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Dietary Guidelines for Americans, 2015

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Clara Lau PhD Comment ID #602


The Beef Checkoff, on behalf of America’s farmers, ranchers and importers, appreciates the opportunity to provide scientific evidence to the Dietary Guidelines Advisory Committee, specifically Subcommittee 2, as they review the research on dietary patterns and cardiovascular disease (CVD) risk. We would like to share a recent and relevant piece of evidence on the role of lean beef in healthful dietary patterns, including those consistent with the Dietary Approaches to Stop Hypertension (DASH) eating plan.

As the Committee considers the role of lean beef as a part of a healthful dietary pattern to reduce CVD risk, we would like to raise awareness of a recently published study in the Journal of Human Hypertension (Roussell MA, et al, 2014). The research conducted at the Pennsylvania State University shows that a dietary pattern rich in fruits, vegetables, low-fat dairy, and 4.0 or 5.4 oz of lean beef daily can reduce risk factors for CVD, including blood pressure and other vascular outcomes. The research suggests that it is the total protein intake -- not the type of protein -- that is instrumental in reducing blood pressure, as part of a DASH-like dietary pattern. This high-quality randomized controlled study conducted with 36 US subjects provides important evidence for the Committee to consider as they evaluate healthful dietary patterns to recommend to the public.

In prior comments, the Beef Checkoff has shared previously published findings from the Beef in an Optimal Lean Diet (BOLD) clinical trial that demonstrated that the inclusion of lean beef (4.0 or 5.4 oz per day) in a DASH-like diet also decreased total and LDL cholesterol levels similar to the standard DASH diet (Roussell MA, et al, 2012). This second publication is a companion to the BOLD clinical trial, building upon these earlier findings, and demonstrating favorable blood pressure and vascular outcomes comparable to those realized in the long-standing DASH research. The DASH diet is frequently cited as the “gold standard” for a heart-healthy dietary pattern, and the multi-faceted BOLD clinical trial research illustrates that lean beef can be effectively incorporated into a pattern consistent with the DASH diet to lower blood pressure and cholesterol.

This latest evidence further supports the inclusion of lean beef in a healthful dietary pattern, including fruits, vegetables, whole grains, and low-fat dairy, to support healthy blood pressure and cholesterol levels to reduce CVD risk.

Roussell MA, et al Effects of a DASH-like diet containing lean beef on vascular health. J Hum Hypertens. 2014 Jun 19. Full text accessible at:

Roussell MA, et al. Beef in an Optimal Lean Diet study: effects on lipids, lipoproteins, and apolipoproteins. Am J Clin Nutr 2012;95:9-16.

Affiliation: Industry/Industry Association Organization: The Beef Checkoff
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Protein (Plant, Animal)

Li Shen Ph.D Comment ID #601


Dear Dietary Guidelines Advisory Committee:

I feel that the current nutritional recommendations are largely based on population association studies, which I agree is beneficial to a majority of people. But without considering the genetic differences in nutrient biosynthesis pathways, the Dietary Guidelines could be less effective and sometime might be harmful to those who are genetically not well-suited for the modern Western diets such as those of Asian or African descent.
One clear example of this is the genetic polymorphism in the essential fatty acid biosynthesis pathway. Polymorphism in the FADS genes cluster influence the conversion rate from plant based PUFA to physiologically important LC-PUFA (EPA, AA, etc.). Numerous publications show that a common polymorphism in the FADS1 gene (rs174550) is strongly associated with type 2 diabetes and CVD. People with the TT genotype of this gene are the most efficient converters, those with the TA genotype are average and those with AA are very poor converters. Based on data from 1000 genomes, MAF (the A allele) is found in 4% of Africans, 36% of Europeans and 41% of Asians. For those with the TT genotype, such as a majority of Africans, omega-6 rich plant oils could lead to over-synthesis of pro-inflammatory arachidonic acid and increase the risk of inflammatory related diseases. For those with the AA genotype, such as 15% of East Asians and Latinos, overemphasis on consuming plant oils and avoiding LC-PUFA rich animal fat such as egg yolk, organ meat, and whole milk products, could lead to deficiency of LC-PUFA and consequently insufficient activation of PPARs pathways which may result in hypertriglyceridemia, low HDL, insulin resistance, and metabolic syndromes.
Another example is polymorphism in the vitamin A biosynthesis pathway. The enzyme that converts plant-based carotene to retinol, BCMO1 (beta-carotene 15,15'-monooxygenase 1), has a distinct allele distribution among ethnic groups. People with lowered ability to convert plant-based carotene to retinol could suffer vitamin A deficiency if they do not eat sufficient animal-based products like whole milk, egg yolk, butter and offal. Due to the critical role that retinoic acid plays in nuclear receptors RARs and RXR, misinformed food and nutrition recommendations could lead to liver malfunction, acne and other skin problems, as well as developmental and mental health problems.
These are only two of the many nutrition metabolism pathways that I believe require special attention from the Dietary Guidelines subcommittee. I suggest keeping this in mind and inviting experts in population genetics, nutritional genomics and nutritional biochemistry fields to join studies. Meanwhile, it is important to conduct genetic and genomic -based nutrition trials to gather evidence needed to support the development of more comprehensive guidelines in the future.
I have attached a few reference articles for your consideration. I hope you will forward my comments to other committee members. We all want to do what is best for people’s health.

Best Regards,
Li Shen, Ph.D.
President of GB HealthWatch

Affiliation: Individual/Professional Organization: GB HealthWatch
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)

Anonymous Comment ID #600


July 23, 2014
Dietary Guidelines Advisory Group

The Salt Institute respectfully submits the following comments concerning the recommendations doer sodium and the need for its declaration on the nutritional facts label. The Salt Institute believes that reference to any daily nutritional intake or requirement for sodium is misleading and unwarranted considering our current knowledge of the nutritional impact of sodium in the diet. It is now confirmed beyond any reasonable doubt that the original Dietary Reference Intake for sodium – the figure that serves as the benchmark for sodium intake was improperly established and strongly urges the Dietary Guidelines Advisory Group to halt any further consideration of recommendations regarding the sodium content in the diet. While this statement spears to be sweeping, the Salt Institute strongly believe that dietary recommendations must be supported by strong and credible data and evidence, and impose the lowest possible burden of risk to consumers.
Our statement that the DRI for sodium was improperly established is based on the following public record. Page 270 of the Dietary Reference Intakes ( ) for sodium states, “Because of insufficient data from dose-response trials, an Estimated Average Requirement (EAR) could not be established, and thus the recommended dietary allowance could not be derived. Hence, an Adequate Intake (AI) is provided. Further on page 270, it states, “The AI for sodium is set for young adults at 1.5 g (65 mmol)/day (3.8 g of sodium chloride) to ensure that the overall diet provides an adequate intake of other important nutrients…” On page 271 of the same document it states, “For adults, a UL of 2.3 g (100mmol)/ day is set.
In the first instance, the justification for the AI to be set at 1.5g/day to ensure that the overall diet provides an adequate intake of other important nutrients…” has no supporting evidence and the latest evidence contradicts this view.
More importantly, page 3 of the “Dietary Reference Intakes: Guiding Principles for Nutrition Labeling and Fortification” clearly sets out the formal procedure for establishing values as follows:
“Adequate Intake (AI): The recommended average daily intake level based on observed or experimentally determined approximations or estimates of nutrient intake by a group (or groups) of apparently healthy people that are assumed to be adequate; used to when an RDA cannot be determined.”
Based on all the data available, from the well-known Intersalt study , and all major studies since , there is not a single healthy population in the world that consumes as low as 1.5 g (65 mmol)/day. As a result the foundation figure used to establish the DRI for sodium disregarded the very standards set out for the establishment of all the DRIs.
Furthermore, on page 3 of the same ‘Dietary Reference Intakes: Guiding Principles for Nutrition Labeling and Fortification’ it states:
“Tolerable Upper Intake Level (UL): the highest average daily nutrient intake level that is likely to pose no risk of adverse health effects to almost all individuals in the general population. As intake increases above the UL, the potential risk of adverse effects may increase.”
Again, all the available data cited above establishes that there is not a single population in the world that demonstrates a risk of adverse health effects to almost all individuals in the general population resulting from consuming more than the UL figure of 2,300 mg sodium per day, because virtually every population in the world consumes levels above that figure.
According to the Guiding Principles for the Dietary Guidelines, the only way that this UL figure of 2,300 mg sodium per day can be justified is if almost all individuals in every population in the world currently suffers adverse health effects since they all consume above that figure. Stated simply, this implies that virtually all individuals throughout the world are sick – a concept that is utterly puerile.
Yet, this is the very basis upon which the sodium recommendations have been made.

The attached document contains all details and references.

Affiliation: Industry/Industry Association Organization: Salt Institute
  • Food Environment
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)

Anonymous Comment ID #599


After watching the committee speak on their findings, I found the research to be skewed and biased regarding the dietary patterns included. There was a particular focus on reducing animal protein further and based off of the comments made, I believe this conclusion was made by the exclusion of dietary patterns from their research. From my understanding, the study included the DASH, the current guidelines, and the Mediterranean dietary patterns. Dietary patterns that did not include grains or dairy were not part of the research. I believe that there should be an explanation for this oversight. When asked about protein (particularly red meat), it was stated that the committee only looked at dietary patterns not individual nutrients and that the typical pattern for red meat eaters also included high fat foods such as french fries and sugar sweetened beverages. This is not the way to set dietary guidelines for the American Public. By this logic, we should eliminate tomatoes and lettuce because they are commonly consumed with greasy fast food.

The health benefits of foods needs to be taken into consideration and the scientific research needs to be done in a non-biased and non-skewed manner. In my opinion, the committee did a poor job of looking at the data as a whole by eliminating certain dietary patterns (much different than normally accepted) that show health benefits and by not taking into consideration scientific facts about specific nutrients.

Affiliation: Educational Institution: Secondary or School System Organization:
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Protein (Plant, Animal)

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)
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