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Dietary Guidelines for Americans, 2015

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Anonymous Comment ID #788

10/22/2014

In recent years, “processed” has become a dirty word for many consumers trying to make healthy food purchases, though ideas and perceptions about what food processing actually entails and implies can vary quite a bit and are not always accurate. Weaver et al. took a close look at this issue in their 2014 report, “Processed foods: Contributions to Nutrition” published in the American Journal of Clinical Nutrition.1 They reviewed not only what “processed” actually means, but also how different processing techniques can affect the cost and nutritional quality of foods and the role that processed foods play in our diet.

While I appreciated the authors’ thorough look at the macro- and micronutrient merits and pitfalls of processed foods, I thought they neglected an interesting and confounding aspect of food processing that contributes to overall poorer nutrition for consumers: product optimization.

Beyond the actual ingredients and nutrients a food manufacturer puts into a food product, many industry giants (Nestlé, Kraft, General Mills, Coca Cola, etc.) also spend a lot of time and resources on the alchemy of product optimization — engineering the perfect product to reach customers’ sensory “bliss point.”2 They scientifically analyze every possible variable and combination of attributes: crunch, color, feel, taste, sound, packaging, product name, and more. They use focus groups, mathematical models, ingredient maps and charts, and neuroscience to perfect a product that will sell well. (Side note: if you’re interested in this subject I would recommend reading this NY Times article from last year; it’s actually quite fascinating.)

The salient point here is that as it is currently used, this systematic approach to designing and selling foods that consumers will crave, purchase, and eat in high quantities comes with a hefty nutritional price tag. This is an approach that appeals to our most basic survival cravings for sugar, salt, and fat — not healthy foods. Though such food product optimization may not by necessity negatively effect the nutrient profile of a food product, it does currently tend to lead to the development of popular processed foods that are higher in “constituents to limit” and lower in “nutrients to encourage,” and thus has a negative impact on overall population nutrition.

This point illustrates what seems to be a common theme or question in population nutrition: who is responsible — the consumer who “chooses” what to buy, the food manufacturer who can craft cheap, craveable, but ultimately unhealthy foods, or the government who sets guidance as to what should be sold, bought, and eaten? (Or d. all of the above?) I see a sort of “monkey-in-the-middle” position for the government here, as it must try to give evidence-based guidance to the public (in the form of the Dietary Guidelines for Americans) but also must consider the economic repercussions that result from any changes in standards and accordingly receives a lot of pressure from the food industry.

I think consumers are at a disadvantage right now, given that many tools used by food processors to sell less healthy foods and make good profits includes the product optimization described above, using misleading information on packaging, preferential product placement in retail outlets — all strategies that put a great burden on the consumer to make healthier purchases. Given this, I think we are at a point — especially with the ongoing development of the Dietary Guidelines for Americans 2015 — where the government should focus more heavily on consumer health and scientific evidence and less on the market interests of food companies and manufacturers.

Going back to the Weaver et al. article, I think they’re right that the word “processed” has taken on an overly-loaded meaning for consumers today. I also agree that the same technologies and sophistication that are giving us the “bliss point” Dorito and snacks like Oreos, Go-gurt, and Red Bull could also be put to good use creating health, nutrient dense, and highly palatable foods more in line with what evidence tells us is good to eat.

References:

1. Weaver, C. M., Dwyer, J., Fulgoni, V. L., King, J. C., Leveille, G. A., MacDonald, R. S., … Schnakenberg, D. (2014). Processed foods: contributions to nutrition. The American Journal of Clinical Nutrition, 99(6), 1525–1542. doi:10.3945/ajcn.114.089284

2. Moss, Michael. “The Extraordinary Science of Addictive Junk Food.” The New York Times, 20 Feb. 2013. Web. 19 Oct. 2014. .

Affiliation: Educational Institution: Higher Education Organization: UNC Chapel Hill
Topic:
  • Other

Anonymous Comment ID #787

10/22/2014

Attached, please find relevant literature references supporting Red Bull North America's comment dated October 21, 2014. Due to file size constraints, this dossier was provided as a separate attachment.

Affiliation: Industry/Industry Association Organization: Red Bull North America
Topic:
  • Food Safety
  • Water & Beverages (Non-alcoholic)

Anonymous Comment ID #786

10/22/2014

On behalf of Red Bull North America, Inc., I am submitting this letter (attached) to supplement the comments we submitted on August 25, 2014. In our earlier submission, we urged the Dietary Guidelines Advisory Committee (DGAC or the Committee) to assess holistically the literature on caffeine safety.

In the present submission, we would like to emphasize that as the Committee prepares to finalize the 2015 Dietary Guidelines for Americans, any meaningful effort to influence dietary caffeine consumption must consider all sources of caffeine in the diet. We also believe the Committee has an opportunity to support the efforts of the Food and Drug Administration (FDA) by promoting the mandatory declaration of quantitative caffeine labeling on all products containing caffeine (despite their product classification as a conventional food or dietary supplement), as well as establishing recommendations for a daily maximum limit for caffeine consumption. We also would like to bring to the attention of the Committee several new and relevant papers pertaining to the regulation of caffeine as an ingredient in the U.S., caffeine exposure, and caffeine when mixed with alcohol. These papers were released ahead of print in the weeks leading up to and following the Committee’s September meeting, and are described in the attachment.

Affiliation: Industry/Industry Association Organization: Red Bull North America
Topic:
  • Food Safety
  • Water & Beverages (Non-alcoholic)

Anonymous Comment ID #784

10/21/2014

Since I submitted two other studies this morning I have been given an additional relevant paper from the Norwegian study mentioned earlier. This one associates prenatal methylmercury exposure at the very low dose levels typical in Norway (comparable to or lower than those here in the US) with low birth weight.

Affiliation: Individual/Professional Organization: Retired
Topic:
  • Food Safety
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)

Edward Groth PhD Comment ID #783

10/21/2014

The attachment here is the Norwegian study I described in Comment #782, just submitted. (I had to copy a PowerPoint presentatiion into a Word document to submit it.) Please see #782 for a brief description of the study and its significance. Note that this is an early report of findings from an ongoing study, presented at a professional meeting, not yet peer-reviewed or published. But it seems like very important new evidence on a pivotal issue.

Affiliation: Individual/Professional Organization: Retired
Topic:
  • Food Safety
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)

Anonymous Comment ID #782

10/21/2014

October 21, 2014
From: Edward Groth III, PhD
TO: Dietary Guidelines Advisory Committee
RE: New Studies on Fish Consumption, Methylmercury Exposure and Cognitive Development

Dear DGAC:

Earlier this year I submitted detailed comments and about 35 studies on mercury, fish consumption and health for the DGAC to consider, via the comment process.

Your deliberations are no doubt far advanced now and you may be well into drafting your reports.

However, I have recently seen two new studies that seem quite relevant to the topic above, so I am attaching them here. I hope, if you judge them important (especially the Norwegian data), you will still be able to take them into account.

The paper by Wu et al. is the first report from mainland China associating neurodevelopmental deficits with prenatal methylmercury exposure from a high-fish diet--in this case, motor/coordination effects in newborns. It joins a cluster of other studies showing such effects in Asian populations with high fish consumption (i.e., Lam et al. in Hong King; Suzuki et al. in Japan; Ng et al. in Taiwan.)

The PowerPoint presentation presentation (no published paper is available yet) by Haugen was given at the International Society of Environmental Epidemiology meeting in Seattle at the end of August. The study it describes was huge—46,750 mother-child pairs. The population eats about 4 times as much fish as US women do, but the mercury exposure levels in Norway and the US are very similar, because the fish we eat here are on average much higher in mercury than those eaten in Norway.

This study found adverse effects of prenatal methylmercury exposure on language development at age 3 years. Exposure above the 90th percentile, which was a dose of 2.82 µg Hg per day, was associated with an Odds Ratio of 2.38 for unintelligible speech.

A striking aspect of the epidemiological studies I submitted in February was the way that the “Lowest Observed Adverse Effect Level” (LOAEL) has dropped over t he past decade. When the 2004 FDA/ EPA Advisory (essentially the basis for the fish consumption advice in the 2010 DGA) was drafted, the best evidence of a LOAEL was a 1997 study in the Faroes, associating adverse effects with a daily dose of 60 µg Hg. Several newer studies I submitted six months ago have suggested effects at doses around 5-6 µg Hg/day. Now, this Norwegian study, with its enormous statistical power, appears to have “reset” the LOAEL once again, to about 3 µg Hg/day.

About 15 percent of US women of childbearing age have daily methylmercury doses above 3 µg/day. This study, like others I submitted, therefore highlights the critical importance of ensuring that women who eat more fish (as they should) choose truly low-mercury fish (i.e., not canned tuna!)

Thank you,
Edward Groth III, PhD
nedgroth@cs.com

I have encountered a problem in that one of the files I wished to upload is a PowerPoint Presentation, which the system will not accept. I will transform it into another format and submit it in a few minutes. However, so as not to lose what I have done here, I am submitting this with the Wu et al. paper now.

Affiliation: Individual/Professional Organization: Retired
Topic:
  • Food Safety
  • Lifespan Needs (Infants, Children, Pregnant Women, Older Adults, etc.)

Anonymous Comment ID #781

10/20/2014

Request 5-2

Our globalized food system is dependent on inexpensive energy to fuel the transportation of food around the world. The farms growing food are often thousands of miles away. In the United States, we have an unhealthy dependence on certain fertile regions to supply a plurality of the produce that we eat.
We must retake our food sovereignty by supporting the development of local and regional food systems. Efficient distribution infrastructure is essential for success; this is generally a weakness for many regional food systems, and deserves particular focus from external benefactors. Many institutions, including universities and hospitals, have sustainability goals. When food is involved, this typically involves a certain commitment to sourcing local products. UNC sources 16% of the food served on campus from within 250 miles; other organizations commit to sourcing up to 40% local. Currently, larger institutions are at a disadvantage because their demand often exceeds the local supply. Aggregating the supply from multiple producers solves this problem; processing partners increase the variety of products available. A collaboration between farmers, food aggregators, and value-added processors can meet the diverse needs of institutional customers, including high-volume demand.
In Michigan, Cherry Capital Foods has exemplified the success of this model. Founded in 2007, they developed partnerships with the Michigan public school system and Kroger, two influential customers that drive Cherry Capital’s $2.2 million in annual revenue. Iowa Choice Harvest demonstrates similar promise. Public policy must reflect our support of these innovations by providing the necessary funding to catalyze their spread.

Affiliation: Individual/Professional Organization: UNC Gillings School of Global Public Health
Topic:
  • Sustainability

Ndang Azang-Njaah Comment ID #780

10/19/2014

Given that greater than 50% of daily consumption of sodium, added sugars, and saturated fat consumed in the American diet is attributable to processed foods, there is greater impetus for food industry firms to modify and provide a healthier product for consumers. Efforts made by the food industry to reduce these nutrients have occurred slowly, albeit with differential levels of communication to health professionals and to the public about how such changes are occurring. While making the transition to a healthier product by food industry firms introduces valid concerns related to increased costs of input, loss of the quality and consistency of a food product, or loss consumer loyalty, many food industry firms have made a successful transition in their efforts to provide a healthier product for consumers.
There have been notable initiatives to reduce the sodium content of foods over the past decade, as the relationship between sodium and cardiovascular disease has been reinforced through scientific literature. One notable initiative, the National Salt Reduction Initiative (NSRI), which is a public-private partnership headed by the NYC Dept. of Public Health established in 2008, has set voluntary targets to reduce the sodium content in packaged and restaurant foods by 25% in over the next 5 years. As firms sign on to the initiative, they pledge for the overall sales for a given food to meet the relevant target for salt content. Currently, over 20 organizations have signed on to the initiative thus far, including food industry firms, Kraft Foods, Butterball, and Heinz. Replacing salt provides notable challenges. Some firms have addressed this concern by substituting salt with herbs and spices, or employing a variety of cooking techniques, like roasting or stewing to retain a concentrated flavor. Other firms have replaced sodium chloride, with potassium chloride, and a various combination of additional ingredients: yeast extracts, monosodium glutamate, umami, vinegar, in order to preserve the integrity of the properties originally attributable to salt.
As reduced sodium products introduced, the publicity of these foods has had a marked difference regarding the audience of choice. Though many firms display their commitment to sodium reduction on their websites, the message provided to consumers is varied. For instance, some messages may display the percentage reduction in sodium, provide a reference to the degree of saltiness, or note the substitutions for more herbs and spices within the product. Other firms have remained mum on reductions and have opted to introduce their lesser sodium food items, without any mention to the change. News reports have documented that firms such as Kraft, who has publicly agreed to the NSRI initiative and promoted a commitment to sodium reduction on their organizational site have remained silent in the most visible manner to consumers- the actual product label. This differential silence to consumers by firms may reflect a general fear of firms that increased publicity of lower sodium foods may lead to a drop in product loyalty and a loss of profit.
There appears to be greater ownership of food products created by firms that reduce added sugars and fats. Firms such as Nestlé have embraced new technologies in product innovation such as ‘slow churning’ ice cream as a method to provide their ice cream brands with half the fat, one third of the calories, while being able to maintain profit margins equivalent to their basic ice cream products. Several firms have also launched a line of “Better For You” products that provide a food that is lower in fats, added sugars, and sodium. Indeed this product line has received noted publicity not only for the formulation of a ‘healthier’ product, but also for the ability for larger firms to produce such a product at an affordable price to consumers en masse.
The call to reduce the content of fats, added sugars, and sodium content in foods is an important initiative that needs to continue in order to address the growing prevalence of chronic disease and in particular its treatment and management. This effort, however, needs to be bolstered by a stronger commitment by firms to communicate to consumers the benefits of choosing a healthier food option if it is truly ‘better for you’. The notable silence on the presence of reduced sodium products by firms to consumers highlights the tension addressing the concerns of consumers, whose goal is optimizing health, and firms, whose goal is to maximize profits. We have already seen evidence that the modified products can raise a profit. It will take time to discern how the consumer’s health behavior and outcomes will change. For the time being I will remain cautiously optimistic.

Affiliation: Individual/Professional Organization: UNC Gillings School of Global Public Health
Topic:
  • Food industry approaches to reducing sodium, added sugars, and fats

Anonymous Comment ID #779

10/18/2014

I am concerned with the phrase "Heart Healthy" and other similar terms used to indicate that the particular food item, cookbook, food label, etc. is healthy for people with heart disease. A great deal of food items, cookbooks, and literature make a claim that the product being promoted is "Heart Healthy". But is it really "Heart Healthy"?
A great number of "Heart Healthy" foods and cookbooks contain a significant amount more sodium per serving than many people with heart disease should be eating in their diet per day.
I think this term can be deceiving to the public. Sodium content needs to be considered while recommending foods that are "Heart Healthy".

Affiliation: Individual/Professional Organization: None
Topic:
  • Food Environment

Anonymous Comment ID #778

10/18/2014

Processed foods contribute "nutrients to encourage" and "constituents to limit" to the American diet. Processing foods yields items with longer shelf lives, but can also create items that are high in sodium, added sugars and fats and very energy dense. The creation of highly processed foods can also have unintended consequences- I'm thinking here of low-fat foods that have higher carbohydrate content in order to create a more palatable lower calorie food, which can leave consumers hungrier after consumption than if the fat was just left in the food. Granted, high saturated fat is a constituent to limit, but so is the addition of sugar. Additionally, just because a food has “no sugar added” doesn’t mean that the caloric content differs drastically from a normal food item, nor does it mean that the food is actually healthier or a better choice, especially if consumed in high quantities.

That being said, I think that the food industry does need to limit the addition of fats and sugars to items to increase their palatability into foods that could not be created at home or in a restaurant without the addition of some complicated food component manipulation. I feel that companies have begun to do this in regards to sodium intake, other commenters have discussed the gradual reduction in sodium intake that some soup companies have begun. I also think there also needs to be a focus on not demonizing different food groups and instead having a discussion about the benefits of having some naturally higher fat foods or foods naturally higher in sugars. I don't want to eat a low-fat avocado or almond, nor do I want to have a low-carb apple or banana, and although that’s a very over-simplified example, I feel that it applies to the greater scheme of processing our foods to reduce “bad” components and increase “good” components.

Affiliation: Other Organization: University of North Carolina
Topic:
  • Food industry approaches to reducing sodium, added sugars, and fats
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