nutrient displacement is obviously absent is underscored by the Figure-1 arrow labeled “This level represents the best with respect to micronutrient intake.”xix Not only has this statement been so generalized as to imply that it is true for all micronutrients, it disregards the fact that Figure 1 pertains only to calcium intakes for children ages 4 to 8. The arrowed statement of Figure 1 further ignores the fact that the second added sugars category (5 – 10%) is not always reflective of highest calcium intakes reported in the IoM added sugars dataset.xviii For example, males ages 19 to 50 have higher calcium intakes in the third added sugars category (10 – 15%) than in the second added sugars category. Second, inclusion of age-specific recommended intake values further weakens the relevance of unilaterally applying the nutrient displacement theory to added sugars and calcium intake comparisons. The dashed line in Figure 2 readily demonstrates that children’s calcium intakes uniformly exceed the recommended 800-mg/day level at added sugars levels as high as 25% of daily calories (fifth category). In fact when the reported statistical errorsxv are included (data not shown), some children within the 25 – 30% added sugars group (sixth category) achieve their daily 800-mg/day intake level established for calcium.Finally, Figure D5–1 should have been labeled with the terminology “added sugars,” not “added sugar.”xix Terminology - Sugar-sweetened drinks The Food and Drug Administration has defined sugar to mean sucrose for the purpose of ingredient labeling, 21 C.F.R. 101.4(b)(20). For the purposes of ingredient labeling, the term sugar shall refer to sucrose, which is obtained from sugar cane and sugar beets in accordance with the provisions of 184.1854. The terms sugars (plural) is used to designate all mono- and disaccharides. Therefore, The Association takes strong issue with the use of the term “sugar-sweetened drinks” to denote caloric beverages throughout the Committee’s final recommendations and asks that the Agencies not allow this terminology in the messages developed to communicate dietary guidance to the American public. Very few beverages, and all major soft drinks, have not contained sugar since the mid 1980s. High fructose corn syrup (HFCS) is the major sweetener in nearly all caloric beverages and to use the term “sugar-sweetened drinks” is not only inaccurate but misleads the consuming public. Today’s foods and food ingredients are not the same as those of our grandmothers. No longer is a jelly or jam, for example, simply made with fruit, sugar (sucrose) and pectin. While consumers can read a detailed list of ingredients on many food products, many of today’s foods contain ingredients that consumers cannot pronounce, let alone have any idea of what the ingredient is and its function in the food. This is particularly true regarding sweetening ingredients used in today’s foods. As verified in Figure 3, the sucrose share of the US caloric sweetener market has fallen from nearly 86% in 1970 to 43% in 2003. While Figure 3 was updated specifically for these comments, an earlier edition was published recently in the peer-reviewed literature.xx The Association recently conducted eight focus groups across the country. In an exercise where participants were asked to list ingredients now used to sweeten foods, not one participant identified high fructose corn syrup as a sweetening ingredient even though HFCS is a major sweetener used in today’s food supply. Nor did these consumers have any knowledge of sugar alcohols or fillers, such as maltodextrins, used today to replace fats and sugar in foods. However, consumers do understand the term “sugar” to mean pure, white granulated sugar that their mothers and grandmothers used and trusted. Although there are conflicting points of view as to whether or not individual caloric sweeteners are equivalent, the Association firmly believes the public interest is not served when consumers continue to be misled by the improper use of the term “sugar” to describe the myriad of sweeteners used in today’s food and beverage products. In closing, the Association would like to restate a part of its oral comments presented on September 21, 2004 to representatives of the Agencies. Sugar is an important food ingredient that has provided safety and important functional properties to our food supply for thousands of years, and is an essential component in many nutrient-rich foods. We are encouraged that the Committee has emphasized the central importance for individuals to balance their energy intake with their activity level for weight control. If one eats more food and thus calories – no matter the source - than one burns, weight gain is inevitable. We agree emphasis should be placed on helping Americans understand the importance of having nutrient-rich diets, and are confident the Agencies will develop science-based, credible messages to help Americans achieve their individual energy balance goals for improved health.
Submission Date 9/27/2004
Author Sugar Association

Summary Thank you again for the opportunity to express my opinion on this topic. Thank you for taking the time to sort through all of the comments that people will no doubt contribute.
Comments Thank you for the opportunity to be able to provide my own individual input on such important matters as the Dietary Guidelines. It is so wonderful to know that you care about individual’s nutrition and health. It is comforting to felt that there is hope in making this country healthy once again. I wanted to comment on the carbohydrate sugars that can increase dental caries. I am in agreement that sugars, over time, can contribute to children having dental caries. This has been a concern of mine for a long time. I work in a hospital and see so many very young children coming in to get multiple crowns and pulpotimies. I think that the most contributing factor to this is negligent hygiene of the parents. Young children can not be responsible for their dental care at such a young age. I think it should be a recommendation that parents help their children brush up until at least age five. This would hopefully instill that habit in to the children for life. Also, I fully believe that parents should carefully watch how much carbohydrates and sugar their child consumes. When parents let the child eat candy this can also contribute to dental caries because of the length of time the sugars remain in the mouth. I completely agree with the studies that were found on this topic in the report. Again, I think it should be recommended that parents keep track of or prevent their very young children from consuming certain sugars and the amounts of the sugars eaten.
Submission Date 9/26/2004 9:28:00 PM
Author Anonymous

   Glycemic Response
Summary We concur with the Committee's statement “The glycemic index and/or glycemic load are of little utility for providing dietary guidance for Americans.”
Comments We concur with the Committee's statement “The glycemic index and/or glycemic load are of little utility for providing dietary guidance for Americans.”
Submission Date 9/21/2004
Author North American Miller's Association

   Sugars
Summary In whole form, carbohydrates support life, but refined carbohydrates are inimical to life because they are devoid of bodybuilding elements.
Comments Only during the last century has man’s diet included a high percentage of refined carbohydrates. Our ancestors ate fruits, vegetables and grains in their whole, unrefined state. In nature, sugars and carbohydrates—the energy providers—are linked together with vitamins, minerals, enzymes, protein, fat and fiber—the bodybuilding and digestion-regulating components of the diet. In whole form, carbohydrates support life, but refined carbohydrates are inimical to life because they are devoid of bodybuilding elements.
Submission Date 9/21/2004
Author Weston A Price Foundation

Summary NFPA recommends that the Dietary Guidelines for Americans acknowledge that there are numerous food products that deliver essential nutrients and contain added sugars, and that these foods can be part of a healthful diet, balanced with physical activity.
Comments NFPA notes that the Dietary Guidelines Advisory Committee focused on added sugars that deliver calories but no essential nutrients. NFPA recommends that the Dietary Guidelines for Americans acknowledge that there are numerous food products that deliver essential nutrients and contain added sugars, and that these foods can be part of a healthful diet, balanced with physical activity.
Submission Date 9/21/2004
Author National Food Processors Association

Summary I would add to this that including meat, dairy, and refined sugars in one’s diet is in fact detrimental to one’s health.
Comments I would add to this that including meat, dairy, and refined sugars in one’s diet is in fact detrimental to one’s health.
Submission Date 9/21/2004
Author Anonymous

Summary The DGA could reword its message to distinguish between healthy and not-so-healthy carbohydrate choices. For example "Choose carbohydrates from unrefined grains and sugars" makes a distinction between whole and processed sources.
Comments Given the current "low-carb" climate, "Choose Carbohydrates Wisely" taken without its supporting message may lead to more confusion over which sources of carbohydrates are the healthiest choices.
Submission Date 9/24/2004 1:04:00 PM
Author from Salem, MA

   Glycemic Response
Summary glycemic responses depend on food not considered in isolation...
Comments Please emphasize that the glycemic response of a food is not fixed. A potato eaten with nourishing sour cream has a much lower glycemic index than a plain potato. Foods are not isolated chemicals. They are parts of a meal.
Submission Date 9/24/2004 4:47:00 PM
Author from Beaverton, OR

   Fiber
Summary Leading health organizations promote the benefits of citrus, including the American Heart Association, American Cancer Society, the National Cancer Institute and the Produce for Better Health Foundation.
Comments One of the key messages is: Choose carbohydrates wisely for good health. Including citrus fruits in the diet helps meet the recommended intake of dietary fiber of 14 grams per 1,000 calories. Oranges and grapefruit rank #1 and #2 in fiber out of the top 20 most consumed fruits and vegetables . One medium-sized orange is an excellent source of fiber, providing 7 grams, or 28 percent of the Recommended Daily Value. Half a grapefruit is also an excellent source of fiber providing 6 grams and 24 percent of the Recommended Daily Value.
Submission Date 9/24/2004 5:21:00 PM
Author Sunkist Nutrition Bureau

   Sugars
Summary Stress lower daily carbohydrate intake. Stress importance of WHOLE grains, not refiled grains of any kind.
Comments
Submission Date 9/24/2004 2:15:00 PM
Author from Holland, MI

Summary It is urgent that you distinguish between simple and complex carbs in the new dietary guidelines for the nation. Urge that people eat complex carbs, and leave simple carbs for on occasional, RARE, treat. We need to lower the rate of obesity in this country or we will be a nation of sick people.
Comments In the new Dietary Guidelines you are working on, it is essential that you explain the difference between COMPLEX carbohydrates and SIMPLE carbohydrates, and the way that difference relates to good health vs. poor health, AND to weight loss opportunities. All carbs are NOT created equal. Other than honey, only complex carbohydrates occur in nature. They contain a great deal of fiber. When the fiber is removed from these naturally-occuring complex carbohydrates--by food processing--the complex carbs become simple carbs (read "sugars")and are then ready to be rapidly digested by the body. Keeping the fiber in the naturally-occurring carbohydrates by using only minimal processing that does not remove fiber results in slow digestion, whereby the calories are released SLOWLY into the bloodstream, which does not result in a rapid rise in blood sugar level. Eating carbohydrates that have had all the fiber removed by food processing releases a cascade of simple sugars (read "calories") into the bloodstream rapidly, causing a rise in insulin, which is called the "insulin response." That is NOT a good thing, as it causes quick calorie storage in the fat cells, followed by a quick blood sugar drop, making us even fatter than we already are, and wanting more of what we just ate. Repeating this cycle frequently can significantly raise the risk of diabetes. Furthermore, I have personally observed over the years (I'm now 62)that simple sugars DULL my tastebuds, and my desire for complex carbohydrates and other health-promoting foods, and give me instead a craving for simple carbs(cakes, candy, cookies, chips, etc, ad infinitum), resulting in the "One is not enough" syndrome. It's really, really easy to want to binge on simple-carb foods. This doesn't happen with complex-carb foods. Simple-sugar foods cause cravings, a result of the rapid rise and fall in blood sugar levels. With complex carb intake, cravings go away and blood sugar stabilizes. I have repeated this unfortunate "learning cycle" more times than I care to admit over my 62 years. It is always the same. At the end of the cycle, I need to lose the weight I gained during the "learning" part! All my acquaintances say the same is true for them. When you are eating simple carbs, you simply don't want good, health-promoting food. You will choose "junk" food, instead, and the more the better! It is imperative that the important difference between types of carbohydrate (unrefined vs refined) be spelled out for our citizens. Many don't know how important the difference is to their overall health, or to their waistines. Please, please do the right thing and tell the truth. We depend heavily on your work, so you need to do it right. You are charged with EDUCATION FOR GOOD HEALTH for all Americans. Fulfill your charge. Please.
Submission Date 9/23/2004 9:52:00 AM
Author from Cary, NC

Summary Omit the word “carbohydrate” from the guidelines. Suggest changing to "Choose sugar containing foods and drinks wisely for good health."
Comments Omit the word “carbohydrate” from the guidelines. Suggest changing to "Choose sugar containing foods and drinks wisely for good health." Many people don’t realize that sugar falls under the carbohydrate group- they only relate carbohydrate to breads/grains.
Submission Date 9/23/2004 12:16:00 PM
Author OSU Extension Program- Cleveland, OH

Summary Suggest removing the term "carbohydrate."
Comments Suggest removing the term "carbohydrate." Carbohydrate is such a “popular” term these days that many people don’t know what to think when they hear the term. They are bombarded with "high carb, low carb, no carb, net carb"…how are they to know what is truly a wise carbohydrate choice? Carbohydrates are not the enemy- over consumption is the issue. Over-consumption of carbohydrates, fats & protein- not just carbs!
Submission Date 9/23/2004 12:20:00 PM
Author OSU Extension Program- Cleveland, OH

   Glycemic Response
Summary Utilizing the clinically proven glycemic index of a food and/or raw material is mandatory in identifying "Net Carb" and "Low Carb" foods, as well as any claims for Diabetic-Friendly foods.
Comments RE: Food Labeling and the Glycemic Index. Low Carb labeling and Sugar Alcohols. Dear Sirs; Our research organization has been conducting clinical studies of the Glycemic Index and human biochemistry for over 20 years. We possess the largest database of glycemic research of any organization in the world. We recently completed clinical for Hershey Foods to identify the biochemical pathway utilized by chocolate in the body. Our clinical studies are conducted at the University of Florida, and include glycemic index, glycemic load, and fat-storing mechanisms in humans, such as Leptin, Lipoprotein Lipase, and Neuropeptide Y. We are submitting our comments to provide scientific evidence that: 1) sugar alcohols can elevate blood glucose and insulin levels, and and stimulate fat-storage in humans, and this needs to be reflected in FDA labeling guidelines. 2) Determination of the glycemic response of foods, Nutraceuticals, and all consumables, is mandatory in the determination of labeling information. 3) Identifying "Low Carb" foods and "Net Carb" foods requires knowledge of the biochemical properties of the food. We concur with the FDA position that the term "Low Carb" should not be allowed until a competent definition on "Low Carb" is established. If the glycemic index of a low carb product is not known, how can that product claim not to elevate blood glucose, insulin levels, and stimulate fat-storing mechanisms in humans? Sugar alcohols can elevate blood glucose, insulin levels, and fat-storage in adipose tissue fat cells, despite what manufacturers claim. Food manufacturers should not be allowed to use the terms "Low Carb" or "Net Carb" foods until there is definitive data showing the clinical response of all raw materials used in food manufacturing, such as sugar alcohols. Only specific laboratory and definitve clinical studies can quantify these terms. If manufacturers are allowed to state "Net Carbs" without clinical evidence of the biochemical properties of foods and raw materials, there will be mis-labeling, misuse, and outright fraud against the public. All carbs and sugars and sugar alcohols present caloric value, as well as blood glucose, insulin, and fat-storage properties. It is our position that all carbohydrates and sugars should be claimed under Carbohydrates, and not allowed to be placed under the guise of "Low Carb" or "Net Carb." Sincerely, Dr. Ann de Wees Allen Chief of Biomedical Research Glycemic Research Institute Washington, D.C. www.glycemic.com
Submission Date 9/21/2004 6:10:00 PM
Author Glycemic Research Institute

   Fiber
Summary The guideline should be modified to increased specificity. Suggested guideline; Choose foods made with whole grains and little added sugar.
Comments If the intent of the proposed general carboydrate guideline is to reinforce the guideline “Increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products” and address the issue of increasing whole grains and reducing sugar intakes a more actionable guideline would read; “Choose foods made with whole grains and little added sugar”.
Submission Date 9/22/2004 2:23:00 PM
Author from Boston, MA

   Sugars
Summary The guideline should be modified to increase specificity. Suggested guideline; Choose foods made with whole grains and little added sugar.
Comments If the intent is to reinforce the guideline “Increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products” and address the issue of increasing whole grain and reducing sugar intakes a more actionable guideline would read; “Choose foods made with whole grains and little added sugar”.
Submission Date 9/22/2004 2:28:00 PM
Author from Boston, MA

   Fiber
Summary Avocados are a natural source of eight vitamins, two minerals and at least three phytochemicals. Avocados are included in dietary programs from many of the world’s leading nutrition organizations and can make a significant contribution to the health of Americans.
Comments One of the nine key messages is: Choose carbohydrates wisely for good health. Including avocados in the diet helps meet the recommended intake of dietary fiber of 14 grams per 1000 calories. One-fifth of a medium avocado provides 3 grams of dietary fiber.
Submission Date 9/17/2004 5:53:00 PM
Author California Avocado Commission

   Sugars
Summary The guidelines should specifically advise against substantial consumption of refined sugar and urge the food industry to reduce the sugar content of beverages and other foods. For people to take the guidelines seriously, the guidelines are to be based on facts, not commercial interests.
Comments Based on the available data from research, both long term average BMI and specific studies on refined carbohydrates such as sugars, I believe that the guidelines should be much more foreceful in stating that sugars should be reduced from present consumption. The dietary guidelines run the risk of being ignored if they do not address clear current dietary problems or appear to pander to commercial interests. The committee is to be applauded for finally stating what has been obvious for at least a dozen years about the adverse health effects of trans-fats. While I can understand that the Government did not want to adversely affect commercial interests, the slow reaction to such a clear problem food gave the users of the guidelines little confidence that the guidelines were constituted with their best interests in mind. Please, don't make the same mistake with sugars. While it may not be absolutely clear that high carbohydrate consumption is entirely responsible for the BMI bloat, there is no doubt that high sugar consumptions is at least partially, and probably mostly, responsible.
Submission Date 9/20/2004 12:22:00 PM
Author Carleton University (retired)

   Fiber
Summary
Comments Regarding: Report of the Dietary Guidelines Advisory Committee on the Dietary Guidelines for Americans, 2005 to the Secretaries of Health and Human Services and Agriculture It is with great interest, we read the Dietary Guidelines Advisory Committee report, which was certainly very thoughtful and comprehensive. We thoroughly reviewed the discussion around the importance of carbohydrates in the American diets. As a producer of a carbohydrate rich product, we were generally in agreement with the committee’s report. Our only concern is the ability to communicate to consumers the fact that all carbohydrates are not equal and how to choose carbohydrates wisely. To that end, we would like to offer the following reasons why we believe that “Pasta is a Good Carb” and should be a food promoted to Americans in the 2005 Dietary Guideline. Choose Carbohydrates Wisely Choose Pasta · Pasta is relatively low in calories Calories 1 Cup Spaghetti (cooked) 200 1 Med. Baked Potato (plain) 220 1 Cup Brown Rice 232 3 oz. Bagel 240 1 Cup Mashed Potato 248 2 oz. Snickers Bar 282 1 slice chocolate cake (iced) 320 4 oz. French Fries (McDonald’s) 515 · A pasta meal consisting of 1 cup cooked spaghetti, ˝ cup spaghetti sauce, 2 oz. lean ground beef, Ľ cup chopped onion and ˝ cup green bell pepper is below 500 calories. For a diet of 2500 calories, this is less than 20% of the daily caloric intake. · Pasta is a good source of thiamin, folic acid, iron, riboflavin and niacin. Pasta is also a low fat; very low sodium and cholesterol-free food. · Pasta is even more valuable nutritiously when accompanied by healthy partners like: vegetables, beans, tomato sauce, olive oil, fish, lean poultry or beef and low-fat cheese. When combined these ingredients can result in a delicious meal that is nutrient rich and low fat. · Pasta, like other complex carbohydrates, is an excellent source of energy. This is very different than other carbohydrates such as: cakes, cookies, candy, donuts, potato chips and corn chips, to name a few, that have relatively little nutritional value and unlike pasta have a high Glycemic Index resulting in a fast blood sugar response. · An article published in the Journal of The American Medical Association supports using the Glycemic Index to help choose healthy foods. “Clinical use of Glycemic index as a qualitative guide to food selection would seem prudent in view of the preponderance of evidence suggesting benefit and absence of adverse effects.” JAMA – May 8, 2002 · The Glycemic Research Institute (GRI), a nonprofit organization based in Washington, DC, gives the following reasons why low Glycemic foods are beneficial to health: - Low Glycemic foods do not stimulate food-cravings or human-food-craving-mechanism - Low Glycemic foods are not based on starvation or deprivation - Low Glycemic foods do not promote fat storage - Low Glycemic food plans have been proven to reduce incidence of Type II diabetes and to help control Type I and Type II diabetes - Low Glycemic foods do not elevate insulin and blood glucose - Low Glycemic foods do not exacerbate hyperactivity - Low Glycemic foods do not reduce sports performance GRI – Copyright 1999-2003 · Based on the facts that Pasta has excellent nutritional value, provides diverse meal options and is low on the Glycemic Index, it should be considered “A Good Carbohydrate” and promoted as part of a healthful diet in the upcoming sixth edition of the Dietary Guidelines for Americans. We hope you will agree that Pasta is indeed a good carb and therefore is worthy of specific mention as a carbohydrate, which consumers should consider favorably when planning a healthful meal. Sincerely, Drew Lericos Director of Marketing American Italian Pasta Company 4100 N. Mulberry Drive Kansas City, MO 64116
Submission Date 9/20/2004 6:48:00 PM
Author American Italian Pasta Company

   Sugars
Summary Include the recommendation: Reduce added sugars.
Comments These guidelines will be considered a travesty unless you address the problem of added sugars that is a main cause of obesity in America.
Submission Date 9/1/2004 7:14:00 AM
Author Anonymous

Summary Sugar is an addictive substance and the public should be told this in a clear fashion. This report does not address this issue strongly enough. Please revise these recommendations to reflect what scientists, health advocates and the public now know about the dangers of sugar.
Comments Sugar is an addictive substance and the public should be told this in a clear fashion. This report does not address this issue strongly enough. For the sake of the health of this country, please revise these recommendations to reflect what scientists, health advocates and the public now know about the dangers of sugar.
Submission Date 9/1/2004 7:16:00 AM
Author Anonymous

Summary Your correct intent to limit added sugars is not reflected clearly in your theme to "Choose CHO wisely." Please don't confuse the average American.
Comments Reading the fine print of your document, I can see your wise emphasis on decreasing added sugars within total calorie intake. I fear that the average American will not get this message clearly with your overarching theme - to choose carbohydrates carefully. Please be clear, and urge Americans to reduce addes refined sugars in the same way that you urge them to resude salt.
Submission Date 9/1/2004 7:17:00 AM
Author from Swarthmore, PA

Summary Be unambiguous about limiting sugar consumption.
Comments It is crucial that unambiguous advice about sugar consumption be in the final guidelines in early 2005. With the growing obesity epidemic this hardly seems to be the time to be any less specific about limiting sugar in the diet of every person. This seems to be clearly indicated by scientific reports.
Submission Date 9/1/2004 7:53:00 AM
Author from Blooming Grove, New York

Summary The Dietary Guidelines Committee should make explicit recommendations about added sugars in its advisory reporet. Recent studies clearly show a link between simple sugars and adverse health, such as obesity and diabetes. The committee must take responsibility to clearly advise our nation.
Comments The Dietary Guidelines Advisory Committee should make explicit recommendations about added sugars in its advisory report on dietary guidelines. Results from recent studies clearly show a link between simple sugars, such as high fructose corn syrup, and adverse health, such as obesity and diabetes. Our nation needs such detailed advice to live healthier lives. This, in turn, should help to reduce the burden of chronic, preventable health problems on our health care system.
Submission Date 9/1/2004 8:21:00 AM
Author from Madison, WI

Summary Your "nine tips for healthy eating" must include a clear, unambiguous statement about the harmful effects of added sugars in the diet. "Reduce added sugars" is what we need to hear. You will be failing your mission if you neglect to include a clear unequivocal warning about sugar.
Comments I am appalled that the new guidelines eliminate a direct mention of the harmful effect of refined sugars in the diet. As a parent, educator, and activist with extensive knowledge of good nutrition, I expect clear and unequivocal advice in the nutritional pyramid. A simple statement such as "reduce added sugars" is essential. Most people do not have the time, as I did, to read the summary report. I am appalled at the appearance your agency has capitulated to the food, drug, and dietary supplement industries' pressure to removed the statment "Avoid too much sugar" from the food pyramid guidelines. The statement "Choose carbohydrates wisely for good health" is blatantly unhelpful for the millions of obese Americans who haven't the time to read the fine print. Your mission is to provide clear unambiguous information for the citizenry regarding the best health choices we can make. As teacher since the late 1970's, I have witnessed first-hand the dramatic rise in childhood obesity, Attention Deficit Disorder, food allergies, and other diet-related illnesses. I have witnessed the rise in marketing highly processed foods to children. I despair to think that your revised guidelines will encourage school lunches to be further degraded and the health of the citizenry to further erode. Do not capitulate to industry pressure. Revise your statement to read "Reduce added sugars." People need to know this. It is no less than your mission to be clear, consise,and, above all, truthful to the American public.
Submission Date 9/1/2004 8:34:00 AM
Author from Topsham, Maine

Summary I URGE you to reconsider and issue REAL advice and guidleines concerning the consumption of artificial/processed sugar. Please do your job.
Comments I am astounded that you would remove any negative or restrictive comments regarding artificial/processed sugars in your new food pyramid guidelines, e.g., "choose carbohydrates wisely"?!? Did the fact that 7 members of that panel are connected to the food processing industry have anything to do with it? Can we say "conflict of interest?" Have you no regard for public health at all? Shame on you!
Submission Date 9/1/2004 10:40:00 AM
Author Anonymous

Summary
Comments This is for the public comment period for the new nutritional guidelines. Please include a caution specific to the need to limit sugar in diet. These guidelines will be used in classrooms everywhere and our children need to know that too much sugar is actually bad for their health.
Submission Date 9/1/2004 11:03:00 AM
Author Organization Name not Specified

Summary Limit sugars in guidelines
Comments This is for the public comment period for the new nutritional guidelines. Please include a caution specific to the need to limit sugar in diet. These guidelines will be used in classrooms everywhere and our children need to know that too much sugar is actually bad for their health.
Submission Date 9/1/2004 11:04:00 AM
Author from Hydesville, CA

Summary As a physician, I am disturbed by the guideline "Choose carbohydrates wisely for good health," apparently a result of sugar industry pressure. This should be replaced with clear, health-based advice: "Avoid sugar and foods with added sugars."
Comments As both a family physician and head of a growing household, I appreciate the importance of sound expert advice on nutrition in face of conflicting messages about health and nutrition in the media. While I generally agree with the recommendations of the advisory committee, I was taken aback by the recommendations on sugars and carbohydrates. I am a bit dumbfounded by the committee's decision to break with past sound advice about added sugar, such as "Avoid too much sugar." The proposed guideline "Choose carbohydrates wisely for good health" is vague and essentially abdicates responsibility for providing sound, easy-to-follow advice about the importance of limiting added sugars. Strong evidence, much of it cited in the committee's report, supports the link between added sugar and obesity. Added sugar, which has no nutritional value, also replaces comsumption of other foods with nutritional value, leading to a general decline in nutritional status. As a parent constantly bombarded with media advertising promoting processed, sweetened food products, I appreciate the importance of strong, unbiased nutritional guidance. The committees vague unhelpful guidance on sugars is disturbing. The only likely explanation is that the committee has yielded to pressure from the sugar and processed food industry. I urge you to rewrite the guideline on sugar, replacing the draft statement with a statement such as "Avoid sugar and foods with added sugars."
Submission Date 9/1/2004 11:13:00 AM
Author from Elizabeth, NJ

Summary Reduce added sugars
Comments Your use of sugars is a bit vague. You should be more specific about limiting added sugars in one's diet. Maybe something along the lines of "reduce added sugars." There is too much research out there that addresses the harms of eating added sugars to ignore it.
Submission Date 9/1/2004 1:34:00 PM
Author from Seattle, WA

Summary Be more specific on dangers of too much sugar.
Comments "Choose carbohydrates wisely for good health" is too general. The growing evidence regarding the bad effects of added sugars(soft drinks)necessitates more specific guidelines. Do not let the sugar industry influence the report.
Submission Date 9/1/2004 1:41:00 PM
Author from Bronx, NY

Summary Recommend "Reduce added sugars"
Comments As someone who attempts to eat healthfully, I feel that issuing a recommendation to the public like "Choose carbohydrates wisely" is useless for the average reader. To provide valuable assistance to the public, we should be told which types of carbohydrates should be chosen and which should be avoided. As the New York Times editorial suggests, "Reduce added sugars" would be far more helpful, unless it is true that the committee is unduly unfluenced by the sugars industry.
Submission Date 9/1/2004 2:14:00 PM
Author from Newark, DE

Summary
Comments What happened to saying we should limit the amount of sugar we eat? If 1980 guidelines said to avoid too much sugar why shouldn't we still say that rather than the mealy-mouthed "Choose your carbohydrates wisely." What a cop-out. You know what sugar does to our teeth & how fat too much sugar, especially in soft drinks, has made too many people. I'm skinny & am tired of all the costs fat people are adding to our health care. If you don't hit people over the head with plain nutrition advice they won't do the research necessary to make the wisest decisions. I eat a lot of junk, but I eat a LOT of fruit & vegetables too. Bravo for emphasizing fruits & vegetables. Now if we could just shift subisdies from sugar & corn to apples, cherries, asparagus, etc. it would be great.
Submission Date 9/1/2004 12:45:00 PM
Author from Montgomery, AL

Summary A more exact definition of healty carbohydrates is essential - people do not look at the ingredients in what they are eating - they think it is sufficient to look at nutritional facts.
Comments Sugar is a highly addictive substance - it should be limited in intake to only natural foods. A strong suggestion should be made to stay away from foods w/ added sugar (in all forms.)
Submission Date 9/1/2004 3:06:00 PM
Author from Brooklyn, New York

Summary Change “dental caries” to “caries” (all caries are dental caries) Use “potentially cariogenic” rather than “cariogenic,” which is an inaccurate term Change “sugar” to “sugars” to more accurately reflect the range of sugars that are potentially cariogenic (more detailed comments being mailed)
Comments September 7, 2004 TO: 2005 USDA Dietary Guidelines Advisory Committee FROM: Stephen J. Moss, DDS, MS Professor Emeritus, New York University College of Dentistry RE: 2005 USDA Dietary Guidelines Advisory Committee Report (Part D, Section 5, Question 1: Carbohydrates and Caries) As a lifelong oral health professional who has focused on caries prevention, particularly in children, I want to commend the Dietary Guidelines Advisory Committee on an enlightened and well-written report. Your sophisticated explanation of the relationship between intake of carbohydrates and caries (Part D, Section 5, Question 1) is of great service to the American public, as it clearly and concisely describes the multifactorial nature of the caries process. The following comments pertain to terminology. 1. Page 4, line 23 Change: “contributes to dental caries” To: “contributes to caries” (There are a variety of caries, e.g. active, buccal, compound, distal, fissure, incipient, etc., but all are dental caries.) _______________________________________________________ 2. Page 4, line 25 Change: “reduce the risk of dental caries” To: “reduce the risk of caries” _______________________________________________________ 3. Page 4, line 26 Change: “A combined approach of reducing the frequency and duration of exposure to fermentable carbohydrate intake” To: “Reducing the frequency of fermentable carbohydrate intake and optimizing…” 4. Page 4, line 27 Change: “most effective way to reduce caries incidence” To: “most effective way to reduce development of caries” 5. Page 4, line 32 Change: “of substrate by cariogenic bacteria in the mouth” To: “of substrate by plaque bacteria in the mouth to produce acid and subsequent demineralization of the enamel surface by the acid.” (Used alone, the terms “cariogenic” and/or “cariogenicity” are meaningless. The concept began as a prediction of how a particular food or group of foods would impact on the caries process. It is, at best, an educated guess and refers to the food rather than the bacteria. More meaningful terms in conveying the concept include “potential cariogenicity,” a prediction of how the author believes the fermentable carbohydrates in particular foods will impact the future development of caries. It takes in the multi-factorial nature of caries development. A second useful term is “relative cariogenicity,” which generally refers to a comparison test among a group of foods. They are tested against criteria such as oral retention, oral clearance, ability to demineralize enamel, ability to stimulate salivary flow, etc. Rat feeding studies are a good example of attempts to determine relative cariogenicity among a group of foods, but they are fraught with problems such as consistency of the food, the preference for certain foods by the animals and the fact that humans are not giant rats. For those reasons, those studies are seldom referenced today. There is actually no one test or group of tests that enable scientists, with any degree of certainty, to predict the potential cariogenicity of a food in humans.) 6. Page 4, line 35 Change: “available to the bacteria, and the susceptibility…” To: “available to the bacteria, salivary flow and the susceptibility…” 7. Page 5, line 1 Change: “much less cariogenic than other carbohydrates…” To: “are not as readily fermentable as other carbohydrates 8. Page 5, line 2 Change: “whether or not substituting sucrose with sugar substitutes…” To: “whether or not substituting sugar with sugar substitutes…” (Sugar substitutes can replace a range of sugars, not just sucrose, which is commonly known as “refined” or “table” sugar. _____________________________________________________ 9. Page 5, line 10 Change: “The longer a cariogenic substance remains in the oral cavity…” To: “The longer a fermentable carbohydrate remains in the oral cavity…” _______________________________________________________ 10. Page 5, line 22 Change: “Dental hygiene may have a greater role in the development of dental caries…” To: “Dental hygiene may have a greater role in the development of caries…” _______________________________________________________ 11. Page 6, line 6 Change: “The impact of sugar intakes on dental caries…” To: “The impact of sugars intake on caries…” (Colloquially, “sugar” typically refers to sucrose; all sugars have an impact on caries formation. 12. Page 6, line 33 Change: “had a higher score for dental caries…” To: “had a higher score for caries…”
Submission Date 9/17/2004 4:52:00 PM
Author Organization Name not Specified

Discretionary Calories
   General
Summary 2005 Dietary Guidelines for Americans looks great! I am extremely excited for this report to impact the individuals of America. Good luck sorting through all the comments!
Comments Dear Secretaries Veneman and Thompson: First of all, I just want to thank you for the opportunity to provide input for the 2005 Dietary Guidelines for Americans. I am currently a senior at Ball State University majoring in elementary education. As a future educator I feel individuals nutrition is imperative for classroom success! Thank you for caring for the people of America. I have always been a huge advocate of fat grams and proportion sizes in food. As I was reading this report, the section on Control Calorie Intake to Mange Body Weight grabbed my attention. This section comments on how calories control weight. Then it goes on to state how the proportion sizes of carbohydrate, fat, and protein in diets don’t matter. I agree with the statement on how calories control weight. But I disagree with how proportion sizes don’t matter. So is this saying an individual’s diet can consist of fatty foods, as long as they keep within there recommended calorie intake? The same goes for carbohydrate and protein. This would not be healthy for an individual. I feel a healthy diet consists of all areas of the food guide pyramid. My concern with this statement is that people will start focusing in on how many calories they consume, and not variety in their diet. This could be a problem. The right variety in a diet is crucial. Our society can become vulnerable to different trends that are diet related. I have seen it happen, for example the Atkins diet. My advice to you would be to take out the statement on how the proportions of carbohydrate, fat, and protein in diets don’t matter. Instead, I would include a statement on how people should control calorie intake by making smart choices within the food guide pyramid. The overall report looks great, and I am really excited! Again, I just want to thank you for the opportunity to here out my comment. Good luck! Sincerely,
Submission Date 9/21/2004 8:18:00 AM
Author from Anderson, Indiana

Summary recommendations to be in real food specifications sugar must be addressed with specifics as to decreased quantity
Comments I concur with letter sent to Ms McMurry Sept 21 signed by numerous professionals beginning with Garry Auld of Colorado State University. Information to the public must be in usable, specific information - not generalities. Sugar must be addressed as well as corn syrup, high fructose syrup, etc as the amount is being consumed in exageraged quantities
Submission Date 9/23/2004 4:31:00 PM
Author from Durango, Colorado

Summary NFPA recommends that the Departments approach the concept of “discretionary calories” cautiously.
Comments NFPA recommends that the Departments approach the concept of “discretionary calories” cautiously. We note that the report reflects some contradictory recommendations on this subject – the physical activity recommendations encourage increased activity, yet the “discretionary calorie” recommendations reflect only needs of sedentary individuals. This concept must be evaluated carefully with consumers to avoid interpretation as calorie permissiveness. “Discretionary calories” must be communicated with great care, if at all.
Submission Date 9/21/2004
Author National Food Processors Association

Summary Discretionary calories is a correct concept scientifically, but difficult educationally. This concept will undoubtedly be preferentially used against the obese while giving thin people the license to eat whatever they want, whether or not the nutritional value of their selected foods is adequate.
Comments Discretionary calories were implicit in all dietary advice before the Food Guide Pyramid. The assumption was that one would eat at least the recommend amounts of each food group. If more calories were needed the person would include some sugar or fat or simply eat more foods from the recommended groups. However, in the pasts 30 years the consumption of added sugars has increased, particularly sweetened beverage consumption [Haines, 2000, Putnam, et al., 2002]. The studies cited by the Committee indicate that practically everyone is eating more fat and sugar than recommended, not just those who are overweight or obese. Although it is a scientific fact that very few discretionary calories are available if one is sedentary, educationally it is a concept that is very difficult to handle. Sedentary and active people are found among those that have a normal BMI, as well as those who are considered overweight or obese [Farrell, et al., 2002, Lee, et al., 1999]. Therefore, there is no good way to tell if a person is sedentary based on whether they are thin or fat. Because of the ignorance of the public as to the true nature of obesity and the difficulty of permanently reducing weight [Stern et al., 1995], this concept will undoubtedly be preferentially used against the obese while giving thin people the license to eat whatever they want, whether or not the nutritional value of their selected foods is adequate. I can best sum up the problem with an incident that occurred about 40 years ago. Dr. Charlotte Young was my major professor for my Master’s studies and a very large woman. She did not own a car, and walked everywhere. One day there was a departmental birthday party. As people were leaving the room she was eating a ˝” wedge of birthday cake, the only piece of cake she had eaten during the celebration. One very thin person remarked in a loud voice as she walked out: “Imagine someone that fat eating cake”. Dr. Young was obviously hurt by the remark. She said to me: “You know, I am 5’ 10” tall and weigh 250 lbs. However, all my brothers and sisters weigh over 300 lbs.” Dr. Young’s area of expertise was obesity and she did everything we have always taught to control her weight. She was successful compared with other members of her family. Please do not turn in a report that foments the kind of ignorance and cruelty to which she was subjected. Farrell SW, Braun L, Barlow CE, Cheng YJ, Blair SN. 2002. The relation for body mass index, cardiorespiratory fitness, and all-cause mortality in women. Obes. Res. 10(6): 417-423. Haines PS. 2000. Consumer trends in fats and sweets: Policy options for dietary change. J. Food Distribution Res. 31(1): 32-38. Lee CD, Blair SN, Jackson AS. 1999. Cardiorespiratory fitness, body composition, and all-cause and cardiovascular disease mortality in men. Am. J. Clin. Nutr. 69(3):373-80 Putnam J, Allshouse J, Kanter LS. 2002. U.S. Per Capita Food Supply Trends: More Calories, Refined Carbohydrates and Fats. Food Review 25(3): 2-15. (Economic Research Service). Stern JS, Hirsch J, Blair SN, Foreyt JP, Frank A, Kumanika SK, Madans JH, Marlatt GA, St.Jeor ST, Stunkard AJ. Weighing the options: criteria for evaluating weight-management programs. The Committee to Develop Criteria for Evaluatin the Outcomes of Approaches to Prevent and Treat Obesity. Obes. Res. 3(6): 591-604.
Submission Date 9/26/2004 7:02:00 PM
Author from Mayagüez, ¨PR

Summary The Association acknowledges that advising the American public on the importance of achieving nutrient adequate diets is a very central consideration for Federal nutrition policy recommendations. We agree wholeheartedly that individuals should strive to meet their nutritional requirements within the
Comments The Association acknowledges that advising the American public on the importance of achieving nutrient adequate diets is a very central consideration for Federal nutrition policy recommendations. We agree wholeheartedly that individuals should strive to meet their nutritional requirements within their particular energy needs. We disagree, however, that nutrient adequacy can be achieved by following extremely restrictive and complicated meal patterns that fundamentally require individuals to exclude calories from individual macronutrients. The concept of discretionary calories is impractical because people don’t eat individual nutrients or calories, they eat foods. While certain foods could be considered “discretionary foods” whose intakes depend on an individual’s energy needs, the premise that all sugars are simply discretionary calories is flawed. For example, a candy bar may have fewer grams of sugars than a nutrient-rich yogurt. To eat within the discretionary calorie intake limits for sugars proposed by the Committee appears to be based totally on the supposition that sugars are an expendable ingredient in all foods. In order to meet this stringent advice for sugars intake, one would have to almost exclusively consume many nutrient-rich foods, such as cereals, yogurt and even peanut butter, that are sweetened only with artificial sweeteners. This could have unforeseen consequences, especially for children. Suggestions to designate added sugars as discretionary calories does not help average consumers make informed food choices, and may direct them to foods that may have fewer sugars but not fewer calories. The meal patterns developed by the USDA Center for Nutrition Policy and Promotion for revising the Food Guide Pyramid (Pyramid) are the mathematical calculations the Committee used for its suggested intake levels of discretionary calories for sugars. It is critical to reiterate that these meal patterns are based on mathematical formulas, not on scientific consensus of negative health impact from sugars intake. The mathematical model used to develop these meal patterns is established on attaining only the highest recommended micronutrient intakes (detailed explanation in section on added sugars and micronutrient displacement) without the benefits of our fortified and enriched food supply. Therefore, in order to consume the required upper levels of micronutrients, caloric intake is unnecessarily inflated. One consequence is sugars calories are artificially restricted. Furthermore, the Association would like to suggest that the current undue emphasis on upper intake amounts as the standard for defining micronutrient adequacy is inadequate for nutrition advice, and such food guidance policy may not achieve the primary goal of better overall health for the US public. In a recent review article, Dr. Cutberto Garza wrote about the importance of considering micronutrient toxicity in the development of revised dietary reference intakes. “It was clear that scientific, healthcare practitioners and consumer communities had moved beyond focused interest in the prevention of classical nutrient deficiencies.” “Related to this consideration was an appreciation of the unprecedented ability to manipulate nutrient intakes over wide ranges by increasingly common voluntary fortification of foods, increasing and expanding uses of nutrient supplements and nutrient-related botanicals, and the growing likelihood of expanded capabilities to alter the nutritional characteristics of food crops and animals by genetic modification. These on-going and anticipated changes in food supply raised concerns regarding the evidence base justifying the putative benefits of intake levels higher than necessary to prevent classical deficiency diseases and to possibilities of more easily reaching toxic levels of nutrients in diets easily accessible to the public.” (Emphasis Added) The Association would like to emphasize its strongly held position. The Pyramid’s mathematical model lacks the scientific underpinning to be used as the basis to make official or unofficial quantitative recommendations for levels of added sugars intake. This is also the conclusion of the American Dietetic Association (ADA) in its revised position paper on nutritive and non-nutritive sweeteners. After providing a detailed description of the paradigm of the Pyramid, ADA concluded, “Thus, the suggestion of 6% to 10% of energy from added sugars was not based on any scientific evidence regarding health impacts but was calculated using the Food Guide Pyramid.” Therefore, we ask the Agencies to re-evaluate the practical implications, as well as the scientific basis, for promoting the concept of discretionary calories based solely on the Pyramid’s proposed meal patterns in issuing guidelines for sugars intake.
Submission Date 9/27/2004
Author Sugar Association

Summary The upcoming edition of the Dietary Guidelines should emphasize the Committee’s conclusion that calorie intake, not macronutrient composition, is the critical factor for managing weight. We believe the concepts of discretionary and essential calories will be difficult to communicate to consumers. T
Comments General Mills appreciates the Committee’s focus on weight management throughout the report and commends the committee for promoting science-based approaches such as increasing intake of whole grains, fruits and vegetables. The scientific evidence supporting these strategies will continue to grow as more emphasis is placed on the health benefits of these foods. The upcoming edition of the Dietary Guidelines should also emphasize the Advisory Committee’s conclusion that calorie intake, not macronutrient composition, is the critical factor for weight maintenance/weight loss. This message enables consumers to select foods from all food groups, thus contributing to a more balanced intake of nutrients. We believe that consumer testing will be critical to determine how best to communicate and motivate consumers about the importance of calories. General Mills is concerned about the consumer appropriateness of the concepts of discretionary and essential calories. We believe that it will be difficult to communicate these concepts to consumers without stigmatizing foods that have been part of the American diet for many years. The strong emphasis on limiting foods with fat and added sugar reduces flexibility in diet planning and may not lead to improved nutrient intakes. As mentioned in the report, research shows that individuals who consume a moderate amount of added sugar (5-10% of calories) have higher intakes of certain micronutrients than those who consume fewer calories from added sugar. This may be because added sugar (and fat) can improve the palatability of many nutrient-rich foods. The Dietary Guidelines should aim to communicate that all foods can fit into a diet rather than reinforcing “good food/bad food” messages. This is an ideal opportunity to educate consumers about the importance of portion size and calorie content when making food choices. General Mills commends the Advisory Committee for reviewing relevant scientific literature and developing physical activity recommendations for adults and children. We strongly believe that a guideline for physical activity should be included in the upcoming Dietary Guidelines. Scientific studies show that physical activity and appropriate food choices form the foundation of a healthy lifestyle. Balancing energy intake and energy expenditure is increasingly important given the high prevalence of overweight/obesity and other associated health conditions and chronic diseases in the US. Developing consumer messages related to energy balance, however, will likely be a significant challenge. Nevertheless, we encourage the Communications Committee to commit to this endeavor since meaningful, motivational messages about the relationship between “calories in” and “calories out” have great potential to improve the health of Americans.
Submission Date 9/27/2004
Author General Mills

Summary The issue of discretionary calories and how to effectively communicate it to consumers will be a difficult problem to deal with when composing the Dietary Guidelines, and in the future, the food Guide Pyramid.
Comments The issue of discretionary calories and how to effectively communicate it to consumers will be a difficult problem to deal with when composing the Dietary Guidelines, and in the future, the food Guide Pyramid. We are concerned that the concept will be confusing to consumers, especially when it seems to restrict foods that provide many nutrients, such as whole milk. If this seen as a punishment for an individual’s weight or inactivity, consumers could tune out this detail, along with the entire positive message of the Dietary Guidelines.
Submission Date 9/21/2004
Author International Dairy Foods Association

Energy Balance/Weight Management
   Weight maintenance
Summary We suggest that the main message regarding calories reflect the fact that most Americans are overweight and over consuming calories relative to their physical activity levels. The message about calorie intake could be edited to something like, limit calorie intake to manage body weight.
Comments We suggest that the main message regarding calories reflect the fact that most Americans are overweight and over consuming calories relative to their physical activity levels. The message about calorie intake could be edited to something like, limit calorie intake to manage body weight.
Submission Date 9/21/2004
Author Center for Science in the Public Interest

Summary We agree with the committee’s conclusion that “When it comes to weight control, calories do count – not the proportion of carbohydrate, fat and protein in the diet. The healthiest way to reduce calorie intake is to reduce one’s intake of saturated fat, added sugars, and alcohol…” This should be th
Comments We agree with the committee’s conclusion that “When it comes to weight control, calories do count – not the proportion of carbohydrate, fat and protein in the diet. The healthiest way to reduce calorie intake is to reduce one’s intake of saturated fat, added sugars, and alcohol…” This should be the overarching message regarding weight management.
Submission Date 9/27/2004
Author U.S. Rice Federal

   Energy density
Summary In summray, I think the term "low fat soups" should be omitted. Soups provide the consumer with a higher sodium content and a low satiety value. I would replace that area and sugges the consumer choose, whole raw fruits and vegetables, dairy products, or whole grains.
Comments I would like to comment, however, on the area in the executive summary titled: Control Calorie Intake to Manage Body Weight. In the summary it states, “consuming large portions of raw vegetables or low fat soups may help limit one’s intake of other foods that are more energy dense.” I feel that this is strongly misleading, contradictory to other sections of the document, and most notably, false. Indeed, the part about consuming raw vegetables is true and important. However, I do not agree with the “low fat soup” comment. For an average American, the word soup immediately causes the consumer to think of a can of soup. Canned goods are generally higher in sodium content, and a simple can of condensed chicken noodle soup contains 175 calories, 4.5 g of fat and 890mg of sodium. While the soup is low-fat, it is not low sodium. Throughout the summary, there is consistent talk of reducing sodium in the diet, and this is surely not the best advice on limiting sodium or controlling caloric intake. The soup is a made up mostly of liquid content. This is not effective in providing a high satiety value. The consumer will most likely eat the soup and be hungry within an hour due to the lack of satiety. I recommend altering this section of the document and offer consumption of raw fruits and vegetables or a serving of a dairy product or whole grain product. By stating these choices instead, the consumer will ingest more essential vitamins and minerals and they will be eating foods that certainly provide a higher satiety value than a can of condensed soup. In turn, the consumer’s caloric intake will be lowered due to consuming foods that keep one fuller for a longer period of time and avoid excessive snacking or excessive portions at meal time.
Submission Date 9/26/2004 11:49:00 PM
Author from Muncie , IN

   Macronutrient ratios
Summary There is no conclusive evidence from epidemiologic studies that dietary fat intake promotes the development of obesity independently of total energy intake.
Comments There is no conclusive evidence from epidemiologic studies that dietary fat intake promotes the development of obesity independently of total energy intake. Many researchers now recognize that one of the most important factors in preventing weight gain involves the total amount of calories consumed; when a significant portion of these calories come from healthy fats, the body experiences satiety and overall caloric intake is reduced.
Submission Date 9/21/2004
Author Weston A Price Foundation

Summary We concur with the committee's statement that “Weight maintenance depends on a balance of energy intake and energy expenditure, regardless of the proportions of carbohydrate, fat and protein in the diet. Popular weight-loss diets encompassing a very wide range of carbohydrate/fat ratios have not bee
Comments We concur with the committee's statement that “Weight maintenance depends on a balance of energy intake and energy expenditure, regardless of the proportions of carbohydrate, fat and protein in the diet. Popular weight-loss diets encompassing a very wide range of carbohydrate/fat ratios have not been tested adequately over the long term and are best followed only for short periods of time
Submission Date 9/21/2004
Author North American Miller's Association

   Weight maintenance
Summary We urge the Committee to be explicit in its recommendations regarding food choices and dietary patterns that help support weight management and that focus on choosing nutrient-dense foods. The simple, over-riding message, and one understandable to the public, would be to choose foods of high nutri
Comments To help reduce consumer confusion and frustration regarding food choices - especially in light of the latest diet trends - we urge the Committee to be explicit in its recommendations regarding food choices and dietary patterns that help support weight management and that focus on choosing nutrient-dense foods. This will offer the public a much more coherent and practical means by which to achieve a healthy diet and to maintain a healthy weight. We suggest that each message that addresses intake of calories, carbohydrates, fats, and choice of foods be presented first in the context of controlling weight – specifically, that these main messages each include parallel language that states “to help manage body weight”. For each of these messages, details should then be provided regarding specific practical recommendations to choose appropriate amounts of nutrient dense, lower calorie choices, rather than choosing less healthy, more calorically-dense foods within each food group.
Submission Date 9/21/2004
Author American Diabetes Association

Summary Suggest retuning to "aim for a healthy weight" and omit the use of the word "control." It carries too many negative connotations if the "control intake" guidleline is not met.
Comments Suggest not using the word “control.” The word “control” tends to set people up for failure- uncontrolled. Suggest changing back to “aim for a healthy weight” & not use “control intake-” when people loose weight, but are unable to reach/maintain a specific weight- adding in the term control will set them up for continued failure. It denotes that they are unable to “gain control” of their lives (out of control) and thus, they must deal with the consequences.
Submission Date 9/23/2004 11:59:00 AM
Author OSU Extension Program- Cleveland, OH

   Weight loss
Summary Leading health organizations promote the benefits of citrus, including the American Heart Association, American Cancer Society, the National Cancer Institute and the Produce for Better Health Foundation.
Comments One of the key messages is: Control calorie intake to manage body weight. As a nutrient-rich food, substituting citrus fruits for nutrient-poor foods helps achieve recommended nutrient intake without excess calories. One medium-size orange contains just 80 calories and has been shown to suppress hunger levels for up to four hours after eating . New research from the Nutrition and Metabolic Research Center at Scripps Clinic shows that consuming half of a fresh grapefruit before meals can result in significant weight loss.
Submission Date 9/24/2004 5:18:00 PM
Author Sunkist Nutrition Bureau

   Weight maintenance
Summary PBH supports the emphasis on nutrient density and the unique role of fruits and vegetables in weight management. We hope that this important concept will be better communicated to consumers.
Comments PBH supports the emphasis on nutrient density and the unique role of fruits and vegetables in weight management. We hope that this important concept will be better communicated to consumers and that more specific examples of substituting fruits and vegetable for energy dense-nutrient poor food choices are provided. PBH would welcome the opportunity to help expand Table E-9: Ways to Increase Consumption of Fruits and Vegetables, by providing actionable ways that consumers can increase the variety of fruits and vegetables especially dark green and orange ones, such as through the successful PBH Color Way Campaign and hope it can be included in the consumer document. Simple, positive and specific examples of how to incorporate more fruits and vegetables into the diet will be welcome by consumers who are constantly reminded of what they should NOT eat. Emphasizing a more positive message including the need for consumers to “SWITCH” to more nutrient-rich, and low calorie fruits and vegetables, will also help consumers meet the higher fruit and vegetable recommendations.
Submission Date 9/24/2004 1:23:00 PM
Author Produce for Better Health Foundation

Summary The Council urges HHS to include statements in the 2005 Dietary Guidelines acknowledging that intense sweeteners are low in calories and the usefulness of reduced calorie products containing them, as well as fat-free and low-fat products that are also reduced in calories.
Comments September 24, 2004 Kathryn McMurray HHS Office of Disease Prevention and Health Promotion Office of Public Health and Science Suite LL100 1101 Wootton Parkway Rockville, MD 20852 RE: 2005 Dietary Guidelines for Americans Dear Ms. McMurray: The Calorie Control Council (the “Council”) is an international association of manufacturers of low-calorie, light, and special dietary foods and beverages, including the manufacturers of a variety of sweeteners, fat replacers and other low-calorie ingredients used in these foods. The Council commends the 2005 Dietary Guidelines Advisory Committee for its diligence and comprehensive report. The Council, is concerned, however, that the report made no mention of the safe and appropriate use of sugar substitutes and fat replacers. The Council urges HHS to include statements in the 2005 Dietary Guidelines acknowledging that intense sweeteners are low in calories and the usefulness of reduced calorie products containing them, as well as fat-free and low-fat products that are also reduced in calories. For example, the 2000 Dietary Guidelines did acknowledge the role of sugar substitutes stating: “Sugar substitutes, such as saccharin, aspartame, acesulfame potassium, and sucralose are extremely low in calories. Some people find them useful if they want a sweet taste without the calories. Some foods that contain sugar substitutes, however, still have calories. Unless you reduce the total calories you eat or increase your physical activity, using sugar substitutes will not cause you to lose weight.” The consumer, as well as the food and beverage industry, is fortunate to now have five low-calorie sweeteners (the four mentioned above plus neotame) and several reduced calorie sweeteners and fat replacers from which to choose. This variety of low-calorie ingredients allows the calorie control industry to use the ingredient, or combination of ingredients, best suited for a given product. According to the Council’s 2004 Light Products Survey, 198 million adult Americans use light products, i.e., low-calorie, sugar free and/or reduced fat products. More than eight out of ten of these consumers say they want additional light products from which to choose. Low-calorie sweeteners, fat replacers and the reduced-calorie products containing them provide good taste without the calories of their full calorie counterparts. Studies demonstrate, for example, that when sucrose is covertly replaced with low-calorie sweeteners non-dieting obese and normal weight individuals incompletely compensate for the calorie reduction. In other words, they eat fewer calories. Importantly, it has been demonstrated that multidisciplinary weight control programs that include the use of reduced-calorie foods and beverages may facilitate weight loss and weight maintenance. The Advisory Committee cites one (Raben et al., 2002) of the number of studies, which demonstrate that reduced calorie products may be useful in weight control and weight maintenance. In its 2004 updated position paper, “Use of Nutritive and Nonnutritive Sweeteners,” the American Dietetic Association concludes that “High-intensity sweeteners can offer consumers a way to enjoy the taste of sweetness with little or no energy and or glycemic response. Nonnutritive sweeteners may assist in weight management, control of blood glucose, and prevention of dental caries.” The Calorie Control Council urges HHS to reconfirm the safe and appropriate use of FDA approved low-calorie sweeteners and fat replacers and state that the use of reduced-calorie foods in place of their full calorie counterparts can assist in weight management efforts. The Council would be pleased to provide additional information upon request. Respectfully submitted, Lyn O’Brien Nabors Lyn O’Brien Nabors Executive Vice President
Submission Date 9/24/2004 4:27:00 PM
Author Calorie Control Council

   Portion Sizes
Summary Simpler portion measurement.
Comments Portion size should be described in a simpler format, other than use of measuring tools. Example: A serving size of protein is equal to the size of your palm.
Submission Date 9/19/2004 12:01:00 PM
Author Seton Hill University

Summary Simpler portion measurement.
Comments Portion size should be described in a simpler format, other than use of measuring tools. Example: A serving size of protein is equal to the size of your palm.
Submission Date 9/19/2004 12:03:00 PM
Author from Greensburg, PA

   Weight maintenance
Summary Please consider revising the Nutrition Facts label to reflect any decreases in recommended total calories for the day. 1800 might be a better level for the daily values to reflect. Thank you.
Comments Recommended calories and other nutrients are listed in table format by age and gender. Just wondering if the Nutrition Facts Label will reflect different total calories. (Currently labels lists 2000 and 2500 calories; and % daily value is based on 2000 calories a day)
Submission Date 9/21/2004 3:58:00 PM
Author Anonymous

Summary
Comments I submit the following 2005 Dietary Guidelines concerns for consideration by the expert committee. It has been my experience when working with patients as well as their care providers that little is understood about the recommended energy requirements. Physicians refer patient to Weight Watchers simply because of availability and it seems any prgram is preferred to no program. I realize you are well aware of the pit falls of weight cycling. Please consider stressing the importance of adequate calories to address those who cut below recommendations in the hope for a rapid weight loss. All the guidelines about adequate carbs but not too many, and the restrictions on fat etc. are great but we skip over education and recommendation on adequate caloreis. I believe the studies by Ancel Keyes from the U of Minnesota should alert us to the probelm with undernutirion and starvation effects. We see so much that addressed overeating and I beleive we can create a positive psychological effect by stressing the importance of getting enough calories. I still see recommendations for 500- 1200 calories orderd by physician. Thank you for your consideration and all the work you do on behalf of the guidelines.
Submission Date 9/22/2004 10:43:00 AM
Author from Fargo , ND

   Energy density
Summary In closing, we would like to point out that avocados are included in dietary programs from many of the world’s leading nutrition organizations including.
Comments Control calorie intake to manage body weight. As a nutrient-rich food, substituting avocados for nutrient-poor foods helps achieve recommended nutrient intake without excess calories.
Submission Date 9/17/2004 5:25:00 PM
Author California Avocado Commission

Summary Avocados are a natural source of eight vitamins, two minerals and at least three phytochemicals. Avocados are included in dietary programs from many of the world’s leading nutrition organizations and can make a significant contribution to the health of Americans.
Comments One of the 9 key messages is: Consume a variety of foods within and among the basic food groups while staying within energy needs. Avocados are a naturally nutrient-dense fruit that can help Americans increase their intake of carotenoids, vitamins E and C, magnesium, potassium, and fiber. As the top-ranking fruit source for folate, avocados can help adolescent females and women of childbearing age meet their needs for folic acid.
Submission Date 9/17/2004 5:48:00 PM
Author California Avocado Commission

Summary In closing, we would like to point out that avocados are included in dietary programs from many of the world’s leading nutrition organizations including.
Comments Control calorie intake to manage body weight. As a nutrient-rich food, substituting avocados for nutrient-poor foods helps achieve recommended nutrient intake without excess calories.
Submission Date 9/17/2004 6:07:00 PM
Author California Avocado Commission

   Weight maintenance
Summary Based on about five years' of personal experience, I recommend that your panel consider the blood type diet developed by Dr. Peter D'Adamo and described in his book, "Eat Right 4 Your Type."
Comments Based on about five years' of personal experience, I recommend that your panel consider the blood type diet developed by Dr. Peter D'Adamo and described in his book, "Eat Right 4 Your Type." I have found his system, which keys dietary recommendations to one's blood type, to be instrumental in strengthening my immune system and maintaining a healthy weight and cholesterol levels. Since going on the diet, my productivity at work is much higher, I recover from minor illnesses more rapidly, and sick days are almost nonexistent. Dr D'Adamo has summarized extensive clinical and research experience that conclusively demonstrates the efficacy of this system.
Submission Date 9/1/2004 9:32:00 AM
Author Anonymous

Fats
   Monounsaturated Fat
Summary Avocados are a natural source of eight vitamins, two minerals and at least three phytochemicals. Avocados are included in dietary programs from many of the world’s leading nutrition organizations and can make a significant contribution to the health of Americans.
Comments One of the 9 key messages is: Choose fats wisely for good health. Avocados are one of the few fruits that provide “good” fats. Unsaturated fat like monounsaturated fat (MUFA) found in avocados has been linked to a reduced risk of heart disease, cancer and diabetes. If equal amounts of MUFAs are substituted for saturated fatty acids, low-density lipoprotein (LDL) or “bad” cholesterol decreases.
Submission Date 9/17/2004 5:45:00 PM
Author California Avocado Commission

   Alpha-Linolenic Acid
Summary The evidence for CHD benefit for ALA is weak, and that for increased prostate cancer risk is growing and cannot be ignored. Further research is needed. A UL for ALA at current intakes should be considered. ALA should not be conflated with EPA+DHA. Recommending two oily fishmeals a week is applauded.
Comments Comments on n-3 fatty acids section of the Draft Dietary Guidelines Question 6 (p. 22) Three papers are quoted supporting a beneficial CHD effect of ALA – Djousse1, Hu2, and Dolecek3. Other supportive studies by Pietinen4 and Ascherio5 are not mentioned. These were all epidemiological studies in which ALA intakes were estimated from diet surveys. Oomen et al.6 did essentially the same in the Netherlands and found no effect of ALA intake on 10-year CHD risk. This study is not mentioned. In the latter, there may have been some confounding by trans FA intakes, but there was still no association with reduced risk for CHD for foods containing ALA but no trans FA. An objective review cannot ignore negative studies and embrace only the positive ones. Two secondary prevention RCTs are mentioned: Singh7 and de Lorgeril8. They both are problematic. The former is a highly questionable study and uninterpretable for several reasons: 1. Based on the reported relative risk reductions given in Table 3, the ONLY significant effect was observed for fish oil and total cardiac events. There was no significant effect of the ALA rich oil on any endpoint. Unfortunately, also in Table 3, there are p-values associated with each intervention for each cardiac endpoint (sudden cardiac death, total cardiac deaths, non-fatal MI, and total cardiac events). In contradiction to the above, for all but the first endpoint, the authors indicate that both fish oil and ALA had statistically significant effects relative to placebo! Yet in the next columns in the same table, they report no significant effect. So it is unclear whether either fish oil or ALA had any statistically significant impact on cardiac events in this study. 2. The 1-year total cardiac event rates in the fish oil and mustardseed oil groups were given as the sum of the total cardiac deaths and non-fatal reinfarctions. For the placebo group, there were 26 cardiac deaths (22% of the group) and 30 non-fatal reinfarctions (25%) for a total of 56 events (47% of the group). But Table 3 lists 41 total cardiac events (37%). Something is wrong, not only with the math but also with the death rates. 3. The authors report phenomenal event rates in this study, especially considering that these patients were only ‘suspected’ of having had a heart attack at admission. In the GISSI Prevenzione study, total cardiac event rates were 1.4% per year and all patients in that study had documented MI’s. In the Lyon Heart Study (below), the rate was 4%. Here the total cardiac event rates were 25% and 47%. There is either something incredibly toxic about either living (or being admitted to the hospital) in Moradabad, or the data are suspect. In any event, this study cannot be used to support the claim that ALA (or fish oil) is cardioprotective. It should have no place in this document. Although a much better study, the Mediterranean diet heart (Lyon) study8 can likewise not be used to conclude that ALA is cardioprotective. There are multiple dietary alterations in the intervention group, and to attribute the benefits to ALA is wishful thinking, not objective science. It is interesting to contrast how the writers dealt with the the Natvig study9 and the Lyon study. The former did not find a beneficial effect of 5 g of ALA per day in a very large (13,578, 50-59 year old men were randomized) but short (1-year) primary prevention study. The writers state on p. 23, “Notably, the two diets [in Natvig] differed in other ways related to [than?] the unique fatty acid profiles of linseed oil and sunflower oil.” First, there is no evidence in the Natvig paper that the diets were different in “other ways.” The subjects were simply randomized to sunflower seed oil or linseed oil and no recommendation for any other dietary change was made. Secondly, why is this (unfounded) criticism considered a weakness of the Natvig study, but in the Lyon study, where diets were very different by protocol, it is not criticized? In Lyon, at least 8 types of foods (breads, fruits, vegetables, legumes, deli and regular meats, butter, cream and margarine) were intentionally altered so as to reduce risk in the intervention group. Yet this is not considered a weakness? The bias toward favorable studies is rather blatant here. Similarly, significant ink is expended by the DGAC authors to explain why the well-controlled, 2-yr, RCT by Bemelmans et al.10 did not show a reduction in CHD risk factors. Maybe no effect was found because no effect was elicited by the intervention. Why was such a critical eye cast upon the studies that failed to show a protective effect of ALA and flawed but favorable studies receive a blind eye? Significantly, the DGAC authors failed to include several case-control studies that reported the relationship between tissue or plasma ALA content and risk for a variety of CHD outcomes. In 10 studies11-21 no association was found, whereas in one22, serum ALA levels were lower in cases than controls. Why were these studies not included? The same trend continues with the potential association between ALA and prostate cancer risk, only here the tendancy to dismiss, not neutral trials, but those suggesting increased cancer risk. This is especially disconcerting. In the meta-analysis of both CHD and prostate cancer with ALA by Brouwer et al.23, the combined relative risk was not significantly different from 1 for CHD but it was significantly increased in for prostate cancer. There were 5 CHD studies included and 9 cancer studies. The unbiased conclusion would be that ALA has no effect on CHD risk but may increase risk for prostate cancer. But the DGAC committee reversed it. They concluded that ALA is cardioprotective, and that the cancer connection “requires further research.” It’s one thing to mistakenly (implicitly) recommend higher intakes of a nutrient in the hopes that CHD risk will be reduced when there is little risk associated with this recommendation. It is quite another to dismiss a larger body of evidence of increased risk for cancer with increased ALA intakes and still paint ALA with a golden glow. The Dietary Guidelines committee have a grave obligation to “first do no harm”, that is, to be especially conservative when recommending increased intakes of a nutrient (or at least painting the nutrient as being “healthy” which will certainly encourage increased intake) for which there is suggestive evidence of harm. The situation with ALA, CHD and prostate cancer may be summarized as follows: Evidence for Reduced Risk for CAD: Cohort/Case-Control Studies (diet record based studies, 5 positive and 1 negative; biomarker based studies, 1 positive and 10 negative). RCT primary prevention trials, 2 negative; RCT secondary prevention trials, 2 inconclusive. DGAC Conclusions: “ALA is cardioprotective”. Evidence for Increased Risk for Prostate cancer: Cohort/Case-Control Studies (diet record based studies, 4 positive and 2 negative; biomarker based studies, 3 positive and 2 negative). RCT primary or secondary prevention trials, none reported. DGAC Conclusions: “More research is needed.” Harris recommended language: ALA may have cardioprotective properties but further research is needed. Higher ALA intakes may be associated with increased risk for prostate cancer, but further research is needed. At present there is no basis for recommending any change in the current ALA intake, and an UL set at current intake levels should be considered. There appears to be a strong bias favoring ALA in these Guidelines. The supporting evidence is accepted uncritically while the non-supportive studies are picked apart and dismissed. In some cases, negative studies are criticized for design elements that are more greviously found in the supportive studies (Natvig vs. de Lorgeril). The epidemiological studies which suggested an increase in cancer risk were just a rigorously conducted, and in one case used essentially the same diet questionnaire (Hu for CHD and Giovannucci24 for cancer) as the studies reporting CHD benefit. Prudence would demand that increased consumption of ALA not be promoted in any way until the cancer question is settled. There is, in fact, reason to consider capping ALA intake at current levels (see UL discussion below). ALA=EPA+DHA? The evidence for ALA and CHD risk reduction is at best suggestive but far less compelling than that for the longer chain n-3 FA. There is no justification for conflating these two types of n-3 FA or implying anywhere in the document that they have equivalent effects. (see P22 para 5; P24, para 3; P25 para 2; P28 para 7). P24 EPA, DHA and Fish Overview The final sentence should be scratched. Next para, line 2: scratch “to” No UL for ALA. There is no mention here of the potential cancer risk. A conservative approach would be to suggest a tentative UL at what is the current upper level of typical American intakes. There is certainly no basis for recommending increased intakes since the CHD data is incomplete, and there is a definite concern about higher intakes potentially being linked to prostate cancer. Until we know more about the latter, a UL could reasonably be set for ALA. P25 Review of the Evidence Near the end, ALA is again interjected in company with n-3 HUFA. Scratch Para 3: line 1: “two servings of high n-3 fish per week” Line 3: “two servings of tuna/other non-fried fish per week…” P26 Line 2. … the relative risks for total stroke were very slightly higher than those for CHD mortality at each level of fish intake.” This is confusing. Simply say, “…the relative risks for total stroke were reduced at each level of fish intake.” Para 2: Under discussion of Singh, the weaknesses of the study should be included (or referred to from the ALA section), and the implication that mustard oil reduced cardiac events etc needs to be removed Para 3: only two nonconforming studies?? There are several others including Pietinen4, Morris25, Osler26, Ascherio27, and Salonen28. The latter showed that one of the confounders, besides those listed here, is mercury. P27 Para3: 500 mg is a 2-fold increase?? On p 28, mean intakes are about 110 mg/d. Adverse effects are not routinely seen at 3 g as implied here. Better to say, “According to the FDA, an intake of up to 3 g of EPA+DHA per day is considered safe for all adults.” P 28 Summary. Line 4. Better to simply say, “Fish is recommended because it is a good source of n-3 fatty acids and other nutients.” There is no reason to mention supplements here, or to imply that supplements have not been shown to reduce risk for CHD events - supplements were used in the GISSI study and shown to be effective. If the DGAC authors want to continue to include the 1997 Singh study as well, then supplements were also reported to be effective there. n-3 FA intake Para 3. Median intakes of EPA are 4-7 mg/d and of DHA, 52-93 mg/d. In Para 4, mean intakes are 40 and 70 mg/d, respectively. If these numbers are true, then the statement on p. 27 para 3, that 500 mg of EPA+DHA/d would be a two-fold increase over current intake would be false; it would be about a 5x increase over current intake. Para 5. In the 2nd to last line, n-fatty acids needs a “3”. Para 6. Line 1. Presumably the authors meant to say “Some foods are fortified…” Also, in line 2, it is not true that foods are fortified with algae, but with DHA (not EPA) purified from algal sources. In addition, what does “EPA+DHA supplements may provide variable amounts of these FA” mean? True, some capsules contain 300 mg and some 600 mg (by intent and as described on the label) but the Consumer’s Report article concluded that label claims were generally correct. Better to simply say, “EPA+DHA are available in supplements in various concentrations and in variable EPA:DHA ratios.” Again, the evidence for ALA is not objectively presented. The authors have ignored the work of Pawlosky et al.29,30 from the NIH who have performed the most sophisticated analysis of ALA conversion to EPA and DHA. They (alone) have used multicompartmental modeling (instead of area under the curve analysis for the accumulation of n-3 FA metabolites in plasma) to determine the rates of conversion of ALA to the long-chain n-3 FA. They reported conversion rates to EPA of 0.2% and to DHA of 0.047%. The Report says “approximately 10%.” Summary ALA should not be endorsed as CHD protective given the thin evidence for benefit and the growing concerns with prostate cancer. Further research is needed, not glowing recommendations. An upper limit of ALA at current intakes should be considered. ALA should never be conflated with EPA+DHA. The recommendation for two oily fish meals a week is applauded. Reference List (1) Djousse L, Pankow JS, Eckfeldt JH, Folsom AR, Hopkins PN, Province MA et al. Relation between dietary linolenic acid and coronary artery disease in the National Heart, Lung, and Blood Institute Family Heart Study. Am J Clin Nutr 2001; 74:612-619. (2) Hu FB, Stampfer MJ, Manson JE, Rimm EB, Wolk A, Colditz GA et al. Dietary intake of a-linolenic acid and risk of fatal ischemic heart disease among women. Am J Clin Nutr 1999; 69:890-897. (3) Dolecek TA. Epidemiological Evidence of Relationships between Dietary Polyunsaturated Fatty Acids and Mortality in the Multiple Risk Factor Intervention Trial. Proc Soc Exper Bio Med 1992; 200:177-182. (4) Pietinen P, Ascherio A, Korhonen P, Hartman AM, Willett WC, Albanes D et al. Intake of Fatty Acids and Risk of Coronary Heart Disease in a Cohort of Finnish Men. The Alpha-Tocopherol, Beta-Carotene Cancer Prevention Study. Am J Epidemiol 1997; 145:876-887. (5) Ascherio A, Rimm EB, Giovannucci EL, Spiegelman D, Stampfer MWWC. Dietary fat and risk of coronary heart disease in men: cohort follow up study in the United States. BMJ 1996; 313:84-90. (6) Oomen CM, Ocke MC, Feskens EJ, Kok FJ, Kromhout D. alpha-Linolenic acid intake is not beneficially associated with 10-y risk of coronary artery disease incidence: the Zutphen Elderly Study. Am J Clin Nutr 2001; 74:457-463. (7) Singh RB, Niaz MA, Sharma JP, Kumar R, Rastogi V, Moshiri M. Randomized, Double-Blind, Placebo-Controlled Trial of Fish Oil and Mustard Oil in Patients with Suspected Acute Myocardial Infarction: The Indian Experiment of Infarct Survival--4. Cardiovasc Drugs Ther 1997; 11:485-491. (8) de Lorgeril M, Salen P, Martin JL, Renaud S, Monjaud I, Mamelle N et al. Mediterranean diet, traditional risk factors, and the rate of cardiovascular complications after myocardial infarction: Final report of the Lyon Diet Heart Study. Circulation 1999; 99:779-785. (9) Natvig H, Borchgrevink CF, Dedichen J, Owren PA, Schiotz EH, Westlund K. A controlled trial of the effect of linolenic acid on incidence of coronary heart disease. The Norwegian vegetable oil experiment of 1965-66. Scand J Clin Lab Invest 1968; 105 (Suppl):1-20. (10) Bemelmans WJ, Broer J, Feskens EJ, Smit AJ, Muskiet FA, Lefrandt JD et al. Effect of an increased intake of alpha-linolenic acid and group nutritional education on cardiovascular risk factors: the Mediterranean Alpha-linolenic Enriched Groningen Dietary Intervention (MARGARIN) study. Am J Clin Nutr 2002; 75:221-227. (11) Albert CM, Campos H, Stampfer MJ, Ridker PM, Manson JE, Willett WC et al. Blood levels of long-chain n-3 fatty acids and the risk of sudden death. N Engl J Med 2002; 346:1113-1118. (12) Lemaitre RN, King IB, Mozaffarian D, Kuller LH, Tracy RP, Siscovick DS. N-3 polyunsaturated fatty acids, fatal ischemic heart disease and non-fatal myocardial infarction in older adults. The Cardiovascular Health Study. Am J Clin Nutr 2002; 76:319-325. (13) Lea EJ, Jones SP, Hamilton DV. The fatty acids of erythrocytes of myocardial infarction patients. Atherosclerosis 1982; 41:363-369. (14) Lemaitre RN, King IB, Raghunathan TE, Pearce RM, Weinmann S, Knopp RH et al. Cell membrane trans-fatty acids and the risk of primary cardiac arrest. Circulation 2002; 105:697-701. (15) Yli-Jama P, Meyer HE, Ringstad J, Pedersen JI. Serum free fatty acid pattern and risk of myocardial infarction: a case-control study. J Intern Med 2002; 251:19-28. (16) Leng GC, Horrobin DF, Fowkes FG, Smith FB, Lowe GD, Donnan PT et al. Plasma essential fatty acids, cigarette smoking, and dietary antioxidants in peripheral arterial disease. A population-based case-control study. Arterioscler Thromb 1994; 14:471-478. (17) Reavis SC, Chetty N. The fatty acids of platelets and red blood cells in urban black South Africans with myocardial infarction. Artery 1990; 17:325-343. (18) Paganelli F, Maixent JM, Duran MJ, Parhizgar R, Pieroni G, Sennoune S. Altered erythrocyte n-3 fatty acids in Mediterranean patients with coronary artery disease. Int J Cardiol 2001; 78:27-32. (19) Siguel EN, Lerman RH. Altered fatty acid metabolism in patients with angiographically documented coronary artery disease. Metabolism 1994; 43:982-993. (20) Leng GC, Taylor GS, Lee AJ, Fowkes FG, Horrobin D. Essential fatty acids and cardiovascular disease: the Edinburgh Artery Study. Vasc Med 1999; 4:219-226. (21) Simon JA, Hodgkins ML, Browner WS, Neuhaus JM, Bernert JT, Jr., Hulley SB. Serum fatty acids and the risk of coronary heart disease. Am J Epidemiol 1995; 142:469-476. (22) Miettinen TA, Naukkarinen V, Huttunen JK, Mattila S, Kumlin T. Fatty-acid composition of serum lipids predicts myocardial infarction. Br Med J 1982; 285:993-996. (23) Brouwer IA, Katan MB, Zock PL. Dietary alpha-linolenic acid is associated with reduced risk of fatal coronary heart disease, but increased prostate cancer risk: a meta-analysis. J Nutr 2004; 134:919-922. (24) Giovannucci E, Rimm EB, Colditz GA, Stampfer MJ, Ascherio A, ChuteCC et al. A prospective study of dietary fat and risk of prostate cancer [see comments]. Journal of the National Cancer Institute 1993; 85:1571-1579. (25) Morris MC, Manson JE, Rosner B, Buring JE, Willett WC, Hennekens CH. Fish consumption and cardiovascular disease in the Physicians' Health Study: A prospective study. Am J Epidemiol 1995; 142:166-175. (26) Osler M, Andreasen AH, Hoidrup S. No inverse association between fish consumption and risk of death from all-causes, and incidence of coronary heart disease in middle-aged, Danish adults. J Clin Epidemiol 2003; 56:274-279. (27) Ascherio A, Rimm EB, Stampfer MJ, Giovannucci EL, Willett WC. Dietary intake of marine n-3 fatty acids, fish intake, and the risk of coronary disease among men. N Engl J Med 1995; 332:977-982. (28) Salonen JT, Seppanen K, Nyyssonen K, Korpela H, Kauhanen J, Kantola M et al. Intake of mercury from fish, lipid peroxidation, and the risk of myocardial infarction and coronary, cardiovascular, and any death in eastern Finnish men. Circulation 1995; 91:645-655. (29) Pawlosky RJ, Hibbeln JR, Novotny JA, Salem NJ. Physiological compartmental analysis of alpha-linolenic acid metabolism in adult humans. J Lipid Res 2001; 42:1257-1265. (30) Pawlosky RJ, Hibbeln JR, Lin Y, Goodson S, Riggs P, Sebring N et al. Effects of beef- and fish-based diets on the kinetics of n-3 fatty acid metabolism in human subjects. Am J Clin Nutr 2003; 77:565-572.
Submission Date 9/17/2004 2:26:00 PM
Author from Kansas City, MO

   Saturated Fat
Summary The guideline should be modified to increase specificity. Suggested guideline; Choose lean meat, low- and nonfat dairy products and eat fish regularly.
Comments If the intent is to advocate restrictions in saturated and to include fish in the diet on a regular basis it would be appropriate to translate these messages into wording of the guideline itself. Because the majority of fat in the American diet does not come from added fat but from foods containing fat the message should be in terms of food, not fatty acids. A potential guideline would read, “Choose lean meat, low- and nonfat dairy products and eat fish regularly”. Additionally, such a guideline would allow for a more focused message in the guideline that currently reads “Increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products”. The concept of limiting intake of hydrogenated fat is a little more difficult to include in the guideline, however, the phrase "foods made with oils” could be added.
Submission Date 9/22/2004 2:26:00 PM
Author from Boston, MA

   Monounsaturated Fat
Summary Avocados are a natural source of eight vitamins, two minerals and at least three phytochemicals. Avocados are included in dietary programs from many of the world’s leading nutrition organizations and can make a significant contribution to the health of Americans.
Comments One of the 9 key messages is: Choose fats wisely for good health. Avocados are one of the few fruits that provide “good” fats. Unsaturated fat like monounsaturated fat (MUFA) found in avocados has been linked to a reduced risk of heart disease, cancer and diabetes. If equal amounts of MUFAs are substituted for saturated fatty acids, low-density lipoprotein (LDL) or “bad” cholesterol decreases.
Submission Date 9/17/2004 6:07:00 PM
Author California Avocado Commission

   Trans Fat
Summary Now that companies have included trans fat in their nutrition labels, I feel that it is important that the general public is informed on what ingredients are responsible for its presence in food and have a brief scientific background of understanding on the formation of trans fat.
Comments Upon reviewing the dietary guidelines I was pleased to see that trans fatty acids were mentioned. However, I feel that there should be a more detailed section describing trans fat. Now that companies are including trans fat on their nutrition labels, the general public may be curious about it. It would be helpful to have a section explaining what trans fat is and how its configuration is obtained. Informing consumers that trans fat comes from partially hydrogenated oils can help them make better food choices by looking for this ingredient in the ingredients list of products who have not yet provided the total trans fat in the nutrition label.
Submission Date 9/21/2004 1:53:00 PM
Author from , Pennsylvania

   Saturated Fat
Summary Please stop villifying natural saturated fats and instead urge US to eliminate trans fats. Check the science!
Comments Please review the actual scientific evidence against naturally occuring saturated fats. They are actually a good form of nutrient dense calories and kept humans healthy for millenia. Transfats are the bad guys, not saturated fat. Check the science!
Submission Date 9/24/2004 4:39:00 PM
Author from Beaverton, OR

   Total Fat
Summary No limits on saturated fats and cholesterol, a low fat diet has been crammed down peoples throats for years, yet heart disease is on the rise. Fat is NOT the problem. Refined grains and added sugar are the culprits.
Comments
Submission Date 9/24/2004 2:17:00 PM
Author from Holland, MI

   EPA/DHA (Fish)
Summary If you check, I believe you will find that tuna is **not** a 'high fat fish'.
Comments If you check, I believe you will find that tuna is **not** a 'high fat fish', contrary to what you state. Please correct me if you find some species of tuna that you do consider to have a high fat content.
Submission Date 9/24/2004 12:12:00 PM
Author from Richmond Hill, ON

Summary Source: USDA Handbook No. 8 ...............
Comments To add to my comment on tuna about ten minutes ago. My data suggest the percentage of calories from fat in tuna are between 20% and 26%, compared with 50% to 65% for fish like mackerel, salmon and some species of trout. My source attributes this data to "USDA Handbook No. 8 Composiion of Foods, Table 1, "Composition of foods, 100 grams, edible portion" "
Submission Date 9/24/2004 12:26:00 PM
Author from Richmond Hill, ON

   Total Fat
Summary Benefits include improvement and elimination of skin problems, lowered cholesterol, weight loss, and overall well-being.
Comments Advocate of grassfed animal protein for 12 years
Submission Date 9/23/2004 12:54:00 PM
Author from salisbury, nc

   EPA/DHA (Fish)
Summary Alternatives need to be offered to obtain essential fatty acids and other nutritional needs besides animal products for those who choose or can't consume them.
Comments I want to compliment your committee on the new guidelines which I think have promise toward guiding people toward healthier eating. I particularly liked the encouragement of conscious calorie consumption and exercise. As a vegan, I would encourage you to offer people alternatives to dairy which can give them more accessible calcium, such as soy, rice, almond, hazelnut, oat, or multi-grain beverages. Many people are lacto-intolerant and need to find alternative sources. Your guidelines recommend eating fish twice a week, yet most fish are contaminated with chemicals and are filled with saturated fat. Again, there are alternatives to getting your essential fatty acids, particularly Omega 3, through plant-based sources, such as ground flax seeds and sea vegetables (Wakame). I would hope the committee would put the healthy of the citizens of the United States above pressure and interests of food producers. Thank you for your attention and hard work. Carol Merrick Secretary, Northwest VEG Tigard, OR 97223
Submission Date 9/23/2004 10:33:00 AM
Author Northwest VEG

   Total Fat
Summary The distinction between raw and cooked foods must be included to make the nutrition guidelines meaningful.
Comments Until the concept of cooked versus raw foods is included in the study, the public cannot utilize the food recommendations adequately because the body processes cooked food differently than raw food. Cooked (and to some extent processed foods) food is absorbed into our systems much faster than raw foods and turns to sugar which is stored as fat in our bodies. Raw food passes through our bodies and acts as roughage and does not turn to fat. The major negative of cooked food is when it is NOT burned off by exercise it goes right into our storage of body fat and leads to diabetes and arthritis.
Submission Date 9/22/2004 5:48:00 PM
Author

Summary
Comments testing
Submission Date 9/23/2004 11:54:00 AM
Author

   Saturated Fat
Summary The data do not support a positive correlation between cardiac disease and saturated fat consumption. My health history is a case in point, as I was raised eating very few sweets, but much milk, cream and butter, and my arteries are free of plaque, in spite of a "high" cholesterol count.
Comments To the Dietary Guidelines Advisory Committee ~ I hope you will take a moment to read through my comments. I was born on a farm, married a farmer, drank whole milk (unpasteurized), butter and ate a lot of meat. My cholesterol has always been around 225, give or take 10 points. In today's world, that is considered high and my last three doctors have all tried to get me to take statins. My triglycerides are very low (below 75). Well, I am lucky (or unlucky, depending on how you look at it), in that I have a genetic disease, fibromuscular dysplasia. The muscles in the wall of the artery wrap around the artery like a rubber band, causing a stenosis. In my case, I have three stenoses, with small aneurysms behind them. It is in my right renal artery, and it was discovered several months after my normally low (100/60) blood pressure jumped to 230/130 in a one week period and resisted all treatment with hypertension medication. Angioplasty seems to have taken care of it. Here is why I am lucky. During the second angioplasty (they cautiously did one stenosis at a time in 1988), the doctor who was performing the angioplasty took a look at my arteries all the way to my heart. He was amazed at them, saying they were totally free of plaque. So my high fat diet - AND a cholesterol reading that is considered too high - has caused absolutely no injuries to my arteries. The reason I say I am lucky is that I have an iron-clad argument about why I should not be on statins. (By the way, 50% of people who have heart attacks have normal cholesterol levels. That does not mean we need to lower cholesterol even further - what it may indicate is that cholesterol level is a poor indicator of heart health.) Having this disease has caused me to do a great deal of research. I am amazed at how we have latched on to a low fat diet when all the data say that we need to limit sugar and simple carbohydrates, not fat. Granted, we must be fussy about our fats, but the very fats I was loading up on as a child were the right ones. What happened? Why were they denigrated? I am totally NOT convinced by any recent trials that are conducted and paid for by the very pharmaceutical companies that will benefit from the sale of statin drugs. If we look at the "old" data, they just simply do not support a low fat diet. In fact, to the contrary, they indicate a high fat diet is better for us. I was a vegetarian for 15 years. On average, I probably ate about 700 g of carbohydrates a day, and did try to watch my fats. During that time, my teeth fell apart (two bridges, lots of crowns, root canals), I developed hypoglycemia and diverticulosis, and I begin struggling with my weight. I also developed some pretty nasty mood swings. Then I read a book, Life Without Bread and decided to go back to eating meat and fat. Since giving up my vegetarian ways in late 2000, my hypoglycemia is virtually symptomless, my bowels are working right again and I have had no additional problems with my teeth. My weight has stabilized. My mood swings are still with me, but I guess four out of five ain't bad! Please go back to the data provided in the 1950 Seven Country Study. Nothing in that study supported a low fat diet. There was no correlation strong enough between fat consumption and heart health to raise a concern. What SHOULD have raised concern was the fact that in some of the countries, increased fat intake actually LOWERED the incidence of death rates due to heart disease. That should have spurred the researchers to find out why it varied so greatly from country to country. The clue is in one paragraph in the middle of this 200-page report. It states that sugar intake is correlated with heart disease. No difference country to country, over all this correlation held true. So why didn't the researches look at those countries with high fat intake AND high incidence of heart disease and look at their sugar consumption? I don't know. I am hoping that your committee will take a look at this now. Certainly the proof is in the pudding. Since 1950, when we were told fats were bad and margarine was good, since we began replacing the good-tasting fat in food with sugar to mask its bland taste, diabetes has risen to epidemic proportions, as has obesity. The answer is not to do what we have been doing since 1950 only more so (even less fat), but to look back at how we were eating prior to 1950. I implore you to examine historical data regarding the correlation between overall health and fat consumption, and to look with great suspicion at recent data compiled by drug companies that have a vested interest in the outcome of these studies. The health of our nation is at stake, and it should be examined without the taint of politics and corporate interests. Respectfully, Susan Siemers Walkerton, IN 46574
Submission Date 9/23/2004 10:37:00 PM
Author Anonymous

   Trans Fat
Summary Omega 3 fatty acids from grass-fed livestock and poultry need to replace trans fat. Grow cotton and peanuts organically because chemicals applied to cotton pollute milk and too many children are allergic to peanuts.
Comments Trans fat needs to be replaced by fat from grass-fed livestock and poultry because fish are affected by mercury pollution. Grass-fed livestock are reportedly high in omega 3 fatty acids that supposedly prevent cancer and heart disease. Zero tolerance of trans fat is recommended because you can never eat just one! Due to many children being allergic to peanuts, the recommendations should require that peanuts be grown organically. It could be encouraged that cotton be grown organically by 2009 so that non-organic milk would not be polluted by chemically grown cottonseed meal. Organic cotton is being produced in New Mexico.
Submission Date 9/23/2004 10:50:00 PM
Author from Jarrettsville, MD

Summary Bread contains very little total fat and therefore cannot be a major contributor of trans fats. Please remove bread from the "foods high in trans fat" category.
Comments We are also concerned about the chart, Table E-17 which discusses the sources of trans fats in the diet. All baked goods appear to be lumped into one category. While we realize that high fat baked goods often contain trans fats, most breads (white, wheat, whole wheat and multi-grain) contains 0 grams of trans fat. Bread contains very little total fat and therefore cannot be a major contributor of trans fats. Please remove bread from that category. The industry is making incredible strides to remove trans fats from all foods, including those baked goods which are actually high in fat.
Submission Date 9/21/2004
Author The Foundation for the Advancement of Grain Based Foods

   EPA/DHA (Fish)
Summary When developing the final dietary guidelines, we urge the agencies to harmonize the dietary guidelines with the science and recognize that foods other than fish can be valuable sources of DHA and EPA.
Comments We were surprised that the Dietary Guidelines Committee limited their recommendation to fish intake given the extensive discussion establishing that it is the DHA and EPA in fish that are primarily responsible for the cardiovascular benefits. Indeed, in the recently issued qualified health claim for DHA and EPA, FDA acknowledges that any source of DHA and EPA is eligible for the qualified health claim. When developing the final dietary guidelines, we urge the agencies to harmonize the dietary guidelines with the science and recognize that foods other than fish can be valuable sources of DHA and EPA.
Submission Date 9/21/2004
Author Martek Biosciences Corporation

Summary DHA is important for maintaining mental and visual performance in addition to its well-recognized role in reducing the risk of cardiovascular disease. By acknowledging that DHA is present in foods other than fish, the dietary guidelines would help consumers select diets that are rich sources of DHA
Comments DHA is a structural component of many body tissues, including the brain, eye, and heart. While the body can synthesize DHA, the synthesis is slow and inefficient, thereby making it important to get pre-formed sources of DHA in the diet. There are extensive studies demonstrating the importance of choosing a diet that contains DHA from infancy throughout life. These studies establish that DHA is important for maintaining mental and visual performance in addition to its well-recognized role in reducing the risk of cardiovascular disease. By acknowledging that DHA is present in foods other than fish, the dietary guidelines would help consumers select diets that are rich sources of DHA. The ability to identify sources of DHA other than fish is particularly important for pregnant women, lactating women, and children because of the methyl mercury risks presented by certain fish. The concerns with methyl mercury are included in the Executive Summary of the Final Report. It is imperative that the dietary guidelines and educational materials mirror this concern. The failure to include this important, balanced, educational message could result in this vulnerable population inadvertently increasing intake of fatty fish.
Submission Date 9/21/2004
Author Martek Biosciences Corporation

Summary In the key messages on dietary fats, for instance, the recommendation to increase intake of fish should come first.
Comments In the key messages on dietary fats, for instance, the recommendation to increase intake of fish should come first. Being first in order is more likely to lead to compliance with the recommended increase in fish consumption. Capturing consumers’ attention with positive messages increases the likelihood of keeping their interest through the full message.
Submission Date 9/21/2004
Author National Food Processors Association

   Trans Fat
Summary With respect to the recommendation to limit trans fat intake to one percent of calories, NFPA believes that the science base may not be adequate to support the level, and that stronger scientific justification be expressed.
Comments With respect to the recommendation to limit trans fat intake to one percent of calories, NFPA believes that the science base may not be adequate to support the level, and that stronger scientific justification be expressed.
Submission Date 9/21/2004
Author National Food Processors Association

   Saturated Fat
Summary In the more detailed part of the report the statements are all in opposition to choosing saturated fats even though there is ample published evidence that saturated fats are quite healthful and even essential under many circumstances. Coconut oil is an important medium-chain saturated fat, which has
Comments The Key Findings of the 2005 DGA Committee contain the recommendation to łChoose fats wisely for good health.˛  In the more detailed part of the report the statements are all in opposition to choosing saturated fats even though there is ample published evidence that saturated fats are quite healthful and even essential under many circumstances.  This is especially true for coconut oil and its medium-chain tryglyceride fatty acids, which serve as antimicrobial fats, as anti-obesity energy sources, anti-inflammatory fats to fight coronary heart disease, and as fatty acids needed for cellular signaling. Coconut oil is an important medium-chain saturated fat, which has been shown by research to benefit humans by maintaining or increasing HDL cholesterol, by increasing  appropriate weight loss, and by providing antimicrobial benefits. Coconut oil has been recognized  in numerous studies for beneficial effects on CHD risk factors, such as: Sundram et al (1994), who added coconut oil  to diets, found (good) HDL cholesterol  increasing  6.3% and (bad) LDL cholesterol decreasing 0.1%, which clearly showed a desirable effect.  In other trials,  Ng et al (1991) fed 75% of the fat ration as coconut oil (24% of energy) to 83 adult normocholesterolemics (61 males and 22 females).  Relative to baseline values,  HDL cholesterol was increased 21.4% , and the LDL/HDL ratio was decreased 3.6%. Medium-chain saturated fatty acids contained in coconut oil have also been shown in recent yearsą research in both humans and animals to have beneficial effects with respect to weight loss  and maintenance of that weight loss. This research has been done in the United States, Canada, Japan, and several parts of Europe. The antimicrobial effects of lauric acid and other medium-chain saturates from coconut oil have been well-studied and published in numerous journals. The initial effort to demonize saturated fatty acids in general was directed at coconut oil, which contains about 90% saturates and, therefore, the highest of saturated fats.   It should be noted that coconut oil has only 28% long-chain saturates whereas, for example, cottonseed oil has about 30% long-chain saturates (Enig 1991), and other longer-chain saturates can make up close to 65% of some other oils.  These long chain saturates, having desirable cooking, baking, and other functional characteristics, were the competition to the trans fatty acids ­ which HHS now seeks to minimize or remove from in the diet -- and it was the trans fatty acid products the food industry wanted to protect at all costs from even legitimate criticism
Submission Date 9/21/2004
Author Granex Corporation USA

   Total Fat
Summary In order to understand how inappropriate are the 2005 Dietary Guidelines Recommendations regarding saturated fat, you need to know the history of the recommendations beginning with the McGovern Committee Dietary Goals of the late 1970s.
Comments In order to understand how inappropriate are the 2005 Dietary Guidelines Recommendations regarding saturated fat, you need to know the history of the recommendations beginning with the McGovern Committee Dietary Goals of the late 1970s. You need to know that the original recommendations regarding fat were developed by lawyers who had no scientific background and by industry lobbyists whose economic agenda was to push polyunsaturated oils and partially hydrogenated oils into the guidelines while pushing out saturated fats from the recommended foods.  This agenda was not understood by the Congressional audience as a marketing grab by corn oil and soybean oil interests, while giving the impression that they were health-related items.
Submission Date 9/21/2004
Author Granex Corporation USA

   Trans Fat
Summary Now HHS is waking up to the overwhelming science that trans fats from partially hydrogenated vegetable oils are bad for human health. 
Comments Now HHS is waking up to the overwhelming science that trans fats from partially hydrogenated vegetable oils are bad for human health.  Yet the perception of tarred saturates like coconut oil remains uncorrected. Saturates are (i) an integral part of motherąs milk, (ii) the principal fatty acid group in the brain, (iii) a necessary component in cell structure, and (iv) are the chief fatty acid for the musclesą energy.  The list goes on.  Yet saturates are still deemed by HHS as łbad.˛
Submission Date 9/21/2004
Author Granex Corporation USA

Summary Trans fatty acids in the diet, created from partially hydrogenating vegetable oils, have been implicated as causing or exacerbating most of our modern diseases, including heart disease, cancer, diabetes, obesity, immune dysfunction and bone loss
Comments During the early 20th century, most of the fatty acids in the diet were either saturated or monounsaturated, primarily from butter, lard, tallows, coconut oil and small amounts of olive oil; heart disease and obesity were virtually non-existent. Today, most of the fats in our diet are polyunsaturated, primarily from vegetable oils derived from soy, corn, safflower, sunflower, cottonseed and rape seed (canola – primarily monounsaturated).Polyunsaturated fatty acids are very fragile. When exposed to heat and oxygen, as during commercial processing, they form free radicals and other harmful breakdown products that damage the human body in many ways. Trans fatty acids in the diet, created from partially hydrogenating vegetable oils, have been implicated as causing or exacerbating most of our modern diseases, including heart disease, cancer, diabetes, obesity, immune dysfunction and bone loss. In addition, a number of researchers have argued that along with a surfeit of omega-6 essential fatty acids from vegetable oils the American diet is deficient in the more unsaturated omega-3 linolenic acid.
Submission Date 9/21/2004
Author Weston A Price Foundation

   EPA/DHA (Fish)
Summary a number of researchers have argued that along with a surfeit of omega-6 essential fatty acids from vegetable oils the American diet is deficient in the more unsaturated omega-3 linolenic acid.
Comments During the early 20th century, most of the fatty acids in the diet were either saturated or monounsaturated, primarily from butter, lard, tallows, coconut oil and small amounts of olive oil; heart disease and obesity were virtually non-existent. Today, most of the fats in our diet are polyunsaturated, primarily from vegetable oils derived from soy, corn, safflower, sunflower, cottonseed and rape seed (canola – primarily monounsaturated).Polyunsaturated fatty acids are very fragile. When exposed to heat and oxygen, as during commercial processing, they form free radicals and other harmful breakdown products that damage the human body in many ways. Trans fatty acids in the diet, created from partially hydrogenating vegetable oils, have been implicated as causing or exacerbating most of our modern diseases, including heart disease, cancer, diabetes, obesity, immune dysfunction and bone loss. In addition, a number of researchers have argued that along with a surfeit of omega-6 essential fatty acids from vegetable oils the American diet is deficient in the more unsaturated omega-3 linolenic acid.
Submission Date 9/21/2004
Author Weston A Price Foundation

   Saturated Fat
Summary Animal fats, such as butter, lard and tallows, as well as fruit/nut-derived saturated fats – coconut and palm oils - are stable, do not easily develop free radicals, and contain nutrients that are vital for good health.
Comments Animal fats, such as butter, lard and tallows, as well as fruit/nut-derived saturated fats – coconut and palm oils - are stable, do not easily develop free radicals, and contain nutrients that are vital for good health. Children, in particular, require high levels of quality animal fats, such as butter and whole milk products, to achieve optimal physical and neurological development.
Submission Date 9/21/2004
Author Weston A Price Foundation

   Total Fat
Summary Beneficial fats include the primarily saturated butter and other animal fats, coconut and palm oils; monounsaturated fats such as olive oil and peanut oil; and the polyunsaturated omega-3 essential fatty acid from flaxseed oil and fish
Comments Naturally occurring unprocessed fruits, vegetables, whole grains and legumes with non-factory farmed animal and fish protein sources are recommended for longevity and well being. Beneficial fats include the primarily saturated butter and other animal fats, coconut and palm oils; monounsaturated fats such as olive oil and peanut oil; and the polyunsaturated omega-3 essential fatty acid from flaxseed oil and fish
Submission Date 9/21/2004
Author Weston A Price Foundation

   EPA/DHA (Fish)
Summary Flax seeds are an excellent source of omega 3's whereas fish and consumption of other sea animals have the downside of potential mercury content, other contaminants, and significant cholesterol
Comments Flax seeds are an excellent source of omega 3's whereas fish and consumption of other sea animals have the downside of potential mercury content, other contaminants, and significant cholesterol
Submission Date 9/21/2004
Author International Vegetarian Union

   Monounsaturated Fat
Summary Put the guidelines on hold. Follow my proposed Siguel’s Natural Food Pyramid. Eat natural foods with cells; Emphasize vegetables and reduce intake of grains; Minimize processed carbohydrates and fat; Be slim or cut your caloric intake (substantially) and exercise more.
Comments TO: HHS/USDA 2005 Dietary Guidelines From: Edward Siguel, MD, PhD Ref: The USDA Food Pyramid Date: September 23, 2004 Introduction My presentation is oversimplified due to time restrictions. These are my opinions and may contain errors. Please read my papers at my web site, essentialfats.com, and at Medline. The disclaimers at essentialfats.com apply to these notes. Definitions: Essential fats = EFs = PUFAs of the omega-3 and omega-6 families. About myself I study the effects of different types of fats on health and disease. I invented a method to measure different types of fatty acids and trans fats in blood. I created a data base of fatty acid profiles with over 1,000 blood samples from patients, people, and Framingham Heart study subjects. Based on my presentations at scientific meetings, published articles, and personal conversations with over 100 fat researchers, I believe I have the best data on the relationship between fats in blood vs. health and disease. I will summarize a few findings. Excessive caloric intake from foods low in essential fats creates a biochemical deficiency of essential fats. Most overweight people have biochemical deficiencies of essential fats. Overweight people who are not biochemically deficient usually became overweight from eating too many healthy foods rich in essential fats, a rare condition in America. These matters are discussed in several of my publications and patent. More than 25% of the US population is biochemically deficient in w6s; more than 50% of the US population is biochemically deficient in w3s (based on blood tests of different population groups). Whole grains and processed grains are not much different from each other. Distinctions are too subtle and too complex for consumers to understand and to use to make wise food choices. It is easy to distort these differences and provide nutrient-poor calories with cookies/ energy bars made with whole grains but few essential fats. A diet that follows the USDA Food Pyramid, as it is interpreted or implemented by most people, is deficient in EFs, particularly w3s, and has too many calories. Americans need to eat few calories or else gain weight. Each calorie must be nutrient dense. Some grains contain relatively few essential fats and nutrients (particularly w3s). When many calories come from grains, it is difficult for people to eat enough essential fats from the remaining daily calories (restricted to maintain optimal weight). Low fat foods, even if made with whole grains, may not provide enough essential fats to meet daily needs. It is also important that the requirements for essential fats should be listed as grams/kg body weight/day instead of as a percent of calories (see my book at amazon.com). The reason being that people on low calorie diets need essential fats in proportion to their body cells, not their caloric intake. There are several other issues relevant to the Food Pyramid. For example, it is misleading to recommend that people eat foods, such as breakfast cereals, with 100% RDA. During the rest of the day, people continue to eat more vitamins and minerals. The body has to work to eliminate them. This may cause kidney overwork and the expelling of key nutrients, such as K, in the urine. The proposed Dietary Guidelines are misleading with regard to fat • MUFAs are not necessarily “healthy” fats and should not be emphasized. Dietary guidelines should follow biochemical principles and distinguish essential from non-essential fats. Essential fats are needed by humans; non-essential fats (including MUFAs) are not needed. My research proves that levels of MUFAs in the body are primarily regulated by levels of essential fats, not by dietary intake of MUFAs. In my opinion, the proposed dietary guidelines will mislead people into eating too many MUFAs. • Recommendations for intake of essential fats should be expressed in grams per kg of ideal body weight (or in a range of grams/day), not as a percent of calories. The body’s need for essential fats depends on the number of cells and processes that use essential fats (repair and maintenance, etc.). The need for EFs is far more related to ideal body weight than to caloric intake. A person needs roughly the same amount of essential fats per day whether he eats 1,200 calories or 2,000 calories. Most Americans are overweight. Many Americans lead sedentary lives. Thus, most Americans need to eat far fewer than 2000 calories/day. A requirement based on calories is misleading. In my opinion, the proposed dietary guidelines are likely to continue the effect of past dietary guidelines. In my opinion, current (and proposed) dietary guidelines are a significant factor in the epidemic of overweight and obesity, and they contribute to cardiovascular disease and cancer. Better guidelines would recommend that people eat more foods in their natural states and minimize intake of foods with highly processed carbohydrates or fats. Essential Fats are more important for optimal health than trans and other fats TC/HDLC (one of the best risk factors for cardiovascular disease) is inversely proportional to Essential Fats, directly proportional to trans fats (based on measurements in human blood). Essential fats account for ~50% of variability, trans for ~ 10%. Levels of essential fats appear to be, by far, the most significant factor in cardiovascular diseases, abnormal lipids, diabetes, and hypertension. Other factors are minor in comparison. Read my papers on these matters. What this means is that essential fats are by far the best and most significant variable (in terms of the percent of variability predicted by correlation R or R2). Other variables such as age, sex, and weight, have less effect on TC/HDLC. It follows that any study that fails to account for blood levels of essential fats fails to consider a major variable and is therefore likely to produce misleading results. Also notice that it is very difficult to predict blood or tissue levels of essential fats from dietary intake (due to a variety of reasons beyond the scope of this document). Trans FA in blood are burned (used) quickly. Although trans fats are likely to be undesirable in foods, it is more harmful to have a diet lacking in essential fats. A diet low in EFs and trans fats is likely to be more harmful than a diet high in trans fats and EFs (this is a complex issue, depending on body levels of trans and EFs, weight, etc.). The implication is that replacing trans fats in foods with non- trans fats may be counterproductive when the fats replaced contain fewer essential fats than the original fats (some foods with trans also contain EFs). For this reason, some margarines rich in essential fats may be healthier than others poor in essential fats, particularly for people who exercise and burn the extra fats. The current trend to replace trans fats in food with fats low in essential fats (accompanied with the trend to eat too many calories) will likely increase morbidity and mortality. This is not necessarily bad news if the intent is to balance the budget by cutting the life span of social security recipients. The replacement of trans fats, in my opinion, offers great opportunities to consultants, lawyers and companies marketing new products. Together with HIPAA, they represent one of the greatest employment acts of the current century. Moreover, while HIPAA applies mainly to the US (thereby reducing its profit-making appeal), reducing trans fats in foods and convincing people to eat other foods has global appeal. Eating too many calories low in essential fats is far more harmful than eating trans fats. This means that being overweight or gaining weight from eating too many calories is likely to be more harmful than eating a few trans fats. A person’s risk for cardiovascular disease may increase when he stops eating 100 calories per day of cookies or French fries with trans and essential fats, and starts eating 150 calories per day of cookies or French fries made with a fat low in essential and trans fats. This situation may occur when people eat a lot of foods rich in saturated or monounsaturated (MONO) fats but low in trans because they read the label low in trans and cholesterol and think the food is healthy (or think MONOs are healthy). Beware of MONOs (= MUFAs). They are mostly unnecessary. Emphasize eating more essential fats, not eating more unsaturated fats (that includes MONOs). It is known that MONOs are not essential fats in humans. Humans can make them from saturated fat. There is a very strong inverse relationship between plasma PUFA and MUFA levels in human blood. The relationship exists in people from different study groups, different health conditions, different weight, sex, etc. My implication is that eating more or less MUFA is likely to have a long term effect similar to sat fat. I consider the reports from the US Dietary Guidelines made in May, 2004, as well as those posted in the HHS web site by August, 2004, to be flawed. They misunderstood my data. I consider their comments on MONOs flawed because apparently they indicate that there is a positive relationship between MONOs and PUFAs, or there is some health advantage to eating more MONOs. Instead, people should eat more calories from natural foods naturally low in fat, such as vegetables or lean meats, and eat fewer calories. Because monos are fat, eating more foods high in monos requires eating foods high in fat. These foods may contain a smaller percent of calories as essential fats in their biologically active form. People do not need to eat artificially produced fats in forms that may not have the same biological activity as natural fats in cells. Beware that olive oil contains little w3s. Eating olive oil requires a sophisticated diet low in calories and rich in w3s and nutrients + lots of exercise. KISS people with KISS principle = Keep It Simple S. There is too much info on labels and nutrition recommendations. I cannot carry a computer and scale to stores, restaurants, kitchen to calculate nutrient intake each day. I submit food labels are misleading for most consumers. Food labels concentrate on a few items and miss many others. The government should get out of the business of requiring people to keep daily track of each vitamin and mineral and major nutrient, and instead offer a simpler message based on practical foods. Alternatively, they could encourage companies to market more PCs with built-in food scales. My simple message is to emphasize total calories, eating natural foods high in cells. These foods are naturally rich in protein, essential fats, vitamins, minerals, and other nutrients. My suggestions are: • Eat foods with cells. Foods without cells ~ = nutrient-poor calories. People can learn to recognize foods with cells. They “grow” in nature. They move or grow before we eat them. That is what animals eat. That is what humans used to eat before the advent of food-processing machinery. • Avoid highly processed foods. They are often nutrient poor and calorie rich. • Eat foods rich in w3 and w6 essential fats, such as membranes, some vegetable oils. This is important for people who are deficient in essential fats or those on low calorie diets who do not get enough essential fats from their foods. • Supplement with a multivitamin a few times per week unless one eats lots of healthy food and little junk food. This is particularly important for people who have a relatively sedentary life and cannot get enough nutrients from their food (because they do not eat nutrient-dense foods or eat few calories to remain slim). Speaking of sedentary life, remember that our ancestors spent time chasing and being chased by food (or hungry colleagues). The way we chase food today at supermarkets and restaurants is not enough exercise. The food pyramid and how to improve it I propose a food pyramid that relies on natural foods rich in cells. These foods contain thousands of nutrients; processed foods contain very few. My food pyramid is available in my web site and publications. Controlling obesity and overweight: a simple message The government should have a very simple message: people gain weight from eating too many calories. There is a simple, practical and meaningful way to lose unnecessary weight: EAT FEWER CALORIES and eat food in accordance with Dr. Siguel’s pyramid (eat more vegetables, avoid processed carbs). Medicare, Medicaid, and health insurance companies are going broke trying to pay for expensive diagnosis and treatment associated with overweight. I propose a radical solution. High tech, simple, inexpensive. People should use their belts (or a rope) to measure their waists. In consultation with a health professional or tables by height, sex, they should select an ideal waist. If they are over it, they should use my TREATMENT. Treatment consists of duct tape applied during meals (on the mouth). This treatment is likely to lead to weight loss regardless of people’s genes, metabolism, environment, state of mind (psychotic or otherwise), or political preference (as I indicated in my book, exceptions apply to people with plant-like genes who gain weight from excessive breathing. These people convert air into carbon like plants do. However, despite contrary opinions, this is probably a very small portion of the US population). I propose that Medicare and Medicaid offer consumers a choice of coverage: they will pay for either (a) conventional treatments, or (b) the use of the belt and duct tape + an all expenses paid trip to the city of the consumer’s choice. Dangers of the proposed dietary guidelines: they should be kept secret I believe the choices and decisions made by HHS/USDA to write the dietary guidelines will shorten the lives of thousands of Americans. Thererfore, I propose that the guidelines be put on hold and be evaluated by the top 20 largest government agencies, including NIH, Department of Homeland Security, National Science Foundation, Dept of Transportation (people who become overweight cause a transportation problem + airlines need to comment on the impact on their food services), Dept of Interior (should employees follow the guidelines?), CIA, FBI, Border patrol (can illegal immigrants be forced to eat in accordance with the guidelines?), and labor (how many people are making a living from dietary guidelines and food pyramids?). Among non-government agencies, I suggest the American Enterprise Institute, CATO, Brookings Institute, The Urban Institute, Hudson Foundation, Gates Foundation, and the dog associations (will dogs be forced to eat leftovers from people who follow the dietary guidelines, and, if so, is that healthy for them or is it animal cruelty?). All the entities that testified on these matters should submit a 30 page paper with references. Thousands of other foundations and medical centers ought to give their comments. Trial lawyers associations should definitely be involved (can the government be sued under RICO if the guidelines are intentionally faulty, like cigarettes?). In my opinion, the proposed dietary guidelines will cause thousands of people to die prematurely. Implementation of better dietary guidelines would prolong the lives of thousand of people and reduce the costs of health care (reduce morbidity and mortality). In my opinion, implementation of the proposed dietary guidelines is unethical, immoral, a violation of our constitutional rights. The nutrition policies being considered are unhealthy. People may have a right to be fat or dumb, but the government has no right to use its influence and power and taxes to promote unhealthy policies. We are better off without any guidelines than with the proposed guidelines. In my opinion, sending the guidelines back to the drawing board and eliminating previous guidelines will save American children from harmful government intrusion that may encourage people to be fat or dumb. Children cannot resist the social pressures of school meals, educators, magazines, peers, and commercials. A child is under tremendous school pressure to eat foods that conform with the guidelines but that will harm them. As a parent, I would be better off without the dietary guidelines. I do not believe that schools should encourage children to eat bad so they are unlikely to live long enough to collect social security. During the past 5 years, the current dietary guidelines were implemented by schools and people across the country. Are you better off today, with less overweight, healthier eating, smarter kids and fewer children with special problems? Or were you healthier 5 years ago? Unfortunately, we know the answer. Bad eating, a major factor in overweight, is responsible for thousands of deaths. Will we be better off with the proposed dietary guidelines? Do they make such a drastic departure from the past that we can predict opposite outcomes, weight reduction, slim and smarter kids, drastic drops in mortality and morbidity? I do not think so. The committee states that MONOs are proportional to PUFAs. My data shows that MONOs are INVERSELY proportional to PUFAs. My studies are easy to replicate. Measure fatty acids in plasma and plot MONOs vs PUFAs. The proposed recommendations lead consumers to believe that eating monos are healthy and should eat more. My research has shown more MONOs to be associated with cardiovascular disease. I spoke with HHS/USDA committee members, I reviewed their sources. I read the IOM documents and papers written about MONOs. I personally did the fatty acid analysis that showed that MONOs are inversely proportional to PUFAs. I wrote about my findings in peer-reviewed journals. I explained my findings to HHS committee member. How can it be that HHS/USDA reach opposite conclusions about MONOs than I do? What secret knowledge they have that I have not found? Perhaps HHS/USDA have sought to incorporate too many views. I once did a mathematical experiment to solve a linear equation with an unknown. I asked the opinion of a variety of consultants and government employees. Resolving mathematical equations by committee lead to absurd results. Trying to incorporate different views and reach a consensus can also lead to absurd results. Cardiovascular disease and cancer caused by suboptimal eating contributes to the premature deaths of thousands of Americans. Getting Americans to eat more processed fat and carbohydrates is a great way to kill brain cells (make people dumb) and cause cardiovascular disease or cancer. Within 30 years, more deaths could be caused by bad eating than by other weapons. The recommendations are also misleading for essential fats. What assurances do we have they are not wrong on other nutrients? I consider the dietary recommendations to be dangerous and harmful. They are an insult to science and the taxpayer. I am afraid this waste of money encourages our foreign enemies, misrepresents the need for fair taxes, and provides support for those who want a smaller government. The Republicans do not want to kill Americans. And the Democrats don’t either. Who is behind these flawed guidelines? Who benefits? The answer may be obvious to everyone with experience providing testimony on the dietary guidelines and understanding the different viewpoints. We really need to know who and why is behind these guidelines. FOLLOW THE MONEY. YOU KNOW [PAUSE --- those who testify ought to know]. I have a new theory. Who are the slim men who exercise a lot and do not follow the US dietary guidelines and want Americans to die prematurely? Who stands to win from fat and dumb Americans eating junk foods rich in processed fats and carbohydrates while our enemies are slim, trim, fast and eat healthy? I recommend that the guidelines be reviewed ASAP by the Dept of Homeland Security. The dietary guidelines should be supervised by the Department of Homeland Security, not HHS. Homeland Security has the talent to keep dangerous documents under wraps. Homeland security should investigate and put the guidelines in a safe 100 ft underground, to be opened AFTER they are reviewed by everyone else (after my kids are grown and safe from misguided nutritional guidelines by government agents). In the meantime, put the guidelines on hold and tell Americans to cut calories. They need to eat more natural foods with cells, low in saturated, monos and trans, and high in essential fats, the kinds of foods humans evolved to eat for the past 50,000 years. Use of ambiguous words and lack of common sense People who know how to eat reasonably and in moderation do not need these guidelines. The guidelines need to be specific and clearly state what types of foods are healthy and which ones are not. The guidelines should not require people to study them for days, carry dictionaries of definitions, and use computers to keep daily track of intake of each food to determine whether or not they are eating too much or too little of the daily allowances for 20+ nutrients. My concerns about the proposed Food Pyramid/Dietary Guidelines I repeat my concerns about the Food Pyramid published in Am. J. Clinical Nutrition, an exchange of letters with the USDA. My position is that current and proposed recommendations encourage eating too many calories low in nutrients and essential fats. The nutrition guidelines encourage the marketing of junk food made with highly processed ingredients low in essential fats and nutrients. One fallacy is that an interpretation of the food pyramid is an energy bar made with highly processed ingredients. Consider a food or energy bar made with vegetable carbs, protein, vegetable cocoa, added vitamins, minerals, and genetically modified oils rich in monos. This type of food bar may be eaten by millions thinking that it provides energy (it does, but people confuse caloric energy with energy as a sense of well-being) and complies with the USDA food pyramid because it has a balance of nutrients. Some food bars may have fiber, choline, antioxidants, and many other nutrients, perhaps in very small quantities, but no one can keep track of so many ingredients. It may even have some soybean or flax seeds to incorporate essential fats (although these fats may not be absorbed). This energy bar may appear to represent an almost perfect food pyramid except that it has no cells. But if we spit on it before we eat it, we add cells, enzymes, and immunoglobulins. We should not need to spit on food that complies with the food pyramid to make it healthier. Conclusion For 20+ years, I hoped science could teach the follies of current nutrition recommendations. Instead, I saw people get overweight and die following the government guidelines. I think the food pyramid is one of the major contributors to premature death. I have tried for many years to convince the government and researchers that nutrition recommendations must be drastically changed, or else people will eat suboptimally and develop health conditions associated with nutrient imbalances. A CME (continuing medical education) course I took discussed the case of an overweight diabetic Type II person. The 1st, 2nd, and 3rd priority treatments proposed were statins, statins, statins. I suggested that the treatment of choice was eating to lose weight, but that was considered too difficult and unnecessarily drastic. Perhaps satire will do better. We must avoid the trail of those who recommended bleeding to cure disease, or assured us the earth was flat. I took me more than 20 years before people recognized the follies of eating low fat diets deprived of essential fats or filled with margarines rich in trans fats. I wish it would not take 20 years to recognize the follies of current nutrition recommendations. Be wary of silly recommendations. Recommending that people eat food in moderation, eat a healthy or balanced diet, do not get overweight, eat sensibly, drink a lot of water but not too much, and so on are like telling people to buy low and sell high - obvious and not useful. To conclude, keep nutrition recommendations and the food pyramid very simple. Follow my proposed Siguel’s Natural Food Pyramid. Eat natural foods with cells. Emphasize vegetables and reduce intake of grains. Minimize processed carbohydrates and fat. Be slim or cut your caloric intake (substantially) and exercise more. Exercising is rarely enough for most people because we can eat in a few minutes what takes an hour to lose by exercise. We should start teaching 3 year old children to eat well. Prohibit schools from dispensing foods with highly processed fat or carbohydrates (i.e., eliminate sweets, pizza, etc.). If we start children early enough, they learn to like vegetables, fruits, and lean protein. Respectfully yours. References Siguel E, Lerman RH. The role of EFAs: Dangers in the USDA dietary recommendations ("pyramid") and in low fat diets. Am. J. Clin. Nutrition, 1994; 60:973-9. Essential fatty Acids in Health and Disease (book). By Dr. Siguel. Available from amazon.com. Siguel, E. Deficiencies and Abnormalities of Essential Fats in Gastrointestinal and Coronary Artery Disease. Journal of Clinical Ligand Assay 2000; 23:104–111. Siguel E. Re: Anticipation in Crohn's disease may be influenced by gender and ethnicity of the transmitting parent. Am J Gastroenterol. 1999 Jul;94(7):1996. Siguel, E. "Low-fat, high carbohydrate diets also reduce high-density lipoprotein (HDL) cholesterol levels and raise fasting levels of triglycerides." BioMedicina, January 1998; 1(1): 9. Siguel, E. Dietary Fat: How Low Can or Should You Go? Abstracts, Am. Oil. Chemistry Society Annual Meeting 1997; INFORM, 1997:8, No7:714-717. Siguel, E. Issues and Problems in the Design of Foods Rich in Essential Fatty Acids. Lipid Technology, 8(4):81-86, 1996 (July). Siguel E, Lerman RH. The effects of Low-Fat Diet on Lipid Levels. JAMA, 1996; 275:759. Siguel, E. A new relationship between PUFAs and TC/HDLC. Lipids, 1996; 31, S51-S56. Siguel E, Lerman RH, MacBeath, B. Very Low-Fat Diets for Coronary Heart Disease: Perhaps, But Which One? JAMA, 1996:275: 1402-1403 Web site. Essentialfats.com. Click on research. Also search on search engine for healthnewsreview, Obesity, poor nutrition may lower test scores. Wash Post, Sept 24, 2004, p. A9. Obese children were found to have lower test scores, have difficulty concentrating and other mental problems. According to Dr. Siguel’s research, obese children are highly likely to be deficient in essential fats and have imbalances of fatty acid metabolism. These abnormalities impair brain function, making people less smart than they could be based on their genetic abilities.
Submission Date 9/26/2004 11:26:00 PM
Author from Gaithersburg, MD

Summary Oral Testimony
Comments ORAL TESTIMONY September 21, 2004 I am Edward Siguel. I patented a method to measure fatty acids. I will present my opinions to help American children. People may have a right to be fat or dumb, but the government has no right to use its influence, power and taxes to promote unhealthy policies. Children cannot resist the social pressures of school meals, educators, magazines, peers, and commercials. Children face school pressure to eat foods that conform with the guidelines but that will harm them. As a parent, I would be better off without the dietary guidelines. In my opinion, sending the guidelines back to the drawing board and eliminating previous guidelines will save American children from harmful government intrusion that may encourage people to be fat or dumb. During the past 5 years, the current dietary guidelines were implemented by schools and people across the country. Are we better off today than 5 years ago, with less overweight, healthier eating, smarter kids and fewer children with special problems? Unfortunately, we know the answer. School children are worse. Bad eating, a major factor in overweight, contributes to thousands of deaths. Will we be better off with the proposed dietary guidelines? Do they make such a drastic departure from the past that we can predict weight reduction, slim and smarter kids, major drops in mortality and morbidity? I do not think so. The committee states that MONOs (MUFAs, monounsaturates) are proportional to PUFAs. My data shows that MONOs are INVERSELY proportional to PUFAs. My studies are easy to replicate. Measure fatty acids in plasma and plot MONOs vs PUFAs. The proposed recommendations lead consumers to believe that eating MONOs are healthy and should eat more. My research has shown MONOs to be associated with cardiovascular disease. The recommendations are also misleading for essential fats. What assurances we have they are not wrong on other nutrients? Getting Americans to eat more highly processed fat and carbohydrates is a great way to kill brain cells (make people dumb) and cause cardiovascular disease or cancer. Within 30 years, more deaths could be caused by bad eating than by other weapons. Who is behind these flawed guidelines? Who benefits? The answer should be obvious. YOU KNOW [PAUSE ---] Who are the slim men who exercise a lot and do not follow the US dietary guidelines and want Americans to die prematurely? I recommend that the guidelines be reviewed by the Dept of Homeland Security. They have the talent to keep dangerous documents under wraps and can help with my cost/effective and foolproof method to lose weight: When hungry, cover your mouth with duct tape. In the meantime, put the guidelines on hold and tell Americans to cut calories. They need to eat more natural foods with cells, low in processed fats, and high in essential fats and nutrients, the kinds of foods humans evolved to eat for the past 50,000 years. Please read my published papers + written comments. Thank you.
Submission Date 9/26/2004 11:28:00 PM
Author from Gaithersburg, MD

   Saturated Fat
Summary USDA should address fast food.
Comments This is the first time I have ever looked at the dietary giudlines and I can see why so many Americans do not bother with them. The informtion is good but it is alot of information. Even with being interested in health and fitness I struggled through the whole thing; imgaine how the everyday person may feel just glancing at the document. We live in a sound bite society. All the specific information is essential but the information needs to be presented in an alternate way- quick, newsflash style like on Entertainement Tonight, jumping from one riveting fact to another. Example: The USDA has discovered 3 ways to get energy up and weight down! 1. Skip McDonalds 2. Walk up stairs 3. Eat a fruit Getting to the FAT. Another component I would add to the fat section is FAST FOOD. We live in a fast food society and i think that topic needs to be addresed. How to Choose Sensibly at McDonalds would be relevent and more specific to the lives of American people. Granted, it is important to know what saturated fat is but alot of people just want the QUICK FIX, so give it to them. Fast Food restaraunts offer very fattening choices; many of which are the most appealing and the ones many Americans go with. The present guidlines does not mention fast food or how it should be eaten in moderation along with cookies, cakes and other refined foods. In the end it comes down to the consumer and if a person really wants that double quater pounder with cheese super sized with fries and a Coke, then they are going to have it. But maybe If people knew that the government is acknowledging that one of the contributing factors(highly refined, sugary, fatty foods) to this nations obesity epidemic is our constant attraction to Jack in the Box, Taco Bell, Arby's, Carl's Jr.,KFC and so on. And that consumers should avoid going to fast food restraunts more then once a month, or at least knowing how to choose sensibly when going into one. Most people understand that the quarter pounder with cheese is not the best thing for their bodily health, but if the government took a stance against the quarter pounder and advocated the chicken cobb salad maybe more Americans would opt for the latter.
Submission Date 9/25/2004 3:08:00 PM
Author from Honolulu, HI

   Total Fat
Summary CSPI strongly urges HHS and USDA to edit and then test the main message regarding fat to something like choose a diet that is low in saturated fat, trans fat, and cholesterol, and moderate and total fat.
Comments CSPI strongly urges HHS and USDA to edit and then test the main message regarding fat to something like choose a diet that is low in saturated fat, trans fat, and cholesterol, and moderate and total fat. It would be even clearer to the public if that advice were expressed not in terms of nutrients, but in terms of food, and read something like, eat less cheese, beef, pork, whole and 2 percent milk, egg yolks, pastries, and other foods that are high in saturated fat, transfat, or cholesterol. People don’t eat nutrients, they eat food. Providing advice about which foods to eat more of and less of would be much easier to understand and more effective than focus on nutrients.
Submission Date 9/21/2004
Author Center for Science in the Public Interest

Summary Change key message #5, "Choose fats wisely for good health," to "Limit the intake of animal fats, organ meats, eggs, and partially hydrogenated vegetable oils."
Comments Change key message #5, "Choose fats wisely for good health," to "Limit the intake of animal fats, organ meats, eggs, and partially hydrogenated vegetable oils." The current message is extremely vague and, therefore, ineffective. The key messages should be capable of conveying essential guidance to consumers in making food choices. This message, as well as the one for carbohydrates, is virtually meaningless without an additional explanation. While the current message, "Choose fats wisely for good health," is ambiguous, the alternative message, "Limit the intake of animal fats, organ meats, eggs, and partially hydrogenated vegetable oils," is clear and will be readily understood by consumers. The Report acknowledges that the intake of saturated fat, trans fat, and cholesterol should be kept low in order to reduce the risk of coronary heart disease. The Report further acknowledges that the major way to keep saturated fat low is to limit the intake of animal fats; the major way to limit cholesterol is to limit the intake of eggs and organ meats, and the best way to limit trans fat is to keep down the intake of foods made with partially hydrogenated vegetable oils. This information can be easily summarized in the alternative key message suggested above.
Submission Date 9/27/2004
Author

   Trans Fat
Summary General Mills supports the Committee’s conclusion that trans fat consumption (as well as saturated fat and cholesterol) should be as low as possible. We believe that greater or at least equal emphasis should be placed on saturated fat in the Committee’s recommendations and in the next phase of comm
Comments General Mills supports the Committee’s conclusion that trans fat consumption (as well as saturated fat and cholesterol) should be as low as possible. We are, however, very concerned that the Committee has defined a recommended intake level of trans fat at 1% or less of energy intake. We are not convinced that the scientific data supports defining 1% as the goal. The Committee states that “the dose-response relationship for trans fatty acid intake and the LDL:HDL cholesterol ratio begins to become greater than that observed for saturated fatty acids at about 2.5 percent of energy intake”. There is no evidence provided to support differentiating the effects of trans from saturated fat at levels below 2.5% of calories. Based on the evidence provided, we propose that trans fat intake should not exceed 2.5% of total calories (instead of 1% or less), and that the recommendations for saturated fat and trans fat be combined, with the total not to exceed 10-12% of total calories (10% is the current recommended limit for saturated fat while 12% is the current total sat + trans recommendation from the report). In addition, by setting such a strict limit on trans fat and due to limited ingredient alternatives, food manufacturers may need to use saturated fat-containing ingredients for many products. Such a shift could lead to an unintended consequence of increasing saturated fat intakes. This does not meet the overarching goal of decreasing both saturated and trans fat established by the IOM Macronutrient Report and reaffirmed by the Dietary Guidelines Committee. We believe that greater or at least equal emphasis should be placed on saturated fat in the Committee’s recommendations and in the next phase of communications of the Dietary Guidelines. The Report appropriately states that “although saturated fat, trans fat, and cholesterol all should be decreased, saturated fat should be the primary focus of dietary modification due to the higher proportion in the diet”. We firmly believe this message should be emphasized in guidance given to consumers to help them make healthier dietary choices concerning saturated and trans fat. The information should be balanced, realistic and based on sound, scientific evidence.
Submission Date 9/27/2004
Author General Mills

   Total Fat
Summary Choose fats wisely for good health. • Suggest changing key message to “Choose fats wisely for good health, including to help manage body weight”. • Supporting text should emphasize substituting monounsaturated and polyunsaturated fat for most of the saturated fat in the diet and include a recommenda
Comments Choose fats wisely for good health. • Suggest changing key message to “Choose fats wisely for good health, including to help manage body weight”. • Supporting text should emphasize substituting monounsaturated and polyunsaturated fat for most of the saturated fat in the diet and include a recommendation to consume more fish (preferably fatty fish).
Submission Date 9/27/2004
Author American Cancer Society, American Diabetes Association, American Heart Association

Fluids and Electrolytes
   Salt
Summary General Mills commends the Advisory Committee for establishing a practical goal for sodium intake (less than 2300 mg/day). We believe that realistic goals, such as this one, are more likely to motivate consumers to make dietary changes than more restrictive, seemingly unachievable goals. The recomme
Comments General Mills commends the Advisory Committee for establishing a practical goal for sodium intake (less than 2300 mg/day). We believe that realistic goals, such as this one, are more likely to motivate consumers to make dietary changes than more restrictive, seemingly unachievable goals. The recommended level (less than 2300 mg) is also very close to the current Daily Value for sodium on food labels (2400 mg), thus enabling consumers to apply this message while selecting foods. In the present report, the terms “salt” and “sodium” are used interchangeably in making dietary recommendations. Consumers, however, may not understand the relationship and important difference between these terms. For example, salt may be perceived as table salt, or the salt that is added during the preparation of food. On the other hand, food labels list the amount of sodium per serving. Consumer understanding of these terms should be carefully evaluated in the development of the salt/sodium guideline. We also recommend that the 5th edition of the Dietary Guidelines be used as a model for communicating advice on sodium/salt and that the Dietary Guidelines continue to encourage consumers to refer to the Nutrition Facts panel of foods for information on sodium content. In addition, the table listing the sodium content of foods needs to be updated with more recent data.
Submission Date 9/27/2004
Author General Mills

Summary See my editorial in NEJM concerning a reduction in dietary sodium that is scientifically appropriate and justified (see Greenland P, N Engl J Med. 2001 Jan 4;344(1):53-5).
Comments I authored the Editorial in the New England Journal of Medicine on the DASH-Sodium Trial. I have been interested in this topic for some time and am knowledgeable about the issues. I regard the current statement as scientifically appropriate and support it fully.
Submission Date 9/26/2004 9:44:00 PM
Author from Chicago, IL

Summary We do not believe the scientific evidence warrants this recommendation, and we recommend further research to examine the question of whether reducing dietary salt would lessen the risk of heart attacks and strokes.
Comments I will confine my remarks today to the prevention of heart attacks and strokes and to the Advisory Committee’s recommendation to prepare foods with “little salt.” We do not believe the scientific evidence warrants this recommendation, and we recommend further research to examine the question of whether reducing dietary salt would lessen the risk of heart attacks and strokes. We recommend that the Report’s research recommendations be augmented with a directive to conduct a study of the health outcomes of reduced salt diets.
Submission Date 9/21/2004
Author Salt Institute

   Fluids
Summary Nowhere does it mention the importance of drinking water for optimum health.
Comments And nowhere does it mention the importance of drinking water for optimum health.
Submission Date 9/21/2004
Author Anonymous

Summary Consider adding water/water intake to the guidelines- as a seperate guideline, or included in one of the existing guidelines...but it needs to be out there for Americans to see.
Comments Consider adding water intake to the guidelines? People don’t know the benefits of water- and because it isn’t included in the guidelines (and thus not included as part of the food pyramid) then the general thought is that they don't need to drink water.
Submission Date 9/23/2004 11:52:00 AM
Author OSU Extension Program- Cleveland, OH

   Salt
Summary Leading health organizations promote the benefits of citrus, including the American Heart Association, American Cancer Society, the National Cancer Institute and the Produce for Better Health Foundation.
Comments One of the key messages is: Choose and prepare foods with little salt. Citrus fruits contain no sodium and are natural sources of potassium. A single orange offers 260 mg of potassium, or 7 percent of the Recommended Daily Value. Consuming citrus fruits, such as lemons, is an excellent way to decrease sodium intake while simultaneously increasing potassium intake to reduce the risk of high blood pressure.
Submission Date 9/24/2004 5:23:00 PM
Author Sunkist Nutrition Bureau

Summary Avocados are a natural source of eight vitamins, two minerals and at least three phytochemicals. Avocados are included in dietary programs from many of the world’s leading nutrition organizations and can make a significant contribution to the health of Americans.
Comments One of the nine key messages is: Choose and prepare foods with little salt. Avocados contain no sodium and ounce-per-ounce contain more potassium than any other commonly eaten fruit. Consuming avocados is an excellent way to decrease sodium intake while simultaneously increasing potassium intake to help reduce the risk of high blood pressure.
Submission Date 9/17/2004 5:55:00 PM
Author California Avocado Commission

Summary Research suggests that a secular reduction in salt intake would benefit the American public. The guideline “Choose and prepare foods with little salt” provides no specific guidance on what to do. Changing "less salt” to "little salt" would encourage reductions from current levels.
Comments Recent research suggests that a secular reduction in salt intake would benefit most segments of the American public. Although the guideline “Choose and prepare foods with little salt” addresses this issue it provides no specific guidance on which to act. In addition, the definition of “little salt” is nebulous. Changing to guideline to “Choose and prepare food with less salt” would encourage reductions from current levels.
Submission Date 9/22/2004 2:45:00 PM
Author from Boston, MA

Summary The 2300 mg Sodium recommendation is not only unrealistic, but harmful to the credibility of the 2005 Guidelines.
Comments What are they thinking? The recommendation for the public to consume 2300 mg Na per day (and even less for those with Na related diseases) is totally unrealistic, even laughable. 2300 mg Na per day is a barely more than the very restrictive low sodium diet perscribed by physicians for serious disease conditions. It is much too far of a leap for anyone to want to take. I feel that this recommendation will decrease the credibility of the report, and turn the public away from the guidelines all together. Sue Summersett, M.P.H., R.D. Departmental Food Administrator California Department of Corrections 1515 S Street Rm. 103-S Sacramento, CA 94283-0001
Submission Date 9/1/2004 2:48:00 PM
Author from Sacramento, CA

Food Groups
   Fruits
Summary Fruit and vegetable intake is notoriously low, especially when French fries are subtracted from the equation. The barriers to fruit and vegetable intake are different from grains, cost, storage, perishability, preparation time. Substitute a variety of whole fruits and vegetables for other foods.
Comments Fruit and vegetable intake is notoriously low in the diet of Americans, especially when French fries are subtracted from the equation. The barriers to fruit and vegetable intake are different from grains, i.e. cost, storage, perishability, preparation time. Similar things could be said about dairy products. Therefore, in order to provide actionable advice, it does not necessarily make sense to lump fruits and vegetables, dairy products, and grains together within a single guideline. By separating them perhaps more focused messages and strategies could be developed to improve the overall quality of the American diet. Proposed guideline; Substitute a variety of whole fruits and vegetables for other foods.
Submission Date 9/22/2004 2:37:00 PM
Author from Boston, MA

   Vegetables
Summary Fruit and vegetable intake is notoriously low, especially when French fries are subtracted from the equation. The barriers to fruit and vegetable intake are different from grains, cost, storage, perishability, preparation time. Substitute a variety of whole fruits and vegetables for other foods.
Comments Fruit and vegetable intake is notoriously low in the diet of Americans, especially when French fries are subtracted from the equation. The barriers to fruit and vegetable intake are different from grains, i.e. cost, storage, perishability, preparation time. Similar things could be said about dairy products. Therefore, in order to provide actionable advice, it does not necessarily make sense to lump fruits and vegetables, dairy products, and grains together within a single guideline. By separating them perhaps more focused messages and strategies could be developed to improve the overall quality of the American diet. Proposed guideline; Substitute a variety of whole fruits and vegetables for other foods. Summary Fruit and vegetable intake is notoriously low, especially when French fries are subtracted from the equation. The barriers to fruit and vegetable intake are different from grains, cost, storage, perishability, preparation time. Substitute a variety of whole fruits and vegetables for other foods.
Submission Date 9/22/2004 2:38:00 PM
Author from Boston, MA

   Meat, Poultry, Beans, Nuts
Summary Use Oldways ethnic pyramids as a guideline
Comments I would like to see a differentiation between types of proteins as well as carbohydrates. I have noticed that my students who eat whole foods, and eat lean proteins have much better overall health and weight control than those who follow the pyramid but eat primarily processed foods. The ethnic pyramids designed by Harvard University and Oldways make much better sense to my students and relate better to traditional foods that people actually eat.
Submission Date 9/20/2004 11:10:00 AM
Author The Natural Pantry

   Fruits
Summary It is important to communicate that consumers need to eat a variety of fruits to meet their nutritional needs, especially fiber, potassium and Vitamin C. PBH's "color concept" has been a successful way to get consumers to think variety when selecting and eating fruits.
Comments It is important to communicate that consumers need to eat a variety of fruits and vegetables within these two food groups. Currently, 6 foods make up about half of all the fruits and vegetables consumed by Americans. While these 6 foods are important, we need to get consumers consuming other fruits and vegetables in addition to these six. Variety is important to meet the key nutrients that have been identified in the report, such as fiber, potassium and Vitamin C. They also contain hundreds and thousands antioxidants and phytochemicals – many which we are just beginning to understand. PBH recommends that consumer materials emphasize the importance of consuming a variety of fruits and vegetables and support the use of the "color concept", such as the successful PBH Color Way Campaign, to help communicate this important concept. This use of "color" to convey variety will also help link the dietary guidelines to existing private sector/industry efforts currently underway. These types of links and partnerships will be essential in communicating key guidelines message to consumers via proven and successful initiatives.
Submission Date 9/24/2004 1:50:00 PM
Author Produce for Better Health Foundation

   Vegetables
Summary It is important to communicate that consumers need to eat a variety of vegetables to meet their nutritional needs, especially fiber, potassium and Vitamin C. PBH's "color concept" has been a successful way to get consumers to think variety when selecting and eating vegetables.
Comments It is important to communicate that consumers need to eat a variety of vegetables within this food group. Currently, 6 foods make up about half of all the fruits and vegetables consumed by Americans. While these 6 foods are important, we need to get consumers consuming other fruits and vegetables in addition to these six. Variety is important to meet the key nutrients that have been identified in the report, such as fiber, potassium and Vitamin C. They also contain hundreds and thousands antioxidants and phytochemicals – many which we are just beginning to understand. We recommend that the consumer materials emphasize the importance of consuming a variety of fruits and vegetables and support the use of the "color concept", such as the successful PBH Color Way Campaign, to help communicate this important concept. This use of "color" to convey variety will also help link the dietary guidelines to existing private sector/industry efforts currently underway. These types of links and partnerships will be essential in communicating key guidelines message to consumers via proven and successful initiatives.
Submission Date 9/24/2004 1:52:00 PM
Author Produce for Better Health Foundation

   Fruits
Summary PBH recommends that consumer materials address cost issues associated with fruits to better equip consumers with information to help them eat more fruits while staying within their food budget.
Comments PBH urges HHS and USDA to educate consumers about the economical factors associated with consuming fruits. An Economic Research Service report: How Much Do Americans Pay for Fruits and Vegetables, issued in July, dispelled the myth that healthy eating is too expensive. The report showed that Americans can meet their fruit and vegetable requirements for less than a dollar per day. According to ERS, 64 cents buys 3 servings of fruit and 4 servings of vegetables. This represents only 16% of an individual’s daily food costs – and this is the analysis for low income households. 1999 A.C. Nielsen Homescan data was used to look at fresh, frozen, dried, and canned fruits and vegetables without other added ingredients. The research showed that more than half of fruits and vegetables cost an average of 25 cents or less per serving. The report also showed that Americans spend about the same amount on fruits and vegetables as they do on soft drinks, bacon, sausage, salty snacks, sugar and candy – food items that do not contribute positively to a healthy dietary pattern. While we realize that there are many other barriers to accessing fruits and vegetables, including availability of grocery stores in inner cities and product shelf life and quality, we now know that cost is not as much of a factor as once thought, and that put in perspective, getting the daily recommended servings of, for example, 7 fruits and vegetables costs less than one three-ounce candy bar. We recommend that the consumer materials address cost issues associated with fruits and vegetables to better equip consumers with information to help them eat more fruits and vegetables while staying within their food budget.
Submission Date 9/24/2004 1:55:00 PM
Author Produce for Better Health Foundation

   Vegetables
Summary PBH recommends that consumer materials address cost issues associated with vegetables to better equip consumers with information to help them eat more vegetables while staying within their food budget.
Comments PBH we urges HHS and USDA to educate consumers about the economical factors associated with consuming vegetables. An Economic Research Service report: How Much Do Americans Pay for Fruits and Vegetables, issued in July, dispelled the myth that healthy eating is too expensive. The report showed that Americans can meet their fruit and vegetable requirements for less than a dollar per day. According to ERS, 64 cents buys 3 servings of fruit and 4 servings of vegetables. This represents only 16% of an individual’s daily food costs – and this is the analysis for low income households. 1999 A.C. Nielsen Homescan data was used to look at fresh, frozen, dried, and canned fruits and vegetables without other added ingredients. The research showed that more than half of fruits and vegetables cost an average of 25 cents or less per serving. The report also showed that Americans spend about the same amount on fruits and vegetables as they do on soft drinks, bacon, sausage, salty snacks, sugar and candy – food items that do not contribute positively to a healthy dietary pattern. While we realize that there are many other barriers to accessing fruits and vegetables, including availability of grocery stores in inner cities and product shelf life and quality, we now know that cost is not as much of a factor as once thought, and that put in perspective, getting the daily recommended servings of, for example, 7 fruits and vegetables costs less than one three-ounce candy bar. We recommend that the consumer materials address cost issues associated with fruits and vegetables to better equip consumers with information to help them eat more fruits and vegetables while staying within their food budget.
Submission Date 9/24/2004 1:57:00 PM
Author Produce for Better Health Foundation

   Fruits
Summary Consumer materials need to include specific examples of to fit fruits into their daily meal plan. Focus groups have shown that once consumers know what a serving size is and given simple tips, they are far more comfortable and willing to increase their consumption of fruits.
Comments PBH recognizes the need to dispel consumer fears about the new higher fruit and vegetable number. We know from focus group testing conducted by the National Cancer Institute, that some consumers may not think they can eat 7 to 9 servings of fruits and vegetables a day – the number may be intimidating at first. Yet, once they are educated on what a serving size actually is and given simple tips on how to include a variety of fruits and vegetables into their diet, they are far more comfortable and willing to make the change. As an example, many Americans need to eat about 2000 calories and 9 servings of fruits and vegetables a day. While the fruit and vegetable number may seem intimidating at first, with the right information and effective messaging, it is very doable. The following example shows how easy it is to consumer 9 servings of fruits and vegetables a day: • A bowl of cereal in the morning with a ˝ a cup each of sliced bananas and blueberries provides 2 servings; • A mid-morning or mid-afternoon snack of a large red Anjou pear provides 2 servings; • A medium salad at lunch – about 2 cups – provides 2 servings; • A handful of baby carrots to nibble on while fixing dinner – about 8 carrots - is another serving; • And finally, a 1/2 cup of cooked spinach and a small baked potato as part of dinner adds up to 9 servings, across all of the color groups, over the course of a day. We recommend that the consumer materials include specific examples, like the one above, of how consumers can fit fruits and vegetables into their daily meal plan throughout the day. While the new, higher goal is attainable, it will take a coordinated effort, among the Dietary Guidelines Advisory Committee, government agencies, health and nutrition professionals and organizations, and the fruit and vegetable industry – commodity groups and retailers – to better communicate serving sizes in practical and actionable ways so consumers can understand and apply this important guideline.
Submission Date 9/24/2004 1:34:00 PM
Author Produce for Better Health Foundation

   Vegetables
Summary Consumer materials need to include specific examples of to fit vegetables into their daily meal plan. Focus groups have shown that once consumers know what a serving size is and given simple tips, they are far more comfortable and willing to increase their consumption of vegetables.
Comments We need to dispel consumer fears about the new higher vegetable number. We know from focus group testing conducted by the National Cancer Institute, that some consumers may not think they can eat 7 to 9 servings of fruits and vegetables a day – the number may be intimidating at first. Yet, once they are educated on what a serving size actually is and given simple tips on how to include a variety of fruits and vegetables into their diet, they are far more comfortable and willing to make the change. As an example, many Americans need to eat about 2000 calories and 9 servings of fruits and vegetables a day. While the fruit and vegetable number may seem intimidating at first, with the right information and effective messaging, it is very doable. The following example shows how easy it is to consumer 9 servings of fruits and vegetables a day: • A bowl of cereal in the morning with a ˝ a cup each of sliced bananas and blueberries provides 2 servings; • A mid-morning or mid-afternoon snack of a large red Anjou pear provides 2 servings; • A medium salad at lunch – about 2 cups – provides 2 servings; • A handful of baby carrots to nibble on while fixing dinner – about 8 carrots - is another serving; • And finally, a 1/2 cup of cooked spinach and a small baked potato as part of dinner adds up to 9 servings, across all of the color groups, over the course of a day. We recommend that the consumer materials include specific examples, like the one above, of how consumers can fit fruits and vegetables into their daily meal plan throughout the day. While the new, higher goal is attainable, it will take a coordinated effort, among the Dietary Guidelines Advisory Committee, government agencies, health and nutrition professionals and organizations, and the fruit and vegetable industry – commodity groups and retailers – to better communicate serving sizes in practical and actionable ways so consumers can understand and apply this important guideline.
Submission Date 9/24/2004 1:36:00 PM
Author Produce for Better Health Foundation

   Fruits
Summary PBH strongly supports the use of household measurements, such as cups and ounces, as well as serving sizes.
Comments PBH strongly supports the use of household measurements, such as cups and ounces, as well as serving sizes. Consumers eat many fruits, like apples, oranges, bananas and pears, as pieces of fruit, not in cups and ounces. On the other hand, other fruits like pieces of melon, and grapes, are best understand in terms of cups. We recommend that the consumer materials include more specific information on what constitutes a serving size, especially in the fruit and vegetable category. For example, a list of fruits and vegetables, and their corresponding common measure that constitutes a serving size, should be included in the materials.
Submission Date 9/24/2004 1:39:00 PM
Author Produce for Better Health Foundation

   Vegetables
Summary PBH strongly supports the use of household measurements, such as cups and ounces, as well as serving sizes.
Comments PBH strongly supports the use of household measurements, such as cups and ounces, as well as serving sizes. Consumers eat some vegetables, like celery and cherry tomatoes as pieces of vegetables, not in cups and ounces. On the other hand, other vegetables, like salads and cooked vegetables, are best understand in terms of cups. We recommend that the consumer materials include more specific information on what constitutes a serving size, especially in the fruit and vegetable category. For example, a list of fruits and vegetables, and their corresponding common measure that constitutes a serving size, should be included in the materials.
Submission Date 9/24/2004 1:42:00 PM
Author Produce for Better Health Foundation

   Dairy
Summary Whole diary products of all kinds. Preferably, unaltered milk from local farmers. No alteration of diary products by lowering the fat content and adding food coloring.
Comments
Submission Date 9/24/2004 2:20:00 PM
Author from Holland, MI

   Fruits
Summary Stress fresh not canned and especially not with added sugar.
Comments
Submission Date 9/24/2004 2:21:00 PM
Author from Holland, MI

   Grains
Summary Whole grains of all kinds; bread, pasta, etc. Refined flour is stripped of of many needed nutrients.
Comments
Submission Date 9/24/2004 2:22:00 PM
Author from Holland, MI

   Meat, Poultry, Beans, Nuts
Summary Stress importance of protien intake for slower and sustained levels of blood sugars.
Comments
Submission Date 9/24/2004 2:25:00 PM
Author from Holland, MI

   Vegetables
Summary Lots of vegetables, fresh, next best frozen and canned as least desireable. Encourage consumption of locally grown and in season as the ideal.
Comments
Submission Date 9/24/2004 2:26:00 PM
Author from Holland, MI

   Fruits
Summary Including fruit/veggies/grains/milk all into one guideline is too much- it is too long, wordy & attempts to be specific on too many ideas.
Comments Including fruit/veggies/grains/milk all into one guideline is too much. It is important to stress these food groups seperate, or in pairs. Such as stressing fruit/veggies in one guideline, and placing the grains/milk in a separate guideline. This guideline is too long and "wordy," and is trying to name too many specific ideas into one, very large, guideline. It seems as if the concept is the same as "consuming a variety of foods..."
Submission Date 9/23/2004 12:37:00 PM
Author OSU Extension Program- Cleveland, OH

   Dairy
Summary The previously flawed guidelines reflected the political influence of commercial interests rather than the science presented. The proposed gidelines are not optimal because of the influence of those interests.
Comments Dietary Guidelines: A myraid of diseases have been spawned by the processed food industries and industrial farming practices. Removing from the market place unhealthy, rancid fats from grain and other processed oils and replacing them with healthy oils like coconut oil, butter, whole milk and fat from grass fed beef would greatly improve the health of all Americans. The food group used in the past did not work and the one proposed is flawed. Each person has his own metabolic system and this should dictate what he should eat. Encourage the growing of rich nutrient foods, free of pesticides and artificial fertilizers damage the intestinal tract, adrenal glands which leads to cancer.
Submission Date 9/23/2004 2:55:00 PM
Author Anonymous

   Meat, Poultry, Beans, Nuts
Summary It should be clearly stated that an animal protein-based diet, especially red meat, dairy products, and eggs are the principle causes of heart diseases, most cancers, diabetes, stroke, hypertension, arthritis, and most other chronic diseases that kill many of us long before our time.
Comments It should be clearly stated that an animal protein-based diet, especially red meat, dairy products, and eggs are the principle causes of heart diseases, most cancers, diabetes, stroke, hypertension, arthritis, and most other chronic diseases that kill many of us long before our time.
Submission Date 9/21/2004
Author Anonymous

   Dairy
Summary I would add to this that including meat, dairy, and refined sugars in one’s diet is in fact detrimental to one’s health.
Comments I would add to this that including meat, dairy, and refined sugars in one’s diet is in fact detrimental to one’s health.
Submission Date 9/21/2004
Author Anonymous

   Meat, Poultry, Beans, Nuts
Summary I would add to this that including meat, dairy, and refined sugars in one’s diet is in fact detrimental to one’s health.
Comments I would add to this that including meat, dairy, and refined sugars in one’s diet is in fact detrimental to one’s health.
Submission Date 9/21/2004
Author Anonymous

   Dairy
Summary calcium fortification or supplementation alone does not compensate for dairy’s total nutrient package.
Comments As the Committee’s evidence-based review of the science concluded, “… the most reliable and easiest way to derive the health benefits associated with dairy consumption is to choose alternatives within the dairy food group, such as lactose-free milk or yogurt.” In sum, calcium fortification or supplementation alone does not compensate for dairy’s total nutrient package.
Submission Date 9/21/2004
Author National Dairy Council

   Grains
Summary We believe that the number 4 recommendation should be “Increase the consumption of fruits, vegetables, whole grains and brans, and non-fat or low-fat milk and milk products” or “Increase the consumption of fruits, vegetables, whole grains and fiber rich foods and non-fat or low-fat milk and milk pro
Comments Bran plays a critical role in whole grain actions. Bran is a more concentrated source of dietary fiber, antioxidants and certain micronutrients than whole grain. Bran is a major contributor to the various health benefits that whole grain foods offer. Researchers found that the inverse association of bran and Coronary Heart Disease (CHD) was even stronger than that of whole grain. The same trend was found for weight gain reduction in men. Most consumers do not understand that bran is an active component in whole grains. There is a disconnect between the nutrition research community and regulatory bodies, such as USDA and FDA. Researchers have simply used a short-handed term of whole grain to describe the entire category of whole grain, bran, and fiber rich foods. Most research teams have studied the combined effects of whole grain, bran foods and fiber rich foods by classifying them in the same category - whole grain foods - while very few studies have been done on investigating the effects of whole grain foods only (botanical perspective). A few research teams have studied the contribution from each component to report that cereal fibers and branshow more protective effects (from weight gain reduction and heart diseases) than whole grains. However, FDA and USDA have not included bran foods and other fiber rich foods in the whole grain food category, since bran rich foods are not classified as whole grain foods from a botanical perspective. It is essential that Dietary Guidelines include “bran foods” or fiber rich foods in the key messages. We need to note that most of the research findings on whole grain foods are based on the combined effects of whole grain, bran, and fiber rich foods, not whole grain foods only (from a botanical perspective) (1-19). Without the inclusion of “bran foods” and “fiber rich foods” as part of the message to increase whole grain consumption, this dietary guideline may be considered untruthful and potentially misleading to consumers. If bran foods are omitted from Dietary Guideline recommendations, American’s healthy cereal/grain consumption (“bran food” and/or fiber rich foods which are concentrated sources of fiber and antioxidants) may decrease. Approximately 90% of Americans do not meet the dietary fiber intake recommendations established by the Institute of Medicine (IOM), National Academy of Sciences. Omission of bran or fiber rich foods from the Dietary Guidelines will make it more difficult for Americans to achieve this IOM recommendation. More importantly, consumers cannot enjoy the full health benefits of bran and/or fiber rich foods and the current public health concerns such as weight problems cannot be easily resolved, unless the Dietary Guidelines spells out ‘increase consumption of brans or fiber rich foods’ within the nine key messages that contain active components. Whole grains contain brans which are concentrated sources of dietary fiber. Whoel grain foods have protective effects because of brans and fiber. That does not mean that bran foods and fiber rich foods are whoel grain foods.
Submission Date 9/21/2004
Author W.K. Kellogg Institute

   Meat, Poultry, Beans, Nuts
Summary With more Americans becoming deficient in core nutrients, consumption of nutrient-rich options, like lean beef, is increasingly important for overall health.
Comments With more Americans becoming deficient in core nutrients, consumption of nutrient-rich options, like lean beef, is increasingly important for overall health. There is new and existing research that illustrates how beef and its core nutrients, such as protein, iron, zinc and vitamin B12, play an important role across the lifecycle in meeting essential nutrients to promote normal development, support good health and prevent deficiency diseases.
Submission Date 9/21/2004
Author National Cattleman's Beef Association

   Grains
Summary It is imperative that the DGA Committee and government staff understand and communicate the difference between refined, enriched, fortified and whole grains. It is important that the government- promulgated Dietary Guidelines for Americans harmonize with, and recognize the value of, FDA’s mandate f
Comments It is imperative that the DGA Committee and government staff understand and communicate the difference between refined, enriched, fortified and whole grains. In the carbohydrate section in the Committee’s report, enriched grains are never mentioned. Refined grains are mentioned twice. However, refined wheat flour makes up only about five percent of the total white flour milled in the U.S., while enriched/fortified white flour comprises approximately 95 percent. Whole grain products contain the entire endosperm, bran and germ found in proportional amounts in the unprocessed grain kernel. There are some whole grain breakfast cereals that are adequately fortified with folic acid on a voluntary basis, but no other whole grain products are. Refined, unenriched grain products have had the germ and brain removed with only the endosperm remaining. This represents less than 5% of the total white flour milled in the U.S. It is used primarily for organic and artisan products. A small amount goes into mixes for overseas consumption.Enriched/fortified grain products are refined grain products that have the three major B vitamins and iron replaced in equal amounts to those in whole grain products as defined by the standards of identity. They also are fortified with folic acid in amounts slightly double that found in whole grain products. This higher level of folic acid fortification now makes enriched grain foods also fortified grain foods. This includes such things as white bread, rolls and the majority of other grain foods. This represents approximately 95% of the total white flour milled in the U.S.Other fortified grain products are those that have a variety of minerals and vitamins in various amounts, not defined by any set standards. They are added voluntarily following FDA guidelines. Many breakfast cereals fit into this category. We urge you to recognize the important public health benefits enriched grains have served since World War II: Most of the Baby Boomers and succeeding generations have never heard of pellagra and beriberi, two diseases which have been eradicated by enriched grains.Since 1998, when FDA mandated that enriched grains be fortified with folic acid, neural tube birth defects have decreased almost 30 percent in the U.S. 50 percent in Canada and 41 percent in Chile , two other countries who also began this public health initiative.Neuroblastomas, a deadly brain cancer in infants, have decreased 60 percent in Canada during the same period. This has also been attributed to folic acid fortificationIn a paper given at the American Heart Association conference in March 2004, the Centers for Disease Control and Prevention gave FDA’s mandated fortification of folic acid (to enriched grains) credit for preventing 31,000 annual deaths from stroke and 17,000 annual deaths from ischemic heart disease If Americans were to quit consuming enriched grain foods and fortified cereals, what would happen to the favorable statistics just quoted? It is important that the government- promulgated Dietary Guidelines for Americans harmonize with, and recognize the value of, FDA’s mandate for folic acid fortification in enriched grains and not perpetuate the confusion among refined, enriched and fortified grain products.
Submission Date 9/21/2004
Author The Foundation for the Advancement of Grain Based Foods

   Meat, Poultry, Beans, Nuts
Summary A diet drawn from varied plant sources easily satisfies protein requirements, without the potential for protein excess
Comments A diet drawn from varied plant sources easily satisfies protein requirements, without the potential for protein excess. Plant sources provide all essential amino acids, even without intentional combining or "protein complementing" as long as calorie intake is adequate. Good protein sources include cooked beans, tofu, soy yogurt, tempeh, seitan, nuts, seeds, and whole grains. Soy protein has been shown to be nutritionally equivalent in protein value to proteins of animal origin.
Submission Date 9/21/2004
Author International Vegetarian Union

   Grains
Summary Add the word “products” whenever “whole grain,” “enriched grain,” “fortified grain,” or “refined grain” is used. As you consider the guidelines for grain based foods, please emphasize a common understanding of the terminology for refined, enriched, fortified and whole grain products in order to avo
Comments Throughout the report reference is made to “whole grains.” While nutritionists, dieticians and others with a science based background understand that “whole grains” refer to milled products, the general public does not. They consider “whole grains” to be wheat, corn, and oat kernels in their unprocessed form. Therefore, it is important to refer to “whole grain products.” Whole grain products contain the entire endosperm, bran and germ found in proportional amounts in the unprocessed grain kernel. There are some whole grain breakfast cereals that are adequately fortified with folic acid on a voluntary basis, but other whole grain products are not. Refined unenriched grain products have had the germ and bran removed with only the endosperm remaining. This represents less than 5% of the total white flour milled in the U.S. It is used primarily for organic and artisan products. A small amount goes into mixes for overseas consumption.Enriched/fortified grain products are refined grain products that have the three major B vitamins and iron replaced in equal amounts to those in whole grain products as defined by the standards of identity. They also are fortified with folic acid in amounts twice that found in whole grain products. This higher level of folic acid fortification now makes enriched grain products also fortified grain products. This includes such things as white bread, rolls, family flour, and the majority of other grain products. This represents approximately 95% of the total white flour milled in the U.S.Other fortified grain products are those that have a variety of minerals and vitamins not defined by any set standards in various amounts. They are added voluntarily following FDA (Food and Drug Administration) guidelines. Many breakfast cereals fit into this category. We understand the desire to encourage Americans to increase the consumption of whole grain products. NAMA supports that initiative. In the process, it is critical to retain a positive view of enriched grain products so the consumer does not believe it is detrimental to eat them.We believe the phrase “preferably by substituting whole grains for refined grains” denigrates the role of enriched grain products and perpetuates the confusion surrounding enriched versus refined grain products. We, therefore, strongly encourage you to make statements that are positive to both whole and enriched grain products.A statement in the document that acknowledges the historical benefits of enriched and fortified grain products in the American diet would help accomplish this objective.Grain products have been enriched since 1941 with iron and the B vitamins, riboflavin, niacin and thiamine. With this enrichment, pellegra and beriberi have been eradicated from the United States. In 1998 folic acid was added to the enrichment formula. Enriched grain products have more than twice the amount of folic acid as whole grain products. A slice of enriched white bread has 37 mcg versus whole-wheat at 17.5 mcg. As a result, neural tube birth defects have decreased almost 30 percent in the U.S., 50 percent in Canada and 41 percent in Chile, two other countries who began this public health initiative. Neuroblastomas, a deadly brain cancer in infants, has decreased 60 percent in Canada during the same period. This has been attributed to folic acid fortification.A 1999 study found that 77 percent of low-income women could consume adequate amounts of folic acid through enriched grain products. The cost of supplements can be expensive, and are often not taken by low-income women.In a paper given at the American Heart Association conference in March 2004, the Centers for Disease Control and Prevention gave FDA’s mandated fortification of folic acid (to enriched grain products) credit for preventing 31,000 deaths annually from stroke and 17,000 deaths annually from ischemic heart disease. A consistent message among government agencies is key to retaining the confidence Americans have in our regulatory agencies. FDA mandated the inclusion of folic acid in enriched grain products. The CDC (Center for Disease Control) has undertaken a universal flour fortification initiative that encourages enrichment of flour worldwide. It is critical that the Dietary Guidelines are consistent in communicating that both enriched and whole grain products support good health.
Submission Date 9/21/2004
Author North American Miller's Association

Summary Whole grain is healthier than processed. Therefore minimally processed grain products are favored. Chronic diseases, e.g. cancer, diabetes, & heart disease are all lessened when a person eats a variety of minimally processed whole grain products.
Comments Breads, rice, pasta, polenta, coucous, bulgar, & other grains should be minimally processed. The glycemic index will be less, the nutritional value is increased, and the body benefits overall.
Submission Date 9/25/2004 4:21:00 PM
Author from Hailey, ID

   Dairy
Summary Yogurt and cheese (not processed cheeses) As adults yogurt and cheese is better tolerated than milk and milk products.
Comments Yogurt and cheese are favored for adults. The asian and mediterrean pyramids do not include milk. People from those cultures tend to be less obese and have fewer chronic diseases.
Submission Date 9/25/2004 4:25:00 PM
Author from Hailey, ID

   Meat, Poultry, Beans, Nuts
Summary Adopt the mediterranean diet pyramid. legumes, and Limit red meat to 12-16 oz/mo. Greatly increase beans, other legumes, & nuts as the main source of protein. Eggs can be eaten 0-4/week. Low to moderate amounts of poultry and fish can be eaten.
Comments Beans, soybean, other legumes, and nuts need to be separated from the "meat group". Overall meat, poultry, and fish need to be eaten in less quantities than beans, soybean, other legumes, and nuts. Plant sources of protein are in general very healthy. But there is an emphasis and superiority of meat when reading the dietary guidelines. Even quantities are compared to "1 ounce of meat". Meat needs to be drastically deemphasized. Asian cultures eat very little meat and in general have much less obesity and chronic diseases e.g. diabetes and heart disease and cancer, especially of breast and prostate. The quantity of meat eaten and expected at one meal in the U.S. is huge and grossly unhealthy.
Submission Date 9/25/2004 4:36:00 PM
Author from Hailey, ID

   Dairy
Summary Children require special nutrients for their development. A one-formula-fits-all-ages Pyramid can mislead parents. They should be told that what may be good for them can be hazardous for their children. Low cholesterol cannot grow smart brains, and a low fat diet does not mean trim young bodies.
Comments Donna Robie Howard, Ph.D. Senior Prevention Advisor FDA Liaison Office of Disease Prevention and Health Promotion Department of Health and Human Services 1101 Wootton Parkway, Suite LL100 Rockville, MD 20852 Dear Dr. Howard: Please enter the following as public comment to the proposed Food Pyramid guidelines: Children, infants in particular, require special nutrients for their development. Proponents of a Food Pyramid must take that into consideration, for it undoubtedly will influence some parents’ decisions. For example, for proper brain development, they need a higher level of cholesterol in their diet as compared with adults. Likewise, saturated fats and the fat soluble vitamins they alone provide are critical to organogenesis. A one-formula-fits-all-ages Pyramid can only mislead parents into thinking that non-fat substitute foods such as those containing soy are safe for children. They are not. They produce irreversible injuries in children. The phytoestrogen levels in most soy-based infant formulae are sufficient to accelerate sexual maturity. Soy’s anti-nutrient effects likewise can cripple a young thyroid and body. Your Pyramid must not give parents of young children the simplistic and erroneous impression that low cholesterol can grow smart brains, or that a low fat diet means trim young bodies. Sincerely, Anthony Shen, M.D., Ph.D.
Submission Date 9/23/2004 6:13:00 PM
Author from Berkeley, California

Summary Consider changing the cereals and breads group to a “whole grains and potatoes” group. The use of potatoes in this way would increase the potassium content of the diet without affecting other nutrients provided by the cereals group and eliminates the need to increase milk for adults.
Comments Fruits, vegetables and whole grains contribute heavily to the positive nutrient contributions of the Dietary Intake Patterns (Table D1-16). However, the contribution of milk and milk products, with the exception of calcium and potassium, is not that clear (see Part 4, Table 1 at the end of this letter). Many of the studies cited by the Committee in the section on milk and milk products refer to the general overall quality of a diet with increased milk consumption, rather than higher milk consumption as such. The DASH diet study hopelessly confounds the effects of a number of changes including increased intakes of low-fat dairy, whole grains, poultry, fish, and nuts coupled with reduced intakes of red meat, sweets and beverages with added sugars. This combination gave a better result for those who followed the recommended diet, when compared with a diet which was similar to usual intakes with the exception of increased fruits and vegetables. Since so many changes were made it is difficult to attribute the better result to a change in low-fat milk consumption. The Table D1-16 (Nutrients in the USDA Revised Food Intake Patterns) indicates that the patterns with three 8-ounce glasses of milk daily meet the calcium needs of children from upper elementary to adolescence (9 to 18 y/o) but exceeds the AI for adults by the equivalent of more than one eight ounce glass of milk, except for those 50 or older, (Part 3, Table 1). The justification in the Executive Summary for increasing the recommended amount of low-fat milk and milk products for adults is the contribution of calcium, potassium, magnesium, and vitamin D. Other nutrients of concern are vitamin A and folate. As Table 1 shows, the shortfall in potassium occurs across all age and sex groups, and for older adults is notable. Vitamin D was not included in Table 1 because the food sources that provide it are mostly fortified foods. Since vitamin D is fat soluble, and the milk products recommended are low in fat, choosing a medium such as soft margarines for fortification would make it more available to the body. I would like to suggest another option that is available that would increase potassium and magnesium levels compared with the current Dietary Intake Patterns without the increase in calcium, which is unnecessary for most adults. This would be to change the basic energy providing group from “cereals and breads” to “whole grains and potatoes”. In this case the recommendation would be to eat at least three servings per day of whole grains, with the remainder from this group coming from potatoes. In other words, potatoes replace “other grains” in this group. As can be seen in Part 4 of Table 1, this substitution would not increase the overall calories of the Dietary Intake Patterns, would significantly increase their potassium levels, and would not affect the other nutrients of concern. If this were done calcium provided by the Daily Intake Pattern would be closer to the AI for adults with the exception of those 50 or older. Given the very high shortfall for potassium in this age group and the positive effects of physical activity on bone strength, resistance to fractures, and improvement in chronic diseases, it makes more sense to emphasize increasing physical activity in this age group rather than higher milk consumption. Many people brought with them to the United States a strong tradition of eating potatoes in their native land. This includes immigrants from the British Isles and much of Europe, as well as Latin America. These traditions are reflected in the food groups selected for dietary advice in different countries [Painter, 2004]. In many families in the United States there is a long tradition of interchanging potatoes, rice, and pastas as a component of an everyday meal, making this a natural substitution in meal planning for many people. In today’s world potatoes are most frequently consumed as French fries. However, this problem is better addressed in the efforts to reduce fat consumption rather than not recommending potato consumption.. Current milk consumption by adults is considerably below what is being recommended. Many people object to the flavor of skim milk and will not drink milk if it does not have at least 1 ˝ to 2 % fat content. Therefore, the practical effect of this recommendation would be for many people to ignore the advice, while others consume higher fat content milk with the concomitant increase in the consumption of saturated fats and cholesterol. Table 1 Calcium (mg) Potassium (mg) Magnesium (mg) Vitamin A (mcg RAE) Folate (mcg) Energy Kcal. male female male female male female male female male female Part 1: Recommended nutrient intake (from Table D1-1) AI AI RDA RDA RDA 9-13 1,300 1,300 4,500 4,500 240 240 600 600 300 300 14-18 1,300 1,300 4,700 4,700 410 360 900 700 400 400 19-30 1,000 1,000 4,700 4,700 400 310 900 700 400 400 31-50 1,000 1,000 4,700 4,700 420 320 900 700 400 400 51-70, 70+ 1,200 1,200 4,700 4,700 420 320 900 700 400 400 Part 2: Nutrients supplied by the Dietary Intake Patterns according to age and sex groups for adults (from Table D1-16) 9-13 1,317 1,253 3,853 3,589 368 340 1,013 871 580 495 14-18 1,376 1,317 4,525 3,853 425 368 1,132 1,013 702 580 19-30 1,409 1,333 4,624 4,154 446 386 1,132 1,057 702 610 31-50 1,376 1,317 4,525 3,853 425 368 1,093 1,013 683 580 51-70 1,333 1,253 4,154 3,589 386 340 1,057 871 610 495 Part 3: Difference between RDA or AI and Revised Dietary Intake Patterns (Part 2 minus Part 1) 9-13 17 -47 -647 -911 128 100 413 271 280 195 14-18 76 17 -175 -847 15 8 232 313 302 180 19-30 409 333 -76 -546 46 76 232 357 302 210 31-50 376 317 -175 -847 5 48 193 313 283 180 51-70 133 53 -546 -1,111 -34 20 157 171 210 95 Part 4: Contribution of these nutrients by selected food groups (from Table D1-15. For potatoes from USDA, 2004) Milk 306 382 27 69 12 83 Potatoes 5 293 17 0 8 70 whole grains 29 78 27 26 37 78 other grains 31 29 7 6 36 84 Macpherson-Sánchez A. 1998. A Food Guide Pyramid for Puerto Rico. Nutrition Today 33: 198-209. Painter J. 2004. Exploring food guide graphics from culturally diverse nations. Presentation given at the Society for Nutrition Annual Conference, Salt Lake City, Utah. July 19. USDA. 2004. National Nutrient Data Base for Windows. Standard Reference Release 17. Information on potatoes prepared at home without added fat. Welsh S, Davis, C, Shaw A. 1993. USDA’s Food Guide: Background and Development. Washington, DC: U.S. Government Printing Office, U.S. Department of Agriculture, Human Nutrition Information Service. Miscellaneous Publication No. 1514.
Submission Date 9/26/2004 6:46:00 PM
Author from Mayagüez, ¨PR

Summary Change the name of the “Milk, Yogurt, and Cheese Group (Milk Group)” to “Calcium-Rich Foods Group” and add non-dairy calcium sources to the group listing
Comments We are encouraged to see that alternative sources of calcium are included in the “Milk Group,” particularly soy-based beverages with added calcium. The Guidelines list “lactose-free and lactose-reduced milk products … [such as] one cup of soy-based beverage with added calcium” as nutritionally equal substitutes to cow’s milk, however, the name of the group itself does not reflect these options. Moreover, by listing non-dairy options under an astericks, a false impression is given that they are somehow not as viable as dairy options when, in fact, this couldn’t be farther from the truth. There is actually strong medical evidence showing that dairy products are detrimental to bone health and are not good sources of calcium. There is a correlation between countries that have high per capita animal dairy consumption and rates of osteoporosis and bone fractures. , Researchers from the Harvard School of Medicine, Harvard School of Public Health, and the Channing Laboratory found that “women consuming greater amounts of calcium from dairy foods had … significantly increased risks of hip fracture while no increase in fracture risk was observed for the same levels of calcium from nondairy sources.” By including non-dairy options such as calcium-fortified soy milk, tofu made with calcium sulfate, fruit juice with added calcium, and dark-green leafy vegetables such as collards and turnip greens within the group listing itself (i.e. not as an astericks), and changing the name of the group to “Calcium-Rich Foods Group,” the group would more adequately represent the healthiest options available. Leaving the group as is will only mislead Americans into thinking that the only sources of calcium are from dairy products, when even the Guidelines themselves acknowledge this not to be the case.
Submission Date 9/27/2004
Author People for the Ethical Treatment of Animals (PETA)

   Meat, Poultry, Beans, Nuts
Summary Reorder the listing of food items in the “Meat and Beans Group”
Comments Given the superior health benefits of choosing plant-based foods over animal products, we ask that you reorder food items in the “Meat and Beans Group” to list dry beans and nuts first. For consistency and in order to ensure the healthiest diet, we also ask that it be changed accordingly in all other references to that group, including the name of the group itself, which we ask be changed to the “Beans, Nuts and Meat Group.”
Submission Date 9/27/2004
Author People for the Ethical Treatment of Animals (PETA)

   Grains
Summary There is ample scientific evidence to support that enriched grains, when consumed as part of a balanced diet, offer public health benefits, and the Dietary Guidelines should highlight these facts.
Comments We commend the panel for bringing forward information about the value of whole grains in the diet and recommending that consumers increase their current consumption level. Since consumers currently eat an average of only one whole grain serving per day, the recommendation for three servings or more may require time and consumer education to achieve. Our experience with brown rice consumption may serve as a useful illustration of why this recommendation may be overly optimistic. As a whole grain, brown rice provides important nutrients and fiber with relatively few calories, no sodium or cholesterol and only a trace of fat. Interestingly, brown rice has received a boost from the low-carbohydrate diets; our companies report seeing an increase in brown rice sales. However, brown rice, which accounts for only about 6% of the consumer rice supply, does not have a well-known role in our culture or cuisine. Consumer focus groups show that most people consider brown rice to be “healthy,” but lack knowledge about preparation and usage. Over the past year, USA Rice has created more information and recipes to help close this gap in both at-home and away from home usage. We are working with the American Dietetic Association to make available nutrition information and usage tips for consumers. As a member of the Oldways Whole Grains Council we will be work aggressively to bring brown rice and other whole grains into more mainstream usage. While we support the panel’s move to increase consumption of whole grains and will actively promote the recommendation, we are concerned about the way the recommendation is presented in the summary and about the general lack of information and support for any grains other than whole grains throughout the report. Suggesting that consumers “substitute whole grains for refined” is negative and suggests that enriched, fortified and refined grains are poor choices or that it is somehow detrimental to eat them. We recommend the following language instead:“Grains Intake: The goal for grains intake is five to ten servings per day, of which three servings (equal to 3 ounces) should come from whole grains. The remainder should come from enriched, fortified and refined grains, which also provide important nutrients, particularly folic acid.” We encourage more positive support for the public health benefits of enriched grains: Taste, cost, availability, versatility, and popularity across many cultures and cuisines are among the many reasons why consumers choose to eat white rice. Enriched white rice, which is the majority of milled rice, is a convenient and healthy partner on the plate, combines well with vegetables and beans, and contains relatively few calories, no fat, salt or cholesterol. Enriched rice provides key nutrients such as folic acid, thiamine, calcium, and iron. There is ample scientific evidence to support that enriched grains, when consumed as part of a balanced diet, offer public health benefits, and the Dietary Guidelines should highlight these facts. We suggest adding a statement in the document that speaks to the historical benefits of enriched and fortified grain products in the American diet. Some of the public health benefits of enriched grain products include: Grain products are enriched with the B vitamins, iron, riboflavin, niacin and thiamine. As a result, pellagra and beriberi have been eradicated in our country. Enriched grains are a key source of folic acid in the diet. Enriched grains like rice contribute over 200 micrograms, or over half of consumers’ total daily folate intake (1). Folic acid in enriched grains is more bioavailable than folate found in legumes, fruits, vegetables and even whole grains (2). Folic acid fortification in the United States has been associated with 31,000 fewer deaths from stroke and 17,000 from heart disease each year from 1998 to 2001 (3). Fortification has resulted in about a 25% reduction in spina bifida and anencephaly (4). Fortification has been linked to the prevention of 50 times more deaths from stroke and heart attack than cases of birth defects each year (5). In Arkansas, the prevalence of spina bifida has decreased since folic acid fortification of foods was implemented (6). Folic acid fortification in the United States has also been linked to a diminished high maternal serum alpha-fetoprotein values, a mid-trimester prenatal diagnostic tool for neural tube defects (7). Additionally, consumption of breakfast cereal fortified with folic acid increases blood vitamin concentrations and reduces homocysteine concentration, a biomarker of increased cardiovascular disease risk (8). Consistent messages among government agencies: In the interest of consumer confidence, a consistent message among government agencies should be a goal of the current revision process. For the sake of consumer and infant health, it is important that the Dietary Guidelines be consistent with FDA’s messaging about folic acid fortification. Grain terminology: When referring to grains, we believe it is important to have an understanding of the terminology for refined, enriched, fortified and whole grain products. • Whole grain products contain the entire endosperm, bran and germ found in proportional amounts in the unprocessed grain kernel. All rice starts off as brown rice; however, as previously noted, only about 6% of the consumer rice supply is brown rice. • Refined unenriched grain products have had most or all of the germ and bran removed with only the endosperm remaining. • Enriched and fortified grain products are refined grain products that have the three major B vitamins and iron replaced in equal amounts to those in whole grain products as defined by the standards of identity. In the case of fortified grains, additional nutrients have been added. These grains also are fortified with folic acid in amounts slightly double that found in whole grain products. This higher level of folic acid fortification now makes enriched grain foods also fortified grain foods. This includes the majority of grain foods. Enriched white rice accounts for the majority of the rice milled in the U.S.
Submission Date 9/27/2004
Author U.S. Rice Federal

   Fruits
Summary The California Dried Plum Board (the Board) supports the recommendation of the Dietary Guidelines Advisory Committee for Americans to enjoy and eat 5-13 servings of fruits and vegetables daily for better health.
Comments The California Dried Plum Board (the Board) supports the recommendation of the Dietary Guidelines Advisory Committee for Americans to enjoy and eat 5-13 servings of fruits and vegetables daily for better health. The Board also supports the Produce for Better Health Foundation in its efforts to secure this recommendation. The Board represents 1,050 dried plum growers and 22 dried plum packers under the authority of the California Department of Food and Agriculture and conducts programs in several market development areas including food and nutrition research. For the past seven years the Board has funded an active nutrition research program to demonstrate the benefits of including dried plums in a health-promoting diet. My comments will focus on the science base that establishes the relationship between fruit consumption and good health as it relates to dried plums, and the consumer market research that indicates dried plums can help remove the barrier consumers face in meeting the goal of increased fruit intake. The Committee report provides rationale for the inclusion of fruits (and vegetables) to help lower the risk of cardiovascular disease based on their nutrient profile (fiber, folate, potassium, carotenoids and other phytochemicals) and potential to enable consumers to lower their intake of saturated fat and cholesterol. Over a decade ago, research at the University of California, Davis, established dried plums’ ability, as a source of pectin/soluble dietary fiber, to help lower cholesterol, and thereby lower the risk of coronary artery disease (Tinker 1991; Tinker 1994). More recent research discovered that dried plums significantly reduced the development of atherosclerotic lesions in the apoE-deficient mouse (Gallaher 2004). While the exact mechanism by which this happens is uncertain, the current research indicates that dried plums may slow the development of atherosclerosis in ways other than lowering serum cholesterol. Market research conducted for the Produce for Better Health Foundation (PBHF) discovered that only 12 percent of consumers meet the 5 A Day recommendation. Some of the reasons stated by consumers include taste and price. Previous research identified convenience and accessibility as barriers to intake (Produce for Better Health Foundation Neilson research 2004 and State of the Plate 2003). Expanding the Dietary Guideline recommendation to 5-13 servings encourages a greater variety of intake to accommodate consumers’ personal taste preferences. Dried plums are available year round and a convenient, portable snack. These “market place” attributes coupled with dried plums’ great taste and nutrient attributes - a good source of dietary fiber, with potassium and other nutrients - all contribute to dried plums’ potential to help consumers close the gap between knowledge of the benefits of fruit intake with their behavior. Thank you for the opportunity to comment on the Dietary Guidelines 2005. I would be pleased to provide you with copies of dried plum research of interest.
Submission Date 9/27/2004
Author California Dried Plum Board

   Meat, Poultry, Beans, Nuts
Summary Split the "Meat, Poultry, Fish, Eggs, Legumes, Nuts, and Seeds Group" into the "Meat, Poultry, Fish, and Eggs Group" and the "Legumes, Nuts, and Seeds Group."
Comments Split the "Meat, Poultry, Fish, Eggs, Legumes, Nuts, and Seeds Group" into the "Meat, Poultry, Fish, and Eggs Group" and the "Legumes, Nuts, and Seeds Group." The current name of the protein-rich food group is lengthy and unwieldy. Use of the shortened version, "Meat and Beans Group," does not adequately represent the various protein sources that make up this food group. Another possible alternative would be to rename the group the "Protein Rich Group." Although all of the foods have in common that they are sources of protein, many consumers are probably unaware of this fact. However, this approach fails to convey the fact that animal sources of protein should be limited while vegetable sources may be consumed in larger quantities. Therefore, we recommend that protein foods be split into animal-based and plant-based groups, and that consumers be instructed to consume items from the animal protein group sparingly or not at all, as is currently done for fats, oils and sweets. The Mediterranean diet pyramid places "Beans, Legumes and Nuts" in the middle of the pyramid where foods to be eaten daily are located, while "Eggs, Poultry, and Fish" are located in a higher tier where foods to be eaten weekly are located, and "Meat" is placed at the apex of the Mediterranean pyramid and recommended to be eaten only monthly. This approach is consistent with the American Institute for Cancer Research (AICR) recommendation that red meat intake be limited to just 3 ounces daily, if eaten at all. A recent study of nearly 30,000 women found that those who followed a majority of nine AICR recommendations, including the avoidance of red meat, had a decreased risk of cancer incidence and cancer mortality over those who followed none or only one of the recommendations (Cancer Epidemiological Biomarkers Prevention 2004;13(7):1114). In Addendum B: Protein in Vegetarian Diets, the Report states that, "Typical protein intakes of lacto-ovo-vegetarians and of vegans appear to meet and exceed protein requirements." Furthermore, the Report acknowledges that, with very limited exceptions, the vegetarian food pattern meets all recommended vitamin/mineral/macronutrient requirements at all calorie levels and, in fact, is significantly higher in vitamin E, potassium, fiber, and folate than the traditional meat, poultry, fish, and eggs pattern. In addition, the vegetarian food pattern is noted to be significantly lower in at least two minerals/nutrients of concern - sodium and cholesterol. Although the vegetarian pattern is lower in some of the B vitamins and zinc, it still meets or exceeds recommendations. Given that plant-based foods provide adequate protein and other nutrients, and that animal-based foods provide unhealthy levels of fat and cholesterol, we recommend that the Dietary Guidelines for Americans clearly differentiate between the two sources of protein and advise consumers against consuming foods derived from animal sources.
Submission Date 9/27/2004
Author

   Dairy
Summary Include research suggesting harmful effect from non-fat milk consumption. Add the intake of "non-dairy sources of calcium" to key message #4.
Comments Include research suggesting harmful effect from non-fat milk consumption. The report fails to make mention of any research demonstrating possible negative consequences of consuming non-fat milk and milk products. At least three studies have shown a strong correlation between milk consumption and coronary heart disease rates in different countries. One of the studies provides evidence not only of correlation but also of causation (International Journal of Cardiology 2003;87:203). The authors of this study noted that it is no longer sufficient to focus on fats and cholesterol and that theories of coronary disease causation will need to concentrate on non-fat properties of milk. One explanation for the reported higher incidence of coronary disease among milk drinkers, regardless of fat content, may be because bovine milk has a significantly higher calcium/magnesium ratio than required by humans. High calcium levels in the gut inhibit magnesium absorption, which means less magnesium is available to breakdown fibrin, slow thrombin formation, reduce platelet clumping, and inhibit vascular muscle contraction. The loss of these valuable functions through a calcium-induced magnesium deficiency could impair cardiovascular performance. Add the intake of "non-dairy sources of calcium" to key message #4. The current message states, "Increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products." It does not recommend the intake of calcium-rich alternatives to milk. Moreover, the Executive Summary of the Report advises, "When considering alternatives to milk, the most reliable way to derive the health benefits associated with milk products is to choose alternatives within the dairy food group such as lactose-free milk or yogurt." However, Appendix G-2 notes, "[T]he most viable alternatives for many individuals may be alternative foods within the milk group or fortified foods such as fortified orange juice or fortified soy products" (italics added). The rationale offered for not recognizing non-dairy alternatives is low calcium content and bioavailability of plant sources of calcium. The Report explains that a food intake pattern that excludes milk would need to include a much larger amount of calcium-containing plant foods than typically consumed by Americans. It would be beneficial for Americans to consume more calcium-containing plant foods. In addition, there is a growing variety of calcium rich non-dairy alternatives such as fortified orange juice and soy milk that contain adequate amounts of calcium. Part D (Section 6) of the Report notes, "Trials using milk, foods fortified with dairy calcium, or calcium supplements have demonstrated a comparable and important increase in skeletal mass in younger subjects and reduction in loss of skeletal mass in older subjects." Table D1-19 shows that several vegetables, such as kale, bok choy and Chinese spinach, and foods with added calcium, such as tofu, fortified orange juice and enriched breads and soy milk, offer calcium in amounts comparable to milk. And, furthermore, the calcium in all of these foods, with the exception of soy milk, is estimated to have absorption efficiencies equal to or better than milk. These vegetables and enriched foods not only provide adequate sources of calcium but also contain lower levels of fat and zero cholesterol. The Report cites no research showing that nondairy sources of calcium are not suitable substitutes for milk and milk products. Without evidence demonstrating the inadequacy of milk substitutes, we see no justification for excluding these alternatives. Therefore, we recommend that key message #4 be revised to read, "Increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products or non-dairy sources of calcium."
Submission Date 9/27/2004
Author

   Grains
Summary We respectfully request your agencies to keep the total number of daily servings of grain foods the same, and recommend in the 2005 edition of the Dietary Guidelines for Americans that Americans continue to eat 6 – 11 servings of grain foods.
Comments The Wheat Foods Council commends the Dietary Guidelines Advisory Committee for its dedication in providing nutritional information and guidelines for the general public age 2 years and older. We agree that Americans should increase whole grain foods in their diets, and are pleased the committee recognized the important role whole grains play in promoting health and reducing chronic disease. However, we are concerned the committee is recommending fewer servings of grain foods, fewer servings of enriched and fortified grains foods and may be giving impractical advice. The committee verifies in their report they want Americans to balance their calories, but also want Americans to substantially increase their caloric intake of fruits, vegetables and milk. Because calories count, Americans will have to do so at the expense of eating less grain foods. A person on a 2200-calorie diet (moderate intake for the Food Guide Pyramid) is expected, by the committee, to eat three more servings of fruits and vegetables and one more serving of milk. Fats, sugar and other additives for these food servings will push caloric intake even higher. The claim is made that increased fruit, vegetable and milk consumption will help Americans meet recommended nutrient intakes and reduce the risk of chronic diseases. Grain foods have been the foundation for a healthful diet because they also provide Americans the nutrients they need to meet dietary recommendations and to reduce the risk of disease. The health benefits of grain foods should not be ignored. By keeping the current number of grain food servings the same number as recommended in the 2000 Dietary Guidelines for Americans, you will insure that Americans will be getting the nutrients they need for a healthful diet. By recommending fewer servings of enriched and fortified grains foods, the committee may be putting babies and adults at risk. In 1998, FDA mandated that enriched grains be fortified with folic acid. Whole grains contain the natural form called folate but they are not fortified with folic acid, the synthetic form. The folic acid fortification program is beneficial for three reasons: First, Americans like enriched grain foods and fortified grain foods help them consume adequate levels of folic acid; second, a fortification program means that more folic acid is available in a food than what nature would naturally provide; and third, folic acid is more bioavailable (more absorbed by the body) than foods with naturally occurring folate. Americans are currently reaping the health benefits of eating enriched and fortified grain foods. The Center for Disease Control and Prevention reports that since enriched grain foods were fortified with folic acid in 1998, neural tube birth defects have decreased 26 percent, and 31,000 stroke-associated deaths and 17,000 deaths from heart disease have been reduced per year. Epidemiological studies have also suggested that folic acid may decrease the risk of certain forms of cancer. The health benefits of eating enriched and fortified grain foods are important, and recommending that Americans reduce their consumption may be detrimental to public health. Furthermore, the food pattern suggested by the committee may be impractical and could further reduce folic acid consumption. The committee report states, “Replacement of the enriched grains in the food patterns with whole grains does not compromise the nutritional integrity of the patterns.” On a spreadsheet this is true; however, goals should be set as close as possible to the current dietary consumption pattern of Americans. We do not believe Americans will meet the same level of folic acid consumption if they are given the message to eat fewer servings of grain foods, and fewer enriched and fortified grain foods. If Americans reduce their intake of enriched and fortified grain foods, they could make up for the shortfall of folic acid if they eat an adequate number of servings of foods containing folate, the natural form of folic acid. An adequate intake of whole grains, dark-green vegetables and legumes would make up for the shortfall. However, Americans on average do not eat enough whole grains, vegetables, or legumes. The nutrition community knows this fact all too well, and the committee verified it in their report. Table G2-9 demonstrates the discrepancy and shows the following: ? Reported intake of whole grains is 437% below the proposed USDA food pattern* ? Reported intake of dark-green vegetables is 431% below the proposed USDA food pattern* ? Reported intake of legumes is 542% below the proposed USDA food pattern* *Note: Finding for adult women 31 to 50 years old. Sending messages to the public to reduce enriched and fortified grain foods, when data shows Americans are consuming too few of the foods that could make up for the shortfall in folic acid consumption, may not be in the best interest of the public. Behavior change requires goals that are practical and reachable. There is a practical reason why enriched grain food products were chosen as the vehicle for folic acid fortification. Grain foods are abundant, economical, easy-to-store, readily available and are consumed by Americans. We respectfully request your agencies to keep the total number of daily servings of grain foods the same, and recommend in the 2005 edition of the Dietary Guidelines for Americans that Americans continue to eat 6 – 11 servings of grain foods. Thank you for the opportunity to submit comments regarding the Report of the 2005 Dietary Guidelines Advisory Committee. The Wheat Foods Council is a non-profit, nutrition education association dedicated to educating the consumer about the importance of grain foods in a healthful diet.
Submission Date 9/27/2004
Author Wheat Foods Council

   Fruits
Summary The IFPA fully endorses and concurs that consumers should be striving to consumer 5-13 servings of fruits and vegetables each day. However, consumers need specific information based on factors such as age, gender, health status, etc as to how many fruits and vegetables to consume. The IFPA recomme
Comments The International Fresh-cut Produce Association (IFPA) represents and provides technical expertise to commercial suppliers of fresh-cut produce, as well as companies affiliated with the fresh-cut produce industry, including equipment manufacturers, retailers and foodservice operators. The IFPA represents over 450 corporate members who are actively involved in the $10 billion plus fresh-cut fruit and vegetable business. Fresh-cut produce is wholesome, convenient and ready-to-eat fresh fruits and vegetables. These products are sold at retail and in food service establishments and include items such as bagged salads, baby cut carrots, broccoli florets, fresh-cut melons and sliced apples. Fresh fruits and vegetables are perceived by consumers to be healthful and nutritious foods because of the plethora of scientifically substantiated and documented health benefits derived from consuming fresh fruits and vegetables. The IFPA applauds the recommendations put forward in the 2005 Dietary Guidelines Advisory Committee Report regarding increased consumption of fresh fruits and vegetables to promote public health and curb the obesity epidemic in the United States. The 2005 Dietary Guidelines Advisory Committee Report reaffirms long-term health benefits of consuming fresh fruits and vegetables including: • reduced cancer risk, • reduced risk of cardiovascular disease, • reduced risk of type 2 diabetes mellitus, • improved health by maintenance of appropriate weight status. The IFPA fully endorses all programs whether governmental or private sector that encourage consumers to include fruits and vegetables as part of a healthy diet. We believe that fresh-cut fruits and vegetables will play an ever increasing and important role in helping Americans attain better health by providing highly nutritious fruits and vegetables in a ready-to-eat form. Below are comments and recommendations of the IFPA and its members regarding the 2005 Dietary Guidelines Advisory Committee Report. 1. Quantity Issue: The 2005 Dietary Guidelines Advisory Committee Report recommends, a range of 5-13 servings of fruits and vegetables each day for daily energy intakes of 1200-3200 calories. For a 2000 calorie daily energy intake, 9 servings (4 ˝ cups) are recommended. The report also emphasizes that fruits and vegetables are important to a healthy diet. Recommendation: The IFPA fully endorses and concurs that consumers should be striving to consumer 5-13 servings of fruits and vegetables each day. However, consumers need specific information based on factors such as age, gender, health status, etc as to how many fruits and vegetables to consume. The Produce for Better Health Foundation recommends five to ten servings per day and this coincides with proposed guidelines recommendation of five to thirteen servings per day. The proposed fruit and vegetable consumption recommendation provides a harmonized message for consumers and the recommendation is substantiated by the findings of the DASH Diet, PREMIER Study, Nurses Health Study, Health Professionals’ Follow-Up Study, World Cancer Research Fund, as well as other reports that support the important role that fruits and vegetables play in promoting health. Higher fruit and vegetable intakes will help reduce the risk for many chronic diseases, including cardiovascular disease, cancer, lung disease, and age-related diseases (e.g., osteoporosis, cataracts, neurodegenerative diseases). 2. Variety Issue: The fresh produce industry is extraordinarily diverse and complex in the number of products produced, how the products are grown and handled and the geographic areas from which these products are sourced. A typical retail grocer in North America will have available on a daily basis upwards of 300 different produce items for sale. Americans currently do not consume a wide variety of fruits and vegetables as potatoes, iceberg lettuce and canned tomatoes account for almost half (48%) of all vegetable consumption and oranges, apples, and bananas account for 50% of total daily fruit servings in the United States. Consumers derive long-term health benefits from consumption of fresh fruits and vegetables particularly when they consume a variety of fruits and vegetables as each fruit and vegetable has a unique assortment of vitamins, minerals, and phytonutrients. Consumption of a variety of fruits and vegetables, especially within and between color groups should be encouraged to maximize the health-promoting benefits of fruits and vegetables. This consumption strategy is also likely to be superior to eating a narrow range of fruits and vegetables for health maintenance and disease prevention. Use of the word “variety” is too vague; consumers need specifics. Recommendation: The IFPA recommends that the fruit and vegetable guidelines include text on specifically what is meant by eating a “variety” of fruits and vegetables. It is also recommended that the Committee include the Produce for Better Health Foundation concept of “color” in the dietary guidelines as a way for consumers to put into practice the vague concept of “variety.” 3. Quality Issue: The 2005 Dietary Guidelines Advisory Committee Report emphasizes and recommends increased fruit and vegetable intake but this in and of itself may not be specific enough to make an impact on health promotion and disease prevention, unless guidelines for the preservation of the integrity of these foods are included. Recommendation: The IFPA recommends that the fruit and vegetable guidelines include text which emphasizes the need for consumers to eat fruits and vegetables that have minimal amounts of processing, with little or no added fats, salt and sugars, to maintain their integrity as healthful foods. The IFPA also recommends that the Dietary Guidelines Committee emphasize that consumption of fruits and vegetables that have been minimally processed and not fried or served with fatty sauces. The guidelines should also emphasize that supplements cannot substitute for whole, unprocessed/minimally processed fresh fruits and vegetables. 4. Replacement Issue: Consumers need specific guidance or recommendations regarding substitution of fruits and vegetables for other foods that contain highly refined carbohydrates, sugars, sodium, and/or fats. It is important to empower consumers to informatively choose foods that promote weight control, curb obesity and assist in attaining the public health goal of getting consumers to eat 5 to 13 servings of fruits and vegetables a day. Recommendation: The IFPA recommends that the 2005 Dietary Guidelines include text that urges Americans to eat fruits and vegetables and other high fiber, nutrient-rich, low energy-dense foods in place of foods high in calories, fat, sodium, and sugar. Use of a food replacement strategy can aid in weight control and potentially reduce obesity. The IFPA recommends that this replacement concept be incorporated into the guidelines. 5. Promotion Issue: Fruits and vegetables are under-consumed by Americans to a greater extent than any other food group. This under-consumption is evidenced in the total number of fruits and vegetables consumed and the variety of fruits and vegetables consumed. Under-consumption results in a reduced intake of the required amounts of both essential (vitamins and minerals) and protective (fiber and phytochemicals) nutrients. Recommendation: The IFPA recommends that the Dietary Guidelines Advisory Committee actively and aggressively promote fruits and vegetables in the revised edition of the guidelines. The IFPA also recommends that the Dietary Guidelines emphasize the need to establish healthy eating habits early in life and this includes consumption of the recommended servings of fruits and vegetables. These habits should be recommended to children, their parents and other caregivers, as well as others involved in caring for and feeding children, such as school administrators, teachers, and school food service professionals. The aggressive promotion of fruits and vegetables is the shared responsibility of the Dietary Guidelines Advisory Committee, federal agencies with health and nutrition responsibilities, other public health agencies, non-profit groups, industry, educators, and individuals.
Submission Date 9/27/2004
Author International Fresh-cut Produce Association's

   Grains
Summary We are extremely concerned that the daily number of servings of grain foods is decreased to 5-10 servings from the current recommendation of 6-11 servings. We believe that fruits, vegetables or dairy foods cannot completely and adequately replace the nutrient contributions of enriched grain foods.
Comments While we support the Advisory Committee’s science-based recommendations to increase intakes of fruits, vegetables and milk/dairy foods, we are concerned that the daily number of servings of grain foods is decreased to 5-10 servings from the current recommendation of 6-11 servings. A reduction of grain servings is never stated in the conclusive statements, in Section E or in Table G2-7 (Proposed USDA Food Intake Patterns) of the Report. It is, however, shown for certain calorie levels in the revised USDA Food Intake Patterns (Table D1-13). In fact, this table indicates that the decrease is between 1-2 grain servings for certain age and calorie intakes. Apparently, the proposed food intake patterns were revised to meet shortfall nutrients described in the nutrient intake section of the Report. We believe that fruits, vegetables or dairy foods cannot completely and adequately replace the nutrient contributions of whole, enriched and fortified grain foods. As shown in Table G2-14, fruits, vegetables and dairy foods have very different nutrient contributions, both in terms of types and levels of nutrients. The Report also shows that with a dietary pattern of 35% of calories from total fat and 5% from added sugars, a reduction of 0.5 –1.0 servings of grains may be necessary to maintain caloric balance (Tables G-2-26 and G2-27). It is clearly acknowledged that the decreased enriched grain servings compromise the nutrient adequacy of several age/gender groups (specifically calcium, iron and dietary fiber, three nutrients already insufficient in these subpopulation groups). We are very concerned that either the Dietary Guidelines communication materials or the revised Food Guidance System might suggest a reduced grain servings approach as the way to achieve recommended food patterns and nutrient intakes based on caloric limitations. Although we recognize the importance of energy balance, a reduction in grain servings (particularly enriched grains) could compromise nutrient intakes. • Whole Grains The Dietary Guidelines Advisory Committee is to be commended their science-based recommendation to increase whole grain consumption to at least three servings daily. This new recommendation builds upon the scientific evidence that has emerged since the 2000 Dietary Guideline that recommended: Choose a Variety of Grains Daily, Especially Whole Grains. General Mills supports the specific conclusive statements and recommendations concerning whole grain with the exception of the parenthetical reference to “equivalent to 3 ounces of whole grain daily”. This reference needs to be removed in the message statement in Section E. It is confusing and potentially misrepresents the quantity of whole grain in a whole grain product. There could be different interpretations of what constitutes a whole grain serving because of the parenthetical reference to “ounces” in the Report. It is not clear if the Committee intended the “ounces” to describe: 1. the serving size of a grain product equivalent to the grain content (16g) of an ounce of bread, or 2. the total weight of the food item. Each of these descriptions could represent a significantly different amount of whole grain in the food. Based on Table D1-13, it appears the Committee intended “ounces” to mean the former (#1) description. Consumers, however, are likely to interpret it to mean the latter (#2) description. We would like to emphasize that an ounce cannot be used as an equivalent of the grain/whole grain content for all types of grain foods due to moisture and other ingredients. The table below illustrates this distinction and why we believe the reference to ounces should be dropped. Please note: a whole grain serving as defined by the USDA Food Guide Pyramid servings study is 16 grams of whole grain flour per 26 g grain serving (~1 ounce), based on commercial bread. Selected Serving Weights and Grain Content for Foods based on the USDA Food Guide Pyramid Food Serving Serving Weight (g) *Grain Content (g) Yeast Bread 1 slice 26 16 Whole Grain Bread 1 slice 28 16 Dinner Roll 1 small 28 16 Muffin 1 small 45 16 English muffin, bagel, croissant ˝ muffin, bagel, croissant 25-29 16 Rice, pasta, cooked breakfast cereals ˝ cup cooked 28 (uncooked) 79-140 (cooked) 16 Ready-to-eat breakfast cereals ~1 cup ~20-65g Minimum 16** Pancake 5 inch diameter 40 16 Flour Tortilla 7 inch diameter 33 16 *Equivalent grain content—could be whole grain, enriched grain or a combination of grains **Grain content varies depending on density of cereal per cup In addition, the recommendation that three servings of whole grains are equivalent to 3 ounces is not necessarily reflective of the science. The 11 published studies reviewed by the Committee expressed whole grain intake in terms of servings per day or servings per week. The Committee recognized the challenge for consumers to identify whole grain foods and we commend them for including information on how to determine whole grain-containing foods. General Mills would also like to make the Departments aware of an initiative that may prove to be very useful in helping consumers sort out whole grain sources in the diet. In May 2004, General Mills submitted a Citizen’s Petition8 to the Food & Drug Administration (FDA) proposing whole grain content definitions or descriptors for “good source” and “excellent source” of whole grains and “made with whole grains” statements for food packages. Our definitions are based on the Pyramid servings and scientific data indicating that three servings of whole grains daily (16 g x 3 servings daily = 48 g) is associated with decreased risk of chronic diseases and overall better health: • Good source=8 g or more whole grain per serving • Excellent source=16 g or more whole grain per serving • Made with/Contains whole grain=8 g or more whole grain per serving This approach takes into account that 6 servings (the minimum number of grain servings recommended for adults) of a “good source” whole grain or 3 servings of an “excellent source” of whole grain fulfill the recommended 3 servings of whole grain daily. Our consumer research indicates that consumers understand that whole grains have various health benefits but they do not fully understand what whole grains are and where they can be found. Thus, the challenge is to have a tool that helps consumers readily identify food products that contain dietarily significant amounts of whole grains so that the recommended daily servings and corresponding health benefits may be achieved. In addition, even health professionals have difficulty identifying whole grain products and thus are not well equipped to help guide consumers to whole grain products containing a significant level of whole grains. In the absence of any defined, consumer friendly term, the predominant advice given to consumers is to look at the ingredient statement to find the whole grain content. However, the ingredient statement does not adequately convey the dietarily significant amount of whole grain contained in the product. In fact, the ingredient list may over- or under-convey the actual whole grain content to the consumer because it is not always declared in the same manner. For example, ingredient lists often include “rolled oats,” which does not immediately convey to the consumer that it is a whole grain ingredient. Further, “whole grain wheat” is sometimes declared as such but sometimes is simply labeled as “whole wheat”. This can result in consumer confusion regarding the whole grain content of a food. Similarly, the position of whole grain in the ingredient list may under-or over-convey whole grain content. The descriptors we have proposed for whole grain content clearly remedy this confusion by establishing defined levels of whole grain content to help consumers easily identify foods that are significant sources of whole grain across a variety of categories. Enclosed you will find a copy of the Citizen’s Petition that details the scientific basis for the definitions and consumer research that supports the need and usefulness of these terms given the challenge of identifying whole grain foods. • Enriched Grains As outlined earlier, we are concerned that reducing or eliminating enriched grains from consumers’ food patterns could compromise the nutrient intakes of certain populations. Intakes of iron, calcium and dietary fiber are affected and folic acid is another key nutrient that may be compromised, depending on the substitute food. It has been well documented that the incidence of neural tube defects has dramatically declined due to improved folic acid intakes since the inception of folic acid addition to enriched grain foods in 1998. Ready-to-eat cereals also supply a significant proportion of the folic acid intake of the population through voluntary fortification. One important distinction concerning added or synthetic folic acid must be considered: the added folic acid in grain products is about twice as bioavailable as the naturally occurring form in fruits, vegetables and other foods. Thus, substituting fruits and vegetables for enriched or fortified grain products may not truly meet the requirements of the population group it was intended to benefit.
Submission Date 9/27/2004
Author General Mills

   Dairy
Summary We strongly support the report’s recommendation that most people consume three servings of dairy each day and believe this recommendation is clear enough for consumers to understand as it stands now.
Comments We strongly support the report’s recommendation that most people consume three servings of dairy each day and believe this recommendation is clear enough for consumers to understand as it stands now. We believe that dairy’s unique nutrient package makes three servings of dairy an important goal for every American’s food plan. In addition to being the largest single source of calcium, magnesium, and potassium, and a significant source of vitamin A, all nutrients of concern in the American diet, milk makes a substantial contribution of eight other nutrients. As the committee’s final report stated, three servings daily of milk and other dairy foods do not cause weight gain. We believe that research will continue to indicate that dairy has an important role in promoting healthy weight loss. As nutrition research progresses, we are confident that studies will indicate that dairy provides additional health benefits beyond strong bones, especially involving weight control and blood pressure. While low-fat and fat-free versions of dairy products are a healthy choice for many Americans, we believe it is more important for people to get the health benefits of consuming dairy, rather than being discouraged from dairy consumption if their choice is something other than low-fat or fat-free products. As acknowledged by the committee’s report, no other food is a complete substitute for dairy. Dairy provides a package of 12 essential nutrients, including calcium, vitamin D, and potassium. As the report stated, bioavailability of calcium and dairy’s contribution of other important nutrients strengthen dairy’s position as a vital part of the American diet. There is no easy substitute for dairy foods, which the report makes clear by stating , the large quantity of plant food that would be needed to provide as much calcium as in a glass of milk may be unachievable for many.
Submission Date 9/21/2004
Author International Dairy Foods Association

Summary Milk and milk products contribute the vast majority of calcium provided in our diets. Milk’s unique nutrient package – its nutrient density – makes it an ideal food group to help people maximize consumption of nutrient dense foods while minimizing consumption of energy dense foods.
Comments Milk and milk products contribute the vast majority of calcium provided in our diets. While this important nutrient is critical to bone health, it is also increasingly clear that milk plays an important role in metabolism, from weight management to reducing the risk of insulin resistance syndrome. That’s why the advisory committee’s recommendation for three servings of dairy a day is so important. Milk’s unique nutrient package – its nutrient density – makes it an ideal food group to help people maximize consumption of nutrient dense foods while minimizing consumption of energy dense foods. That’s why we strongly concur with the committee’s recommendation that when considering milk alternatives, the best thing to do is to choose alternatives within the dairy food group such as lactose-free milk or yogurt, if you want the health benefits associated with milk. The advisory committee’s review of the literature notes that “none of the studies show that milk group consumption is associated with an increase in body weight.” While we believe the scientific literature supports a stronger positive statement, we understand the committee’s conservative approach and support their recommendation for more research on the issue.
Submission Date 9/21/2004
Author National Milk Producers Federation

   Fruits
Summary United supports the committee’s focused attention on fruits and vegetables because of the growing body of research linking them to health, and because intake of produce by many Americans is far below current dietary guideline recommendations. Specifically, we believe that the guidelines must commu
Comments As the produce industry’s oldest national trade association and public policy advocates for producers, wholesalers, distributors, brokers, and processors of fresh fruits and vegetables, we have long supported scientific evidence endorsing the health benefits associated with a varied diet based on fruit and vegetable consumption as the cornerstone to good health. We commend the agencies for their important work on the task of updating and revising one of our nation’s most important nutrition education tools to reflect the most recent science regarding healthy diets. United supports the committee’s focused attention on fruits and vegetables because of the growing body of research linking them to health, and because intake of produce by many Americans is far below current dietary guideline recommendations. Today, only one in five Americans meets the minimum five-a-day requirement. The committee concluded that Americans should increase their intake of fruits and vegetables to five to 13 servings, depending on calorie needs. Because fruits and vegetables are a vital foundation to optimal health, it is critical that they are not lost within the new guidelines. Fruit and vegetable consumption information must be the foundation of any educational tool detailing good consumer eating habit. And we strongly support the inclusion of the five to 13 servings recommendation in the revised document. We also agree that the guidelines must encourage consumers to eat a variety of foods within and among the basic food groups, while staying within energy needs. Specifically, we believe that the guidelines must communicate the need for Americans to consumer a wider variety of fruits and vegetables, as they provide the wide range of vitamins, minerals, fiber, and vital chemicals consumers need to maintain good health and energy. We encourage the agencies to include the concept of color, as a way for consumers to put into practice the otherwise vague concept of variety. Eating a variety of fruits and vegetables within and across color groups would expand the intake of traditional nutrients, as well as vital chemicals whose important connection to promoting health is emerging. This is extremely important given that one six fruits and vegetables account for almost half of fruit and vegetable consumption in the U.S. This concept provides a positive, action-oriented road to increase variety, and can also be a platform for increasing consumption.
Submission Date 9/21/2004
Author United Fresh Fruit and Vegetable Association

   Grains
Summary Increase daily intake of fruits and vegetables, whole grains, and nonfat or lowfat milk and milk products. • We are pleased to see the total daily amount expressed as cups instead of only by serving. We recommend this carry over into consumer pieces, as well. • Supporting text should incorporate th
Comments Increase daily intake of fruits and vegetables, whole grains, and nonfat or lowfat milk and milk products. • We are pleased to see the total daily amount expressed as cups instead of only by serving. We recommend this carry over into consumer pieces, as well. • Supporting text should incorporate this message within the context of substituting these foods for more calorically-dense foods. • To include legumes and to emphasize nutrient-dense choices within groups, we suggest the key message be changed to “Increase intake of vegetables and fruits, whole grains, legumes, and nonfat or lowfat milk and milk products.”
Submission Date 9/27/2004
Author American Cancer Society, American Diabetes Association, American Heart Association

   Vegetables
Summary Specifically, we believe that the Guidelines must communicate the need for Americans to consume a wide variety of fruits and vegetables as they provide the range of vitamins, minerals, fiber, and phytochemicals consumers need to maintain good health and energy levels, protect against the effects of
Comments Increase daily intake of fruits and vegetables, whole-grains, and nonfat or low-fat milk and milk products United supports the Committee’s focused attention on fruits and vegetables because of the massive body of research linking these foods to health. Little more needs to be said about the scientific basis for the Committee’s strong recommendations. The Committee concluded that “greater consumption of fruits and vegetables, 5-13 servings depending on calorie needs, is associated with a reduced risk of stroke and perhaps other cardiovascular diseases, with a reduced risk of cancers in certain body sites, and with a reduced risk of type 2 diabetes….” Moreover, it noted that increased consumption of fruits and vegetables may be a useful component of programs designed to achieve and sustain weight loss. We strongly support the inclusion of the 5-13 servings recommendation in the final document, and as much of the scientific basis establishing the critical public health need to achieve these consumption levels. With such an overwhelming body of evidence on the need to increase fruit and vegetable consumption, we strongly urge the Departments to directly address in the Guideline the huge gap that exists today between what we are telling people to eat, and what is actually consumed. The Guidelines themselves must not only set the targets; they must acknowledge how far below those targets we are today and demand action to close that gap. Because actual consumption levels of fruits and vegetables today are so far below what the 2005 Guidelines will recommend, we urge the Departments to give prominence to this public health challenge. The fruit and vegetable consumption recommendations cannot be “lost” within the new Guidelines. The need for all Americans to dramatically increase their fruit and vegetable consumption to meet the Dietary Guidelines must “jump off the page” and grab consumers, public health, and government’s attention in the final Dietary Guidelines. Consume a variety of foods within and among the basic food groups while staying within energy needs The Committee report suggests that at least 34 nutrients are needed for growth and normal body functioning and notes that nutrients function in many ways to build, maintain, and protect body structures and systems and to promote health. The advisory Committee believes that these nutrients should be obtained primarily through food consumption and recommends that the revised Guidelines encourage consumers to eat a variety of foods within and among the basic food groups while staying within energy needs. We concur with this suggestion and encourage the Agencies to incorporate this message in the guidance. Specifically, we believe that the Guidelines must communicate the need for Americans to consume a wide variety of fruits and vegetables as they provide the range of vitamins, minerals, fiber, and phytochemicals consumers need to maintain good health and energy levels, protect against the effects of aging, and reduce the risk of cancer and heart disease. We have found success in delivering this message to consumers through the use of 5 A Day the Color Way, which encourages consumption of many different colored fruits and vegetables. This simple mantra allows consumers to remember to consume a wide variety of fruits and vegetables, without having to keep track of which products contain which nutrients. We encourage the Departments to incorporate the concept of “color” as a way for consumers to put into practice the otherwise vague concept of “variety. This concept provides a positive, action-oriented way to increase variety and can also be a platform for increasing consumption overall.
Submission Date 9/27/2004
Author United Fresh Fruit and Vegetable Association

Food Safety
   Listeria
Summary The incorporation of food safety information may be confusing and overwhelming for the average consumer grappling with the application of the Guidelines into their daily living.
Comments Keep food safe to eat For the first time, the Committee put forth recommendations concerning food safety. Of course, we support the safest possible food supply, and all efforts to increase safe food production, distribution, handling, and in-home preparation. Yet, the Departments will be challenged just to communicate the revised dietary guidance and its core nutrition messages to the public. The incorporation of food safety information may be confusing and overwhelming for the average consumer grappling with the application of the Guidelines into their daily living. If the Departments choose to include food safety in the Guidelines, we encourage consumer testing of the messages prior to their incorporation in the final guidance. Further, we recommend that the messages are consistent with both USDA and FDA consumer food safety messages. Specifically, such messages should focus on consumer handling and establish four key messages (clean, separate, cook and chill) mirroring the FightBAC! Campaign established by the Partnership for Food Safety Education. We strongly object to the Dietary Guidelines process being used to develop new or untested food safety messages when the expertise of the Advisory Committee and the staff working on the Guidelines is outside of the food safety area. This is primarily a nutrition and health initiative, and if food safety messages are to be included, they must reflect tested messages developed by other experts within the FDA, USDA, and others in the National Partnership for Food Safety Education.Keep food safe to eat
Submission Date 9/27/2004
Author United Fresh Fruit and Vegetable Association

Summary The IFPA recommends that the 2005 Dietary Guidelines not include text regarding consumer food safety practice recommendations. The new revised 2005 Dietary Guidelines should focus solely on food nutrition as they have historically.
Comments Inclusion of Consumer Safe Food Handling Recommendations in the Dietary Guidelines Issue: The 13-member 2005 Dietary Guidelines Advisory Committee was appointed by the Departments of Health and Human Services and Agriculture to assist the departments in providing sound and current dietary guidance to consumers. Chapter 9 of the 2005 Dietary Guidelines Advisory Committee report addresses the issue of food safety and specifically: • What behaviors are most likely to prevent food safety problems? • What topics, if any, need attention even though they are not an integral part of the "FightBAC!®" campaign? While discussion and educational outreach to consumers regarding safe food handling and preparation practices is warranted, inclusion of food safety recommendations for specific food products in the 2005 Dietary Guidelines is not appropriate. Food safety recommendations are outside the scope of Dietary Guidelines and may send mixed or confusing messages to consumers regarding consumption of various food groups. Recommendation: The IFPA recommends that the 2005 Dietary Guidelines not include text regarding consumer food safety practice recommendations. The new revised 2005 Dietary Guidelines should focus solely on food nutrition as they have historically. Assuring consumer safety is an issue the IFPA and the fresh-cut produce industry takes very seriously as it is of paramount importance. The IFPA and our member companies are steadfastly committed to providing fresh, safe and wholesome products to consumers. Consumer educational outreach regarding safe handing and preparation of foods is a shared responsibility of federal agencies, other public health agencies, non-profit groups, industry, educators, and individuals. Active promotion of food safety educational outreach efforts such as FightBAC! ® that provide consumers with information regarding how to handle and prepare food safely is preferred, rather than inclusion of consumer safe food handling recommendations in the 2005 Dietary Guidelines.
Submission Date 9/27/2004
Author International Fresh-cut Produce Association's

   FightBAC!
Summary
Comments I would like to comment on the key finding related to food safety in the 2005 proposed Dietary Guidelines for Americans. I believe that it is very important to stress proper food storage methods in order to reduce the risk of exposure to food borne pathogens. Many of the millions of cases of food poisoning each year could be prevented by practicing safe food storage guidelines in the home. Items that should be highlighted are the appropriate temperature of a refrigerator (less than 40 degrees F), the importance of using a thermometer to ensure that the interior of the refrigerator is below 40 degrees F, and to refrigerate leftovers within two hours of service. It appears that while the public is concerned with food safety, very few people put these techniques into practice. Thank you for your attention in this matter.
Submission Date 9/22/2004 9:34:00 PM
Author Anonymous

Summary The discussion should be proper cooking temperatures, defrosting/thawing of foods, freezing, reheating of foods and time limits of all of the above. Thank you, Pauline
Comments I would like to see discussion on the importance of food safety in the home. Especially since most of the seniors cook and shop for themselves. I am certified in food safety and sanitation and would like to see more emphasis on this issue.
Submission Date 9/23/2004 10:45:00 AM
Author Meals on Wheels of RI

   Listeria
Summary Food safety is essentially an agricultural matter, not a consumer concern. Safe food supply begins with safe and healthy soil. Industrial agriculture needs to address truly unsafe practices and the regulatory agencies need to get on their case hard and fast.
Comments Instead of focusing on food handling issues, the entire scope of food safety should include HOW food is raise, vegetables and animals alike. Modern agriculture does NOT need to poison us with the chemicals that are common practice. Food safety begins with living, fertile, healthy soil. Safety continues by protecting us from food irradiation, genetically modified genes and carcinogenic crop treatments. Cows should never ever have been fed animal foods. They were designed to GRAZE!!! The essence of Food safety is an AGRICULTURAL problem, not a consumer problem.
Submission Date 9/24/2004 4:44:00 PM
Author from Beaverton, OR

General/Overarching issues
   Other
Summary PBH strongly supports the recommendation for consumers to eat 5 to 13 servings of fruits and vegetables a day -- or 2-1/2 to 6-1/2 cups. The real challenges come in translating the broader recommendations into actionable steps that consumers can understand and apply.
Comments The Produce for Better Health Foundation commends USDA, HHS, and the Dietary Guidelines Advisory Committee for their work on the development of the 2005 Dietary Guidelines for Americans and the Scientific Report released in August. We are especially pleased with the attention, throughout the report, on the important role of fruits and vegetables both in preventing disease as well as in promoting a healthy lifestyle. We strongly support the recommendation for consumers to eat 5 to 13 servings a day -- or 2-1/2 to 6-1/2 cups. The real challenges come in translating the broader recommendations into actionable steps that consumers can understand and apply.
Submission Date 9/24/2004 2:01:00 PM
Author Produce for Better Health Foundation

   Methods
Summary PBH recommends consumer testing to assure that dietary guidance messages "work" with consumers and drive them to change behaviors.
Comments PBH recommends consumer testing to assure that dietary guidance messages "work" with consumers and drive them to change behaviors.
Submission Date 9/24/2004 2:03:00 PM
Author Produce for Better Health Foundation

   Other
Summary PBH believes the timing is right for USDA and HHS to outline a plan to align American diets with the proposed guidelines. PBH thanks you and the other HHS and USDA staff members for your tireless efforts and hard work and we stand ready to assist in any way.
Comments PBH believes that the timing is right for USDA and HHS to outline a plan to align American diets with the proposed guidelines. While diet is a matter of personal choice, our choices are greatly influenced by access, availability, convenience, advertising, cost, taste, and many other factors. The sound science and communication messages emanating from your agencies are critical, but education alone can no longer be the only response to our national failure to eat according to the Dietary Guidelines. Our national crisis of obesity, chronic disease and soaring health care costs require a more diligent and comprehensive federal approach to changing consumer eating behaviors – including expanding access to fruits and vegetables by incorporating more fruits and vegetables into the WIC program, adding more schools to the free fruit and vegetable snack program, providing incentives to food stamp recipients to purchase fruits and vegetables, or providing industry grants to enhance placement of produce in non-traditional venues such as vending machines. These sample strategies as part of a comprehensive federal approach to improve American diets could have a huge impact on health and associated costs. We thank you and the other HHS and USDA staff members for your tireless efforts and hard work and we stand ready to assist in any way.
Submission Date 9/24/2004 2:08:00 PM
Author Produce for Better Health Foundation

Summary
Comments Kathryn McMurry HHS Office of Disease Prevention and Health Promotion, Office of Public Health Science, Suite LL100 1101 Wooton Parkway Rockville, Md. 20852 Dear Kathryn, The California Department of Health Services (CDHS) is pleased to submit comments on your recent release of the 2005 Dietary Guidelines Advisory the CDHS Physical Activity and Nutrition Coordinating Committee. A. We like the proposed guidelines because they are evidence based, and also because they are consistent with the IOM guidelines. B. Our concerns include: 1. How will these be made practical for the general population? For example, how will the average individual balance caloric intake with caloric expenditure, or calculate different percentages of total calories for certain types of fat? How will the average individual define and account for "discretionary calories?" 2. The report does not include any recommendations for non-nutritive sweeteners. Many Americans want to know what and how much is safe. Sincerely, Seleda Williams, MD, MPH, Chair Physical Activity and Nutrition Coordinating Committee Public Health Medical Officer
Submission Date 9/24/2004 1:34:00 PM
Author CA Dept. of Health Services

Summary
Comments 1. Food Group: I commend the Dietary Guideline Advisory Committee for recognizing the importance of fruits and vegetables throughout the Dietary Guidelines Advisory Committee Report and support the recommendation for consumers to eat 5 to 13 servings a day - or 2-1/2 to 6-1/2 cups. 2. Nutrient Intake: I support the emphasis on nutrient density and the unique role of fruits and vegetables in weight management. 3. Energy Balance/Weight Management: I would strongly urge that more specific examples of substituting fruits and vegetable for energy dense-nutrient poor food choices are provided and that the consumer materials include specific examples of how consumers can fit fruits and vegetables into their daily meal plan throughout the day. This will help dispel consumer fears about the new higher fruit and vegetable number. 4.Food Group: I stress that for consumers to attain the higher goals, a coordinated effort is essential, among government agencies, health and nutrition professionals and organizations, and the fruit and vegetable industry – commodity groups and retailers – to better communicate serving sizes in practical and actionable ways so consumers can understand and apply this important guideline. 5. Food Group: I support the use of household measurements, such as cups and ounces, as well as serving sizes and recommend that the consumer materials include more specific information on what constitutes a serving size, especially in the fruit and vegetable category. For example, a list of fruits and vegetables, and their corresponding common measure that constitutes a serving size, should be included in the materials. 6.Food Group: I stress that consumer materials need to explain clearly how consumers can determine their calorie needs, and subsequently their fruit and vegetable goal. 7. Food Group: I recommend that the consumer materials emphasize the importance of consuming a variety of fruits and vegetables and support the use of the "color concept", such as the successful PBH Color Way Campaign, to help communicate this important concept. This use of "color" to convey variety will also help link the dietary guidelines to existing private sector/industry efforts currently underway. These types of links and partnerships will be essential in communicating key guidelines message to consumers via proven and successful initiatives. 8. Food Group: I urge HHS and USDA to educate consumers about the economical factors associated with consuming fruits and vegetables. An Economic Research Service report: How Much Do Americans Pay for Fruits and Vegetables, issued in July, dispelled the myth that healthy eating is too expensive. The report showed that Americans can meet their fruit and vegetable requirements for less than a dollar per day. Recommend that the consumer materials address cost issues associated with fruits and vegetables to better equip consumers with information to help them eat more fruits and vegetables while staying within their food budget. 9. General Overarching: I would recommend consumer testing to assure that dietary guidance messages "work" with consumers and drive them to change behaviors. 10. General Overarching: I thank the Committee as well as HHS and USDA for their efforts and let them know that you/your organization stand ready to assist in helping consumers meet the higher, health promoting goals. # # #
Submission Date 9/24/2004 5:00:00 PM
Author from LOS ALAMITOS, CA

Summary 1) No limitations on saturated fats and cholesterol. 2) Consumption of whole dairy products, not reduced fat. 3) Throw out the food pyramid, but keep it simple with four food groups. 4) Children need animal fats for proper growth.
Comments As a member of the allied health community as a Certified Medical Assistant with Administrative and Clinical Specialties for 26 years and active in dietary counseling for six years I urge you to consider the following: 1) No more food pyramid, it promotes too much refined flour and starchy items. Do promote the four good groups. 2) No limits on saturated fats and cholesterol, a low fat diet has been crammed down peoples throats for years, yet heart disease is on the rise. Fat of this nature is NOT the problem. Refined grains and added sugar are the culprits. 3) Stress the importance of animal fats, especially for growing children. 4) Promote the use of WHOLE foods, including whole grain breads (not brown colored bread!) and other whole grain products. Whole dairy products unaltered by reducing the much needed and NATURAL fat content. 5) Stress the important of severely limiting the intake of added refined sugar. 6) Look at some of the newest research in terms of the benefits of fat and the effects of refined sugar consumption. In hundreds of patients tested monthly with blood work, following an unrestricted fat diet with no refined sugar and using whole grains; triglycerides, lipid levels and blood pressures normalize within one month of implementation. All levels stay normal as long as these dietary guidelines were followed. With the overweight epidemic in this country showing no signs of changing it is time to go back to the types of food our ancestors ate over 100 years or more ago.
Submission Date 9/24/2004 2:32:00 PM
Author from Holland, MI

Summary Cholesterol is not the evil that is portrayed by our health gurus, but a necessary part of life if we keep it moving in our blood passages.
Comments Cholesterol is an important part of every cell in our bodies. and the amount in our blood is not as important as the viscosity. Cholesterol melts at 300o F – add lecithin and the melting point is reduced to 160o F – add Omega 3 and it gets down to 32o F, i.e., liquid at body temperature which is necessary to prevent clogging blood vessels while being transported to sites for making cell membranes Therefore, ingesting the right nurishment keeps our cholesterol from becoming the bain of good health; on the contrary, it keeps our cholesterol viable to help keep our cells healthy.
Submission Date 9/24/2004 10:28:00 AM
Author

   Children
Summary We need to return to our traditional foods and traditional farming methods and get the politics out of our food.
Comments I am writing this letter to ask the Dietary Guidelines Advisory Committee to reevaluate the current direction of health and nutrition in this country. Our citizens are growing more diseased by the year and the current recommendations for low fat/no cholesteral diets are only making things worse. Instead of taking an honest look at the root of the problems (sugar, white flour, vegan diets, ect,) we have put our efforts into designing pills to "fix" our issues. As a mother, my number one priority is ensuring the healthy and safety of my children. My daughter is now 2.5 and She has been breastfeed until recently and eaten a diet rich in full fat dairy, pasture raised meat and eggs and seasonal fruits and veggies plus a supplement of cod ilver oil. She is a healthy and robust child. Since we have switched to this traditional diet she has not had any earaches or invections. In fact we have not even had our usual colds and our entire family has had a noticeable increase in energy and stamina.
Submission Date 9/24/2004 10:29:00 AM
Author Anonymous

   Other
Summary Importance of reading food labels to choose a food. Should stress the amounts of an item; what is considered a low/high amount, say of sodium or sugar.How to compare labels for the most nutritious product for the money. Smart shopping/recipes are important for seniors. Pauline Asprinio, LDN
Comments The issue of properly reading food labels is important. I do various seminars on nutrition and try to also do one on the reading of food labels.
Submission Date 9/23/2004 11:01:00 AM
Author from Providence, R.I.

Summary Make grant dollars available to Cooperative Extension and health agencies that are interested and capable of disseminating the 2005 Dietary Guidelines. These monies need to be made available ahead of the final press release so that educators can be ready when this information hits the press.
Comments As an Extension Educator that strives to keep residents of my county current on nutrition issues, it seems to me that each time new dietary guidelines and/or food pryramids come out, there out to be mini grants available that coincide with the release so that nutrition educators can be ready to deliver the new messages to citizens while it is still "news worthy". Has it been considered to appropriate money toward the dissemination and teaching of these new materials? I am pleased with the 2005 Dietary Guidelines, but as always, they will need clarification by the general public! Extension budgets are so tight that we won't even be able to afford to have the new materials to share without some sort of budget supplementation!
Submission Date 9/22/2004 7:02:00 PM
Author from Craig, CO

Summary I recommend including a section labeled, Choose Protein Wisely for Good Health with guidelines recommendations for preferred intake of plant protein, such as legumes, nuts, and seeds and also fish. Lean meats and skinless poultry need to be discussed as well.
Comments The Dietary Guidelines panel has omitted a section on protein, such as Choose Proteins Wisely for Good Health. There is ample evidence regarding the type of fat in various protein sources to warrant guidelines on choosing protein-rich foods for good health. For, example there are many scientific studies indicating the value of consuming nuts, especially walnuts, in > reducing risk for cardiovascular disease. In fact, the FDA has recently issued a special type of Health Claim for nuts. Nuts, seeds, and fish are important sources of protein that are low in saturated fat and high in mono-unsaturated fat. Legumes contain protein, unsaturated fatty acids and are excellent sources of fiber. The public needs to be informed regarding the healthful; qualities of nuts, seeds, fish, and legumes. Soy protein is associated with reduced cholesterol levels. Lean meat and skinless poultry are preferred sources of protein due to the high biological activity of the protein they contain and as well iron, zinc and other minerals. Lean meat and skinless protein also less saturated fat than fatty cuts of meat and poultry with skin. With the evidence currently known regarding the differences in protein sources regarding health benefits, it is inconceivable that protein would not be addressed in the Dietary Guidelines for Americans. Even older versions of these guidelines contain more information and guidance regarding protein sources.
Submission Date 9/23/2004 12:54:00 PM
Author from Gallatin Gateway, Montana

Summary I recommend including a section labeled, Choose Protein Wisely for Good Health with guidelines recommendations for preferred intake of plant protein, such as legumes, nuts, and seeds and also fish. Lean meats and skinless poultry need to be discussed as well.
Comments The Dietary Guidelines panel has omitted a section on protein, such as Choose Proteins Wisely for Good Health. There is ample evidence regarding the type of fat in various protein sources to warrant guidelines on choosing protein-rich foods for good health. For, example there are many scientific studies indicating the value of consuming nuts, especially walnuts, in > reducing risk for cardiovascular disease. In fact, the FDA has recently issued a special type of Health Claim for nuts. Nuts, seeds, and fish are important sources of protein that are low in saturated fat and high in mono-unsaturated fat. Legumes contain protein, unsaturated fatty acids and are excellent sources of fiber. The public needs to be informed regarding the healthful; qualities of nuts, seeds, fish, and legumes. Soy protein is associated with reduced cholesterol levels. Lean meat and skinless poultry are preferred sources of protein due to the high biological activity of the protein they contain and as well iron, zinc and other minerals. Lean meat and skinless protein also less saturated fat than fatty cuts of meat and poultry with skin. With the evidence currently known regarding the differences in protein sources regarding health benefits, it is inconceivable that protein would not be addressed in the Dietary Guidelines for Americans. Even older versions of these guidelines contain more information and guidance regarding protein sources.
Submission Date 9/23/2004 12:56:00 PM
Author from Gallatin Gateway, Montana

Summary The "Choose Wisely" statements for carbohydrates and Fats are far too vague. Specifics are needed even in the topic headings. The 1959 guidelines for cardiovascular disease prevention by Ansel Keys are preferrable to vague guidelines. The public deserves more specific information.
Comments The "Choose Wisely" statements for carbohydrates and Fats are far too vague. Specifics are needed even in the topic headings. The 1959 guidelines for cardiovascular disease prevention by Ansel Keys are preferrable to vague guidelines. The public deserves more specific information.
Submission Date 9/23/2004 1:01:00 PM
Author from Gallatin Gateway, Montana

Summary Thank you for including eating disorders in the new 2005 Dietary Guidelines. According to the NEDA as many as 11 million Americans suffer from anorexia or bulimia while another 25 million struggle with binge eating disorder. I hope this will increase awareness of this devastating problem.
Comments
Submission Date 9/23/2004 2:54:00 PM
Author Anonymous

Summary The guidelines need to omit/substitute the higher level vocabulary terms/concepts, as well as, make less "wordy" overall.
Comments Overall, the guidelines are too “wordy." The general wording of the guidelines seems to be directed more towards the educated subset of the American population. Using terms/phrases such as: foods "within and among," "consume," moderation," and "energy needs."
Submission Date 9/23/2004 12:28:00 PM
Author OSU Extension Program- Cleveland, OH

   Children
Summary recommend the consumption of whole dairy products, not "reduced fat" children need animal fats for optimal development--this crazy idea that children need skim milk once they're two is doing great harm to our children's development Put no restrictions on saturated fats and cholesterol
Comments I think we've been grossly misled by teaching that saturated fats are bad for you. Natural fats (butter, olive oil, lard, coconut oil) have vital, life-giving fat-soluble vitamins that are necessary for adults and extremely necessary for children. DO THE RIGHT THING!! This is people's health we're talking about!! Go with the studies, and not with the politically correct nutrition we've been taught over the last 20 years.
Submission Date 9/23/2004 3:10:00 PM
Author Anonymous

   Other
Summary Don't listen to big business groups or research tainted by them. Encourage Americans to eat like the healthy people groups studied by Weston A. Price in the 1930's. Quality fats (butter, lard, coconut oil), grass-fed meat, no vegetable oils, raw milk!
Comments Please, please help the American people by providing good guidelines. We are so lied to by big business. Even the "research" is tainted. Let's recommend what we know people ate 200+ years ago before the onset of cancer, heart disease, diabetes... the list goes on and on. Fresh fruits and vegetables - support local! and fermented fruits and vegies Grass-fed meat, truly free-range poultry; broths (saturated fats are fine!) Raw whole milk and cultured milk products (no low fat! ugh -fillers! gross) Butter, lard, tallow, tropical oils Whole grains Tell people the truth about white flour, sugar and vegetable oils (all poison) Artificial sweeteners as well... another huge lie of big business. www.westonaprice.org has it right - I agree with their recommendations. Our children are getting fatter and fatter; their brains aren't being fed what they need to learn and grow, everyone's on ritalin. What a disaster. It's time for some DRASTIC changes. Thanks for listening... Heather Holland Portland, OR
Submission Date 9/23/2004 3:25:00 PM
Author from Tualatin, OR

   Children
Summary Personal history of how Weston A. Price Foundation eating guidelines (good saturated fats, organic foods, avoiding food-industry food; and fresh clean raw milk) healed my family.
Comments To the Advisory Committee on Dietary Guidelines, I have always been health-conscious; reading labels and working to understand and implement the food pyramid. In the last five years, we've tried a variety of diets. I would like to tell you what has happened to our family since we adopted the diet advocated by the Weston A. Price Foundation. This diet includes plenty of grass-fed meat (including bacon), eggs, butter, nuts, fermented dairy and vegetables, whole grains, and whole raw milk. There has been a substantial reduction in sugar, soy, MSG/other additives, and white flour (almost complete - but kids still get it from school and social events) , and the only fats we eat come from coconut oil, butter (lots!) and other dairy products, nuts and produce, and olive oil (not much olive oil). Up until about 2 years ago, I was diligent about a low-fat, low-cholesterol, soy-inclusive diet for my family, trying to be a "good mother". I now think that was a tragic mistake. Here's why: Our youngest son age 12: Previously had vision problems (doctors could not diagnose), was diagnosed ADD, (I didn't want to use drugs), and had frequent falling accidents. Academic performance was poor ('D' average). Poor sleep patterns. Could not sit still to read. Hated school. Poor self-esteem. Dental health marginal. I was desperate to help him. Then I found WAPF. This year, he has a 3.4 Grade Point Average! He reads better, spells better, and writes better. He likes school. Vision problems are gone. I hardly even think about ADD issues anymore; unless he has had soda and junk food. Much more coordinated; much fewer accidents. He sleeps better, looks better, and acts better. He is growing in leaps and bounds. His last dental checkup was full of praise. Our household is much, much saner now. Our oldest son, age 18: Raised on pasterized or soy milk, has been very quiet/depressed most of his life. I would hate to count how many anti-biotic drugs have been prescribed for him! He had no energy, no social life whatsoever. He always seemed sad. Had four broken bones in minor accidents (things that in my opinion, should not have broken a bone; such as the dog on a leash, darting at a rabbit, broke his thumb; a fall off a 2-foot fence broke his arm, etc.). He sat in front of the computer or TV; had no ambition or desire to do anything else. He had allergies, his skin was bumpy, he had dandruff, and was in the doctor's office every other month for some respiratory infection / strep throat, etc. He practised poor hygiene, had poor dental checkups, and very poor sleep habits. He missed a lot of school due to illness. Every school year (except for the last semester, when his diet improved), he was in bed, exhausted for 3 days, every 4-6 weeks. He did not get into the college he wanted due to a low GPA. Kaiser (HMO) wanted to put him on anti-depressants. He refused, and I am so glad! Last spring, he began to turn around. His grades improved. He stopped getting sick all the time. He started to care about the way he looked. He began dating and socialising. He started working out every day, still does. He talks (he's funny!), and smiles now! No more doctors, dentists, allergies, dandruff, or bumpy skin. He is more focused, more outgoing, more handsome, more responsible and ambitious. He is currently working 2 jobs and saving his money, anxious to go to college soon. He he is finally excited about life. (YAHOO!!!) My husband, age 51: Had allergies, gout, some arthritis, high triglycerides. He now reports that his allergies are much better, has no arthritis, and triglyceride levels now in a good range (went from 215 to 160). He did have one gout attack earlier this year, but that was after a too much beer and shrimp, and before we started the raw milk. Except for the gout event, has not had to see the doctor in 2 years, except for the annual checkup. He's lost about 10 pounds, and his skin is less wrinkled and tired looking. Me, age 51: I had periodontitis, osteoporosis, candida, was depressed, and overweight. Took a nap every day. Dry skin and hair, pneumonia 3 years in a row. I now weigh 125 pounds (was 160), and I've lost a few wrinkles, too! Bone density test pending, but I am so much more energetic and hopeful! My periodontist told me in June that I should get a check up some time next year (I had been going in every 3 months for the last 2 years). My HDL was 72 last May, (was 40, two years ago). Instead of getting older and weaker, I feel like I'm getting better and stronger. We're all in better physical and mental shape, and we're happier. Food not only affects your body, it affects your mood and your personality. And maybe not so strangely, your fears. I laugh at commercials that prey on bacteriophobia; because we eat yogurt or kefir, or fermented veggies every day! There's more, but I'm trying to be brief. And all because of food - no drugs! I am so grateful for Sally Fallon, Mary Enig, et al at the Weston A. Price Foundation! Although it's a lot of work to find good food, I pray I never go back to a low fat, low cholesterol diet. Those government guidelines made us sick, depressed, and fat! I hope you will consider this testimony, and WAPF's guidelines. Americans are sick and getting sicker, and they need your help. You could easily fix our national "health-care crisis" with one little document! Thanks for your attention, Mary Blair McMorran
Submission Date 9/23/2004 3:26:00 PM
Author Anonymous

Summary
Comments there should be no restrictions on dietary fats and cholesterol from well-rasied animals and whole unprocessed oils such as coconut, olive and cod liver oil. the distinction must be made between these and hydrogenated fats which are the culprits in heart disease, not natural fats. children need these fats for brain development and neurological development, and pregnant and nursing mothers need to be eating them for the optimal growth and development of the unborn fetus and breastfeeding baby. in that vein, fat-free and fat-reduced dairy products have been processed to the point where the fats have been rendered useless by the body, and the fats that are so necessary for development, especially in children, are missing. I would prefer to see the four food groups stressed rather than the food pyramid, a pyramid places so much emphasis on a certain food when a spectrum of the four food groups is what the human body truly needs. I would also like to see whole foods stressed and packaged and processed foods de-emphasized as they are the real culprits in heart disease and obesity and
Submission Date 9/23/2004 4:26:00 PM
Author from west linn, OR

Summary No restrictions on saturated fats and cholesterol especially for children; Consumption of whole dairy products, not reduced fat; Abandon food pyramid, have our 4 food groups
Comments there should be no restrictions on dietary fats and cholesterol from well-rasied animals and whole unprocessed oils such as coconut, olive and cod liver oil. the distinction must be made between these and hydrogenated fats which are the culprits in heart disease, not natural fats. children need these fats for brain development and neurological development, and pregnant and nursing mothers need to be eating them for the optimal growth and development of the unborn fetus and breastfeeding baby. in that vein, fat-free and fat-reduced dairy products have been processed to the point where the fats have been rendered useless by the body, and the fats that are so necessary for development, especially in children, are missing. I would prefer to see the four food groups stressed rather than the food pyramid, a pyramid places so much emphasis on a certain food when a spectrum of the four food groups is what the human body truly needs. I would also like to see whole foods stressed and packaged and processed foods de-emphasized as they are the real culprits in heart disease and obesity and DM.
Submission Date 9/23/2004 4:28:00 PM
Author from west linn, OR

Summary No restrictions on saturated fats and cholesterol especially for children; Consumption of whole dairy products, not reduced fat; Abandon food pyramid, have our 4 food groups
Comments there should be no restrictions on dietary fats and cholesterol from well-rasied animals and whole unprocessed oils such as coconut, olive, butter and cod liver oil. the distinction must be made between these and hydrogenated fats which are the culprits in heart disease, not natural fats. children need these fats for brain development and neurological development, and pregnant and nursing mothers need to be eating them for the optimal growth and development of the unborn fetus and breastfeeding baby. in that vein, fat-free and fat-reduced dairy products have been processed to the point where the fats have been rendered useless by the body, and the fats that are so necessary for development, especially in children, are missing. I would prefer to see the four food groups stressed rather than the food pyramid, a pyramid places so much emphasis on a certain food when a spectrum of the four food groups is what the human body truly needs. I would also like to see whole foods stressed and packaged and processed foods de-emphasized as they are the real culprits in heart disease and obesity and DM. I would like to see an emphasis placed on eating organic produce and cage-free, hormone and antibiotic-free animal meats.
Submission Date 9/23/2004 4:29:00 PM
Author from west linn, OR

Summary No restrictions on saturated fats and cholesterol especially for children; Consumption of whole dairy products, not reduced fat; Abandon food pyramid, have our 4 food groups
Comments there should be no restrictions on dietary fats and cholesterol from well-rasied animals and whole unprocessed oils such as coconut, olive, butter and cod liver oil. the distinction must be made between these and hydrogenated fats which are the culprits in heart disease, not natural fats. children need these fats for brain development and neurological development, and pregnant and nursing mothers need to be eating them for the optimal growth and development of the unborn fetus and breastfeeding baby. in that vein, fat-free and fat-reduced dairy products have been processed to the point where the fats have been rendered useless by the body, and the fats that are so necessary for development, especially in children, are missing. I would prefer to see the four food groups stressed rather than the food pyramid, a pyramid places so much emphasis on a certain food when a spectrum of the four food groups is what the human body truly needs. I would also like to see an emphasis on whole foods, and packaged and processed foods de-emphasized as they are the real culprits in heart disease and obesity and DM. I would like to see an emphasis placed on eating organic produce and cage-free, hormone and antibiotic-free animal meats.
Submission Date 9/23/2004 4:31:00 PM
Author from west linn, OR

Summary No restrictions on saturated fats and cholesterol especially for children; Consumption of whole dairy products, not reduced fat; eating conscientiously raised animals and organic produce Abandon food pyramid, have our 4 food groups
Comments there should be no restrictions on dietary fats and cholesterol from well-rasied animals and whole unprocessed oils such as coconut, olive, butter and cod liver oil. the distinction must be made between these and hydrogenated fats which are the culprits in heart disease, not natural fats. children need these fats for brain development and neurological development, and pregnant and nursing mothers need to be eating them for the optimal growth and development of the unborn fetus and breastfeeding baby. in that vein, fat-free and fat-reduced dairy products have been processed to the point where the fats have been rendered useless by the body, and the fats that are so necessary for development, especially in children, are missing. I would prefer to see the four food groups stressed rather than the food pyramid, a pyramid places so much emphasis on a certain food when a spectrum of the four food groups is what the human body truly needs. I would also like to see an emphasis on whole foods, and packaged and processed foods de-emphasized as they are the real culprits in heart disease and obesity and DM. I would like to see an emphasis placed on eating organic produce and cage-free, hormone and antibiotic-free animal meats.
Submission Date 9/23/2004 4:32:00 PM
Author from west linn, OR

Summary No restrictions on saturated fats and cholesterol especially for children; Consumption of whole dairy products, not reduced fat; Abandon food pyramid, have our 4 food groups; eating conscientiously raised animals and organic produce
Comments there should be no restrictions on dietary fats and cholesterol from well-rasied animals and whole unprocessed oils such as coconut, olive, butter and cod liver oil. the distinction must be made between these and hydrogenated fats which are the culprits in heart disease, not natural fats. children need these fats for brain development and neurological development, and pregnant and nursing mothers need to be eating them for the optimal growth and development of the unborn fetus and breastfeeding baby. in that vein, fat-free and fat-reduced dairy products have been processed to the point where the fats have been rendered useless by the body, and the fats that are so necessary for development, especially in children, are missing. I would prefer to see the four food groups stressed rather than the food pyramid, a pyramid places so much emphasis on a certain food when a spectrum of the four food groups is what the human body truly needs. I would also like to see an emphasis on whole foods, and packaged and processed foods de-emphasized as they are the real culprits in heart disease and obesity and DM. I would like to see an emphasis placed on eating organic produce and cage-free, hormone and antibiotic-free animal meats.
Submission Date 9/23/2004 4:32:00 PM
Author from west linn, OR

   Other
Summary
Comments September 23, 2004 HHS Office of Disease Prevention and Health Promotion % Kathryn McMurry Office of Public Health and Science Suite LL100 1101 Wootton Parkway Rockville, MD 20852 Dear Secretaries Veneman and Thompson: Thank you for this opportunity to comment on the Dietary Guidelines for Americans. I am a Dietetics student at Ball State University and am interested in how the general public interprets the guideline and applies them to daily menu planning. I am concerned with the following three areas: • Do Environmental influences have to be out of our control? The last paragraph of the executive summary says that environmental influences tend to be beyond the control of the back that control. The environment will change when the consumer’s dollar demands it. People need to trust that appropriate eating (not dieting) will lead to an appropriate weight. • Fiber and Vitamin Fortified Foods…are they good or bad? So many foods today are fortified with vitamins and fiber that the general public may ask “Do I really need fresh fruits, vegetables and whole grains?” How do we get people to choose an orange instead of Sunny D orange drink, or steel cut oatmeal in place of Captain Crunch cereal? A possible solution could be labeling “Best Choice” foods. • Soymilk…do I count soymilk as a Dairy serving? Many women are drinking soymilk in place of dairy milk. Where does a glass of soymilk appear on the Food Guide Pyramid? The Dietary Guidelines for Americans are not clear on this matter. Also, what about people who consume no dairy products and take a calcium supplement or eat other calcium rich foods. Should the Food Guide Pyramid include pictures of other calcium rich foods in the dairy group to help people with menu planning? Once again, thank you for this opportunity. You have done a great job in sorting through the many issues. I wish you luck in sorting through all the comments. Sincerely, Laura Hormuth 7959 Glenway Drive Apt. 408 Indianapolis, Indiana 46236
Submission Date 9/24/2004 1:11:00 AM
Author from Indianapolis, IN

Summary 1. Recommend a committee report on micronutrient nutriture in US, and the results are included in the Guidelines. 2. Recommend deletion of the concept of “shortfall” nutrients.
Comments May I introduce myself? I am a Professor in the Departments of Preventive Medicine and Community Health, Internal Medicine, and Human Biological Chemistry and Genetics, of the University of Texas Medical Branch (UTMB), Galveston, TX. I graduated from Vanderbilt University School of Medicine in 1958, and have post-graduate training in Internal Medicine (Washington University, St Louis and Vanderbilt) and Pathology. I am a Fellow of the American College of Physicians and American Society for Nutrition Sciences, and have board certification in Internal Medicine and Human Nutrition. I was a faculty member of the Departments of Biochemistry (nutrition) and Internal Medicine at Vanderbilt (1965-71) until I was recruited the USDA ARS to be the first Director (1971-84) of the USDA ARS Grand Forks Human Nutrition Research Center, Grand Forks, ND, with the mission of elucidating human requirements for trace-element nutrients. I subsequently was Director (1984-5) of the USDA ARS Human Nutrition Research Center on Aging at Tufts University. I came to UTMB to serve as Professor and Chairman Of Preventive Medicine and Community Health (1985-90). I 1990 I assumed my present post. I was introduced to nutrition research as a medical student in 1955. In 1961-3 I was a USPHS officer at the US Naval Medical Research Unit #3 where I was assigned to the Vanderbilt University Nutrition Research Group that first described human zinc deficiency. That experience inspired me to study aspects of zinc nutrition, a topic that is my major research interest. I am writing to comment on the Dietary Guidelines Report. The Committee brought substantial expertise and thoughtful consideration to their task. We, the US public are indebted to the Committee for their important contribution to public health. My suggestions are offered in the spirit of improving the message. The major thrust of the Guideline is to provide consumers dietary information that the Committee believes will be useful for preventing or decreasing morbidity from certain chronic diseases. The focus is mainly on energy and macronutrients. Selected “shortfall” nutrients also receive attention. The method of designation of “shortfall” nutrients and indeed the term is of concern. The source of the data is Foote et al J Nutrition 2004; 134: 1779-85. Below is Table D1-2 “Probabilities of Adequacy for Selected Nutrients on the First 24-hour Recall among Adult CSFII 1994-96 Participants” that highlights “shortfall” nutrients. “Shortfall” nutrients are those with less than a 50% probability of an adequate intake for adults, using the mean IOM Estimated Average Requirement (EAR) as the criterion. By implication nutrients consumes at levels greater than the mean EAR are not of concern. This in my opinion, is not an appropriate message. Table D1-2. Probabilities of Adequacy for Selected Nutrients on the First 24-hour Recall among Adult CSFII 1994-96 Participants. From Foote et al J Nutrition 2004;134: 1779-85. Probability of adequacy (as a percentage) Nutrient Men Women Vitamin A 47.0% 48.1% Vitamin C 49.3 52.3 Vitamin E 14.1 6.8 Thiamin 83.9 72.2 Riboflavin 85.8 80.9 Niacin 90.5 80.4 Folate1 33.9 20.9 Vitamin B-6 78.3 60.7 Vitamin B-12 80.5 64.2 Phosphorus 94.3 85.1 Magnesium 36.1 34.3 Iron 95.5 79.4 Copper 87.4 73.3 Zinc 65.7 62.0 Calcium 58.6 45.7 The table is based on 24-hour recall dietary data obtained on 4969 men and 4800 women. Findings were compared to the Estimated Average Requirement (EAR) cited in the Dietary Reference Intakes of the Institute of Medicine (IOM). If the calculated mean intake of a nutrient was less the 50th percentile of the EAR the nutrient was designated a “shortfall” nutrient, and is highlighted in bold in the table. The Guidelines report does not include strong evidence that deficiencies of micronutrients such as vitamins A, C, and E are a health problem in the USA. Clinically deficiencies of there vitamins are distinctly unusual in the USA. In contrast, there is clinical evidence that certain populations are at risk of deficiencies of micronutrients not designated “shortfall” nutrients, e.g., thiamin (vitamin B1), riboflavin (vitamin B2), pyridoxine (B6), and vitamin B12. Designating certain micronutrients “shortfall” nutrients might suggest to consumers that other micronutrients are not of concern. Two particular micronutrients have long interested me. Therefore I comment further on them. It seems the approach concerning iron status of Americans may be out of date. Indeed, iron deficiency anemia is not common in the US. However, iron deficiency without anemia is common especially among premenopausal women. The 25th percentile for serum ferritin for premenopausal women was 14 ng/mL in NHANES-III. Iron stores are absent when serum ferritin concentration is in this range. This means that 25 % of young women who participated in NHANES-III were affected. This is not an insignificant number of people. Regarding effects of iron deficiency without anemia. It causes physiological and neuropsychological morbidity that is preventable by appropriate diets. Other groups at risk are pregnant women, infants and children. The second micronutrient of special concern to me is zinc. Clinical diagnosis of mild zinc deficiency requires a high index of suspicion and certain technologies. Good clinicians well know that failure to diagnose does not mean the condition is absent. There is substantial clinical literature to refute the statement in the IOM report that zinc deficiency is rare. Groups at special risk for zinc deficiency are the same as those at risk of dietary iron deficiency. Thus a finding of low serum ferritin indicates individuals at risk of zinc deficiency. Mild zinc deficiency causes a variety of morbidities including abortion, fetal teratology including neural tube defects, fetal growth stunting, short stature, low immunity, poor healing, dermatitis, poor night vision, and decreased neuropsychological function. This is not a trivial condition. I recommend a new Committee be formed to examine the issue of micronutrient nutriture of Americans, and that the results of their deliberations be included in the Guidelines. I recommend the Guidelines include clear information concerning the essentiality of iron and zinc throughout the life cycle, and the best dietary sources. I recommend the categorization of some micronutrients as “shortfall” nutrients are removed from Guidelines. I recommend that the Guidelines include the importance of micronutrients for heath, and include best dietary sources of bioavailble forms of each. I recommend that the Guidelines include information concerning food substances that interfere with of absorption of essential metals such as calcium, magnesium, iron, zinc, and copper. Thank-you for this opportunity. This letter is submitted via the web. I will also send it by regular mail.
Submission Date 9/21/2004 2:51:00 PM
Author from Galveston, TX

   Methods
Summary too little or not enough nutrients are harmful depending on the unique biochemical nutritional needs of each person we need to individualize nutritional needs with common tests - we have developed some - and not publish a one six fits all diet
Comments Research has shown that one size all nutrition does not work. We are not created the same and we have different biochemical needs. I have two points to make - #1 Look at the headlines of the diet industry and two distinctly different camps emerge. One low carb and high protein Atkins and South Beach Diets) and the other, an opposite approach of High Carbs and low protein ( Pritikin and Ornish), Both have scientific data to bolster their diets effectiveness, If one looked beyond the claims and studied the individuals involved it becomes obvious that both diets are correct. It depends on the individual's biochemistry. There are subgroups of individuals that thrive on high carbs and low protein and other subgroups that thrivs on the opposite - high protein and low carbs. We have develop a simple inexpensive test to help individuals determine which group they fall under. Our research has shown us that some individuals have too much calcium and niacinemide, and folic acid - contrary to popular thinking - however these are subgroups out of the total population - other subgroups exist that need more of these nutrients.
Submission Date 9/21/2004 4:25:00 PM
Author Individual Health Solutions

Summary thew pyrmid is trying to teach too much to everyone our unique nutritional needs are nopt addressed by one pyramid use the pyramid concept for each food group
Comments #2 Since everyone is familiar with the pyramid why not use a pyramid for each major food group? A pyramid for protein, carbohydrates, Fats, calories. Each pyramid would show the favored to unfavorable choices within each food group. A simple guideline should accompany this for each age group, which would then tell us how much of each of the 4 groups we should eat each day. Children, teens, young adults, adults, and seniors. Maybe each pyramid could have a number of servings for each group on each level of the pyramid. So the 4 pyramids would have several steps from essential to avoid and each level would have a series of number of servings based on the age range.
Submission Date 9/21/2004 4:27:00 PM
Author Individual Health Solutions

   Other
Summary We believe the Committee has not sufficiently recognized the role of dietary supplements as an economical and convenient tool for improving nutrient intake, particularly where shortfalls are known to exist in the general population or in specific subgroups.
Comments The Council for Responsible Nutrition (CRN) is pleased to submit these comments on the Report of the Dietary Guidelines Committee. CRN is a trade association representing manufacturers of dietary supplements and their ingredients. Our industry serves consumers who are more than usually health conscious, as demonstrated by their nutrition awareness, their adoption of other healthy lifestyles, and their decision to use dietary supplements. CRN congratulates the Committee on its thorough analysis of dietary and lifestyle choices that affect the public health and on its nine major recommendations for improving such choices. We believe, however, that the specific food patterns offered by USDA as models for dietary improvement are overly stringent and unrealistic. The report rightly emphasizes the importance of obtaining adequate nutrient intake from conventional foods, but also recognizes the important contribution that can be made by fortified foods and in some cases by nutritional supplements. In analyzing nutrient adequacy, the Committee has correctly determined that the appropriate intake target for the individual is the Recommended Dietary Allowance (RDA) or the Adequate Intake (AI) established in the Dietary Reference Intakes, for each nutrient. CRN agrees that meeting nutritional needs through selection of a healthy diet is a high priority, but we also recognize that even health-conscious consumers often fall short of nutritional goals, and we are convinced that people who have nutrient shortfalls would be well advised to add appropriate dietary supplements to their daily regimen. We believe the Committee has not sufficiently recognized the role of dietary supplements as a convenient, economical and nearly calorie-free tool for improving nutrient intake, where shortfalls are known to exist in the general population or in specific subgroups. Attachment 1 provides excerpts from the Report recognizing shortfall nutrients and specifying that fortified foods or supplements may be useful in remedying those shortfalls. CRN suggests it would greatly simplify the recommendations and improve consumers’ ability to comply with the Committee’s advice if there were a simple general recommendation for use of a multivitamin supplement for most people. This could logically be signaled by a tenth general recommendation such as “Consider a daily multivitamin.” It would make much more sense for everyone to take a multivitamin than for men and women and children and adolescents and people over 50 to attempt to respond separately to numerous specific recommendations regarding individual micronutrients. In addition, a calcium supplement with vitamin D would be beneficial for most people who do not have calories to spare for an additional 2 or 3 cups of milk per day, or its equivalent. At a minimum, dietary supplements should be mentioned along with fortified foods in the list of suggestions for improving intakes of some specific nutrients. For people who are already consuming an adequate number of calories and for people with limited budgets, calories and cost may be two reasons to consider opting for a dietary supplement rather than a fortified food to compensate for recognized nutrient shortfalls. For example, people who are not currently consuming adequate amounts of dairy products to provide the recommended calcium intake have at least 3 options: they can start consuming more dairy products, they can use another type of product fortified with calcium, or they can take a calcium supplement. Getting 1000 mg of calcium will “cost” them over 300 calories per day for the first two options as compared to zero to 40 calories per day for a supplement in the form of tablets or in the form of soft chews. The monetary cost will be about 82 cents a day for the milk option, 90 cents a day for two servings of a calcium-fortified breakfast cereal, or $1.38 for 3 cups of calcium-fortified orange juice, as compared to 18 to 28 cents a day for the calcium supplement option. The supplement option is one that deserves more attention in the Report, not only in the case of calcium but in the case of other nutrient shortfalls, as well. The Report recognizes that fortified foods and dietary supplements have some role to play in ensuring nutrient adequacy, but first offers consumers lists of foods that could be added to the diet in order to increase intake of specific nutrients. In reality, a multivitamin would do the majority of Americans infinitely more good than yet another well-intentioned but doomed entreaty for the public to enthusiastically embrace foods such as collards, kale, Brussels sprouts, and buckwheat flour. A careful study of the food patterns recommended in the Report reveals that the Committee is not merely calling for some minor tweaking of usual diets. Far from it. The Committee appears to be contemplating a major overhaul not only of individual food choices but of the entire food supply. While it is a given in current debates over healthy diets that eating more fruits and vegetables would be a good thing, the evidence for this is based on studies of intakes within the usual range of variation, in numerous populations. The food patterns presented in the Report incorporate quantities of fruits and vegetables far beyond usual dietary intakes. At the same time, these food patterns permit only an extremely small degree of discretionary caloric intake – so small as to be puritanical in its implications. Is this really a reasonable goal to offer the American public? Is it even a scientifically supportable goal? Do these food patterns invite failure? If so, what are the implications of such goals for consumers? CRN believes the food patterns included in the report err on the side of disproportionately high intakes of fruits and vegetables and permit less discretion than is compatible with consumer satisfaction or with realistic efforts to follow the recommendations. This is illustrated by Attachment 2, showing the weekly shopping list suggested by the food intake pattern outlined for an individual consuming a 2000 calorie diet. The food pattern suggests nine servings per day of fruits and vegetables and permits only 208 calories per day of discretionary calories, which have to stretch to cover not only frivolous foods such as desserts or chips but also the fat contributed by cheeses or whole milk, the butter and jam one may spread on a couple of pieces of whole wheat toast, or the glass of red wine that might accompany a chicken dinner. Any one of these choices would deplete the entire day’s allotment of discretionary calories. Even the food pattern for a 3000-calorie diet permits only 298 discretionary calories per day (Attachment 3). What is the rationale for such dietary stringency? What is the evidence that people are likely to thrive within such a narrowly defined range of flexibility? The Dietary Guidelines Committee is proposing nothing less than a revolution in how we as a nation choose to feed ourselves, and CRN believes the food patterns offered in the Report are unlikely to serve as a sufficient rallying point for such a revolution. While CRN fully endorses reasonable recommendations for nutritional improvement, we believe the food patterns offered by the Report are unrealistic and far exceed the recommendations and restrictions necessary to define healthy dietary habits. We urge a strong dose of reality. Comments respectfully submitted, Annette Dickinson, Ph.D. President ATTACHMENT 1: REFERENCES TO NUTRIENT SHORTFALLS AND THE APPROPRIATENESS OF FORTIFIED FOODS OR SUPPLEMENTS EXCERPTS FROM THE EXECUTIVE SUMMARY REGARDING NUTRIENT ADEQUACY: “For most nutrients, intakes by Americans appear adequate. However, efforts are warranted to promote increased dietary intakes of vitamin E, calcium, magnesium, potassium, and fiber by children and adults and to promote increased dietary intakes of vitamins A and C by adults.” “Special nutrient recommendations are warranted for a few large subgroups of the population as follows: · Adolescent females and women of childbearing age need extra iron and folic acid. · Persons over age 50 benefit from taking vitamin B-12 in its crystalline form from foods fortified with this vitamin or from supplements that contain vitamin B-12. · The elderly, persons with dark skin, and persons exposed to little UVB radiation may need extra vitamin D from vitamin D-fortified foods and/or supplements that contain vitamin D.” “A reduced risk of both sudden death and CHD death in adults is associated with the consumption of two servings (approximately eight ounces) per week of fish high in the n-3 fatty acids called eicosapentaenoic acid (EPA) and docosahexaenoic acid (DHA).” Consume two servings of fish per week, especially fish high in EPA and DHA, but pregnant women, lactating women, and children should avoid fish with a high mercury content. Consult consumer advisories for more information regarding contaminants. Choose fiber-rich foods from among fruits, vegetables, and grains. Whole fruits over juices, whole grains over refined grains. “A reduced intake of added sugars (especially sugar-sweetened beverages) may be helpful in achieving the recommended intakes of nutrients and in weight control.” EXCERPTS FROM THE SCIENCE BASE: MEETING RECOMMENDED NUTRIENT INTAKE “One premise of the Dietary Guidelines Advisory Committee is that the nutrients consumed should come primarily from foods. Many people understand the importance of good nutrition but believe that a daily vitamin pill will substitute for actually eating the foods that they know are good for them.” “If a group has a high prevalence of inadequate dietary intake of a nutrient, that nutrient is called a shortfall nutrient.” The probability of adequate dietary intake is less than 60% among adult men and women for six nutrients: vitamin E, vitamin A, vitamin C, folate, calcium, and magnesium. Folate intakes have undoubtedly improved as a result of new regulations for enriched grain products, but “folate may continue to be a nutrient of concern.” Vitamin E “is a shortfall nutrient for nearly the entire population of U.S. adults and children.” Iron: “Substantial numbers of adolescent females and women of childbearing age have laboratory evidence of iron deficiency. Efforts are warranted to increase the dietary intake of iron-rich foods and of enhancers of iron absorption by these groups.” Folic acid: “Since folic acid reduces the risk of the neural tube defects (NTD) called spina bifida and anencephaly, daily intake of 400 mcg of synthetic folic acid (from supplements or fortified food) is recommended for women who are capable of becoming pregnant and those in the first trimester of pregnancy.” Increased folic acid intake as a result of changes in the U.S. pattern of grain enrichment has reduced the incidence of NTDs, but not to the extent that has been shown in studies involving supplementation. Vitamin B-12: “A substantial proportion of individuals over age 50 may have reduced ability to absorb naturally occurring vitamin B-12 but not the crystalline form. Thus, all individuals over the age of 50 should be encouraged to meet their RDA for vitamin B-12 by eating foods fortified with vitamin B-12 such as fortified cereals, or by taking the crystalline form of vitamin B-12 supplements.” Vitamin D: “The elderly, persons with dark skin, and persons exposed to insufficient UVB radiation are at risk of being unable to maintain vitamin D status. Persons in these high-risk groups may need substantially more than the 1997 AI for vitamin D from vitamin D-fortified foods and/or vitamin D supplements.” “Vitamin D intakes of approximately 1000 IU per day can be achieved by consuming 3 cups of vitamin D fortified milk per day (300 IU) plus a supplement containing vitamin D (600 IU) plus 1 cup of vitamin D fortified orange juice (100 IU). Although this level of vitamin D intake exceeds the AI of 600 IU per day for an elderly person, there is no evidence that consuming this amount will have a detrimental effect on health.” USDA SUGGESTED FOODS TO INCREASE INTAKE OF SPECIFIC NUTRIENTS Vitamin A: liver, carrots and carrot juice, sweet potato, pumpkin, spinach, collards, kale, turnip greens. Vitamin C: guava, red pepper, oranges or orange juice, grapefruit juice, kiwi, green pepper, broccoli. Vitamin E: fortified cereals, almonds, sunflower seeds, sunflower oil, cottonseed oil, safflower oil, hazelnuts, avocado. Calcium: fortified cereals, plain yogurt, cheese, tofu, sardines, skim milk. Magnesium: pumpkin seeds, bran cereal, brazil nuts, halibut, quinoa, spinach, almonds, buckwheat flour, cashews, soybeans. Potassium: sweet potato, tomato paste, beet greens, baked potato, white beans, yogurt, clams, prune juice, carrot juice, blackstrap molasses. ATTACHMENT 2: WEEKLY SHOPPING LIST FOR A PERSON CONSUMING A 2000 CALORIE DIET (DERIVED FROM TABLE D1-13: USDA Food Intake Pattern for Meeting Recommended Nutrient Intakes) 14 cups per week of fruit without added sugars or fats: oranges, orange juice, apples, apple juice, bananas, grapes, melons, berries, raisins. 3 cups per week of dark green vegetables: broccoli, spinach, romaine, collard greens, turnip greens, mustard greens. 2 cups per week of orange vegetables: carrots, sweet potatoes, winter squash, pumpkin. 3 cups per week of legumes: pinto beans, kidney beans, lentils, chickpeas, tofu. 3 cups per week of starchy vegetables: white potatoes, corn, green peas. 6.5 cups per week of other vegetables: tomatoes, tomato juice, lettuce, green beans, onions. 21 servings (ounces) per week of whole grains: whole wheat and rye breads, whole grain cereals and crackers, oatmeal, brown rice. 21 servings (ounces) per week of other grains: white breads, enriched grain cereals and crackers, enriched pasta, white rice. 38.5 ounces per week of lean meat or beans: meat, poultry, fish, dry beans and peas, eggs, nuts, seeds. Count beans and peas either in this group or with legumes in the vegetables group. 21 cups per week of milk: Food pattern is based on skim milk. Fat or added sugar in other dairy products will count against discretionary calories. 154 grams (5.5 ounces) per week of oils: vegetable oils and soft vegetable oil spreads that are free of trans fats. 1456 discretionary calories per week (208 calories per day): Includes fats or added sugars in dairy products, meats, fruits, vegetables, or grain products. Also includes alcoholic beverages, if any. ATTACHMENT 3: COMPARISON OF WEEKLY FOOD PATTERN FOR 2000 AND 3000 CALORIE DIETS (DERIVED FROM TABLE D1-13: USDA Food Intake Pattern for Meeting Recommended Nutrient Intakes) QUANTITY PER WEEK FOOD CATEGORY 2000 CALORIES 3000 CALORIES Fruit 14 cups 17.5 cups Dark green vegetables 3 cups 3 cups Orange vegetables 2 cups 2.5 cups Legumes 3 cups 3.5 cups Starchy vegetables 3 cups 9 cups Other vegetables 6.5 cups 10 cups Whole grains 21 servings (oz) 35 servings (oz) Other grains 21 servings (oz) 35 servings (oz) Lean meat or beans 38.5 oz 49 oz Milk (skim) 21 cups 21 cups Oils 154 grams (5.5 oz) 280 grams (10 oz) Discretionary calories 1456 per week 2086 per week (208 per day) (298 per day) NOTE: For fruits and vegetables, a serving is generally considered to be half a cup, so the number of servings being recommended is twice as great as the number of cups being recommended.
Submission Date 9/21/2004 10:26:00 AM
Author Council for Responsible Nutrition

   Process
Summary Generally Excellent! The Guidelines should be shortened, edited by outside editors for readability. Redundancies, jargon and technical language should be eliminated or explained.
Comments Excellent! Excellent! These guidelines are in line with good science and should encourage better health among all of us. I just have a few suggestions: Overview 1. Please limit the Guidelines to 32 (4” x 9”) pages, similar in shape to the earlier editions. This will save printing costs and encourage wider circulation. Make an expanded version available for professionals. 2. Have some outside editors review the text for redundancy and readability. They can also help to pare down the text and eliminate excessive wording. 2. There is some jargon in the text. For example, although we consume nutrients, we “eat” food. Please don’t say, we “consume” food. There are also some technical terms in the text that many readers would not readily understand.
Submission Date 9/21/2004 12:26:00 PM
Author from Hartford, CT

   Other
Summary ADA commends the Committee and agencies on the report, recommends developing a consumer document via consumer testing, and supports increasing resources and partnerships to expand educational outreach, meet research needs, and conduct ongoing evidence analysis.
Comments ADA commends HHS and USDA for their dedication to a transparent evidence-based revision process. ADA recognizes the tremendous workload such a thorough analysis requires and is extremely grateful to the Advisory Committee and the staff for their contributions to this project. ADA recommends expanding the resources available for the revision including adding USDA and HHS staff dedicated to the process. This expansion would enable ongoing evidence analysis. In addition, the Advisory Committee selected for the 2010 revision may have a more manageable workload. Given the budget challenges at many academic institutions, scientists, such as those on the 2005 Committee, may be unable to dedicate unlimited time to the revision process without compensation, such as a sabbatical program or fellowship. Thus, ADA would encourage HHS and USDA to explore new options such as these for Advisory Committee members in the future. With regards to the 2005 Dietary Guidelines for Americans, the ADA believes the Advisory Committee’s report is a scientifically sound and thorough document from which to build consumer messages. The document was written for a scientific audience, and thus, we anticipate the language of the key messages being further evaluated in the process of establishing consumer messages. ADA recommends the nine key messages and their supporting points be translated into clear and actionable messages using consumer testing. Statements such as “Choose carbohydrates wisely for good health” may not mean to consumers what it means to the health professionals and scientists writing the document or to the health professionals reading the document. The only way to make sure that consumers understand the messages is to work with them directly to choose words and images that make sense to them. The consumer-testing component of the guidelines development should be approached with the same rigor as the scientific report. Likewise, consumers need to be educated on the new Guidelines, how to interpret them and how to implement them. ADA would encourage HHS and USDA to continue to pursue creative partnerships with other organizations in order to maximize the reach of educational efforts. Finally, ADA strongly supports pursuing the research needs identified by the 2005 Dietary Guidelines Advisory Committee. A strong commitment toward expanding the evidence base will lead to clearer and more effective nutrition guidance in the future. The 67,000 nutrition professionals of the American Dietetic Association (or ADA) would like to reiterate our appreciation of the effort that has gone into this revision process to date, encourage USDA and HHS to maintain the evidence analysis through the next revision process, and thank you, the agencies for the opportunity to present testimony today. ADA and its members look forward to continuing to work with HHS and USDA in revising, disseminating, and evaluating the Dietary Guidelines for Americans.
Submission Date 9/22/2004 4:06:00 PM
Author American Dietetic Association

Summary Lack of consistency within the guidelines with respect to specificity will communicate a confusing message to the American public. Lack of specificity within each guideline represents a missed opportunity to education and inform the public.
Comments Independent of the design or intent, the Dietary Guidelines for Americans are frequently reproduced devoid of supporting text. Although single phrases cannot be expected to convey the complex science behind each guideline as presented in the supporting text, it would be in the public’s best interest to have a set of guidelines that are internally consistent and provide as much specify as possible. It is perplexing that some guidelines recommend specific behaviors, i.e. “Choose and prepare foods with little salt”, whereas others are devoid of an actionable message, i.e. “Choose carbohydrates wisely”. In the later example, the lack of specificity results in a missed opportunity to education and inform the public. Specific suggestions submitted separately.
Submission Date 9/22/2004 2:13:00 PM
Author from Boston, MA

Summary The guidelines should include something to the effect of "Reduce the consumption of added sugars.
Comments Considering the problem with obesity in America, how can you possibly avoid making a direct comment about sugars in the diet? Oh, wait, you _did_ know that we have a problem with obesity?
Submission Date 9/1/2004 12:12:00 PM
Author Anonymous

   Data Sources
Summary Sugar is an addictive substance and the report does not go far enough in making this clear.
Comments Ignoring your own research regarding the nutrient deficiency of sugar puts the health of Americans and the general well being of our country at risk. DO YOUR JOB!
Submission Date 9/1/2004 10:02:00 AM
Author Anonymous

   Other
Summary Please include in your guidelines the phrase, "Avoid too much sugar" or a comparable statement.
Comments As the parent of a ten-year-old, I am concerned that nowhere in your proposed guidelines is the word "sugar" included. The connection between obesity and sugar is clearly defined, and obesity is a serious, widespread problem in our country. Too much sugar in our diets can likewise engender or exacerbate diabetic conditions. Through these guidelines, our government needs to provide leadership and guidance on better health through minimizing sugar in our diets. Please include in your guidelines the phrase, "Avoid too much sugar" or a comparable statement.
Submission Date 9/1/2004 9:26:00 AM
Author Anonymous

Summary Reasonable limits on sugar intake are necessary
Comments I agree with today's NY Times editorial (http://www.nytimes.com/2004/09/01/opinion/01wed2.html?th) -- don't let industry control the new dietary guidelines. Issue dietary guidelines with reasonable limits on sugar intake. Stand up to them. A country full of obese, unhealthy people is a tragedy. Aside from the moral necessity to handle this correctly, there's the expense of caring for unhealthy people and their lost contributions to society.
Submission Date 9/1/2004 8:21:00 AM
Author Anonymous

Summary test
Comments test
Submission Date 9/17/2004 2:52:00 PM
Author Anonymous

Summary Physical exercise is a very important missing part of the food pyramid. However, milk is not. There are many draw backs to milk that can be overcome with the use of soy.
Comments I am glad to read that physical activity might be added to the dietary guidelines. It is so very important to every persons life and yet is commonly over looked. I am not excitted to see that a recommended 3 cups of milk a day may be added. Milk is high in fat, a great alternative like Soy milk also brings more to the table, mainly isoflavonoids and lignans, which are very benifical for the body. Cow's milk often contains hormones. I would rather see soy take the place of milk on the food pyramid.It has been shown that people in Asian countries that use more soy often have longer life expectancies. Although, if we cannot get past milk, it may be important to at least distinguish the type of milk, which non-fat ORGANIC milk would be the best. Let's keep in mind that the body is also supplied with adequate calcium through fruits and vegetables.
Submission Date 9/17/2004 3:14:00 PM
Author from portland, or

   Data Sources
Summary The Dietary Guidelines are a very useful tool. However, they are in danger of becoming antiquated. We need to update the guidelines with more recent and specific information to ensure that consumers are receiving the best available information.
Comments I would like to start by discussing the Dietary Guidelines that give Americans a specific course of action to take in order to manage their weight by making long-term changes to their eating behavior. To do this, a person needs to make healthy and sensible food choices. Vegetables, fruits, grains (especially whole grains), skim milk, and fish, lean meat, poultry, or beans are some of the main foods that should be included in everyone’s diet. Foods that are low in fat and added sugars should also be chosen. In addition, a sensible portion size should always be eaten regardless of the food or beverage.1 These guidelines are insightful and helpful to anyone that seeks a healthy balanced eating lifestyle. A healthy body starts with a well balanced diet and these suggestions are very good. Another aspect of the Dietary Guidelines is physically active and maintenance of a healthy weight. Each for these is needed for good health, but they benefit the body in different ways. Children, teens, adults, and the elderly—all can improve their health and well-being and have fun by including moderate amounts of physical activity in their daily lives.  Physical activity involves moving the body.  A moderate physical activity is any activity that requires about as much energy as walking 2 miles in 30 minutes.1 Unfortunately, I will have to disagree with the latter statement. The Dietary Guidelines are too ambiguous in this instance. A 30 minute walk at the aforementioned pace would have would have little to no effect on a conditioned individual. These guidelines must be fine-tuned to an individual’s height, weight, age, and current physical conditioning. This would not only give individuals more definitive short-terms goals, it would also give them a guide to where they need to be once improvements have been made (i.e. long-term goals). The Dietary Guidelines then go on to discuss food labels. This is a very important aspect of nutrition because individuals cannot satisfactorily follow any diet or recommendation without being able to fully understand these labels. The food labels have several parts, including the front panel, Nutrition Facts, and ingredient list. The front panel often tells you if nutrients have been added—for example, "iodized salt" lets you know that iodine has been added, and "enriched pasta" (or "enriched" grain of any type) means that thiamin, riboflavin, niacin, iron, and folic acid have been added.1 This is a good start, but future labeling will need to be more detailed. As consumers become more educated, information such as exact percentages of each ingredient, percentage of trans-fatty acids, percentage of certain proteins (i.e. soy vs. whey), etc. need to be readily available. People need to know these things, so they can customize their diet according to their needs. In addition, a visual aid needs to be displayed or described on each label with regard to portion size, so the consumer has a better idea of how much they need to be eating. Finally, the Dietary Guidelines discuss food safety and preparation. Foods that are safe from harmful bacteria, viruses, parasites, and chemical contaminants are vital for healthful eating. Safe means that the food poses little risk of foodborne illness. Farmers, food producers, markets, food service establishments, and other food preparers have a role to keep food as safe as possible. However, we also need to keep and prepare foods safely in the home, and be alert when eating out.1 The steps discussed in this section are very helpful to anyone that is unsure about proper food safety and preparation.
Submission Date 9/17/2004 3:57:00 PM
Author Ball State University

   Children
Summary Has the importance of eating many small meals a day versus three large meals been addressed?
Comments Has the importance of eating many small meals a day versus three large meals been addressed? More specifically, has the importance of children snacking at school been considered? Many children are forced to eat an early breakfast due to daycare arrangements, bus schedules, etc. and can not eat again until their school lunch time (for many this isn't until 12:30). My son complains of headaches and nausea because he is "starving" as he puts it by the time he eats lunch. I require many healthy snacks a day to maintain my energy. Why would my growing children be any different? Our school does not allow snacking due to pest concerns; however they DO allow birthday snacks (cupcakes, junk food!) periodically during the year! I feel that a DRY SNACK, such as pretzels, animal crackers, etc. around 10:00 a.m. would not contribute to pest problems and would promote concentration in schoolchildren.
Submission Date 9/17/2004 11:14:00 AM
Author from Butler, PA

   Other
Summary
Comments Other components of diet are mentioned specifically in the summary of the new proposed dietary guidelines - it is CRIMINAL to include business and marketers power to intrude in waht should be a science based statement - tell people up front that consumption of refined sugars has/can have negative consequences and let the taxpaying public make up its mind what to eat. We real TAXPAYERS are your bosses - not a few large corporations that have for years actually paid little or no taxes.
Submission Date 9/1/2004 1:33:00 PM
Author Organization Name not Specified

Summary I ask that the following three things be included in the guidelines: 1. choose lean meats 2. choose grass-finished meat and milk, because of the advantageous fatty acid profile 3. balance good and bad fats - not all fats are the same
Comments
Submission Date 9/17/2004 2:19:00 PM
Author Anonymous

Summary Grassfed products have MAJOR benefits. We MUST have EXACT guidelines for grassfed products. We MUST be confident that an "American Grassfed" label actually means the product was never in a feedlot/never in a "warehouse"/never pumped with chemicals -- that what we pay for is REALLY what we get.
Comments Grassfed -- the benefits MUST be considered.
Submission Date 9/18/2004 3:18:00 PM
Author Anonymous

   Process
Summary List separately among the major messages: "Limit one's intake of added sugars." This would conceptually parallel the fourth major message, "Increase the daily intake of ... "
Comments Limiting one's uptake of added sugars should be pointed out clearly by listing it as one of the major messages of the DIETARY GUIDELINES. Because the message is so important, it should be distinct for summarizations made by the media and by groups dependant on the DIETARY GUIDELINES such as school lunch programs. It is not sufficient to point this out within other major messages. A separate major message should be specified: "Limit one's intake of added sugars". This would be directly parallel to the concept of the fourth major message, "Increase the daily intake of ... ".
Submission Date 9/18/2004 10:35:00 PM
Author from Alexandria, VA

Summary "Limit your intake of added sugars" should be a separate major message.
Comments DIETARY GUIDELINES should make it very clear about the importance of limiting uptake of sugars. This should be made clear in a separate major message: "lIMIT YOUR INTAKE OF ADDED SUGARS" and not just be incorporated with other messages.
Submission Date 9/18/2004 11:43:00 PM
Author Anonymous

   Other
Summary We commend HHS and USDA for your work thus far in developing a broad-based revision of the 2000 Dietary Guidelines to reflect the most recent science regarding healthy diets. The 2005 Dietary Guidelines Advisory Committee has done an excellent job, and we strongly encourage the Departments to remai
Comments We commend HHS and USDA for your work thus far in developing a broad-based revision of the 2000 Dietary Guidelines to reflect the most recent science regarding healthy diets. The 2005 Dietary Guidelines Advisory Committee has done an excellent job, and we strongly encourage the Departments to remain true to its recommendations as you develop the final Guidelines. The Committee’s extensive scientific review and deliberations led to the development of nine core concepts that should prove useful to the Departments as you assess the vast report and incorporate its findings into the revised Guidelines. We would like to briefly comment on several of the report’s core concepts and their importance.
Submission Date 9/27/2004
Author United Fresh Fruit and Vegetable Association

   Process
Summary we encourage the Dietary Guidelines Advisory Committee to recommend that all nutrition related activities be removed from the jurisdiction of the U.S. Department of Agriculture and transferred to either the U.S. Department of Health and Human Services or the office of the Surgeon General.
Comments In addition to the points cited above, we encourage the Dietary Guidelines Advisory Committee to recommend that all nutrition related activities be removed from the jurisdiction of the U.S. Department of Agriculture and transferred to either the U.S. Department of Health and Human Services or the office of the Surgeon General. With a stated mission of marketing animal agriculture, the USDA is unable to perform in an objective, unbiased manner in regards to human nutrition policy. For example, a recent defense of the USDA Food Guide Pyramid, published in the July 2004 issue of the Journal of the American Dietetic Association, was funded by the National Cattlemen's Beef Association, a major client/partner of the USDA. The relationship between the USDA and the U.S. animal agriculture industry makes it impossible for this agency to act in the best interest of American consumers.
Submission Date 9/27/2004
Author

   Other
Summary Moving ahead, we must make sure that dietary goals set out in the new guidelines are fully achieved.Now we must take the next critical step and not only speak frankly with Americans about what they should be eating, but put all of our energies into creating an environment that will help them make so
Comments the 2005 Dietary Guidelines will provide a benchmark against which American dietary habits can be measured. Moving ahead, we must make sure that dietary goals set out in the new guidelines are fully achieved. The agencies must strive to help all Americans attain the recommended dietary guidelines, rather than just read about them. This effort will require a reshaping of the American diet in many areas, not the least of which is increased consumption of fruits and vegetables. The government must focus its efforts and develop programs designed to aggressively meet this goal. United pledges its support to us and your staff as you tackle this daunting project. It is clear that the scientific Advisory Committee has done its job and we strongly support the sound science of independent research that was conducted. Now we must take the next critical step and not only speak frankly with Americans about what they should be eating, but put all of our energies into creating an environment that will help them make sound choices for a lifetime.
Submission Date 9/21/2004
Author United Fresh Fruit and Vegetable Association

Summary We urge HHS and USDA to adopt the committee’s nine major messages, to make them clear to the public. Those main messages should do more than provide just a uniform theme. They must also provide direct advice that people can understand to use to improve their diets.
Comments Overall, the Center for Science in the Public Interest wholeheartedly congratulate the Dietary Guidelines Advisory Committee and the departments for their excellent scientific report, which should provide a very strong basis for national nutrition programs, policy, and nutrient education and promotion. The general advice and scientific rationale regarding fats, refined sugars, sodium, alcohol, and body weight are strong and well documented throughout the report. Importantly for the first time, we were glad to see the committee providing quantitative advice regarding trans fat, sodium, and whole grains. The challenge is now for HHS and USDA to convey the committee’s science-based advice to the general public in a way that is understandable and conducive to improved diets, which we’ve heard from several previous people testifying. While the supporting details of the report are important, it’s usually the major messages of the Dietary Guidelines that are publicized and used most widely by the media and in nutrition education materials. We urge HHS and USDA to adopt the committee’s nine major messages, to make them clear to the public. Those main messages should do more than provide just a uniform theme.
Submission Date 9/21/2004
Author Center for Science in the Public Interest

Summary NFPA recommends that the guidelines be framed in positive terms. Negative messages do not motivate consumers – behavior change results from positive recommendations. The key messages should be “DO,” rather than “DO NOT.”
Comments NFPA believes that the nine key messages developed by the Dietary Guidelines Advisory Committee have merit, and should be developed into practical guidance for consumers. NFPA considers it essential that the Dietary Guidelines facilitate understanding and motivate consumers toward action and behavior change. NFPA recommends that the guidelines be framed in positive terms. Negative messages do not motivate consumers – behavior change results from positive recommendations. The key messages should be “DO,” rather than “DO NOT.”
Submission Date 9/21/2004
Author National Food Processors Association

Summary Guidance must clearly and positively illustrate how eating healthfully and moving more can be enjoyable and easy if we want to achieve real change in American’s behavior.
Comments Guidance must clearly and positively illustrate how eating healthfully and moving more can be enjoyable and easy if we want to achieve real change in American’s behavior.
Submission Date 9/21/2004
Author Purdue University

Summary Translate current science into messages that resonate with consumers and conduct consumer research to ensure that messages are both meaningful and actionable. It is important to that dietary guidance messages be guided by consumers, rather than merely developed for consumers.
Comments While the nine main messages are not necessarily consumer messages, the opportunity exists to translate them into motivating communications. Conducting consumer research to determine barriers and motivators for compliance becomes imperative as we communicate the science of dietary guidance. Conducting consumer research allows us to ensure that our science-based messages are received by the public as intended. It also allows us to communicate with consumers, rather than to them
Submission Date 9/21/2004
Author International Food Information Council

Summary We urge the Secretaries to adopt the report’s nine major messages as the main points of the Dietary Guidelines.
Comments We urge the Secretaries to adopt the report’s nine major messages as the main points of the Dietary Guidelines.
Submission Date 9/21/2004
Author International Dairy Foods Association

   Process
Summary We commend the Dietary Guidelines Advisory Committee and staff members of the two departments on their monumental undertaking to develop the technical report using a scientific, evidence-based approach. As DHHS and USDA move into the next phase of translating the Dietary Guidelines Technical Report
Comments General Mills appreciates the opportunity to comment on the 2005 Dietary Guidelines Advisory Committee Technical Report. As a major manufacturer of food products such as cereal, flour, baking mixes, refrigerated and frozen grain products, main meals, soups, snacks and yogurt, we believe it is also our responsibility to provide dietary guidance and nutrition information to the public. For over 40 years, we have been a leader in providing nutrition information and education materials to health professionals and our consumers. We conduct research on consumer understanding of how our products fit within the total diet, and continuously monitor and evaluate the nutritional impact these foods have on the overall diets of consumers. We commend the Dietary Guidelines Advisory Committee and staff members of the two departments on their monumental undertaking to develop the technical report using a scientific, evidence-based approach. It is a significant step in the right direction to utilize such a process to systematically assess the scientific underpinnings of the key nutrition and health policy guidelines for the U.S. population. We also appreciate the opportunity to observe the open meetings of the Committee as they debated and discussed the scientific issues and data. As DHHS and USDA move into the next phase of translating the Dietary Guidelines Technical Report into simple, easy to understand messages for the public, we encourage you to test, refine and re-test the messages with consumers to understand the interpretation and motivational value of the messages. Without this critical step, the efforts of the Dietary Guidelines Advisory Committee will be compromised and the American public will not reap the full benefit of this impressive report.
Submission Date 9/27/2004
Author General Mills

Summary To increase dietary guidance effectiveness, two actions are critical: 1. Translate current science into messages that resonate with consumers and 2. Conduct consumer research to ensure that messages are both meaningful and actionable
Comments Thank you for the opportunity to provide comment on the 2005 Dietary Guidelines for Americans and the recommendations of the Advisory Committee. The Committee’s report provides the latest science yet recognizes that the translation of the science into consumer-friendly dietary guidance should be left to the communications experts. As a premier consumer communications and research organization, the IFIC Foundation facilitates the translation of science-based food safety and nutrition information into meaningful consumer messages. It is through the IFIC Foundation’s experience that we would like to share the following insights. To increase dietary guidance effectiveness, two actions are critical: 1. Translate current science into messages that resonate with consumers and 2. Conduct consumer research to ensure that messages are both meaningful and actionable The Advisory Committee report provided specific content recommendations for “main messages” based on the current science. While the nine “main messages” are not necessarily “consumer messages,” the opportunity exists to translate them into motivating communications. Conducting consumer research to determine barriers and motivators for compliance becomes imperative as we communicate the science of dietary guidance. Conducting consumer research allows us to ensure that our science-based messages are received by the public as intended. It also allows us to communicate with consumers, rather than to them. In 2001, the IFIC Foundation, in collaboration with the United States Department of Agriculture and the Food Marketing Institute, conducted consumer research on the 2000 Dietary Guidelines. In the words of the consumer, the Dietary Guidelines messages were “common sense” or “too generic, too basic.” One consumer observed, “Most people know this. They just don’t follow it.” Consumers tell us that generalized messages, like those provided in the Advisory Committee report, make sense to them intellectually, but they are not compelling enough to implement into their hectic lifestyles. Consumers increasingly report that they need personalized information that applies to them and their lives specifically. Ultimately, it is important that dietary guidance messages be guided by consumers rather than merely developed for consumers. This is accomplished by conducting consumer research and using these insights to translate the science into messages that consumers can identify with and apply to their lives. In addition, partnerships, such as the Dietary Guidelines Alliance, will allow us to reach the widest possible audience with consistent and harmonized messages. Recognizing the value of partnerships, the International Food Information Council Foundation also looks forward to working in collaboration with the Departments of Health and Human Services and Agriculture to communicate messages that resonate with consumers and motivate them to better health. Thank you.
Submission Date 9/27/2004
Author International Food Information Council

   Other
Summary Executive Summary Should Reflect the Order of Priority of the Guidelines Written by: Maureen Storey & Richard Forshee
Comments Executive Summary Should Reflect the Order of Priority of the Guidelines As it is currently written, the executive summary does not reflect the order of the dietary guidelines—“choose fats wisely for good health” and “choose carbohydrates wisely for good health” should follow the guideline, “increase daily intakes of fruits and vegetables, whole grains, and reduced-fat milk and milk products.” 1 Federal Register: Notice. August 27, 2004, Volume 69, Number 166, pages 52697-52698. 2 Presumably, the 2005 Dietary Guidelines for Americans Committee (DGAC) prioritized the guidelines based on the importance and likelihood of accruing positive health benefits, such as maintaining or achieving a healthy body weight. This appears to be the underlying key message for the first three and fully one-third of the guidelines. • Consume a variety of foods within and among the basic food groups while staying within energy needs; • Control calorie intake to manage body weight; • Be physically active every day. Assuming that most people will remember only a few messages, these three are the most important to a population that is increasingly overweight and obese.
Submission Date 9/27/2004
Author Center for Food and Nutrition Policy

Summary Delete “The Role of the Environment in Implementing the Guidelines” Written by: Maureen Storey & Richard Forshee
Comments Delete “The Role of the Environment in Implementing the Guidelines” The task given to the DGAC was to review the “available science base to characterize elements of guidance for a healthful diet—dietary guidelines that, if followed, will reduce the risk of chronic disease while meeting nutrient requirements.”2 Proposals such as those suggested by the DGAC regarding the role of the environment in implementing the guidelines should certainly be scrutinized rigorously. For example, the policy options proposed by in this section should be evaluated against several welldefined, objective criteria in the following areas: 1) scientific validity, 2) technical feasibility, 3) value acceptability, 4) cost, and 5) risk reduction. Unfortunately, certain statements made in this section are based on conjecture and untested hypotheses that are inappropriate for this scientific report. There is virtually no “science” to support the speculations made by the DGAC; therefore, this section should be deleted from the report. The DGAC opines that “because many of these factors are beyond the control of individuals (e.g., the size of portions served in food establishments and lack of information on calorie content at point of purchase), substantial changes to the environment are required to achieve a milieu that supports healthy behaviors”3 This language is not supported by the scientific evidence. While portion sizes served in food establishments have increased, the idea that patrons can not refuse to eat the entire offering or order a smaller portion is wrong and misguided. Patrons have many choices in restaurants including how much of a purchased food or meal they will consume at one sitting. Most restaurants already have some items with smaller portion sizes and/or “healthy” or “light” items designed specifically for consumers who want a lower-calorie option. Furthermore, the food and restaurant industries have proven very responsive to consumer demand in the past, most recently as exhibited by the wave of new products and menu items for individuals following “low-carb” diets. If consumer demand for smaller portion size options increases, the food and restaurant industries are likely to respond without any need for government intervention. In addition, CFNP is not aware of any evidence that displaying calorie content at the point of purchase will have any effect on consumer purchases that will ultimately support healthy behaviors and better health outcomes. Given persistent budgetary constraints, the federal government can ill-afford to promote the unsupported speculations that are proposed in this section. The Center therefore urges the Secretaries of Agriculture (USDA) and Health and Human Services (DHHS) to delete the section entitled “The role of the environment in implementing the guidelines” in Part B—Introduction.
Submission Date 9/27/2004
Author Center for Food and Nutrition Policy

Summary To increase the likelihood that the key messages resonate with the consumers to which they are targeted, focus groups should be conducted to ensure: • Key messages are able to be understood and acted upon; • Supporting text provides meaningful guidance with regard to making food choices (for example
Comments In this report, the Committee has made a strong effort to adapt the guidelines to the various segments of the US population relative to age, gender, and ethnicity, thus making it possible for the public to individualize the messages. However, the effectiveness of this effort may be diminished due to the inconsistency in both substance and guidance of the key messages. Some make specific recommendations, i.e. “Choose and prepare foods with little salt”; while this is not quantitative, the clear message is to reduce salt intake. Others are more generic in nature, i.e. “Choose fats wisely for good health”; such messaging provides little information or guidance on what a “wise” choice is or how to determine what a “wise” choice would be. We feel strongly that if any key messages are communicated in terms of nutrients, as opposed to foods (i.e. “Choose fats wisely”, “Choose carbohydrates wisely”), supporting text must be explicit about those foods to eat less of and which to include more of. As they currently exist, these more general messages result in a lost opportunity to provide consumers with clear guidance regarding specific food choices. Given that 64% of Americans are overweight, it would seem prudent that each message regarding food consumption be considered within the context of reducing calories and/or controlling weight. Therefore, key messages regarding fat and carbohydrates should include an explicit weight management focus. Messages to “eat more” of a particular food should emphasize substituting these foods for other more calorically-dense (and potentially less nutrient-dense) food choices. Further, the importance of portion control and food preparation (selection of foods and lower-calorie cooking methods) should be stressed. Of great concern to our organizations is the impact that the current trends in overweight among youth will have on future chronic disease rates. Overweight and obesity rates in US children have doubled over the last two decades and continue to rise. Increasing consumption of foods high in fat, added sugar and refined grains and low levels of physical activity are of particular concern, especially among children, who are establishing lifetime patterns of diet and physical activity. Concerted efforts must be made to ensure that the key messages of the Guidelines are effectively translated to and applied by those who influence youth eating and physical activity habits. To increase the likelihood that the key messages resonate with the consumers to which they are targeted, focus groups should be conducted to ensure: • Key messages are able to be understood and acted upon; • Supporting text provides meaningful guidance with regard to making food choices (for example, identification of foods and beverages high in saturated fat and/or added sugar; nutrient-dense choices within food groups; understandable household equivalents - cups and ounces as opposed to servings; 1 tsp salt as opposed to 2400 mg, etc.). • Barriers (and motivations) to living healthier lifestyles are considered while developing the Guidelines’ communication and dissemination strategies
Submission Date 9/27/2004
Author American Cancer Society, American Diabetes Association, American Heart Association

Summary
Comments Anyone focusing for just one minute and logically looking at the general health of our population and especially our younger generations with the epidemic of chronic automimmune disorders, cancers, obesity, and heart disease that plague us today, one must realize we have made a terrible turn in the direction of our health care in relation to diet. Saturated fats having been a staple of our diet when heart disease affected 7% of our population in 1930's and now thanks to chemically altered fats including hydrogenated vegetable oil we have heart disease affecting 65% of our population, surely we can't continue to saturated fats. Please do not continue this propaganda to the public.
Submission Date 9/24/2004 9:08:00 PM
Author Anonymous

Summary Adults and children need opportunities to learn and experience healthier eating and get regular physical activity. Obesity needs to be eradicated. We need a system of health promotion in this country.
Comments In comparing the U.S. Food Guide Pyramid to the Mediterranean Diet Pyramid there are some differences. In the Mediterranean Diet Pyramid there is an emphasis on protein sources from beans, other legumes, & nuts rather than meat, eggs, and milk. Also there is an emphasis on whole grain, minimally processed, eating seasonally and buying locally. It appears that these cultures actually take time to cook meals. It seems people from these cultures have much less obesity and therefore much less diabetes, cancer, and heart disease. In the U.S. obesity is astounding. Our grocery stores are filled with processed foods. More and more people are eating quick, processed foods and often without sitting down with friends or family members. Fast food is chosen frequently. There is no particular time for family meals anymore. Mothers don't want to cook a large meal because one third of the family won't be there, one third of the family won't be hungry because they already grabbed something to eat and the other third won't eat that particular food. Then there is the family in which one is vegetarian, one is on the Atkin's diet, and others prefer more mainstream. No wonder no one wants to spend time cooking a healthy, nutritious meal. Schools bend over backwards trying to prepare meals that the children will eat to the point that the meals become too salty, too fat filled, and too processed and then no one wants to eat them. Not too many children value their lunches at school even if the meals are brought from home in a sack. My guess is that 1/2 of the food at least is thrown out from both home lunches and school prepared lunches. There is not a value on eating a well prepared meal. On the other hand many people today are relying on quick to prepare meals and food. Kitchens have never been better equiped with the latest and prettiest gadgets and appliances and yet used with less frequency. It would help greatly if the American Food Guide Pyramid would deemphasize red meat and meats in general and promote beans, other legumes, and & nuts as protein sources. Deemphasize dairy as well and promote yogurt and cheese. Emphasize using olive oil, omit other fat sources. I am in favor of schools teaching cooking and healthy living beginning in preschool. Parents will learn from their children. Parents can be involved in the healthy living aspects by participating in a meal, assiting in the preparation of the meal, or the clean up. Many other parent involved activities is possible. Schools need to eliminate all coke, candy, fast food machines. Physical fitness time needs to be included everyday a child is at school including through high school. There needs to be empasis on improving the general health and physical fitness of all students. Getting a baseline record of abilities and physical assessment is important. Improvement for each child is the goal. Set individual short term goals and long term goals. Somehow the value of eating a well prepared healthy meal with friends and family needs to be encouraged as well as providing opportunities for people to learn and experience healthier ways of eating.
Submission Date 9/25/2004 5:22:00 PM
Author from Hailey, ID

Summary Strive to change eating habits gradually.
Comments From the milling industry’s practical experience; taste, custom, cost, and convenience are strong influences in shaping eating habits. Efforts to change eating habits by persuasion will succeed very slowly and only incrementally. This is evidenced in the following excerpt from the book, “Millers National Federation: A History” by Herman Steen (copyright 1975, Library of Congress Catalog Card #75-10154): “During and preceding this period (1939-40) white flour and its products had been under harsh attack…These groups (leaders in the field of human nutrition) turned to whole wheat as the remedy, but after a generation or more of activity they had little to show for their efforts, for the proportion of whole wheat never reached three percent of all flour.”Research conducted for NAMA this past year by Wirthlin Worldwide, Reston, VA identifies a continuum important to the consumption of grain based foods. The research findings demonstrate that consumers, as they become more health aware, migrated from eating white bread to whole wheat bread. If, however, the consumer doesn’t like the taste of whole wheat bread, they choose to eliminate bread entirely. As more emphasis is placed on the value of whole grain products, the consumer is ill served if led to believe that enriched products are of lesser nutritional value.The reasons most people should, and do, eat significant amounts of enriched grain products are:·They are inexpensive. ·They are accessible, sold everywhere in a wide variety of forms.·They serve as a convenient carrier for many other foods, contributing to dietary diversity even while enabling the casual, high-activity lifestyle most Americans today value.·They have flavor and texture characteristics that encourage consumption, i.e.,people are used to them and like them.·They are a major source of energy for the brain.Whole grain products share several of these characteristics; and contain several minerals, vitamins, phytonutrients, and insoluble fiber that enriched grains lack. However, looking realistically at changing eating habits, it is important to remember the following about whole grain products:   They are not as much a part of our culture as are enriched grain products. Many people, especially children, find the flavor or texture unappealing. They are not nearly as available as enriched grain products. They tend to be significantly more expensive, resulting in a strain on many household budgets.
Submission Date 9/21/2004
Author North American Miller's Association

   Methods
Summary SNE advocates a well-planned introduction of the Dietary Guidelines coordinated with the Food Guidance System. To be effective the wording of the nine proposed “themes” requires consumer testing to ensure that they are understandable, appealing and actionable for consumers.
Comments The Society for Nutrition Education would like to commend the Dietary Guidelines Advisory Committee (hereafter called “the Committee”) for the strong report and willingness to review a massive literature base. The scholarly evaluation, including a weighing of the merits of the methodology involved, and the extensive citations show a great dedication to the task. SNE would like to share considerations for a well-planned introduction of the Dietary Guidelines coordinated with the Food Guidance System. We encourage those involved in the communications planning to focus on how best to translate the work of the Committee into action for the consumer. To be effective the wording of the nine “themes” proposed by the Dietary Guidelines Advisory Committee needs to be understandable, appealing and actionable for consumers while conveying the original scientific intent. Therefore, consumer testing of each message is critical to assure that the concepts of selecting foods of higher nutritive value and of having a healthy balance of energy use and intake are understood by the public. The messages also need to be consistent with USDA Food Guidance System and FDA Food Labeling initiatives. Consumer Friendly Language: In our previous communication to the Committee we gave examples of what we considered actionable messages. We are aware that the Committee does not determine the actual wording of the guidelines, but in light of our previous communication we think it would be appropriate to give some examples of wording that we consider to be easier to understand and that still convey the science behind the messages. Example 1: Consume a variety of foods within and among the basic food groups while staying within energy needs. We think that an appropriate wording would be: Eat a variety of foods from the basic food groups of the Pyramid (or whatever the new Food Guidance System is called). Assuming the graphic that accompanies the Food Guidance System shows the foods of higher nutritive value within the group, it should be obvious which foods are the preferred choices. This also ties the Food Guidance System to the Dietary Guidelines, which is appropriate for federally funded programs. It is our opinion that addressing the desire to stay within calorie needs introduces a second concept within this guideline, which may lead to confusion. We believe the calorie issue is best addressed in a separate guideline. Example 2: Control calorie intake to manage body weight. We think a more appropriate wording would be: Balance calorie consumption and physical activity. This wording highlights both intake and output of calories. Controlling energy intake requires accurate knowledge of the caloric content of various foods, as well as reasonably accurate estimates of portion sizes and how food preparation impacts calories. All of this may be difficult for the consumer to accomplish. Example 3: Choose fats wisely for good health. We think a more appropriate wording might be: Use a moderate amount of oils and soft margarines, and very little solid fat. This wording emphasizes the use of fats that are higher in linoleic, a-linolenic and mono unsaturated fats, while contrasting their use with that of fats that are higher in trans and saturated fats [USDA, 2004]. We recognize that dietary fats and fat metabolism related to health are complex, and the proposed guideline does not communicate all related facets. However, the idea is to give a general guideline that consumers can understand and, if followed, will improve their relative consumption of fats. We are not sure that our suggested phraseology is adequate but it was the best we could formulate given the time constraints for these comments. Possible phrasings could be tested by showing groups of consumers examples of oils and soft margarines, contrasted with solid fats, such as butter, meat with fat, etc and asking them how they would explain the difference to someone else. Example 4: Choose carbohydrates wisely for good health. It is our understanding that the guideline to increase daily intake of fruits and vegetables, whole grains, and non-fat or low-fat milk includes the carbohydrates that are recommended to be consumed. If a more specific guideline were desired for these carbohydrates, we suggest the following: Eat more whole grains, starchy vegetables, beans and legumes in preference to other carbohydrate sources. We also feel, given the increase in consumption of added sugars over the last 30 years [Haines, 2000, Putnam, et al., 2002], that a specific guideline about them should be included. We think that appropriate wording would be Choose and prepare foods with less added sugars. Communication aspects A well-founded theoretical basis such as the Transtheoretical Model (also called Stages of Change) [Prochaska &Velicer, 1997] should be the basis for the public awareness campaigns that will be needed for the introduction of the new Dietary Guidelines and the Food Guidance System. In keeping with broad public guidance based on behavioral change theories, the new information should be introduced in a way that captures the attention of people who do not intend to make behavior changes in the near future (precontemplators and contemplators), people who will immediately consider adopting some of the recommendations (preparation stage) and people who are already following the best advice available (action/maintenance). Thus, educational messages should be adapted to utilize a range of communication channels and strategies that are tailored to the needs and interest level of specific audience segments. To facilitate behavior change, Government agencies and nutrition educators should extend and leverage their messages and communication strategies through food manufacturers, food donation agencies, supermarkets, schools, fitness clubs, and other organizations to assure that the messages are reinforced through repeated exposure in different settings and consistent with food available in local communities. As stated in the introduction, we encourage those involved in the communications planning to focus on how best to translate the work of the Committee into action for the consumer. As a case in point, we are particularly concerned about the amount of attention directed toward “discretionary calories.” In the current report the term “discretionary calories” is addressed in Section D of the scientific basis of the Guidelines. The term is not, in and of itself, a Guideline. Yet, already “discretionary calories” have been given extensive attention in related media reports and by committee and staff member presentations to professional audiences [Bronner, 2004], to some extent overshadowing other important concepts that are actually stated in the Guidelines. Educationally, the idea that one has to earn such calories is a disquieting development, along with the implication that the use of calorie dense foods is a problem only for sedentary people who presumably are obese or overweight. However, sedentary people can be found at all BMI levels [Lee, et al., 1999; Miller, 1997, Barlow, et al., 1995]. In the opinion of SNE the communication of the Guidelines should emphasize that good food is nutritious food that tastes good, looks good, smells good and has a pleasant and appropriate texture. We understand that using non-nutritious foods as a reward for good behavior [Puhl & Schwartz, 2003], or limiting their consumption [Fisher & Birch, 1999], makes them more desirable and promotes their use in preference to more nutritious food. The concept of self-efficacy, as proposed by many top behavior theories [Bandura, 1986; Glanz, et al., 2002], indicates that people have to feel good about themselves before they are willing to make changes in their lives. Overweight and obese people are subject to intense criticism, without any acknowledgment of the multiple times they may have tried to maintain a lower weight [Puhl & Brownell, 2003]. This criticism may increase with the dissemination of the concept of discretionary calories resulting in a concomitant lowering of self-esteem making it less likely that they will take steps toward healthy eating and exercise patterns [Johnson, 2001; Berg, 2002]. It should be possible for all to celebrate birthdays and weddings and other special occasions without censure. In the comments to the CNPP about the Food Guidance System we included our recommendations for the introduction of the Dietary Guidelines and the Food Guidance System. We repeat these recommendations so that the Committee is aware of our concerns related to this area: • A well planned introduction of the Dietary Guidelines coordinated with the Food Guidance System should target principal nutrition educators within all major federal nutrition mission areas and leading nutrition-related professional organizations, including, but not limited to: U.S. Department of Agriculture’s (USDA) Center for Nutrition Policy and Promotion (CNPP), Food and Nutrition Service (FNS), and Cooperative State Research, Education and Extension Service (CSREES); U.S. Department of Health and Human Services’ (DHHS) Administration on Aging (AOA), the Food and Drug Administration (FDA), the Health Resources and Services Administration (HRSA), the Centers for Disease Control (CDC); U.S. Department of Education (DOE) Office of Elementary and Secondary Education (OESE); Society for Nutrition Education (SNE); American Dietetics Association (ADA), and others. • An ongoing evaluation of the Dietary Guidelines together with the Food Guidance System will be necessary to measure effectiveness of the messages, the distribution system, and the reach to consumers. In addition, evaluation of the effectiveness of implementation activities in changing dietary behavior and the effects of changed behavior on nutritional status and health are necessary. For evaluation to be possible, it will be essential to maintain an adequate national nutrition monitoring system. Food and nutrient databases must be complete and up-to-date. National data on food consumption, food expenditure, diet-health knowledge, and health status need to be collected regularly. Making data available in a timely manner to researchers at universities and other private sectors would encourage more policy-oriented research and evaluation, thus adding to the information base. • A multi-channel roll-out with varied government and community-based agencies/media/trade organizations/industry partners/CDC and schools is needed. Professional and community organizations should include, but not be limited to: the American Dietetic Association, American Public Health Association, American Medical Association, American Heart Association, Society for Nutrition Education, School Nutrition Association, Boys and Girls Clubs, and Action for Healthy Kids. A concerted outreach and marketing campaign through Cooperative Extension, public schools, WIC, Head Start and public health will “saturate” the public sector. All government agencies should collaborate and provide a joint announcement of the new system (USDA/DHHS). Industry should be encouraged to participate. The guidelines together with the Food Guidance System should be introduced at nutrition, medical and science meetings over a two-year period. • To disseminate the Guidelines and new Food Guidance System consistently over time, spokespersons or intermediaries need to be available to conduct trainings and answer questions from the industry, medical professional groups, i.e., physicians, dietitians, nurses, dentists, and allied health professionals, and consumers. • The Guidelines and new Food Guidance System can be marketed through all national, state and local newspapers and TV, including targeting culinary programs/chefs on food channel programs, radio and cable stations and on the web. Trade organizations should be encouraged to broadly disseminate the guidelines and new system. A roll-out during March 2005, National Nutrition Month, would be very effective. • The Transtheoretical Model should be the basis for the public awareness campaigns. This means that local people should coordinate with food donation agencies, supermarkets and other food outlets to assure that the recommended foods are available to the people who will receive the messages. • Training professionals on the guidelines and new system and providing supporting educational materials for school-age youth and adults is critical. In addition, guidelines for industry and consumer use are important. Industry should be encouraged to use the system for promotion of healthy eating. References: Bandura A. 1986. Social Foundations of Thought and Action: A Social Cognitive Theory. Englewood Cliffs, NJ: Prentice Hall Barlow CE, Kohl HW3rd, Gibbens LW, Blair SN. 1995. Physical fitness, mortality and obesity. Int. J. Obesity Relat. Metab. Disord. 19 (suppl. 4): S41-44. Berg FM. 2004. Underage & Overweight: America’s Childhood Obesity Crisis: What every family needs to know. New York: Hatherleigh Press. Bronner, Y. 2004. Food Guide Pyramid: What’s New? Address given to the Colegio de Nutricionistas y Dietistas in Río Grande, Puerto Rico, August 27, 2004. Fisher JO, Birch LL. 1999. Restricting access to palatable foods affects children’s behavioral response, food selection, and intake. Am. J. Clin. Nutr. 69(6): 1264-72. Glanz K, Rimer, BK, Lewis FM., 2002. Health Behavior and Health Education: Theory, Research, and Practice. 3rd ed. Haines PS. 2000. Consumer trends in fats and sweets: Policy options for dietary change. J. Food Distribution Res. 31(1): 32-38. Johnson C. 2001. Self-Esteem Comes in All Sizes: How to be Happy and Healthy at Your Natural Weight. Carlsbad, CA: Gurze Books. Lee CD, Blair SN, Jackson AS. 1999. Cardiorespiratory fitness, body composition, and all-cause and cardiovascular disease mortality in men. Am. J. Clin. Nutr. 69(3):373-80. Miller WC. 1997. Health promotion strategies for obese patients. Healthy Weight J. 11: 47-48. Prochaska JO, Velicer WF. 1997. The transtheoretical model of health behavior change. Am. J. Health Promotion 12(2): 38-48 Puhl RM, Brownell KD. 2003. Psychosocial origins of obesity stigma: toward changing a powerful and pervasive bias. Obesity Reviews 4(4):213-27 Puhl RM, Schwartz MB. 2003. If you are good you can have a cookie: How memories of childhood food rules link to adult eating behaviors. Eat. Behav. 2003. 4(3): 283-93 Putnam J, Allshouse J, Kanter LS. 2002. U.S. Per Capita Food Supply Trends: More Calories, Refined Carbohydrates and Fats. Food Review 25(3): 2-15. (Economic Research Service). USDA. 2004. National Nutrient Data Base for Windows. Standard Reference Release 17. Section on fats and oils
Submission Date 9/26/2004 10:00:00 PM
Author Society for Nutrition Education

   Other
Summary
Comments Dietary Guidelines 2005 Your 2000 dietary guidelines for americans state"go easy on foods high in fat or sugars" and you go into percentages of sat. fat intakes based on different caloric diets. It also says to limit use of trans fatty acids. i would like to see the guidelines be more specific as far as partially hydrogenated oils go. These oils are in such a large % of the foods taht people consume. consumers should be aware that foods on shelves in boxes should be cautiously looked over as this is where these hydrogentaed oils are found, and these may increase their risk for heart disease and cancer. I am also concerned with flavor enhancers such as M.S.G. and things on the GRAS list that consumers are probably consuming high amounts of, not to mention sugar substitues which should not exceed the average daily intake. People are counting calories, or carbs, or fats, but should also know that these are important things to be aware of.
Submission Date 9/26/2004 9:10:00 PM
Author Anonymous

Summary In the greater societal context, what's better for the individual in terms of vegetarian foods is also what's best for the health of the country and planet.
Comments In the greater societal context, what's better for the individual in terms of vegetarian foods is also what's best for the health of the country and planet. The key characteristics are natural, healthy, sustainable, and economically viable. We must look at and re-assess our system of food production with its enormous inefficiencies and the tremendous toll it takes on people, our resources, and the living world around us. The numbers are truly staggering in terms of land use, water required, energy used, grains to animal food conversion, and so on.
Submission Date 9/21/2004
Author International Vegetarian Union

   Process
Summary We are pleased that both HHS and CNPP are conducting consumer research to identify messages that will resonate with consumers.
Comments We are pleased that both HHS and CNPP are conducting consumer research to identify messages that will resonate with consumers. It is vital that these messages are positive and consumer-tested before the final guidelines are issued. We also urge the departments to work with the Dietary Guidelines Alliance, an organization which is comprised of industry and government agencies. The Dietary Guidelines Alliance’s mission is to bring the guidelines and graphic to the consumer in a meaningful way.
Submission Date 9/21/2004
Author The Foundation for the Advancement of Grain Based Foods

   Other
Summary GMA stands willing to partner with HHS and USDA to motivate Americans to step on to the path of better health by following the Dietary Guidelines
Comments As the leading voice of the food and beverage industry in the obesity and nutrition debate, GMA stands willing to partner with HHS and USDA to motivate Americans to step on to the path of better health by following the Dietary Guidelines. We hope to establish a public/private partnership soon so that GMA and – most especially – its member companies can help disseminate the messages of Dietary Guidelines when they are announced in January.
Submission Date 9/21/2004
Author Grocery Manufacturers of America

Summary Most Americans don’t eat the way the Committee has recommended they eat. We believe Americans will begin to adopt the recommendations to eat more whole grains, more beans, more fruits and vegetables, more fish, but only if they can also use the recommendations to prepare meals that they enjoy.
Comments GMA applauds the work of the Committee, but its report falls short in at least one area. Most Americans don’t eat the way the Committee has recommended they eat. In fact, it is very likely that Americans will find these Guidelines to be both limiting and proscriptive because of the limitation on using sugars and fats for added flavor. For example, the Committee describes discretionary calories as the sauce used to flavor a vegetable stir-fry. Whereas most consumers think of discretionary calories as being the fortune cookies they have for dessert. We believe Americans will begin to adopt the recommendations to eat more whole grains, more beans, more fruits and vegetables, more fish, but only if they can also use the recommendations to prepare meals that they enjoy.
Submission Date 9/21/2004
Author Grocery Manufacturers of America

Summary The Report is inconsistent in its dietary advice to consumers.
Comments The Report is inconsistent in its dietary advice to consumers. On the one hand, the Committee acknowledges the nutrient contribution of pre-sweetened cereals and flavored milks. However, in the case of vegetables and beans, which are some of the most nutrient-dense foods, the Committee has effectively limited the acceptable choices to steamed vegetables or plain beans without added fats, sodium and/or sugar for added flavor. Additionally, the Report describes low-fat soups as a means to reduce caloric consumption in the meal. Yet later, the Report warns consumers about the sodium content of soups. And these are just a few examples of the Report’s inconsistencies.
Submission Date 9/21/2004
Author Grocery Manufacturers of America

   Process
Summary We are concerned with the process used by the Advisory Committee. It should have been evidence-based, not expert-based.
Comments That the Advisory Committee report is not evidence-based and does not address health outcomes of its recommended intervention on salt should be embarrassing to the Secretaries. Internationally, evidence-based medicine is the accepted standard. It is defined by the Cochrane Collarboration around the world and promoted within HHS by the U.S. Preventive Services Task Force. The scientifically-rigorous methods of the Cochrane Collaboration were not adopted by the Advisory Committee. As a result, the experts on your Advisory Committee reached very different conclusions than those of the evidence based reviews. The Cochrane Collaboration finds no evidence supporting universal sodium reduction. The U.S. Preventive Service of HHS agrees: there is no scientific evidence that justifies a population recommendation on salt.
Submission Date 9/21/2004
Author Salt Institute

Summary We do not believe that some of the key messages are fully supported by the available science.
Comments We do not believe that some of the key messages are fully supported by the available science.
Submission Date 9/21/2004
Author National Food Processors Association

   Children
Summary Adding milk to the current recommendations for fruits, vegetables and grains is strongly supported by the science – as the committee’s report makes clear – and is necessary to address the chronic under-consumption of milk at all age levels, particularly among children and adolescents in their critic
Comments The committee has improved the existing dietary guidelines by one of its nine major messages urging Americans to “increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products.” Adding milk to the current recommendations for fruits, vegetables and grains is strongly supported by the science – as the committee’s report makes clear – and is necessary to address the chronic under-consumption of milk at all age levels, particularly among children and adolescents in their critical bone-building years.
Submission Date 9/21/2004
Author National Milk Producers Federation

   Other
Summary The government should step in and teache people that the quality of their food must change,
Comments Until the government steps in and teaches people that the quality of their food must change, that they must re-train their palate to adjust to the flavor of real food, as opposed to food that is artificially flavored and chemically enhanced, they will continue to gain weight and be subject to the numerous chronic diseases outlined in your study. It is not enough to say that food must be “nutrient rich”; in fact it is misleading. The large food companies will use this wording to entice consumers to buy enriched and refined food products that are fundamentally unhealthy. Just look at the results of the low calorie, low fat, and low carb crazes. The products that these crazes spawned are usually loaded with chemicals and flavor enhancing ingredients that have nothing to do with real food. A healthy diet is not about weighing, measuring, or counting calories, points, grams and carbs of the same old food. As your study points out, too many people are starving their bodies while they are stuffing their faces with the wrong foods, that make them fat, sick, and subject to a myriad of preventable diseases. I know for a fact, if you improve the quality of your food, the quantity takes care of itself.
Submission Date 9/21/2004
Author Anonymous

   Children
Summary the hormones, preservatives, pesticides, and steroids that are present in many of our foods today are especially dangerous to our children.
Comments I would also add that the hormones, preservatives, pesticides, and steroids that are present in many of our foods today are especially dangerous to our children.
Submission Date 9/21/2004
Author Anonymous

   Other
Summary I believe our government’s greatest responsibility in giving dietary guidelines to the public is to present dietary facts truthfully and with utmost clarity, so the public is no longer confused and therefore, easily misled and manipulated by profit-motivated food industries, fad diet authors, and il
Comments I believe our government’s greatest responsibility in giving dietary guidelines to the public is to present dietary facts truthfully and with utmost clarity, so the public is no longer confused and therefore, easily misled and manipulated by profit-motivated food industries, fad diet authors, and ill-advised diet trends.
Submission Date 9/21/2004
Author Anonymous

Nutrient Intake
   Dietary Patterns
Summary NFPA supports recommendations regarding increased consumption of fruits, vegetables and whole grains. I
Comments NFPA supports recommendations regarding increased consumption of fruits, vegetables and whole grains. It is important to eat a variety of fruit, vegetable and whole grain foods, in all forms, including juices and juice beverages, vegetables in sauces, and flavored whole grain foods. Addition of sugars, fats or salt to processed fruit, vegetable, and grain products helps to improve palatability, and can promote their consumption in the context of a well-balanced, calorie-controlled diet.
Submission Date 9/21/2004
Author National Food Processors Association

   Nutrient Goals
Summary the guidelines, as written, will only reinforce the tendency for Americans to eat processed foods, high in sugar, dairy products, and meat.
Comments . I learned that eating a plant-based diet full of organic fruits, vegetables, whole grains, and legumes is by far the healthiest way you can eat. That is why I feel that the guidelines, as written, will only reinforce the tendency for Americans to eat processed foods, high in sugar, dairy products, and meat.
Submission Date 9/21/2004
Author Anonymous

   Dietary Patterns
Summary The food supply, with a few exceptions, can meet nutrient needs and does not need fixing – it’s our diets, eating behaviors and levels of activity that need work.
Comments Finally, it is imperative to emphasize to consumers the importance of choosing nutrients “primarily from foods.” There are inherent dangers in relying on unnecessary fortification and supplements for nutrient intake, including bioavailability issues, the toxicity of certain nutrients over upper-tolerable levels, and the loss of naturally occurring compounds found in food that may have added beneficial effects (such as anti-cancer compounds found in dairy products). The food supply, with a few exceptions, can meet nutrient needs and does not need fixing – it’s our diets, eating behaviors and levels of activity that need work.
Submission Date 9/21/2004
Author National Dairy Council

   Special Population Groups
Summary not all adolescents and teens in their peak bone-building years are meeting 100% of the calcium and potassium recommendations in the proposed food patterns. The research shows that these individuals cannot afford to miss out on key nutrients for bone growth and would be better served with a recomme
Comments not all adolescents and teens in their peak bone-building years are meeting 100% of the calcium and potassium recommendations in the proposed food patterns. The research shows that these individuals cannot afford to miss out on key nutrients for bone growth and would be better served with a recommendation for an additional, or fourth, serving of dairy foods.
Submission Date 9/21/2004
Author National Dairy Council

   Nutrient Goals
Summary dairy products contribute important amounts of many essential nutrients, including four nutrients that have a high prevalence of inadequate dietary intake in the population: calcium, potassium, magnesium and vitamin A.
Comments With more intense calorie restrictions, it will be even more important to communicate how to choose foods that are naturally rich in nutrients and to consider a food’s complete nutrient package, not single nutrients. The Committee’s analysis of the scientific evidence shows that dairy products contribute important amounts of many essential nutrients, including four nutrients that have a high prevalence of inadequate dietary intake in the population: calcium, potassium, magnesium and vitamin A. Individuals substituting high-calcium non-dairy sources for dairy products may put themselves at increased risk of inadequacy in meeting the “shortfall” nutrients identified by the Committee.
Submission Date 9/21/2004
Author National Dairy Council

   Minerals
Summary Calcium fortified products treat the symptom of low calcium intake, but do not treat the problem—which is a poor dietary pattern.
Comments Calcium fortified products treat the symptom of low calcium intake, but do not treat the problem—which is a poor dietary pattern. In addition, because there is no standard of identity for soy beverages this shortfall could be worse and soon-to-be published data indicate that many calcium fortified products have lower bioavailability or are manufactured in a way that results in the calcium precipitating out to the bottom of the container.
Submission Date 9/21/2004
Author National Dairy Council

   Dietary Patterns
Summary Each food group offers different nutrients, and individuals should be advised to consume a variety of foods within and among all five nutrient-bearing food groups.
Comments As the report indicates, many Americans are consuming too many calories but not getting an adequate supply of nutrients each day. Each food group offers different nutrients, and individuals should be advised to consume a variety of foods within and among all five nutrient-bearing food groups.
Submission Date 9/21/2004
Author National Cattleman's Beef Association

Summary Major health issues are diet related and the solution to illness can be found in nutrition. Americans spend over 90 percent of their food dollars on these processed foods - foods that contain high levels of refined sugars, high fructose corn syrup, refined polyunsaturated oils and trans fatty acids
Comments According to a USDA study on nutrition, major health issues are diet related and the solution to illness can be found in nutrition. The real potential from improved diet is preventative in that it may defer or modify the development of a disease state. These findings are corroborated by Surgeon General C. Everett Koop’s 1988 Report on Nutrition and Health. Fifty years ago, grocery stores stocked about 200 items. Seventy percent of those were grown, produced or processed within a 100-mile radius of the store. Today, the average supermarket carries 50,000 food items or more; most of these foods are highly processed and refined, most of which are transported thousands of miles to their final destination. Americans spend over 90 percent of their food dollars on these processed foods - foods that contain high levels of refined sugars, high fructose corn syrup, refined polyunsaturated oils and trans fatty acids, excitotoxins such as MSG and aspartame, as well as highly processed protein isolates. The reduction in nutrients in these foods requires that we eat more to satisfy the body’s nutritional requirements.
Submission Date 9/21/2004
Author Weston A Price Foundation

Summary The dietary patterns shown in the Report’s tables are overly restrictive because they are based upon a sedentary lifestyle.
Comments The dietary patterns shown in the Report’s tables are overly restrictive because they are based upon a sedentary lifestyle. If Americans should be striving to improve their diets, then why would the final Report neglect to incorporate physical activity in its tables? Instead, the Report’s recommendations should base dietary patterns on – at a minimum – a “low active” level of physical activity, thereby illustrating a healthy lifestyle that incorporates both improved diets and regular physical activity.
Submission Date 9/21/2004
Author Grocery Manufacturers of America

Summary Vegetarian foods offer powerful advantages and study after study as well as the most current and comprehensive nutritional science have shown, and proven, the remarkable health benefits of a well-planned vegetarian diet.
Comments Vegetarian foods offer powerful advantages and study after study as well as the most current and comprehensive nutritional science have shown, and proven, the remarkable health benefits of a well-planned vegetarian diet. Animal products are the main source of saturated fats, the only source of cholesterol in the diet, and contain no fiber which we know helps to reduce cholesterol levels. We claim that a well-planned, low-fat vegetarian diet - actually a vegan diet where no animal products whatsoever are consumed - is the best diet for humans. Preventing and actually reversing heart disease, preventing certain cancers, preventing and reversing diabetes, lowering blood pressure, and helping manage weight are some of the successes of such a diet, and there are many more.
Submission Date 9/21/2004
Author International Vegetarian Union

Summary Support for vegetarian diets is established and strong. The Dietary Guidelines for Americans must emphasize plant foods and alternatives to meat and dairy more prominently
Comments the USDA in its 5th ed of the Dietary Guidelines for Americans in 2000, states: "Vegetarian diets can be consistent with the Dietary Guidelines for Americans, and meet Recommended Dietary Allowances for nutrients." They give recommendations on meeting nutrient requirements for those who choose to avoid all or most animal products. The Unified Dietary Guidelines developed by the American Cancer Society, the American Heart Association, the National Institutes of Health, and the American Academy of Pediatrics call for a diet based on a variety of plant foods, including grain products, vegetables, and fruits to reduce the risk of major chronic diseases. The Dietary Guidelines for Americans must emphasize plant foods and alternatives to meat and dairy more prominently. As in the case of past emphases in the basic food groups of specific nutrients like calcium and protein, represented by the Milk (etc) Group and Meat (etc) Group, the updated Guidelines should reflect a broader view of a Calcium (etc) Group or the Protein (etc) Group. Not only can plant products provide calcium and protein along with all the nutrients needed, they are typically lower in saturated fats and contain no cholesterol. Plant foods are then indeed better sources. A broad variety of plant foods consisting of whole grains, whole fruits, vegetables, legumes, nuts, seeds, and fortified cereals can ensure a healthy, well-balanced diet. An emphasis on consuming a wide variety of plant foods would take care of all nutrients being included in the diet. The key is removing the emphasis on animal derived foods in favor of plant foods, with a well-represented vegan diet being optimal. Eating patterns are changing and the diets of a great many are more plant-based than a decade ago, including vegetarians (with a proportionately high % of vegans), and many quasi-vegetarians. There is tremendous interest around vegetarianism and the USDA guidelines must address the needs of those moving away from animal products. This is consistent with the major messages of the Advisory Committee, but with additional and clear guidance that is more comprehensive in terms of alternatives to animal foods and cow's milk.
Submission Date 9/21/2004
Author International Vegetarian Union

   Minerals
Summary Many plant-based sources of calcium exist. Iron is plentiful in beans, whole grains, and fruits.
Comments Many plant-based sources of calcium exist. Examples are dark leafy greens like collard greens, mustard greens, turnip greens, kale, broccoli; fortified soy or rice milk, blackstrap molasses; tofu processed with calcium sulfate, and tempeh; and also fortified juices like orange, cranberry, or apple juice. The more extensive range of dietary sources of calcium from plant foods would increase intakes of boron, vitamin K, and magnesium, helping reduce the risk of osteoporosis. Animal products being acidic force calcium out of the body and so promote bone loss. Iron is plentiful in beans, whole grains, and fruits.
Submission Date 9/21/2004
Author International Vegetarian Union

   Nutrient Goals
Summary The nutritional benefits of eating breakfast, particularly a breakfast with ready-to-eat (RTE) cereal, should be emphasized. The major emphasis of the scientific evaluation of breakfast focused on its relationship to Body Mass Index (BMI) but the positive nutrient contributions from breakfast and i
Comments GMI believes that the nutritional benefits of eating breakfast, particularly a breakfast with ready-to-eat (RTE) cereal, should be emphasized. The Advisory Committee overlooked the important nutrient contribution of RTE cereal (and breakfast) while focusing on the contributions of various food groups in this section of the Report, and on the relationship between breakfast consumption and BMI in another section. Studies show that adults and children who frequently consume RTE cereal have higher intakes of fiber and several essential vitamins and minerals than those who don’t ,2,3,4,5. Other studies indicate that skipping breakfast (any type) lowers the nutritional quality of diets 6,7.
Submission Date 9/27/2004
Author General Mills

   Special Population Groups
Summary I commend the committee for its science-based approach and I support the report’s message that dietary guidance should recognize populations at risk, such as adolescent girls and young women, and not just nutrients of concern. My research with young women shows they tend to give up entire food grou
Comments I support the report’s message that dietary guidance should recognize populations at risk, such as adolescent girls and young women, and not just nutrients of concern. I couldn’t agree more. As you report indicates, some women are especially at risk for micronutrient inadequacies. The data indicate that 7.8 million adolescents females and women of childbearing age are affected by iron deficiency, and there is a 38 percent probability that women over age 19 have inadequate zinc intakes. As we know, both iron and zinc are critical for supporting healthy growth, optimal cognitive development, and normal energy levels in young women. In several studies, we examined the relationship of increased exercise to iron and zinc status in young women. We conducted this research because so many women decrease red meat consumption to decrease fat intake, and because public health recommendations highlight participation in moderate intensity exercise. My research with young women shows they tend to give up entire food groups in their attempt to achieve energy balance or lose weight. In particular, they give up animal products such as meat and dairy, which can lead to nutrient inadequacies. Most of the women who were not consuming red meat in my studies had reached iron deficiency anemia. By adding small to moderate portions of lean read meat to their diets, these women met their daily requirements for iron and zinc, they were no longer iron deficient, and they experienced improved physical performance. These studies confirm the need for strong and clear dietary guidance messages about choosing nutrient dense foods from all five food groups and reaching subpopulations, like young women, with these messages.
Submission Date 9/21/2004
Author Purdue University

   Nutrient Goals
Summary As the committee’s report details, in addition to calcium, the science is clear that milk and milk products are associated with adequate consumption of potassium, magnesium, zinc, iron, riboflavin, folate, vitamin A, and vitamin D.
Comments As the committee’s report details, in addition to calcium, the science is clear that milk and milk products are associated with adequate consumption of potassium, magnesium, zinc, iron, riboflavin, folate, vitamin A, and vitamin D. Of these important nutrients, calcium, potassium, magnesium and vitamin A are all identified by the committee as “shortfall” nutrients – , that is, they are likely to be consumed by the general public in amounts low enough to be of concern.
Submission Date 9/21/2004
Author National Milk Producers Federation

   Dietary Patterns
Summary Explicitly endorse vegetarianism as the healthiest lifestyle available rather than just stating that vegetarian diets can be consistent with the Guidelines
Comments Research has conclusively shown that serious health risks such as heart disease, cancer, diabetes, and stroke, among others, can be significantly reduced through vegetarianism. Furthermore, the consumption of animal products has been scientifically linked to life-threatening conditions. To mention just a few of the many studies supporting the health benefits of vegetarian diets: A 20-year project following 27,529 subjects concluded that consumption of animal products was positively associated with mortality due to coronary artery disease, diabetes, and cancers of the colon, prostate, and ovary. Another study of 34,192 Californians reported that the lifetime risk of ischemic heart disease is 37 percent greater for nonvegetarians than for their vegetarian counterparts, and that incidence of diabetes mellitus, hypertension, arthritis, and cancers of the colon, prostate, and bladder were significantly higher in nonvegetarians. At the University of Western Australia, researchers found consumption of meat to be associated with increased risk for all strokes and for all first-ever strokes. Research at the Harvard School of Public Health found, “[G]reater dietary intake of certain meats and fats was associated with a higher risk of non-Hodgkin’s lymphoma.” And a recent study revealed “[S]ubjects who ate meat were more than twice as likely to become demented as their vegetarian counterparts” and “there was a trend toward delayed onset of dementia in vegetarians.” Vegetarianism has also been shown to help overcome and prevent the onset of obesity. Study after study shows that vegetarians are leaner, as measured by body-mass index, than meat-eaters. , , , , , , , , One study, published in the New England Journal of Medicine, found that the average vegetarian weighed significantly less than the average meat-eater. In a study in the British Medical Journal, researchers reported that out of 21,105 subjects, vegan men weighed 5.9 kilograms less and vegan women 4.7 kilograms less than their meat-eating counterparts. The authors write, “these data suggest that a meat-free diet is associated with a low prevalence of obesity.” In another study, “researchers have found that, on average, people on vegetarian diets are a good 10 percent leaner than omnivores.” Brown, et al., concluded that vegetarians had a higher probability of not being overweight than meat-eaters. And the American Dietetic Association states that “vegetarians, especially vegans, often have weights that are closer to desirable weights than do nonvegetarians.” For those working to overcome obesity, “it is much easier to lose weight on a plant-centered diet than on a meat-centered diet. Many people, when first adopting a vegetarian diet, lose several pounds without trying and without going hungry.” Another medical doctor reports, “[W]hen meat-eaters switch to vegetarian diets, they find that the more overweight they were, the more weight they lose.” Furthermore, vegetarian diets contain all the nutrients necessary for good health. In fact, recent research published in the American Journal of Clinical Nutrition found that “populations of vegetarians living in affluent countries appear to enjoy unusually good health,” and that this is due to an “adequate consumption of beneficial dietary factors – rather than just the avoidance of harmful factors [referring to meat]–including an abundance of fruits, vegetables, and whole grains, and regular consumption of vegetable oils, including those from nuts.” Given that vegetarian diets 1) do not inherently lack nutrients that cannot be obtained from plant-based foods or supplements, 2) have been shown to reduce the risks for disease, and 3) are less susceptible to food-borne illnesses, there is no reason not to recommend vegetarianism as the healthiest lifestyle available. We therefore urge you to acknowledge the vast benefits of vegetarianism and include a section that explicitly endorses it as a healthy lifestyle.
Submission Date 9/27/2004
Author People for the Ethical Treatment of Animals (PETA)

   Minerals
Summary When eating out while traveling, or at theme parks, restaurants do not offer salt-free items for those of us having to watch salt intake for high blood pressure. Salt content of items is not readily available either.
Comments salt information when eating out
Submission Date 9/22/2004 10:23:00 AM
Author Anonymous

   Dietary Patterns
Summary The major public health problem facing the Americans is overweight and obesity. Therefore, rather than wording guidelines in a way that could be misconstrued to mean increase food intake, the concept of substitution and displacement of some foods with others should be included.
Comments As indicated in the report, and in two guidelines “Control calorie intake to manage body weight” and “Be physically active every day”, the major public health problem facing the Americans is overweight and obesity. Therefore, rather than wording guidelines in a way that could be misconstrued to mean increase food intake, the concept of substitution and displacement of some foods with others should be included. Specific suggestions; • “Increase daily intake of fruits and vegetables, whole grains, and nonfat and low-fat milk and milk products” should be reworded to read; “Substitute a variety of whole fruits and vegetables for other foods” • “Consume a variety of foods within and among the basic food groups while staying within energy needs” includes the concept of limiting total energy intake but does not provide specific guidance to ensure that the proper substitutions will be made. Since there are data to suggest that greater variety within certain food groups increases energy intake (with the exception of fruits and vegetables), whether due to sensory-specific-satiety or shear volume, the intent of the guidelines might be better accomplished by providing more specificity in the others (see comments on other specific guidelines).
Submission Date 9/22/2004 2:33:00 PM
Author from Boston, MA

Summary
Comments
Submission Date 9/22/2004 5:02:00 PM
Author Floridia Department of Elder Affairs

Summary The recommendation should be: Increase the consumption of fruits, vegetables, whole grains, cereal brans, and non-fat or low-fat milk and milk products. Ensure the inclusion of fiber rich foods such as bran containing products in the Nine Key Messages of the Dietary Guideline recommendations.
Comments UNIVERSITY OF ILLINOIS AT URBANA-CHAMPAIGN Elvira de Mejia Department of Food Science and Human Nutrition September 17, 2004. College of Agricultural, Consumer and Environmental Sciences 228 ERML, MC-051 1201 W Gregory Drive Urbana, IL 61801 (phone) 217-244-3196 (fax) 217-265-0925 (email) edemejia@uiuc.edu 2005 Dietary Guidelines Advisory Committee c/o Ms. Kathryn McMurry HHS Office of Disease Prevention and Health Promotion 200 Independence Avenue, SW, Room 738-G Washington, D.C. 20201 RE: Comments to 2005 Dietary Guidelines Dear Committee Members: I applaud your efforts in revising the 2005 Dietary Guidelines for Americans. I am submitting these comments regarding the number 4 key message on “Increase the consumption of fruits, vegetables, whole grains, and non-fat or low-fat milk and milk products.” Based on the scientific and epidemiological information presented by the Committee, I believe that the recommendation should be “Increase the consumption of fruits, vegetables, whole grains, cereal brans, and non-fat or low-fat milk and milk products” for the following reasons: 1) Over 90% of Americans do not meet the dietary fiber intake recommendations established by the Institute of Medicine (IOM), National Academy of Sciences. Omission of cereal bran from the Dietary guidelines will make it more difficult for Americans to achieve this IOM recommendation. 2) Cereal bran, due to its significantly lower moisture content than fruits and vegetables, is a more concentrated source of dietary fiber, antioxidants and certain micronutrients. Thus, bran is a major contributor to the various health benefits that whole grain foods offer. For example, researchers have found that the inverse association of bran and CHD is stronger than that of whole grain (1-3). 3) Cereal bran or bran containing products also have an important effect on laxation and prevention of diverticulosis/diverticulitis (4-5) as well as on other chronic diseases such as diabetes (6-8) and cancer (9-11). The recommendation of whole grain alone will not be enough to help Americans fight against these health conditions if bran, or bran containing products, is not part of the dietary guidelines. 4) If bran foods are omitted from the Dietary Guideline recommendations, American’s fiber consumption levels may not significantly improve. It is also possible that without specific mention of “bran” or “bran containing foods” in the key messages, the consumption of healthy grain products (“bran containing foods” and/or fiber rich foods) which are concentrated sources of fiber and antioxidants) may even decrease and not reach the expected grain food consumption of three servings per day. Thus, it is critical for the Committee to ensure the inclusion of fiber rich foods such as bran or bran containing products in the Nine Key Messages of the Dietary Guideline recommendation to make sure that Americans obtain the recommended level of fiber intake. Conclusion I believe that the number 4 key message of Dietary Guidelines 2005 should be “Increase the consumption of fruits, vegetables, whole grains, cereal brans, and non-fat or low-fat milk and milk products”. Respectfully. Elvira de Mejia Elvira de Mejia, Ph.D. Assistant Professor Department of Food Science & Human Nutrition University of Illinois at Urbana-Champaign 228 ERML, MC-051 1201 W. Gregory Drive Urbana, IL 61801 Phone: (217) 244-3196; Fax: (217) 265-0925; edemejia@uiuc.edu References 1) Mozaffarian D, Kumanyika S, et al. (2003). Cereal, fruit, and vegetable fiber intake and the risk of cardiovascular disease in elderly individuals. JAMA 289: 1659-1666. 2) Liu S, Manson JE, et al. (2000). Whole grain consumption and risk of ischemic stroke in women. A prospective study. JAMA 284: 1534-1540. 3) Jensen MK. Rimm EB, et al. (2004). Intake of whole grains, bran and germ and risk of coronary heart disease. AHA Annual Meeting. March3-6, 2004, San Francisco, CA. 4) Cummings JH, Branch W, Jenkins DJ, Southgate DA, Houston H, James WP. (1978). Colonic response to dietary fibre from carrot, cabbage, apple, bran. Lancet 7; 1(8054): 5-9. 5) Kelsay JL. (1978). A review of research on effects of fiber intake on man. Am J Clin Nutr. 31(1): 142-59. 6) Montonen J, Knekt P, et al. (2003). Whole-grain and fiber intake and the incidence of type 2 diabetes. Am J Clin Nutr 77: 622-629. 7) Jenkins DJA, Kendall CWC, et al. (2002). Effect of wheat bran on glycemic control and risk factors for cardiovascular disease in type 2 diabetes. Diabetes Care 25: 1522-1528. 8) Fung TT, Hu FB, et al. (2002). Whole-grain intake and the risk of type 2 diabetes: A prospective study in men. Am J Clin Nutr 76: 535-540. 9) Jacobs DR, Slavin J, et al. (1995). Whole grain intake and cancer: A review of the literature. Nutr Cancer 24: 221-229. 10) Tuyns AJ, Kaaks R, et al. (1988). Colorectal cancer and the consumption of foods: A case-control study in Belgium. Nutr Cancer 11: 189-204. 11) Slattery ML, Curtin KP, et al. (2004). Plant foods, fiber and rectal cancer. Am J Clin Nutr 79: 274-281.
Submission Date 9/22/2004 3:45:00 PM
Author Anonymous

Summary Since there are data to suggest that greater variety within certain food groups increases energy intake (except fruits and vegetables), either due to sensory-specific-satiety or shear volume, the intent of the guidelines might be better accomplished by providing more specificity in other guidelines.
Comments “Consume a variety of foods within and among the basic food groups while staying within energy needs” includes the concept of limiting total energy intake but does not provide specific guidance to ensure that the proper substitutions will be made. Since there are data to suggest that greater variety within certain food groups increases energy intake (with the exception of fruits and vegetables), whether due to sensory-specific-satiety or shear volume, the intent of the guidelines might be better accomplished by providing more specificity in other guidelines (see comments on other specific guidelines).
Submission Date 9/22/2004 2:42:00 PM
Author from Boston, MA

   Minerals
Summary nutrition is individualized subgroups thrive on carbohydrates and low protein others thrive on high protien low carb diets Unless we honor that indidivudlity and adopt a common test we will be overdosing some and underdosing others too much of these we can create other health problems
Comments Research has shown that one size all nutrition does not work. We are not created the same and we have different biochemical needs. I have two points to make - #1 Look at the headlines of the diet industry and two distinctly different camps emerge. One low carb and high protein Atkins and South Beach Diets) and the other, an opposite approach of High Carbs and low protein ( Pritikin and Ornish), Both have scientific data to bolster their diets effectiveness, If one looked beyond the claims and studied the individuals involved it becomes obvious that both diets are correct. It depends on the individual's biochemistry. There are subgroups of individuals that thrive on high carbs and low protein and other subgroups that thrivs on the opposite - high protein and low carbs. We have develop a simple inexpensive test to help individuals determine which group they fall under. Our research has shown us that some individuals have too much calcium and niacinemide, and folic acid - contrary to popular thinking - however these are subgroups out of the total population - other subgroups exist that need more of these nutrients. Whether you receive to much or too little of certain essential supplements teh outcome isnot good for ones health
Submission Date 9/21/2004 4:21:00 PM
Author Individual Health Solutions

   Vitamins
Summary too much or not enough supplements can cause harm in different individuals without individlized tests we not not know each persons needs
Comments Research has shown that one size all nutrition does not work. We are not created the same and we have different biochemical needs. I have two points to make - #1 Look at the headlines of the diet industry and two distinctly different camps emerge. One low carb and high protein Atkins and South Beach Diets) and the other, an opposite approach of High Carbs and low protein ( Pritikin and Ornish), Both have scientific data to bolster their diets effectiveness, If one looked beyond the claims and studied the individuals involved it becomes obvious that both diets are correct. It depends on the individual's biochemistry. There are subgroups of individuals that thrive on high carbs and low protein and other subgroups that thrivs on the opposite - high protein and low carbs. We have develop a simple inexpensive test to help individuals determine which group they fall under. Our research has shown us that some individuals have too much calcium and niacinemide, and folic acid - contrary to popular thinking - however these are subgroups out of the total population - other subgroups exist that need more of these nutrients.
Submission Date 9/21/2004 4:23:00 PM
Author Individual Health Solutions

   Dietary Patterns
Summary Suggest changing guideline to say "Consume a variety of foods from the 5 basic food groups."
Comments Suggest changing guideline to say "Consume a variety of foods from the 5 basic food groups." It wording is much easier to understand, and it reinforces the idea that intake from all of the food groups is important- so that one group is not overemphasized/or omitted.
Submission Date 9/23/2004 12:11:00 PM
Author OSU Extension Program- Cleveland, OH

   Nutrient Goals
Summary Avoid all highly processed food, particularly altered fats, white sugar & flour, high fructose corn syrup. Advocate traditional foods that give good health: whole grain breads, animal fats, cold pressed coconut & olive oils, organic vegetables & fruits, & especially full-fat dairy.
Comments Dear Committee, I urge you to do our children a favor, and abandon calls for low-fat milk, low-fat cheese & yogurt, low-fat anything. Children need full fat food to develop in mind and body. Consider how many children are depressed, even suicidal today. Consider how many are overweight, diabetic, even growing cancers in their young bodies. Children of yesteryear were not so. They had healthy bodies, able to withstand disease. They ate differently. All of us, but particularly the young, need full fat food, and this fat should not industrially processed vegetable oils. Butter had been the fat of choice for generations before us. Not only is there nothing wrong with butter, but the substitution of highly processed fats and margarine have taken us all down the road to disease. Heart disease is a new phenomenon in the history of mankind. Nor is the wrong fat the only culprit. Equally important is the avoidance of all highly processed food, particularly white sugar, white flour, and high fructose corn syrup. You must advocate the foods that give good health: whole grain breads and cereals, animal fats, cold pressed coconut & olive oils, organic vegetables and fruits, and especially full-fat dairy products. It is important that these foods should be as clean and unprocessed as possible. A pyramid is not an especially good illustration, as not all bodies are identical in their requirements--some do better on more carbohydrates; some do worse. Number of servings is not useful. Quality is key. This will go a long way toward restoring the health and well-being of our most important national commodity, our children. Jeanne Underhill 610 S.W. Atlantic Dr. Lantana, Fl 33462 Dear Committee, I urge you to do our children a favor, and abandon calls for low-fat milk, low-fat cheese & yogurt, low-fat anything. Children need full fat food to develop in mind and body. Consider how many children are depressed, even suicidal today. Consider how many are overweight, diabetic, even growing cancers in their young bodies. Children of yesteryear were not so. They had healthy bodies, able to withstand disease. They ate differently. All of us, but particularly the young, need full fat food, and this fat should not industrially processed vegetable oils. Butter had been the fat of choice for generations before us. Not only is there nothing wrong with butter, but the substitution of highly processed fats and margarine have taken us all down the road to disease. Heart disease is a new phenomenon in the history of mankind. Nor is the wrong fat the only culprit. Equally important is the avoidance of all highly processed food, particularly white sugar, white flour, and high fructose corn syrup. You must advocate the foods that give good health: whole grain breads and cereals, animal fats, cold pressed coconut & olive oils, organic vegetables and fruits, and especially full-fat dairy products. It is important that these foods should be as clean and unprocessed as possible. A pyramid is not an especially good illustration, as not all bodies are identical in their requirements--some do better on more carbohydrates; some do worse. Number of servings is not useful. Quality is key. This will go a long way toward restoring the health and well-being of our most important national commodity, our children. Thank you. Jeanne Underhill 610 S.W. Atlantic Dr. Lantana, Fl 33462 Dear Committee, I urge you to do our children a favor, and abandon calls for low-fat milk, low-fat cheese & yogurt, low-fat anything. Children need full fat food to develop in mind and body. Consider how many children are depressed, even suicidal today. Consider how many are overweight, diabetic, even growing cancers in their young bodies. Children of yesteryear were not so. They had healthy bodies, able to withstand disease. They ate differently. All of us, but particularly the young, need full fat food, and this fat should not industrially processed vegetable oils. Butter had been the fat of choice for generations before us. Not only is there nothing wrong with butter, but the substitution of highly processed fats and margarine have taken us all down the road to disease. Heart disease is a new phenomenon in the history of mankind. Nor is the wrong fat the only culprit. Equally important is the avoidance of all highly processed food, particularly white sugar, white flour, and high fructose corn syrup. You must advocate the foods that give good health: whole grain breads and cereals, animal fats, cold pressed coconut & olive oils, organic vegetables and fruits, and especially full-fat dairy products. It is important that these foods should be as clean and unprocessed as possible. A pyramid is not an especially good illustration, as not all bodies are identical in their requirements--some do better on more carbohydrates; some do worse. Number of servings is not useful. Quality is key. This will go a long way toward restoring the health and well-being of our most important national commodity, our children.
Submission Date 9/23/2004 11:07:00 AM
Author from Lantana, Florida

   Dietary Patterns
Summary It is important to communicate to consumers the need to understand their fruit and vegetable needs. We recommend that consumer materials explain clearly how consumers can determine their calorie needs, and subsequently their fruit and vegetable goal.
Comments It is important to communicate to consumers the need to understand their fruit and vegetable needs – not many people need to eat 13 servings a day (though it would not hurt), and most Americans would likely need about 8 to 10 servings a day - or about 4 to 5 cups. We recommend that the consumer materials explain clearly how consumers can determine their calorie needs, and subsequently their fruit and vegetable goal.
Submission Date 9/24/2004 1:44:00 PM
Author Produce for Better Health Foundation

   Special Population Groups
Summary Thank you for considering our comments regarding the Advisory Committee’s report. Leading health organizations promote the benefits of citrus, including the American Heart Association, American Cancer Society, the National Cancer Institute and the Produce for Better Health Foundation.
Comments One of the key messages is: Consume a variety of foods within and among the basic food groups while staying within energy needs. Citrus is a naturally nutrient-dense fruit that can help Americans increase their intake of vitamins A and C, potassium, fiber and calcium. Citrus fruits can help adolescent females and women of childbearing age meet their needs for folic acid. One medium-sized orange is a good source of folate, providing 15 percent of the Recommended Daily Value.
Submission Date 9/24/2004 5:16:00 PM
Author Sunkist Nutrition Bureau

   Nutrient Goals
Summary Leading health organizations promote the benefits of citrus, including the American Heart Association, American Cancer Society, the National Cancer Institute and the Produce for Better Health Foundation.
Comments One of the key messages is: Increase daily intake of fruits and vegetables, whole grains, and nonfat or low-fat milk and milk products. Including citrus fruits in the diet helps meet the suggested 5 to13 servings of fruits and vegetables each day to meet nutrient adequacy recommendations.
Submission Date 9/24/2004 5:20:00 PM
Author Sunkist Nutrition Bureau

Physical Activity
   General
Summary Although the amount of physical activity among children has decreased in the past decade there are actions in which the local communities could take in order to increase the activity and thus increase the health of the children in those communities.
Comments The guidelines recommend that at least 60 minutes of moderate physical activity is recommended for children to maintain good health so it is incredibly unfortunate that nearly half of American youths, ages 12-21, are not active on a regular basis. Between 1991 and 1995, daily enrollment in physical education classes dropped from 42 percent to 25 percent among high school students. However, there are more opportunities than gym class for children to be active everyday and the local community, such as the parents and teachers, could provide after-school activities. For example, interested parents and teachers could develop clubs or intramural sports in which children could participate as well as provide access to school buildings or community facilities after hours which would enable safe participation in those activities. If these suggestions to increase physical activity among children were put into action it would result in an increase in the health of the local children as well.
Submission Date 9/24/2004 1:34:00 AM
Author Anonymous

Summary I suggest that incentives be established for local government to provide safe, accessible areas for individuals and families to be physically active such as more sidewalks and bike lanes, community centers, and parks. Thank you.
Comments Provide easier access for individuals and families to be physically active.
Submission Date 9/19/2004 5:52:00 PM
Author Anonymous

Summary
Comments Increasing physical activity should be top of the list.
Submission Date 9/17/2004 2:17:00 PM
Author University of California

Summary Be physically active each day. • Accompanying text for consumer pieces should reflect the different recommendations for goals, for example: o Fitness and reducing chronic health conditions: at least 30 minutes daily o Prevention of weight gain: at least 60 minutes daily o Maintenance of weight lo
Comments Be physically active each day. • Accompanying text for consumer pieces should reflect the different recommendations for goals, for example: o Fitness and reducing chronic health conditions: at least 30 minutes daily o Prevention of weight gain: at least 60 minutes daily o Maintenance of weight loss: at least 60-90 minutes daily • Given that less than 25% of the population currently meets the minimum recommendation for physical activity and that 64% are overweight, careful consideration needs to be given to how this message is communicated.
Submission Date 9/27/2004
Author American Cancer Society, American Diabetes Association, American Heart Association

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