Public Comments on the Scientific Report of the 2015 Dietary Guidelines Advisory Committee

Introduction

The U.S. Departments of Health and Human Services (HHS) and Agriculture (USDA) jointly release the Dietary Guidelines for Americans (Dietary Guidelines) every 5 years. As part of the process for developing the 2015–2020 Dietary Guidelines, HHS and USDA convened an independent 2015 Dietary Guidelines Advisory Committee (Advisory Committee) that was charged with:

  • Examining the 2010 Dietary Guidelines for Americans
  • Reviewing current scientific evidence on nutrition and health
  • Submitting its findings and recommendations to the Secretaries of HHS and USDA in the Scientific Report of the 2015 Dietary Guidelines Advisory Committee (Advisory Report)

The Advisory Report, along with consideration of public and federal agency comment, informed revisions to the Dietary Guidelines.

On February 23, 2015, HHS and USDA published a Federal Register Notice [PDF - 180 KB] to request written public comment on the Advisory Report for a period of 45 days (this period was ultimately extended by an additional 30 days [PDF - 176 KB]). During the 75-day public comment period ending May 8, 2015, HHS and USDA received just over 29,000 public comments on the Advisory Report. These comments were processed and available for public viewing in their entirety by June 1, 2015.

This online summary provides an overview of the public comment process and the themes of public comments submitted on the Advisory Report.

Process

HHS and USDA accepted written public comments throughout the Advisory Committee’s deliberations over 18 months and on its Advisory Report. The written public comments summarized here are those submitted to the federal government on the 2015 Advisory Report. (This summary does not include the 972 written public comments submitted to the Advisory Committee during its work from June 2013 through December 2014.)

The public comment database was designed specifically to receive public insights to inform the 2015 Advisory Committee and subsequently the federal government. It was based on the database used for the 2010 Dietary Guidelines process.

HHS and USDA staff processed and summarized all public comments. This process included:

  • Reviewing each comment
  • Categorizing the comment by relevant Advisory Report chapters or sections
  • Identifying comments that should not be posted (e.g., duplicate or unrelated comments)
  • Summarizing the comment

All relevant comments were posted. See below for information on the 1.25% of comments that were not posted.

Comment Categories & Quantification

Comments by Affiliation

About 93% of comments were submitted by individuals. Of the estimated 7% of comments submitted on behalf of an organization, about 33% represented educational institutions; 19% represented industry organizations; 6% represented professional associations; 6% had an affiliation with state or local government. The remaining 36% were submitted by some other type of group.

Comments by Advisory Report Chapter or Section

About 50% of all public comments submissions were in the category for “Chapter D.5 – Food Sustainability and Safety.” An additional estimated 35% were in the category for the “Executive Summary;” in most cases this was due to the comment addressing more than one section of the Advisory Report. The remaining 15% of comments were on other sections of the Advisory Report.

Comments Submitted as Form Letters and Petitions

Just over 21,000 of the estimated 29,000 comments received were either form letters or petitions. Form letters accounted for about 72% of all submissions. Approximately 21,000 form letters were submitted from 33 different sources. There were 47 petitions submitted, with a total of about 187,000 signatures.

Comments That Were Not Posted

There were 363 duplicate submissions or submissions that were not relevant. Comments determined to be irrelevant included those that were not related to the Advisory Report or the Dietary Guidelines and comments that were vulgar, inappropriate, or blank.

Summary

This summary captures common themes and provides a broad overview by topic of the comments submitted. It is not intended to be an exhaustive description of individual comments received on the Advisory Report. Topics are summarized in alphabetical order. For more detail, view public comments to the federal government on the Advisory Report.

Advisory Committee Membership

Public commenters voiced the opinion that future Advisory Committees should include more registered dietitians, food scientists, and other health professionals and practitioners.

Alcoholic Beverages

Commenters expressed strong opposition to the Advisory Report’s conclusions on alcoholic beverages. Comments included concern that changing the daily drinking limits would encourage binge drinking. Commenters expressed a desire to retain the recommendations of the 2010 Dietary Guidelines, including the definitions of binge drinking, heavy drinking, and moderate drinking. Other commenters suggested removing alcohol from the Advisory Committee’s description of a healthy diet.

Behavior Change

Commenters on behavior change suggested the Dietary Guidelines focus on eating behaviors and health outcomes other than body weight. Commenters supported inclusion of strategies for how families can make healthy choices and how to address cultural differences. Commenters also supported inclusion of the social-ecological model of health behavior.

Dairy

People submitted comments on the beneficial nutrient composition of dairy products. Some commenters pointed out that different types of dairy products can aid in addressing health disparities by providing nutrients in commonly accepted foods and beverages, not all of which induce the negative effects of lactose intolerance. Other commenters stated that dairy products are not needed in the human diet. Multiple commenters discussed the absorption and delivery of calcium found in many plant-based dairy alternatives.

Dietary Cholesterol

Commenters on dietary cholesterol expressed concern over the Advisory Committee’s suggestion to remove the restriction on dietary cholesterol from the Dietary Guidelines. Commenters recommended limiting intake of dietary cholesterol as the body can synthesize the cholesterol it needs. Additionally, commenters indicated that the public would like clarification on recommendations regarding egg consumption.

Dietary Patterns

Commenters supported the Advisory Committee’s “total diet” approach, though some expressed concern that the Committee did not adequately reflect typical American eating habits. Commenters conveyed support for recognizing that a variety of dietary patterns can promote health.

Education and Application of the Dietary Guidelines

The public submitted wide-ranging comments on how the Dietary Guidelines should be applied. Commenters recommended practical, food-based guidelines that support families in achieving nutrient requirements by choosing foods that taste good. Commenters suggested framing recommendations in positive rather than negative statements to encourage greater adherence. Commenters also requested explanations for why long-standing recommendations have changed. Additionally, commenters supported including consumer education materials like MyPlate in the next Dietary Guidelines—some also suggested adding a symbol for water.

Fats

Some commenters supported limiting saturated fats and substituting with monounsaturated and polyunsaturated fats. Others stated that low-fat recommendations are based on “debunked science” and suggested the removal of an upper limit on total fats.

Food Safety

Comments on food safety covered many different topics—for example, recommendations to thoroughly wash all fruits and vegetables before consumption, concern about the perceived lack of consideration of artificial food dyes, and the risk of foodborne illness from consuming uncooked foods. Support for including a discussion of a variety of food safety issues was widespread.

Grains

Commenters expressed that the Advisory Report’s recommendation on grains is confusing and contradictory. Commenters noted that the Dietary Guidelines should distinguish between whole and enriched grains in plain language and in measurement units familiar to the public (i.e., rather than ounce-equivalents).

Meat

Many commenters expressed concern that lean meat was not included in the description of what constitutes a healthy diet. These comments included evidence on the quality and nutrient density of lean meats, differentiating red and processed meats, grass-fed and grain-fed beef, and health outcomes associated with consumption of different types of meat. Some commenters wanted to see more prominent discussion of the difference between plant and animal proteins.

Commenters who did not favor inclusion of meat in the definition of a healthy diet cited concern about cholesterol and saturated fat consumption, as well as antibiotic and hormone use in livestock management. Some commenters stressed that individuals should take into account their own health status when making food choices, and that consumption of lean meats has a place in a healthy diet.

Non-alcoholic Beverages

Commenters were in favor of promoting water and tea, removing sugary drinks from the diet, and including a discussion about energy drinks in the Dietary Guidelines. Commenters suggested that FDA—rather than the Dietary Guidelines—address caffeine in beverages.

Other Nutrients

Many commenters noted the beneficial properties of specific micronutrients. Additionally, some commenters requested that the Dietary Guidelines include a discussion on dietary supplements. Commenters also suggested that the final policy include clear and actionable guidance regarding the types of protein foods that should be a regular part of the diet.

Plant-Based Diets

People submitted many comments on the pros and cons of plant-based diets. Commenters in favor of plant-based diets mentioned the growth of plant-based alternatives available, several individual foods and their beneficial properties, and the importance of promoting plant proteins. They recommended that explicit guidance on how to adopt this style of eating be included in the Dietary Guidelines.

Commenters against shifting to a plant-based diet noted that the American diet is already plant-based and inadequate in nutrients due to the overabundance of refined grains. Others communicated concern over dietary restrictions. Commenters supported the concept of “better” plant food choices—not simply more.

Seafood

Commenters expressed conflicting views on seafood. Some recommended that everyone consume 2 to 3 servings per week, while others suggested removing seafood from the Dietary Guidelines. Commenters expressed general concern about the environmental effects of overfishing and the potential health effects of consuming methylmercury. Commenters also requested clear and actionable recommendations for consuming enough seafood—or a combination of seafood and supplements—to reach the desired levels of omega-3 fatty acids while minimizing the consumption of methylmercury.

Sodium

Public comments on sodium varied. Some commenters said that the Advisory Committee’s conclusion for the general population is appropriate. Others wanted clear guidance that sodium restriction is not for everyone. Some commenters recommended a focus on promoting the 3 proposed dietary patterns as a more realistic approach to managing sodium intake.

Sugar

The majority of comments pertained to added sugars. While some commenters called for limiting added sugars, including high-fructose corn syrup and artificial sweeteners, others encouraged a focus on total calories and portion sizes.

Sustainability

Advocates of including sustainability in the 2015 Dietary Guidelines stated that sustainable diets are good for both the environment and human health—that they are nutritious, socially acceptable, and affordable. Others said that sustainability is premature for inclusion as the relevant science is still developing. Some commenters voiced concerns that sustainable diets are more costly. Commenters also defended the efficiency and sustainability of modern ranching practices.

Note: Unlike other topics, comments received on the topic of sustainability were primarily form letters (n=19,763) and petitions (n=26). A large majority of both form letters and signatories on the petitions favored inclusion of sustainability.

Miscellaneous

Multiple commenters critiqued the Advisory Committee, the Advisory Report, and the science base used to inform the Advisory Report.

Other commenters suggested that the Dietary Guidelines should focus on balance, variety, and moderation; pictorial representations of foods; and practical suggestions for daily and weekly dietary patterns. The commenters largely voiced support for the Dietary Guidelines, particularly guidelines based on science and not influenced by special interest groups.

People also submitted comments on additional topics such as genetically modified organisms (GMOs), food labeling, food security, and processed foods. Some commenters expressed concern that the implications of the Advisory Report may lead to increased government control, which is viewed negatively.