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Hi, thank you for your work. Please be objective when deciding recommendations on sodium. I am still learning myself, but I question the roll of sodium on risk of death. Is it possible we might be going the wrong direction focusing on sodium reduction?Thanks!
There continues to be inadequate scientific evidence that a severely restricted sodium diet is of any benefit for healthy Americans. Placing a quantitative specific level in the 2010 DGA has caused significant problems for the National School Lunch Program (NSLP) because of the way they are tied together in federal code. Please consider taking out the specific quantitative level when writing the 2015 DGA. As a RD, I support the initiative to strive to reduce sodium, but if the NSLP continues it's sodium restrictions, it will be the end of this important federal program.
The Dietary Guidelines should include research-based recommendations for the maximum daily intake of added sugars, such as the American Heart Association's recommendation of no more than 9 teaspoons of added sugar per day for men, 6 teaspoons for women, 5-8 for adolescents and 3-4 for preschool to preteen.Much more than these recommendations are currently being consumed by all age groups with serious public health consequences, as have been researched, analyzed and documented in myriad publications over several decades. With guidelines, a consistent message can be marketed and changes in the amount of sugar allowed in school nutrition services can be implemented.
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.114.0892842. Moss, Michael. “The Extraordinary Science of Addictive Junk Food.” The New York Times, 20 Feb. 2013. Web. 19 Oct. 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.
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.
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.
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.
October 21, 2014From: Edward Groth III, PhD TO: Dietary Guidelines Advisory CommitteeRE: New Studies on Fish Consumption, Methylmercury Exposure and Cognitive DevelopmentDear 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, PhDnedgroth@cs.comI 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.
Request 5-2Our 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.
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Last updated: 10/26/2014