Comments for the Dietary Guidelines Advisory Committee

Comments Prepared by the Academy of Nutrition and Dietetics for the Dietary Guidelines Advisory Committee for the committee's second public meeting.

July 11

America faces a debilitating health crisis that is largely of our own making. Rates of obesity and diet-related chronic disease are on the rise. Our diets are killing too many of us and making too many of us sick. More than ever, we need evidence-based Dietary Guidelines, but we also need strategies and funding and a commitment to implement them so that all Americans can make healthier decisions for ourselves and our families.

The Academy of Nutrition and Dietetics represents 108,000 credentialed women and men committed to evidence-based practice who are making a difference producing lifestyle change and improving health in communities throughout the country—in schools, hospitals and other health care facilities, and private practice.

We have confidence in this Dietary Guidelines Advisory Committee as a body and in the individual members selected to serve on it. Having observed the discussion yesterday and at the first public meeting, all Americans should feel confident in this Committee’s abilities, approach, and astuteness in answering the scientific questions before you and fulfilling your charge outlined in the charter.

Sometimes—rarely actually—our Dietary Guidelines get it wrong. Whether it's the unintended consequences of a focus on total fat or political decisions that reject, weaken, or rewrite recommendations in the scientific report to make them more anodyne, it happens. And we learn from it, and we dig deeper, and we work to ensure the Guidelines evolve as the science evolves. This advisory committee and the USDA and HHS scientists working alongside you are well-suited to this task of distilling the science from the silliness.

The nature of science is iterative, and we have confidence that this Dietary Guidelines Advisory Committee will not miss the forest for the trees. We continue to support a focus on dietary patterns over individual nutrients and taking a systems approach, reflecting the need to think about nutrition as a biological variable. This requires a willingness to see topics and questions anew and cast off guidelines and theories that assumed too much or were overly reliant upon surrogate endpoints that may matter less than we first thought.

The Academy of Nutrition and Dietetics will follow-up with specific comments on proposed protocols, processes, and purposes of the Guidelines and the complexities of nutrition science and systematic reviews. But in the remaining time allotted, we would like to emphasize 3 salient points:

  1. Transparency. The Committee and the Departments to date have worked to implement and incorporate the National Academies recommendations. Where the rubber meets the road is that period and process between submission of your scientific report and the issuance of the final guidelines. We at the Academy are committed to ensuring our final DGAs reflect science, not politics, in accordance with statutory requirements.
  2. Timing. The DGAC charter was issued in October of 2018 for a period of two years. Take the entire two years. You have the new and added responsibility of B-24 recommendations and significant new evidence in the literature. Take all the time you're allotted and get it right rather than getting it—artificially and arbitrarily—fast.
  3. Finally, be bold when the evidence allows it, be humble when the evidence isn’t quite yet there, be honest with the American people about the challenges we face, and be blunt about the evidence-based solutions you recommend and the strategies for achieving them.

Thank you for your service and your commitment to improving public health.