October 10, 2017
John Howard, MD, MPH, JD, LLM, MBA
Director, National Institute for Occupational Safety and Health
Centers for Disease Control and Prevention
National Institute for Occupational Safety and Health
NIOSH Docket Office
1090 Tusculum Avenue
Cincinnati, Ohio 45226-1998
Re: Draft National Occupational Research Agenda for Cancer, Reproductive, Cardiovascular and Other Chronic Disease Prevention - CDC-2017-0068; NIOSH-299
Dear Dr. Howard,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Centers for Disease Control and Prevention (CDC) at the United States Department of Health and Human Services (HHS) related to its August 9, 2017 docket item, "Draft National Occupational Research Agenda for Cancer, Reproductive, Cardiovascular and Other Chronic Disease Prevention” (hereafter, the DNORA). Representing more than 100,000 registered dietitian nutritionists (RDNs)1, dietetic technicians, registered (DTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to supporting provision of essential food and nutrition services to the public in multiple settings, including in the allied health, primary care, and corporate wellness settings.
The Academy supports the DNORA and emphasizes its particular support for the DNORA’s focus on preventive care and its concomitant potential to encourage provision of evidence-based preventive and wellness services in workplace settings in addition to novel research useful in developing and testing such services.
A. Significance of Worksite Health Environment
Given the significant amount of time Americans spend in the workplace, the health effects of our respective occupational settings cannot be understated. Assuming an eight-to-nine hour workday2 and noting that Americans are spending 41% of every food dollar on food purchased away from home,3 worksite food consumption should be recognized for its substantial expected contribution to overall nutrition and calorie intake and thus an effect on health status. CDC already recognizes various nutrition and lifestyle habits as potentially useful targets for effective worksite interventions, such as increasing physical activity and fruit and vegetable intake, reducing red meat intake, and supporting healthy weight management.4
Americans’ tendency to consume fewer fruits and vegetables than the Dietary Guidelines for Americans 2015 recommends is well-documented.5 In 2013, 39% and 23% of Americans reported consuming less than one serving of fruit and vegetables, respectively, per day.6 Simply providing a worksite cafeteria increased the likelihood of consuming at least two servings of either fruits or vegetable by 28% and decreased the tendency to eat fast food twice weekly by 20%.7 Notably, Healthy People 2020 included nutrition services in the worksite as an objective.8
B. Need for Health Promotion and Disease Prevention
It is the position of the Academy that primary prevention is the most effective, affordable course of action for preventing chronic disease. Cost-effective interventions that produce a change in personal health practices are likely to lead to substantial reductions in the incidence and severity of the leading causes of disease in the United States.9 In an era of increasing health care expenditures and relative decreases in availability of federal funds, the value of cost-effective health promotion and disease prevention efforts is substantial.
Indeed, large studies looking at the relationship between modifiable risk factors and medical claims showed that several risk factors, including tobacco use, overweight and obesity, high blood glucose, high stress, and lack of physical activity, accounted for an estimated 25% of total employer healthcare expenditures.10 Accordingly, the DNORA provides a prime opportunity to encourage and emphasize the potential role of worksite support systems to improve not only health, but also productivity and absenteeism.
The Academy strongly supports the federal government’s helpful role in the assessment of effective worksite wellness measures through continuation of funding research, vetting relevant resources, and the sharing of best practices and strategies from successful evidence-based workplace wellness programs. Selected clinical and community preventive services that have a positive influence on personal health and are cost-effective in comparison with the treatment of disease should be highlighted and encouraged in agency guidance.11, 12 The results of prevention effectiveness studies should provide a basis for CDC's public health program recommendations, guidelines for prevention, and a framework for resource-based decision-making. The current inclusion of workplace interventions for chronic disease in the National Research Agenda is laudable, and the benefit from this agenda item could be maximized by including a focus on comparative effectiveness research to identify successful intervention program components, including the training and preparation of program managers.
The Academy appreciates the opportunity to comment on the proposed information collection for the Draft National Occupational Research Agenda for Cancer, Reproductive, Cardiovascular and Other Chronic Disease Prevention docket. Please contact either Jeanne Blankenship at 312/899-1730 or by email at firstname.lastname@example.org or Mark Rifkin at 202/775-8277 ext. 6011 or by email at email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Vice President, Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Mark E. Rifkin, MS, RD, LDN
Manager, Consumer Protection and Regulation
Academy of Nutrition and Dietetics
1The Academy approved the optional use of the credential “registered dietitian nutritionist (RDN)” by “registered dietitians (RDs)” to more accurately convey who they are and what they do as the nation’s food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
2Average hours employed people spent working on days worked by day of week. Bureau of Labor Statistics, American Time Use Survey, June, 2017. Accessed October 1, 2017.
3Table A. Average annual expenditures by major category of all consumer units and percent changes, Consumer Expenditure Survey, 2011–14 BLS Reports, October, 2016.
4Cancer Prevention in the Workplace Writing Group. Cancer Prevention and Worksite Health Promotion: Time to Join Forces. Prev Chronic Dis 2014;11:140127.
5U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015–2020 Dietary Guidelines for Americans (Figures 2-3, 2-4). 8th Edition. December 2015.
6Dodson EA, et al. The Impact of Worksite Supports for Healthy Eating on Dietary Behaviors. J Occup Environ Med. 2016 Aug;58(8):e287-93.
8Healthy People 2020 [Internet]. Washington, DC: U.S. Department of Health and Human Services, Office of Disease Prevention and Health Promotion [cited October 7, 2017].
9U.S. Preventive Services Task Force. "Guide to Clinical Preventive Services." AHRQ website. Accessed June 23, 2016.
10Goetzel R, Ozminkowski R. The Health and Cost Benefits of Work Site Health-Promotion Programs. Ann Rev Pub Health 2008; 29:303-23.
11U.S. Preventive Services Task Force. "Guide to Clinical Preventive Services" (accessed January 24, 2013).
12Tengs TO, Adams ME, Pliskin JS, Safran DG, Siegel JE, Weinstein MC, Graham JD. Five-hundred life-saving interventions and their cost-effectiveness. Risk Analysis. 1995;15:369-390.