OFW Law founding principal Richard L. Frank fills in for former USDA Secretary John R. Block.
There are a variety of disturbing questions surrounding the Dietary Guidelines for Americans now being drafted for release in 2015. The questions relate to whether the Dietary Guidelines Advisory Committee should focus its review and recommendations on the current science on nutrition and diet, or whether it should be working to ensure the guidelines fit a policy agenda. Part I of this mini-series focused on what the Advisory Committee has called “high dose caffeine” products.
USDA and HHS have jointly published the Dietary Guidelines for Americans every five years since 1980. The American public is best served when federal dietary guidance is based on the totality of scientific evidence. In 1990, Congress mandated that the Dietary Guidelines “shall be based on the preponderance of scientific and medical knowledge…current at the time of the report.” Despite these clear instructions and limitations, the 2015 Dietary Guidelines Advisory Committee, at multiple levels, appears to be crafting its recommendations to support government policy and political initiatives, such as placing limits on the amount of “added sugars” in the diet despite the fact there is absolutely no scientific justification for differentiating between added sugars and naturally occurring sugars.
Since 2010, the Dietary Guidelines Advisory Committee has relied on the Nutrition Evidence Library to assist in evaluating new science and developing its recommendations. The NEL provides a standardized and systematic way to evaluate new research which has emerged since the previous Guidelines.
The 2010 Dietary Guidelines recognized that the human body does not differentiate between added sugars and naturally occurring sugars. Unfortunately, the 2015 Advisory Committee is deviating from the Nutrition Evidence Library approach and selectively looking at only those studies and recommendations which support establishing limits on “added sugars.”
Examples of this type of “politically motivated” activity include:
1. Efforts to provide support for the Food and Drug Administration’s controversial proposal to disclose “added sugars” on food product labels, in addition to total sugars, calories, and carbs which are already required.
2. Recommending punitive taxes on certain foods and beverages; and
3. Relying heavily on the controversial USDA Food Pattern Modeling in an effort to support actual limits on “added sugars” consumption.
These limits have not been accepted by the Institute of Medicine or the Food and Drug Administration when it recently refused to set a daily value or intake limit for added sugars.
The Dietary Guidelines should be a practical and achievable set of recommendations based on balance, variety, and moderation. The process should not become a political circus used to impose an agenda without a sound scientific basis or Congressional authority. Hopefully, the Secretaries of Agriculture and Health and Human Services will ensure the Dietary Guidelines recommendations continue to be based solely on the preponderance of scientific evidence, as required by its Congressional mandate.
