Attachment to Comments on the 2015 Scientific Report of the Dietary Guidelines Advisory Committee

Prepared by Jordan Faires, Union of Concerned Scientists

24 March 2015

Over the past 35 years, the Dietary Guidelines for Americans (and the Dietary Guidelines Advisory Committee(DGAC) reports) have broadened fromindividual-level factors influencingfood consumption tothe complex and systemic factors influencingthe health of Americans. Recent reportshave addressed issues ranging from racial health disparities to limiting screen time to sustainable agriculture. Given the inclusion of these broad subjects in prior Guidelines,the inclusion of environmental sustainability in the 2015 Dietary Guidelines has ample precedent. This paper documents elements in theDietary Guidelines for Americansand DGAC reports that reach beyond individual-level factors related to consumption.

While the Guidelines began as a voluntary outreach tool, they have become a legally-mandated technical document that conveys scientific information to the public. The 1980, 1985 and 1990 Dietary Guidelines were issued voluntarily by the Department of Health and Human Services (DHHS) and the Department of Agriculture (USDA). However, the 1995 version was the first report produced under Section 3 of the National Nutrition Monitoring and Related Research Act of 1990 (Law 101-445), , which charged DHHS and the USDA with releasing the Dietary Guidelines every five years. As the mechanism for producing the report changed, so did the purpose. The Guidelines process is now both an outreach tool and a comprehensive, rigorous technical assessment ofthe best-available science related to diet and health.

Recognizing the role that economic, social, and political systems play in human health, the DGACaddresses questions that are holistic, systems-based, and future-oriented. In the 2010 report, the DGAC states, “all segments of society—from parents to policy makers and everyone else in between—must now take responsibility and play a leadership role in creating gradual and steady change to help current and future generations live healthy and productive lives.”

From 1980-2010, the DGAC’s reports includedsubjects outside of a narrow view of diet and consumption, such as:

  • Sustainable agriculture and aquaculture(2010 DGAC report and Dietary Guidelines)
  • Healthcare costs (1995 DGAC report)
  • Access to healthy food (2005 DGAC report, 2010 DGAC report and Dietary Guidelines)
  • Physical activity (1980-2010 Dietary Guidelines, 1995-2010 DGAC reports)
  • Plant-based foods and meat consumption
  • Societal barriers to health and systemic change

A conclusive list of topics discussed in either the Dietary Guidelines or DGAC reports can be found at the end of this document.

Sustainable agriculture and aquaculture

Since the DGAC only began considering systemic issuesin 2005, it does not come as a surprise that environmental sustainability has only been broadly discussed. Both the 2010 DGAC Report and the 2010 Dietary Guidelines recommended “develop[ing] and expand[ing] safe, effective, and sustainable agriculture and aquaculture practices to ensure availability of recommended amounts of healthy foods to all segments of the population” (2010 Dietary Guidelines, p 57).Both the DGAC and the Guidelines themselves already publically recognize that the sustainability of the American food system underpins food access and security for American citizens. Sustainability itself is a health issue. Unsustainable food production can contribute to air and water pollution and negatively impact human health, while the sustainability of food systems is necessary for long-term food security (Lang and Barling 2013).

Healthcare costs

Past DGAC reports have addressed the future-oriented impacts of diet on economic and social systems. In the 1995 DGAC Report, the Committee concluded that “the advice in the 1995 Guidelines, if followed, will lead to the improved health status of Americans and reduced health-sector costs.” This was one of the first references to the impact of diet on healthcare costs.

Access to healthy food

The 2005 DGAC Report was the first to conclude that the cost and availability of fruits and vegetables plays a direct role in healthand health disparities across racial groups. The 2005 DGAC Report was the first to highlight dietary change as a way to mitigate disparities, explaining that social action and educational efforts were required to facilitate change. The 2010 Guidelines specifically called for “recognize[ing] health disparities among subpopulations and ensure[ing] equitable access to safe and affordable healthy foods and opportunities for physical activity for all people” and “expand[ing] access to grocery stores, farmers markets, and other outlets for healthy foods” (p 57). The 2010 DGAC report also calls for creating “greater financial incentives to purchase, prepare, and consume vegetables and fruit, whole grains, seafood, fat-free and low-fat milk and milk products, lean meats, and other healthy foods.”

Physicalactivity

Recommendations on physical activity have been included in the Dietary Guidelines since the first iteration in 1980. While the first Dietary Guidelines focused on the inverse relationship between physical activity and weight, later Guidelines (2005 and 2010) examined reasons why Americans were not exercising enough.

The 2005 DGAC Report recognized that societal barriers to physical activity, such as safe places to be active and accessible outdoor places, were directly tied to health. The 2010 Dietary Guidelines wentone step further, recommending that physical activity in schools and childcare centers be improved through physical education programs, recess and active transportation such as biking and walking to school. The 2010 Guidelines also advised limiting screen time (in front of a television, video game or computer) to maintain good health.

Plant-based foods and meatconsumption

While the Guidelines have never directly advised that consumers should “eat less meat,” the DGAC began recommending that plant-based foods, such as fruits, vegetables, and whole grains, be the “foundation of your meals” in 2000 (2000 DGAC Report, p 28). They also recommended that the Guidelines should focus on lean meat, replacing some red meat and poultry with seafood. These recommendations have remained consistent through the 2010 Dietary Guidelines, with the 2010 DGAC Report concluding that scientific evidence suggests that Americans should shift food intake patterns to a more plant-based diet, increase the intake of seafood, and lower-fat milk products and consume only moderate amounts of lean meats, poultry, and eggs.

Societal barriers to health and systemic change

The 2010 DGAC Report discussed the reasons why Americans were not following the Dietary Guidelines. Government regulations and policies, especially land use policy and economic incentives for food manufacturerswere not supporting healthy choices for Americans. The DGAC urged a strategic plan that involved “individuals, families, educators, communities, allied health professionals, public health advocates, policy makers, scientists, and small and large businesses (e.g., farmers, agricultural producers, food scientists, food manufacturers, and food retailers of all kinds)” (p 53) to create a systemic change in American society, and also recommended that zoning policies be altered to promote the responsible location of fast food outlets around schools and recreational areas (p 54). The 2010 Committee also recommended developing and enforcing regulations on the marketing of food and beverage products to children (p 54).

Conclusions

The inclusion of environmental sustainability concerns in the 2015 DGAC report is not at all unprecedented. The 2010 DGAC Report and Guidelines themselves recommend increasing environmentally sustainable food production to support a healthy diet. The systems-based approach of the 2010 Report, their inclusion of societal-level barriers like land use policy and commercial interests and their interest in the health of future generations of Americans all suggest that more detail exploration of environmental sustainability is well within the spirit of the Dietary Guidelines.

Contact:

Douglas Boucher, PhD

Director, Climate Research and Analysis

Union of Concerned Scientists

List of topics referenced in either Dietary Guidelines (DG) or Dietary Guidelines Advisory Committee Reports (DGAC):

  • Physical activity (DG 1980-2010, DGAC 1995-2010)
  • Alcohol consumption, warnings against use of driving or machinery (DG 1980-2010, DGAC 1995-2010)
  • Reducing healthcare costs through diet (DGAC 1995)
  • Poverty as a barrier to nutritional implementation (DGAC 1995, DGAC/DG 2010)
  • Racial health disparities (DGAC 2005, DGAC/DG 2010)
  • Cost and availability of fruits and vegetables (DGAC 2005, DGAC/DG 2010)
  • Geographic distribution of fast food and convenience store vs. grocery stores (DGAC/DG 2010)
  • Opportunities for safe and enjoyable outdoor activities (DGAC 2005, DGAC/DG 2010)
  • Benefits of plant-based diets (DGAC/DG, 1995, 2000, 2005, 2010)
  • Reducing screen time (i.e., television, video games, computer use (DGAC/DG 2010)
  • Sustainable agriculture and aquaculture (DGAC/DG 2010)
  • Land use policy and zoning policy (DGAC 2010)
  • Food safety and technology (hand sanitation, kitchen cleanliness, temperature control) (DGAC/DG 2000-2010)
  • Economic incentives for food manufacturers as barrier for health (DGAC 2010)
  • Increasing comprehensive education for health, nutrition and physical education (DGAC 2010 in most depth, but included in prior years)
  • Improving public/private partnerships for health (DGAC/DG 2010)
  • Developing legislation and policies in diverse sectors (public health, retail, transportation, etc.) (DGAC/DG 2010)
  • Limiting food and beverage marketing to children (DGAC/DG 2010)

References

Lang, Tim and David Bartling. 2013. Nutrition and sustainability: an emerging food policy discourse. Proceedings of the Nutrition Society 72: 1-12.