Appendix E-7: Public Comments
As a government advisory committee, the Dietary Guidelines Advisory Committee (DGAC) is required by the Federal Advisory Committee Act to function in an open process in which the public may participate. This is accomplished through public submission of written comments and oral testimony given to the DGAC.
Federal Register notices alerted the public to DGAC meetings held in-person and/or by webcast. In these notices the public was invited and reminded to submit their comments to an online database at www.DietaryGuidelines.gov. The public comments process opened on May 29, 2013. Comments continued to be submitted throughout the time the DGAC operated. Following the submission of the 2015 DGAC Report to the Secretaries of HHS and USDA, the Federal government alerted the public of its availability through a Federal Register notice [PDF - 181KB]. This notice also announced a public comment period and the date of an in-person meeting where the public can provide comments to the Federal government about the DGAC Report.
A public comments online database was developed for the 2015 DGAC process based on the structure and content used for the 2010 process, but with many enhancements that were intended to streamline submission of comments by the public and processing by staff.
When submitting comments, the public selected one or more topic areas into which they felt their comments belonged. Initially, these topic areas were: Food Groups, Eating Patterns-Diets, Energy Balance, Carbohydrates, Protein, Fats, Micronutrients, Water and Nonalcoholic Beverages, Alcoholic Beverages, Food Safety, Behavior and Food Environment, Lifespan Needs, and Other. During their deliberations and at the DGACs request, the topic area “Behavior and Food Environment” was split into two distinct topic areas, “Behavior” and “Food Environment,” and a new topic area, “Sustainability,” also was added. Individual submissions were allowed to include up to five attachments, such as journal articles, reports, and other scientific material for the DGAC to consider. The submission page noted that submitters should take care to not violate copyright laws when submitting attachments.
For the first time, the 2015 DGAC requested public comments related to specific topic areas. Subcommittee (SC) 2 requested comments on “steps the food industry is taking or has taken to reduce the nutrients listed below in the food supply, including what nutrients have been increased as a consequence of reductions where applicable: sodium, added sugars, fats (i.e., total fats, saturated fats, trans fats, and other individual fatty acids).” SC 5 requested public comments on “a targeted topic on food system sustainability, including comments from both the private and public sectors and addressing local, regional, national, or international scales. Specifically, it seeks approaches and current examples of sustainability in the food system. Comments are encouraged that address: (a) Elements of a whole food system; (b) Information on specific food groups or commodities; and (c) Sustainability metrics that have been implemented or are in development.”
In addition, for the first time, the Committee also provided specific guidance to the public on “length and timing of public comments.” This guidance was shared through the Federal Register and on www.DietaryGuidelines.gov. This guidance stated to “provide a brief summary (approx. 250 words) of the points or issues in the comment text box.” It asked that “if providing literature or other resources, one of the following forms is preferred: complete citation, as in a bibliographic entry; abstract; electronic link to full article or report.” The public was encouraged to “provide comments as early as possible in the Committees process to increase the opportunity for meaningful impact.” Lastly, as of April 2014, it stated that “a deadline for comment submission prior to each public meeting will no longer be used.”
For all public comments, submitters were required to provide the following information: topic area(s), the comment itself (5,000 character limit), any accompanying attachments, full name (with option to make it public), affiliation, and organization. They also were required to provide their email address, phone number, and zip code, but this information was not included when the comment was posted on the www.DietaryGuidelines.gov public comments page. Submitters were given the option, but not required, to also provide their business or academic credentials and postal address, including country. This information was not posted on the public website. After the comment was submitted, confirmation was provided to the submitter by e-mail.
Staff reviewed each submitted comment. Only a few comments were not posted; reasons were: (1) duplicate submission of another comment posted by the same submitter, (2) test submission, (3) partial comment due to the 5,000 character limit, which was corrected by a shorter comment being submitted, and (4) comments that did not pertain to the DGAC.
At the request of the DGAC, staff generated reports and drafted summaries on each topic area for comments submitted since the previous meeting or since the previous comment summary. On occasion, various Committee members also chose to access the public comments database themselves in order to read comments.
A total of 972 comments were submitted from May 29, 2013 through the closing of the public comments database on December 30, 2014. Of these, 918 were relevant to the DGACs work.
The majority of comments submitted fell into these topic areas: Food Groups; Eating Patterns-Diets; Sustainability; and Energy Balance. However, comments were received in all 18 topic areas and covered a wide range of issues. Comments came from the United States, Australia, India, Spain, Canada, Brazil, France, Belgium, Norway, Iraq, United Kingdom, Pakistan, Indonesia, and Denmark.
In addition to written comments, oral comments from 53 individuals were presented at the January 2014 public meeting. The list of presenters along with their affiliations is located on www.DietaryGuidelines.gov under Meeting 2 (January 13-14, 2014). These 53 individuals each provided 3 minutes or less of testimony before the Committee, and they submitted a brief outline of their comments when registering to participate in the comment session.
The oral and written comments provided by the public were valuable in that they helped the Committee gather background information and understand public and professional perceptions. Comments from the public brought new issues to light as well as new approaches to current issues and emerging evidence. They also highlighted and ensured consideration of topics deemed to be important by the submitters, who represented a variety of backgrounds and focus areas. The public comments will remain archived at www.DietaryGuidelines.gov.