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Dietary Guidelines for Americans, 2015

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Anonymous Comment ID #444


I am a Nutrition and Dietetics student, and I want to solidify the importance of having adding sugars on the new food label. In 1976, the estimated overweight adult population in the United States was 47%, and 15% were considered obese (1). In 2005, the number of overweight adults increased to over 66%, and 33% were considered obese (1). This is a serious problem in the United States, and is predicted to continuing growing to reach 2.3 billion overweight adults by 2015 (1). The American Heart Association identified the main source of extra sugar in the American diet from sugar-sweetened beverages (1). The average obese or overweight adolescent consumes over 300 calories a day from SSB, which counts for 15% of their daily intake (1). By having the added sugar on the food label, this will help individuals to decide if they want to consume foods or beverages that are high in added sugar to hopefully decrease the overweight and obese individuals in the U.S. Thank you.

1. Malik V, Popkin B, Bray G, et al. Sugar-sweetened beverages, obesity, type 2 diabetes mellitus, and cardiovascular disease risk. Contemporary Reviews in Cardiovascular Medicine. 2010;121(11):1356-1364.

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

Anonymous Comment ID #443


Affiliation: Industry/Industry Association Organization: Calorie Control Council
  • Food Safety

Anonymous Comment ID #442


In school, I took a class on nutrition and biochemistry. It included at least one hour dedicated to learning about how to read a food label. This indicates to me, that it is too complicated and the proposed changes do not simplify it much.

The best part of the proposed food label changes is the 'added sugars'. Still there remains much room for ambiguity when it is presented in grams and grams are not calorically equal among the macronutrients. This requires the consumer to do math to get to the caloric proportions of macronutrients in the item.

What I want to know about certain products is how much preservatives and chemicals are in foods. I find the food labels do not address this. I've noted that foreign labels indicate percentages in the ingredient lists. For example, if I cannot find coconut milk without preservatives like guar gums, I would like to know which brand has the LEAST amount of this questionable additive.

We need to draw a hard line with the food processing companies. A complex food label leaves ample room for the food industry to play on the ambiguities. I love the example of Brazil's proposed 'food guide'. It's simple, straight-forward, and addresses lifestyle as well. To eat healthfully, lifestyle is a huge factor.

The only REAL way to reduce obesitys is to reduce or eliminate the factors that contribute to it. These are overwhelmingly due to chemicals in our food, foods our bodies do not recognize and foods that cause cravings for more -- ALL of which are processed foods made by companies that have utmost care for increasing market share and profit.

Luckily, the best antidote to this poison is the freedom to find information about the true processes and tactics of the food industry. Yet this information is vast, difficult to decipher and I'd rather spend my time and energy somewhere else, rather than learning how to avoid unhealthy foods in a maze of marketing and unethical or quasi-ethical practices.

I see a major flaw recommending so many servings of grains. This often is interpreted as processed foods like 'Ritz' crackers for a serving of grains. If you look at some of the information found in 'Death by Food Pyramid' by Denise Minger, you'll find that initially the researched recommendation was for vegetables to be the largest component of meal servings and limited grains. The department of agriculture flipped this for agricultural gain. Grains are carbs. Carbohydrates are long chains of glucose. Glucose is stored as fat in our cells and spike our blood glucose levels. These are all things that lead to metabolic syndrome and worse - diabetes, heart disease, high blood pressure, etc. It's double speak to recommend avoiding sugar and processed foods in any significant quantity but fill a large portion of your plate with pasta or things made with flour, etc. It's double speak to recommend minimal amounts of sugar-laden foods and then subsidize processed sugar.

Foods that our body recognizes are whole foods. Humans do best on whole foods prepared in their own homes. And what Brazil is doing is an example of prioritizing human life by prioritizing whole foods that one makes for themselves. It doesn't fit with our way of life, but our way of life and our food supply is not sustainable. It has to change. For once, our government can play a role in being a leader rather than cowtowing to industrial powers. These proposals do not go far enough and will not meet the ultimate goal of a healthier population.

Affiliation: Individual/Professional Organization: Visa
  • Food Environment

Keith Ayoob EdD, RD Comment ID #441


To the Dietary Guidelines Advisory Committee:

As a clinician and registered dietitian in practice for 30 years with both general populations and those with special needs, a Dannon Nutrition Advisor, and as a consumer, I am a strong advocate of Americans eating a nutritionally balanced breakfast. While I have long encouraged consumers to drink milk to meet nutrient needs, the declining consumption of fluid milk (1) suggests that Americans are finding it a challenge to comply with such advice. Here,yogurt can play a critical role.

The importance of breakfast

Historically, breakfast has been a meal of habit. People who refuse to eat the same dinner two days in a row will eat the same breakfast for years. Thus the importance of a nutrient-rich breakfast as a vehicle for meeting dietary gaps that would otherwise go unmet.
Adequate dietary calcium and potassium are nutrients of concern. A daily serving of yogurt at a meal of habit such as breakfast, could go a long way towards correcting such a gap.
Protein presents different challenges. The timing of protein consumption appears to be useful for building muscle. Approximately 30 grams of protein at each meal was more effective at stimulating muscle synthesis than skewing protein toward the evening meal (2). Protein at breakfast can be critical to attaining sustained satiety throughout the day, particularly for those needing to restrict energy or lose weight (3,4). Low-fat and fat-free yogurt, especially the concentrated protein of Greek yogurt, can be a significant adjunct or mainstay of a nutrient-rich higher protein breakfast. The brand of yogurt matters not, but the inclusion of yogurt seems to also be associated with better diet quality and lower health risks (5).
Despite these and more advantages of a daily breakfast, up to 75% of Americans frequently skip breakfast (6), thereby potentially missing nutrients at this important meal that will likely not be made up during the day. Twenty to 30% percent of children and 31% of adolescents have been identified as breakfast skippers (7). Children and adolescents who skipped breakfast also tended to have poorer diets and were more likely to be obese.

Dietary Guidelines must be practical and realistic

Dietary recommendations need to be practical or consumers will not follow them. We need to eat well every day and that means recommending foods that are versatile and likeable enough to include every day but also convenient for current lifestyles.

Yogurt is just such a food. Indeed, people who eat yogurt have been found to have better diet quality and fewer health risks (Wang, Livingston, et al). It is ready-to-eat, requires no preparation, and can be savory or sweet in nearly limitless flavors, fat-free, low-fat, or full-fat, sweetened or unsweetened, low in calories and be included as part of a meal or as a stand-alone snack by all ages of Americans. It also provides 2 nutrients of concern: calcium and potassium and is DASH-diet friendly.

The recent addition of yogurt into the approved choices in WIC food packages clearly affirms that the nutritional and practical value of yogurt in the diets of mothers and children deserves strong support. Plus, yogurt is a healthful food that people already like and feel good about eating. Consumers like positive nutrition messages – they want to hear about what they CAN eat, not what they CAN’T eat or should avoid.
Yet despite yogurt’s nutritional assets, 9 out of 10 people eat less than one cup of yogurt per week (8). This is lost nutrition and it shouldn’t be. A recommendation to include one yogurt every day could go a long way towards helping consumers eat healthier diets, meet dietary recommendations, and reduce their health risks.


I respect your mandate to make evidence-based recommendations. A best case scenario combines the benefits of evidence-based research with practical, realistic guidelines that consumers can easily implement. For the reasons stated above, calling out the importance of a higher protein, nutrient-rich breakfast is worthy of a strong recommendation. I hope you will also show support for recommending one yogurt every day for both its nutritional and practical contributions to nutrient-rich diets for Americans.

Thank you again for your time.

Respectfully submitted,

Keith Ayoob, EdD,RD,FAND

(1) Accessed March 13, 2014.
(2)Mamerow, MM et al.
(3)Leidy et al. (2013)
(4)Wang et al. (2013)
(5)http://appliedresearch.cancer gov/diet/usualintakes/pop/yogurt.html

Affiliation: Industry/Industry Association Organization: Dannon
  • Eating Patterns-Diets (USDA Food Patterns, DASH, Vegetarian, Low Carb, Hi-Protein, etc.)
  • Food industry approaches to reducing sodium, added sugars, and fats
  • Protein (Plant, Animal)

David Wallinga MD, MPA Comment ID #440


David Wallinga, MD, MPA

Comments on Aspects of the 2015 Dietary Guidelines Related to Seafood Consumption; Balancing Nutritional Benefits with Longer-Term Risks Due to Methylmercury Exposure

Dear Dietary Guidelines Advisory Committee:

The literature on risks associated with methylmercury exposure at levels known to exist in seafood is voluminous. As a clinician, the greater challenge is how to communicate to patients the win-win of eating some seafood for its nutritional benefits while avoiding or reducing the mercury risks through smarter seafood choices.

The topic of benefits and risks of seafood consumption has been flagged for a coordinated evaluation by DGAC Work Groups 1 and 3. In fact, the 2015 Dietary Guidelines must give equal weight to both important public health goals: Promoting some fish consumption for the nutritional benefits it confers, but also guiding consumers in choosing low-mercury fish so as to minimize methylmercury exposure, particularly in more vulnerable populations. Here are the thought steps underlying this approach:

1. Methylmercury effects on the developing brain are clearcut, and known to occur at levels of exposure an order of magnitude lower than was recognized when fish consumption advice was first developed (in 2003) that later came to be incorporated into the preceding 2010 Dietary Guidelines was initially developed.

2. Yes, women of childbearing age and young children are at risk of excessive methylmercury exposure. However, several additional subpopulations can be identified that are at heightened risk, and therefore need and deserve guidance to choose low-mercury fish. These include frequent fish consumers, of all ages and genders. Certain ethnic minorities, including here in Minnesota, such as Hmong Americans and Native Americans, consume high fish diets, as do sushi lovers. Many health-conscious individuals have chosen fish as their primary protein source.

3. The type of fish consumed drives both the nutritional benefits (PUFA intake) and risks (methylmercury dose). To optimize the balance between the two, consumers need advice that guides them to choose specific high-PUFA, low-mercury varieties of seafood most often.

To summarize, the Committee should highlight the need for balanced, clear health messages that stress both benefits and risks. We urge it to craft layered, nuanced advice -- advice that includes details of the PUFA and methylmercury content of all popular seafood choices, so that consumers can choose wisely.

Thank you for your consideration.

David Wallinga, MD, MPA
Director, Healthy Food Action
St. Paul, MN 55105

Affiliation: Other Organization: Healthy Food Action
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)
  • Food Environment
  • Food Safety

Thomas R Blakeslee engineer Comment ID #439


Dear Dr. Millen and 2015 Dietary Guidelines for Americans Advisory Committee Members:

The existing USDA dietary recommendations regarding fat have created a $30 billion “low fat” food industry and caused an alarming increase in carbohydrate and PUFA consumption. Since these changes, the incidence of obesity, CVD, CHD, diabetes, cancer and chronic autoimmune diseases has increased dramatically. This committee has a golden opportunity to make recommendations that will restore the health of the people and save billions in future medical costs. But admitting an embarrassing mistake is difficult because we all unconsciously filter our perception through a lens that distorts reality in a way that justifies previous actions. Denial and groupthink produce the “Semmelweis reflex” which causes leading experts to ignore information that contradicts established conclusions.

Critics of the status-quo are often ignored without careful reading because established leaders have dismissed and even mocked them. I would like to suggest that members of the committee make a conscious effort to reread, with an open mind, some 2014 references. Please resist the groupthink tendency to dismiss because you have heard negative comments about the authors. It is natural for peer groups to “shoot the messenger” when the conclusions are embarrassing.

Fat and sugar consumption are highly correlated, so many of the conclusions about fat consumption may have blamed fat when the real culprit was sugar and flour. Another source of confusion is that the word “fat” includes trans fats, which are clearly harmful and also healthy low and medium density saturated fats like coconut, avocado, nuts and cheese. “Saturated fat” is a term that includes good and bad fats, so studies that lump them all together are meaningless.

2014 has seen a major shift in establishment thinking with important publications finally recognizing that a mistake has been made. I encourage the committee to review the April 2014 Mayo Clinic Proceedings paper titled “The questionable benefits of exchanging saturated fat with polyunsaturated fat.” It concludes: “The benefits of replacing SFAs with PUFAs are questionable. There is no evidence that a lower intake of SFA can prevent CVD and a high intake of PUFAs without specification may result in a high intake of omega-6, which is associated with many adverse health effects.Because there is much evidence that saturated fat may even be beneficial, we urge the American Heart Association, the American Diabetes Association, and the National Institute of Clinical Excellence to consider the aforementioned evidence when updating their future guidelines.”

In the March 2014 issue of The Annuls of Internal Medicine, Chowdhurry et al examined 59 trials with over half million participants and concluded that “Current evidence does not clearly support cardiovascular guidelines that encourage high consumption of polyunsaturated fatty acids and low consumption of total saturated fats.”

The March 2014 issue of BMJ has an article by Wise titled “Evidence does not support guidelines on saturated fat”

The Jan 2014 issue of BMJ Open Heart has an editorial by DiNicolantonio called, “The cardiometabolic consequences of replacing saturated fats with carbohydrates or O-6 polyunsaturated fats: Do the dietary guidelines have it wrong?”

Siri-Turano et al reached similar conclusions in a 2010 study published in the American Journal of Clinical Nutrition. They concluded, “there is no significant evidence for concluding that dietary saturated fat is associated with an increased risk of CHD stroke or CVD.”

Sometimes a consensus is reached prematurely but experts are embarrassed to admit that a mistake was made. Ultimately the “elephant under the rug” becomes impossible to ignore and reality must be faced. The staggering expense and pain caused by the “low-fat” campaign is so great that I urge this committee to carefully reconsider the evidence on saturated fats with an intentionally open mind. The rush to judgement of the 1977 Senate committee has done incalculable damage.

request 2-1

Affiliation: Individual/Professional Organization: Clearlight Foundation
  • Energy Balance (Weight Loss, Weight Maintenance, Calorie Intake, Physical Activity)
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)
  • Food industry approaches to reducing sodium, added sugars, and fats

Anonymous Comment ID #438


Please see the attached letter and supporting research. There are five attachments.

Thank you.

Affiliation: Industry/Industry Association Organization: USA Rice Federation
  • Carbohydrates (Added Sugars, Fiber, Glycemic Index, Whole Grains)
  • Energy Balance (Weight Loss, Weight Maintenance, Calorie Intake, Physical Activity)
  • Micronutrients (Sodium, Potassium, Vitamin D, Calcium, Iron)

Anonymous Comment ID #437


I've been interested in finding an example meal log for the duration of about a week (the longer the better) that strictly includes & itemizes the perfect nutritional meals.

I believe this would be helpful if made available to the public along side of the food pyramid. We've all heard the recommendations of "An apple a day, 8 glasses of water, 3 cups of beans a week, etc..", but having these things Incorporated into a visual aid of sample meals could help individuals apply it to their daily lives if not ideally follow it exactly. We know what to eat (fruits, veggies, fiber, omegas... etc) But when and how do we eat it without going over the average 2000 calorie diet?
The suggestions of eating healthy may be useless if we do not know how to apply it (especially with the majority growing up poor and being surrounded with cheap commercialized foods & knowing nothing else). Individuals who do try to apply a healthy diet to their lives may need a little more than just what foods to eat.

I may create such a sample log myself with the proper research from trusted sites as yours. I'd just hate to do so if it already exists. I was imagining 7 photographs of meals (based on the average 2000 cal. diet and what it ideally consists of) laid out like a comic strip with details of what the meals contained (serving size, calories, nutrition details), and having one strip for each meal time (breakfast, lunch, dinner).

Let me know if my requests exists, that'd be very helpful to me.

Thank you so much for your time
-Anita Torres

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

nashoa tawil Comment ID #436


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Affiliation: Public Health Department Organization: dtk
  • Energy Balance (Weight Loss, Weight Maintenance, Calorie Intake, Physical Activity)
  • Fats (Total Fat, Solid Fats, Oils, Fatty Acids, Cholesterol)
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)

Eyassu Abegaz PhD. Comment ID #435


At the March 14, 2014 meeting of the 2015 Dietary Guidelines Advisory Committee, the Subcommittee on Food Sustainability and Safety presented “draft key findings” about the safety of the low-calorie sweetener aspartame. The Ajinomoto Company respectfully submits the attached comments on the current scientific evidence that affirms the safety of aspartame.

Affiliation: Industry/Industry Association Organization: Ajinomoto North America, Inc.
  • Food Safety
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