US Dietary Guidelines Scientific Report Draws Record Number of Comments Over Environmental Sustainability Issue

06 Oct 2015 --- As U.S. Health and Human Services (HHS) Secretary Sylvia Burwell, Department of Agriculture (USDA) Secretary Tom Vilsack and the House Agriculture Committee prepare for an Oct. 7 hearing on the process for developing the 2015 Dietary Guidelines for Americans (DGA), FoodMinds LLC is sharing insights gleaned from the 28,643 written public comments recently submitted to the agencies.

Sue Pitman, FoodMinds Co-Founder and Partner, MA, RD told NutritionInsight: “The Dietary Guidelines Scientific Report generated a record number of written comments from the public primarily because of the controversy surrounding the role of environmental sustainability in Dietary Guidelines policy. 80% of the comments were based on form letters and write-in campaigns advocating policy positions promoted by professional associations, environmental, science and consumer advocacy groups, and industry groups, among others. The top three sources were Friends of the Earth, Food Democracy Now and My Plate, My Planet, all groups that support the inclusion of sustainability themes in dietary guidelines.”

The public comment period in the federal government’s multiyear effort to update the DGA provided an opportunity to react to the Scientific Report of the 2015 Dietary Guidelines Advisory Committee. The Report generated a record number of comments – over 2000% more than were received in response to the 2010 Scientific Report. By law, the federal government updates the DGA every five years. The DGA is the cornerstone of federal nutrition policy and nutrition education activities in the U.S. and influences dietary guidance around the world.

To gain a full understanding of public sentiment around the report, FoodMinds undertook the formidable task of reading and analyzing the nearly 30,000 comments submitted to the government between Feb. 19 and May 8.

Top findings include:
•   80% of the comments were based on form letters and write-in campaigns advocating policy positions promoted by professional associations, environmental, science and consumer advocacy groups, and industry groups, among others. The top three sources were Friends of the Earth, Food Democracy Now and My Plate, My Planet. All three groups support the inclusion of sustainability themes in dietary guidelines.
•   Of the 32 topics tabulated in the analysis, the most popular topics among independent, non-form letters were sustainability, meat/processed meat consumption, plant-based diets and added sugars.
•   Less than 2% of the comments were from industry representatives or industry trade associations.
•   Nearly 80% of comments were contributed anonymously.

“We are bringing this analysis forward to provide a fresh perspective on the public’s role in the development of national nutrition policy,” said FoodMinds Co-Founder and Partner Susan Pitman, MA, RD. “Independent citizens, academic experts and food and nutrition stakeholders all weighed in on the Advisory Committee’s Scientific Report as part of the government’s process; however, this analysis shows the Report sparked controversy and mobilized interest groups to advocate on policy rather than on the science behind the recommendations.”

“Ultimately, the question is whether dietary guidelines can contribute to improvements in public health. It is important to note that this question has not been evaluated scientifically. Dietary guidelines may be only one step in a process to promote public health – perhaps the government and allied health professional organizations need to develop a plan to implement the guidelines. Such a plan has never been in place. And this may require more than five years to develop. For example, the country is still wrestling with changes to the National School Lunch Program (NSLP) as a result of the 2005 and 2010 dietary guidelines.”