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Dietary Guidelines for Americans, 2015

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Jose Sotolongo MD Comment ID #837


Dietary guidelines that insist on lowering all fat intake are misguided and are largely responsible for the obesity epidemic in this country. The food industry, following the guidelines released in early 2011, promotes and manufactures fat-free or low-fat foods, particularly milk and other dairy products. It is unclear whether the marketing and selling of this category of foods represents increased revenue for the food industry over less- manipulated products.

Anyone on your panel of advisory members with a strong background in human metabolism would well to educate the panel at large on the importance of fats (primarily, but not exclusively, from vegetable sources, such as nuts, avocadoes, etc.) in a healthy diet. When the consumer avoids fats, inevitably calories ingested will come from carbohydrates, perhaps protein, both of which have a lower caloric/energy value, and will be metabolized much faster than fats. This results in a real metabolic need for further ingestion of foods earlier than if a moderately fatty meal had been ingested.

I urge the panel to look towards its members with extensive background in human metabolism and apply that knowledge to the development of guidelines that will benefit, not cause further damage, to the American citizenry.

Affiliation: Individual/Professional Organization: Physician
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)

Laura MacCleery JD Comment ID #836


Request 5-1

Please see attachments.

Affiliation: Other Organization: Center for Science in the Public Interest
  • Food Safety

Robert Rutkowski Comment ID #835


Dietary Guidelines Committee
The U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
Toll Free: 1-877-696-6775

Re: Dietary Guidelines Committee should Recommend Pregnant Women Avoid Caffeine, Coffee/ Increased Risk of Miscarriage, Childhood Leukemia

Dear Committee:

The federal government may be poised to give women who are or might become pregnant bad advice on how much caffeine is safe to consume during pregnancy. Draft advice from the government's Dietary Guidelines Advisory Committee indicates that pregnant women should be sure to limit their caffeine consumption to 200 milligrams per day. But that advice could increase the risk of adverse pregnancy outcomes, including spontaneous abortion, stillbirth, preterm delivery, and childhood leukemia.

The Dietary Guidelines Advisory Committee should instead advise pregnant women to avoid caffeine-containing foods and beverages. In comments filed today CSPI pointed to a recent meta-analysis published in the European Journal of Epidemiology which found that a dose as low as 100 mg per day of caffeine was associated with a 14 percent increase in risk of miscarriage, and a 19 percent increase in the risk of stillbirth. Consumption of 100 mg of caffeine per day was also associated with increased risks of small-for-gestational-age fetuses and low birth weight. Risks increase as caffeine dosages increase, according to the study.

To put 100 mg of caffeine into context, a 16-ounce Grande Starbucks coffee has 330 mg of caffeine. Coffee you brew at home has between 60-150 mg per 5-ounce cup, depending on how it is brewed. A 20-ounce bottle of Diet Coke has 78 mg.

Pregnant women deserve accurate advice about the risks caffeine poses to their healthy pregnancy and have been badly misinformed. The Dietary Guidelines for Americans should n?ot compound this problem by conveying an impression that 200 milligrams per day is some kind of red line below which caffeine is safe and above which caffeine is dangerous. Instead, the science indicates that even lower levels of caffeine can increase the risk of serious problems, including for only a cup or two of regular coffee per day.

CSPI's comments indicate flaws in the advice given to pregnant women by the respected American College of Obstetricians and Gynecologists, which the Dietary Guidelines Advisory Committee cites in its draft recommendation. ACOG's analysis of the risk of miscarriage posed by caffeine is thin and outdated. While the recent meta-analysis considers 25 separate studies, ACOG considered only two of those, including the lone study that found no link to an increased risk of miscarriage.

The Food and Drug Administration used to recommend that pregnant women avoid caffeinated drinks altogether, or consume them only sparingly. "As a general rule, pregnant women should avoid substances that have drug-like effects and can cross the placenta," the agency wrote in a 1981 brochure.

Also DGAC should consider the risk of childhood leukemia related to drinking coffee during pregnancy. A 2014 meta-analysis published in the American Journal of Obstetrics and Gynecology found a dose-related increased risk of childhood acute leukemia associated with maternal coffee consumption. The evidence linking maternal coffee consumption during pregnancy and childhood acute leukemia "strong." In the U.S., lifetime probability of childhood acute leukemia in children aged 0 to 14 is approximately 73 per 100,000. According to a risk analysis by biostatistician Steven Bayard, 19 of those cases might be attributable to coffee consumption of one to two cups per day during pregnancy.
Thank you for the opportunity to bring these remarks to your attention.

Yours sincerely,
Robert E. Rutkowski

cc: House Minority Leadership

2527 Faxon Court
Topeka, Kansas 66605-2086
P/F: 1 785 379-9671

Re: CSPI comments:

Affiliation: Individual/Professional Organization: n/a
  • Food Safety

Sandy Perkins MS, RD/LD Comment ID #834


The Association of State Public Health Nutritionists (ASPHN) appreciates the opportunity to provide the attached recommendations on the 2015 Dietary Guidelines for Americans.
Recommendation 1: Emphasize Dietary Patterns
Recommendation 2: Strengthen and expand advice on reducing portion sizes
Recommendation 3: Add a quantitative recommendation for added sugars
Recommendation 4: Emphasize the important role of the food environment & public policy
Recommendation 5: Review the impact of food marketing environment

ASPHN thanks you for taking these comments into consideration.

Affiliation: Professional Association Organization: ASPHN
  • Behavior
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Energy Balance (Weight Loss, Weight Maintenance, Calorie Intake, Physical Activity)
  • Food Environment

Anonymous Comment ID #833


I respectfully request that your agency refer to and utilize Brazil's most recent set of dietary guidelines when formulating/updating the 2015 Dietary Guidelines for Americans. These guidelines utilize commonsense language and practices that consider people's real needs, concerns and interests with the potential to make a significant impact on dietary and food intake patterns and behaviors.

Affiliation: Individual/Professional Organization:
  • Other

Anonymous Comment ID #832


Richard D. Olson, MD, MPH
Prevention Science Lead and Designated Federal Officer, 2015 DGAC
Office of Disease Prevention and Health Promotion, OASH
U.S. Department of Health and Human Services
1101 Wootton Parkway, Suite LL100 Tower Building
Rockville, MD 20852

Colette I. Rihane, MS, RD
Director, Nutrition Guidance and Analysis Division
Center for Nutrition Policy and Promotion
U.S. Department of Agriculture
3101 Park Center Drive, Room 1034
Alexandria, VA 22302

RE: Maintaining the Current Definition of ‘Standard Drink’; Rebuttal of the Wine Institute Submission

Dear Dr. Olson and Ms. Rihane:

Last June, I submitted comments to the Committee in support of maintaining sensible, evidence-based recommendations for moderate alcohol consumption by adults. The 2010 Dietary Guidelines defined moderate consumption as no more than one drink/day for women, and no more than two drinks/day for men. This concept is very important for providing guidance to the American people and should be maintained in the 2015 Dietary Guidelines for Americans (DGA). The 2010 DGA defined a drink as a 12-fluid ounce portion of 5%-alcohol beer, a 5-fluid ounce glass of 12%-alcohol wine, or a 1.5-fluid ounce glass of 80-proof distilled spirits. The standard drink reflects the fact that typical servings of beer, wine, and distilled spirits contain the same amount of pure alcohol: 0.6 fluid ounces. These recommendations are based on the best-available science and form the foundation for nutrition policy in America.

This letter is to respond to the Wine Institute’s submission dated October 30, 2014 to reject the definition of a standard drink. As Professor of Medicine, Pharmacology & Toxicology, Distinguished University Scholar Associate Vice President for Translational Research and Associate Vice President for Health Affairs/Research at the University of Louisville, who has been continually federally funded for >35 years for my research from the VA and the National Institute on Alcohol Abuse and Alcoholism (NIAAA), and from my perspective as Director of Research Affairs for the Division of Gastroenterology, Hepatology and Nutrition, and as a current member of the National External Advisory Council for NIAAA and a member of the Council of Councils for NIH, I would like to point out that scientifically, the definition of a standard drink is on solid ground. While the volume of an alcoholic beverage and alcohol content vary, the standard drink does give an indication to the consumer of their consumption. For example, a person consuming a 20-oz beer (5% alcohol), a 12-oz beer (8 -10% alcohol, which is common in micro-breweries), or a 5-oz wine (15% alcohol) knows that the amount of alcohol consumed is actually higher than a standard drink. Not only the knowledge of a standard drink is important for a lay person to monitor their alcohol intake, it is also crucial for scientific research. All epidemiological studies quantify alcohol intake based on this principle. Deleting this definition from DGA 2015, as the Wine Institute recommends, will basically remove one of the criteria that have been adopted by NIAAA for research purposes, and by many states, departments of motor vehicles, and other organizations.

Thus, by maintaining the definition of a standard drink, the 2015 Dietary Guidelines for Americans would provide an excellent framework for educating adults who choose to drink in moderation and responsibly. The Dietary Guidelines are essential to serve as the basis for nutrition information for federal and state agencies across the country. In addition, the concept of a standard drink provides consumers with an important reference point similar to serving size information on packaged food labels.

I appreciate your consideration of maintaining the definition of a standard drink, not only because it is scientifically correct, but also because it is the cornerstone of alcohol research, as evidenced by its inclusion on the NIAAA website. Abandoning this concept will have deleterious consequences to research and other federal agencies’ efforts. The current, unequivocal definition of a standard drink is used nationwide and is necessary to help educate the American public about responsible alcohol consumption.


Craig J. McClain, M.D.
Professor of Medicine and Pharmacology & Toxicology
Distinguished University Scholar
Chief of Research Affairs, Division of Gastroenterology, Hepatology, and Nutrition
Associate Vice President for Translational Research
Associate Vice President for Health Affairs/Research
University of Louisville School of Medicine

Affiliation: Educational Institution: Higher Education Organization: University of Louisville School of Medicine
  • Alcoholic Beverages

Ajia Minnis Comment ID #831


Please stop letting the Livestock and Dairy Industry dictate what we should eat. Dairy should NOT be in the recommendations for what to eat/drink. Water should be put in the food plate glass, people should be encouraged to drink more water, not milk. Dairy is not a necessary component of any adult diet. 70% of adults do not produce enough lactase to digest dairy properly anyway...Also protein is not a food group, it is a nutrient...that confuses people when you write: Fruits, Vegetables, Grains...Protein...odd

Affiliation: Educational Institution: Higher Education Organization: Columbia Univesity
  • Food Groups (Fruits, Vegetables, Grains, Dairy, Protein Foods)
  • Water & Beverages (Non-alcoholic)

David Weed Psy.D. Comment ID #830


Greater Fall River Partners for a Healthier Community, Inc. is one of six inaugural Robert Wood Johnson Foundation Culture of Health Prize Winners serving a four-town area in Southeastern Massachusetts. For over a decade, we have worked to improve the health status of the City of Fall River through the Healthy City Fall River initiative. As we considered the factors that have led to high rates of both adult and childhood obesity and the related increase in rates of heart disease and diabetes, we have examined the available research on likely causes of these disorders.
Over the past five years, it has become clear to us that one of the most significant factors leading to these increases has been the recommendations of the USDA Dietary Guidelines for Americans. Specifically, these guidelines have had the effect of encouraging food manufacturers, schools, dietary educators and consumers to shift their food choices away from foods and beverages containing dietary fats toward those containing carbohydrates, whether refined or whole, including added dietary sugars.

It is our strong recommendation that information about added sugars should be on the nutrition label, preferably in teaspoons as well as grams, along with the recommended percentage of sugar in a healthy diet. This corresponds to the World Health Organization’s recommendation to reduce sugar from 10 percent of daily calorie intake to 5 percent. For an adult of a normal body mass index (BMI), that works out to about 6 teaspoons -- or 25 grams (around 6 teaspoons) -- of sugar per day. Americans consume too much sugar, with 16 percent of the average diet coming from added sugars, about three pounds of sugar each week!

In the Dietary Guidelines for Americans 2010, the USDA’s recommendation are more vague, advising that combined calories from solid – that is, saturated or trans – fats and added sugar be limited to 5 to 15 percent of total daily calories. On a 2,000-calorie diet, this would mean limiting intake to between 100 and 300 calories from these two types of ingredients, but the USDA offers no separate recommendation for sugar.

Affiliation: Other Organization: Partners for a Healthier Community Inc.
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)

Sylvia Klinger MS, RD Comment ID #829


Choice and Information Are Key to Better Health

As the Dietary Guidelines debate winds down, the Academy of Nutrition and Dietetics member interest group of Latinos and Hispanics in Dietetics and Nutrition (LAHIDAN) would like to provide commentary on behalf of the Latino community, especially as choosing between what’s healthy and what’s familiar can be a tremendous struggle for this population. Please see attachment for my full comments.

Affiliation: Professional Association Organization: Academy of Nutrition and Dietetics - LAHIDAN
  • Behavior
  • Energy Balance (Weight Loss, Weight Maintenance, Calorie Intake, Physical Activity)

Anonymous Comment ID #828


The opportunity to provide comments on the committee conclusions/statements provided at the November 7 public meeting is appreciated. Various documents are attached to assist the committee in finalizing the conclusions/statements to more accurately reflect the evidence that they selected to review.

Affiliation: Individual/Professional Organization:
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)
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