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Dietary Guidelines for Americans, 2015

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Feda Dapic concerned Comment ID #598


Water use in food production has to be a major decisive factor in any discussion of dietary guidelines. Personal taste and cultural preferences need to be guided by the principle of sustainability. Without considering the water use in food production, and without the urgent change in current practice of collosal waste of food, we might witness the largest migration of people from arid areas in US history. Water levels in dams are unlikely to recover, and we urgently need water pipelines. Invest in local food production. Change the food culture, to reflect the realities of this planet's limits. Promote plant-based foods, because they are less resource-intensive than animal-based foods. Thank you for this opportunity.

Affiliation: Individual/Professional Organization:
  • Sustainability

Stephanie Winnard MA Comment ID #597


I wholeheartedly support your idea to encourage Americans to eat a plant-based diet for sustainability and health. Please do this, and don't allow the meat and dairy industries to change your minds. The dietary guidelines must be based on science, not corporate interests. Also, the health of our children and saving our planet for future generations are more important than the profits of the meat and dairy industries. I am certified in plant-based nutrition, and I look forward to seeing the new guidelines in 2015, which I hope will establish whole foods, plant-based diets as the ideal for healthy eating and environmental stewardship.

Affiliation: Educational Institution: Higher Education Organization: Pierce College Vegan Society
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Sustainability

Lois Redican B.A. Chem Comment ID #595


The subcommittees' research regarding what the population is currently doing regarding food and beverage consumption can only be appropriately evaluated when it is compared with a standard of healthful eating. Has the committee determined a healthy diet based on the nutrient needs of a human from a biochemical perspective or will the dietary guidelines for 2015 be representative of current eating patterns?

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

Roni Neff PhD, MS Comment ID #594


To the Dietary Guidelines Advisory Committee:

The Johns Hopkins Center for a Livable Future (CLF) is an interdisciplinary academic center based within the Johns Hopkins Bloomberg School of Public Health. CLF investigates the interconnections among diet, food production, public health, and ecosystems. We commend the DGAC for exploring ways to integrate sustainability into the 2015 Dietary Guidelines for Americans (Request 5-2). On behalf of the Center for a Livable Future and 30 faculty, staff, CLF-Lerner Fellows, and research assistants who have signed their names, we are pleased to submit the attached comment on how the 2015 DGA can help guide American diets toward individual health while simultaneously promoting the sustained capacity of our food system to provide the healthy and nutritious foods that should be available to all Americans, now and for future generations.

CLF makes the following recommendations to the Committee:

1. Encourage consumers to reduce food waste, and provide strategies to assist them in doing so.

2. While the guidelines appropriately emphasize the healthfulness of seafood consumption, the new guidelines should advise consumers to eat products lower on the aquatic food chain.

3. The new guidelines should communicate with emphasis the many benefits of a plant-based diet, which include sustainability in addition to individual health.

4. Encourage consumers to choose foods and beverages that are minimally processed and packaged.

5. Highlight synergies between dietary recommendations for nutrition and sustainability.

6. Consider ways that consumers can support sustainable food production methods.

In the attached document, we provide evidence-based rationale for each of these recommendations, as well as strategies for their implementation. For additional information and/or assistance with incorporating messages to improve the sustainability of individual diets into the dietary guidelines, please contact Roni Neff, PhD, MS, at or (410) 614-6027.

Affiliation: Educational Institution: Higher Education Organization: Johns Hopkins Bloomberg School of Public Health, Center for a Livable Future
  • Sustainability

Anonymous Comment ID #593


As a parent and educator, I request that the label state what percentage of the product is made up of sugar. Specifically, I support the recommendations of Marion Nestle, Professor, New York University as follows:

RE: Nutrition Facts panel: ADDED SUGARS

1. Retain the line for Sugars but call it Total Sugars

2. Add a line for Added Sugars


Excessive intake of dietary sugars is well established to raise the risk of obesity and type-2 diabetes.[i]
Americans on average twice as much as is generally recommended.[ii]
The amount typically consumed comes close to the upper limit recommended by the Institute of Medicine on the basis of increased risk of nutrient deficiencies.[iii]
Sugars intrinsic to foods are accompanied by nutrients; added sugars are not.
Although there is no biochemical difference between intrinsic and added sugars, food and beverage companies know exactly how much sugar they add as part of the recipes for their products.
Listing the amount of added sugars on food labels would inform consumers about how much sugars are added to the foods they buy.
Randomized, controlled clinical trials to test the hypothesis that added sugars increase disease risk would violate ethical standards and, therefore, are impossible to conduct.
3. Establish a Daily Reference Value for Added Sugars of 10% of total calories


Since the 1977 Dietary Goals, health officials have consistently recommended an upper limit of 10 percent of calories from added sugars.[iv]
The 1992 USDA Food Guide Pyramid suggested an upper limit of 6, 12, and 18 teaspoons of sugars, respectively, for daily diets of 1,600, 2,200, and 2,800 calories, respectively. This works out to 7, 10, and 13 percent of calorie intake, respectively, for an average of 10 percent.[v]
By 1992, health officials in several European countries had recommended much the same.[vi]
The Institute of Medicine’s 2002 upper safety limit of 25% of calories was based on risk for nutrient deficiencies, not obesity and chronic disease.[vii]
In 2009, the American Heart Association recommended that women consume no more than 100 calories per day from added sugars (25 grams), and men no more than 150 calories per day (38 grams). These come to 5 percent and 7.5 percent, respectively, of a 2000-calorie daily diet.[viii]
The 2010 Dietary Guidelines for Americans state that no more than 5 to 15 percent of calories should come from a combination of solid fats and added sugars. This implies that added sugars should be less than 10% of calories.[ix]
Dr. Robert Lustig says that a “dose” of added sugars up to 50 grams a day poses little risk for metabolic or chronic disease. This amounts to 200 sugar calories and 10% of a 2,000-calorie daily diet (he says twice that much, the amount commonly consumed by Americans, is toxic.[x]
The World Health Organization in 2014 said that added sugars should make up less than 10 percent of total calories per day, and less than 5 percent would be even better,[xi] based on two research reviews, one on sugars and obesity[xii] and one on sugars and tooth decay.[xiii]
Added sugars as 10% of calories represents about half the amounts currently consumed and comes close to consensus.

[i] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and co studies. BMJ 2012;345:e7492. doi: 10.1136/bmj.e7492.

[ii] USDA. Loss-adjusted food availability documentation. March 11, 2014. USDA. Food availability documentation: added sugar and sweeteners. The tables used to construct figure 3D are at: Refined Sugar, Corn Syrup, Other Sweeteners.

[iii] Institute of Medicine (IOM) of the National Academies. “Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein, and Amino Acids (Macronutrients), Chapter 6: Dietary Carbohydrates: Sugars and Starches”, Washington, DC: National Academies Press; 2002.

[iv] U.S. Senate Committee on Nutrition and Human Needs. Dietary Goals for the United States, December 1977.

[v] USDA. Food Guide Pyramid, 1992.

[vi] Cannon G: Food and Health: The Experts Agree. London: Consumers’ Association, 1992.

[vii] USDA. Is intake of added sugars associated with diet quality? Nutrition Insights, Insight 21, October 2000.

[viii] Johnson RK, Appel LJ, Brands M, et al. Dietary sugars intake and cardiovascular health: a scientific statement from the American Heart Association. Circulation. 2009;120(11):1011-1120. doi: 10.1161/CirculationAHA.109.192627.

[ix] USDA and USDHHS. Dietary guidelines for Americans, 2010.

Affiliation: Educational Institution: Secondary or School System Organization: SAU 50, Rye, NH
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)

Kari Hecker Ryan PhD, RD Comment ID #592


Executive Summary

The Dietary Guidelines for Americans are intended to serve as the basis for consumer nutrition messages and are developed by synthesizing the published knowledge regarding individual nutrients and foods and how they can be incorporated into healthy eating diet patterns. The USDA evidence review along with a diet modeling analysis resulted in the 2010 recommendation for Americans to:

"Choose a variety of protein foods, which include seafood, lean meat and poultry, eggs, beans and peas, soy products, and unsalted nuts and seeds".

Nuts are nutrient dense sources of unsaturated fats, fiber and plant-based protein as well as vitamins and minerals. The recommendation to encourage consumption of nuts is based on extensive research that has demonstrated the beneficial effects of nut intake on diet quality, health outcomes, as well as validated surrogate biomarkers of chronic disease. The recommendation to restrict consumption to “unsalted” nut and seed varieties implies that:

1)Data demonstrate a significant difference between the benefits of unsalted and salted nuts.
2)Salted nuts have a significant and disproportionate impact on total dietary sodium intake.

In fact, scientific evidence contradicts both of these assumptions and use of this qualifying language has the potential to mislead the public and/or discourage intake of nuts. Therefore, we strongly encourage the Committee to remove the “unsalted” guidance and present the recommendation in a manner that is consistent with the evidence base and more likely to achieve nutrition goals.

Affiliation: Industry/Industry Association Organization: Kraft Foods Group, Inc.
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Food Groups (Fruits, Vegetables, Grains, Dairy, Protein Foods)
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)

Constance Hilliard Ph.D. Comment ID #591


I am an applied historian and epidemiologist. While the health of mainstream America has improved by most statistical accounts, that of blacks has declined. My concern is that federal dietary guidelines are in large measure responsible for this unfolding tragedy. Dietary standards are based on a Northern European ethnic model, while giving the impression that it is universal and one-size-fits-all. I will identify my greatest concerns below:
(1) Blacks whose daily sodium intake fall within the 2300 mg. range recommended, are at high risk of developing salt-sensitive hypertension and dying of end-stage renal failure. The medical studies are clear on this point. (See Appendix). It is the responsibility of the Federal Government and the FDA to help the American public see that the present standards are not based on a universal model, but on a parochial Northern European ethnic paradigm. However, just because certain nutritional standards benefit people of Nordic ancestry, does not mean that it automatically benefits people of West African ancestry. While the ancestors of African Americans lived in sodium-deficient regions of the African interior, Nordic populations have always inhabited salt-rich environments. As a consequence, what would be a normal sodium intake for a Northern European, might cause sodium-poisoning for a West African. This is hardly hypothetical since Black Americans are dying of kidney failure brought on by salt-sensitive high blood pressure at 4 times the rate of whites. My recommendation is that in instances where there are clear ethnic differences in standards, nutritional labels should list micronutrient requirements for that ethnic group as well.
(2) African-Americans are being warned that they are calcium deficient and therefore should consume more dairy products even though more than 75% of blacks are lactose intolerant. However, this group has the highest bone mass density of any American ethnicity and the lowest rates of osteoporosis, fragile bones and fractures. Medical studies have shown that although black adolescents consume less calcium because of lactose intolerance, genetics has provided them with a biological mechanism that retains calcium far longer than is the case with other groups, and releases less of it into the urine. Thus blacks require less dietary calcium. If you’re thinking, what does it matter if they eat a bit more calcium than what they need, I will explain. Recent medical studies have also shown that the over-consumption of calcium triggers prostate cancer in males. Black men have the highest rate of prostate cancer in the world. They are encouraged to eat dairy products despite their lactose intolerance, which means that they are over-consuming the mineral because the standard daily intake is based on the biology of Northern Europeans who require more of it. Calcium needs should be recalibrated for people of West African origin in addition to the normal standards provided.
(3) What we in American society call lactose intolerance is more properly termed lactase non-persistence (LNP), and it is not a disorder. It is an ethnic trait, like skin color or hair texture. Populations of dairy-farming cultures tend to have low levels of LNP, while those of non-dairy cultures have high levels. But why are African-Americans being encouraged by the Federal Government to eat dairy products when they make them sick and are clearly not required for healthy bone growth in this population? Rather than impose mainstream priorities on Blacks, which is a focus on osteoporosis and calcium, why not pay attention to the serious health crisis that blacks face? The rates of obesity and Diabetes II are skyrocketing among Black juveniles. Since they have strong bones, what does it mean for them to be forced to eat high-fat, high-sodium, high-cholesterol dairy products? Not only that, but because Black parents are pressured to get their lactose-intolerant children to drink milk, the parents end up giving them chocolate milk, because it doesn’t make the children as nauseous as plain milk. Not surprisingly, this trend also contributes to this obesity problem.
But why am I saying that the Federal Government bears responsibility for these health problems? It may not be able to lower sodium levels for the entire food supply, but it can at the very least, add ancestry (where necessary) to nutritional labels and do the necessary research required to establish the appropriate values for sodium, Vitamin D, calcium and whatever else may differ from the mainstream. Otherwise, there is no possible way for healthy African-Americans to know that they are at risk of hypertension, or worse from following nutritional labels based on Federal guidelines.

Affiliation: Educational Institution: Higher Education Organization: University of North Texas
  • Food Groups (Fruits, Vegetables, Grains, Dairy, Protein Foods)
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)

Nicole Burda MPH Comment ID #590


The American Public Health Association, a diverse community of public health professionals who champion the health of all people and all communities, appreciates the opportunity to submit comments on the Dietary Guidelines for Americans.

Please contact Nicole Burda at 202-777-2513 with any questions concerning the attached comments.

Affiliation: Professional Association Organization: American Public Health Association
  • Behavior
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)
  • Food Environment
  • Food industry approaches to reducing sodium, added sugars, and fats
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)
  • Sustainability

Ashley Colpaart MS RDN Comment ID #589


SC 5: Food and Sustainability and Safety Subcommittee,

I support applaud the US Dietary Guidelines Advisory Committee (DGAC) for their venture to incorporate food system sustainability into future dietary guidelines. This decision is a critical mechanism for ensuring nutrition and food security for all Americans.

I thank you for your service and encourage you to consider and explore the following questions in your deliberations:

• How does dietary choice affect where food is grown and what foods are grown, water consumption and water quality?

• How can the Dietary Guidelines for Americans help consumers, industry and institutions to reduce food waste?

• How does the quality and type of meat we recommend and consume relate to environmental impacts including energy inputs and outputs?

• How can the inclusion of community, local or regional food systems serve economic development, inequity, food justice, dignity, seasonality and imports?

• How will plant-based diets be acknowledged for their health benefits as well as their low environmental footprint?

• How can the Dietary Guidelines for Americans reduce human and environmental impacts of agricultural inputs?

Further, I offer the following study's for your continued review:

Masset, Gabriel, Louis-Georges Soler, Florent Vieux, and Nicole Darmon. “Identifying Sustainable Foods: The Relationship between Environmental Impact, Nutritional Quality, and Prices of Foods Representative of the French Diet.” Journal of the Academy of Nutrition and Dietetics 114, no. 6 (June 2014): 862–69. doi:10.1016/j.jand.2014.02.002.

P. Gerber, H. Steinfeld, B. Henderson, et al. Tackling Climate Change Through Livestock - A Global Assessment of Emissions and Mitigation Opportunities Food and Agriculture Organization, Rome, Italy (2013)

E. Audsley, M. Brander, J. Chatterton, D. Murphy-Bokern, C. Webster, A. Williams How Low Can We Go? An Assessment of Greenhouse Gas Emissions from the UK Food System and the Scope for Reduction by 2050
Food Climate Research Network and World Wildlife Fund UK, Godalming, UK (2010)

E. Stehfest, L. Bouwman, D.P. van Vuuren, et al. Climate benefits of changing diet Clim Chang, 95 (1-2) (2009), pp. 83–102

J.I. Macdiarmid, J. Kyle, G.W. Horgan, et al. Sustainable diets for the future: Can we contribute to reducing greenhouse gas emissions by eating a healthy diet? Am J Clin Nutr, 96 (3) (2012), pp. 632–639

D.J. Millward, T. Garnett Plenary Lecture 3: Food and the planet: Nutritional dilemmas of greenhouse gas emission reductions through reduced intakes of meat and dairy foods Proc Nutr Soc, 69 (1) (2010), pp. 103–118

M. Berners-Lee, C. Hoolohan, H. Cammack, C.N.N. Hewitt The relative greenhouse gas impacts of realistic dietary choices Energy Policy, 43 (2012), pp. 184–190

G. Page, B. Ridoutt, B. Bellotti Carbon and water footprint tradeoffs in fresh tomato production J Clean Prod, 32 (2012), pp. 219–226

Affiliation: Individual/Professional Organization: Hunger and Environmental Nutri
  • Sustainability

Anonymous Comment ID #588


Please assist in getting ADDED SUGAR on the Nutrition Facts Label. Please address the topic of added sugar in depth in the new Dietary Guidelines for Americans.

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