On February 19, 2015, a group of 14 outside experts who formed
the 2015 Dietary Guidelines Advisory Committee
("Committee") released the Scientific Report of the 2015 Dietary
Guidelines for Americans ("Advisory Report") to
the Secretaries of the U.S. Department of Health and Human Services
and the U.S. Department of Agriculture. Although the
recommendations are nonbinding, the agencies are likely to rely on
the 571-page Advisory Report in developing the Dietary
Guidelines for Americans, 2015, to be jointly released by HHS
and USDA later this year. HHS's Office for Disease Prevention
and Health Promotion takes the administrative lead in developing
the Dietary Guidelines, partnering closely with USDA's
Center for Nutrition Policy and Promotion and USDA's
Agricultural Research Service. As mandated by the National
Nutrition Monitoring and Related Research Act, 1 new
Dietary Guidelines have been published every five years
since 1980 and form the basis of federal nutrition policy,
education, outreach, and food assistance programs used by
consumers, industry, nutrition educators, and health professionals.
The Dietary Guidelines are intended for Americans ages two
and over.
Against the backdrop of data showing that more than two-thirds of
Americans are obese or overweight, the Committee concludes in the
Advisory Report that "a healthy dietary pattern is higher in
vegetables, fruits, whole grains, low- or non-fat dairy, seafood,
legumes, and nuts; moderate in alcohol (among adults); lower in red
and processed meats; and low in sugar-sweetened foods and drinks
and refined grains." In doing so, however, the Advisory Report
focuses less on individual nutrients and more on overall patterns
of eating, highlighting Mediterranean-style and vegetarian diets in
particular.
While much of the Advisory Report reinforces what we saw in the
2010 Dietary Guidelines, and the Committee's
suggestion that we eat more fruits and vegetables is hardly
radical, there are some notable changes with respect to added
sugars, cholesterol, and caffeine, as discussed in more detail
below.
A Focus on Sugar
Although previous Dietary Guidelines warned generally
against eating too much added sugar, the Committee for the first
time recommends in its Advisory Report that Americans limit their
added sugars to no more than 10 percent of daily calories (roughly
12 teaspoons per day) due to the link between added sugar and
obesity and chronic disease. Americans currently consume 22 to 30
teaspoons of added sugar daily, with beverages supplying 47 percent
of added sugars, and sweets and snacks composing 31 percent. Along
those lines, the Committee suggests removing sugary drinks from
schools and endorses a
proposed Food and Drug Administration rule that would require
added sugars to be separately and distinctly labeled on the
nutrition facts panel. 2
But the Advisory Report also warns against relying on artificial
sweeteners rather than sugar, saying that there is little evidence
on the long-term effects of relying on artificial sweeteners for
weight loss and healthy weight maintenance. Instead, the Committee
recommends drinking water in place of sweet beverages.
The shift to focusing on sugar represents a contrast from earlier
Dietary Guidelines. Starting in the 1980s, the Dietary
Guidelines largely encouraged a low-fat diet, in turn
triggering an explosion of sugar-loaded, low-fat processed foods.
The Advisory Report reflects more recent studies showing that
replacing fat with refined carbohydrates can actually threaten
cardiovascular health. The recommendation is also in line with the
World Health Organization's suggested goal of limiting sugars
to 5 percent of daily calories.
Looser Restrictions on Cholesterol
The Committee has eased some of the earlier restrictions on fat and
cholesterol. Previously, the Dietary Guidelines
recommended that cholesterol intake be limited to no more than 300
milligrams per day. But the Advisory Report discontinues this
recommendation "because available evidence shows no
appreciable relationship between consumption of dietary cholesterol
and serum cholesterol." In determining that
"[c]holesterol is not a nutrient of concern for
overconsumption," the Committee aligns itself with other major
health groups, such as the American Heart Association, which
recently backed away from dietary cholesterol restrictions, instead
focusing on reducing added sugars.
This recommendation echoes more recent thinking among nutritionists
and researchers who have argued that the great danger comes not
from eating high-cholesterol foods such as eggs, shrimp, and
lobster, but instead from too many servings of foods laden with
saturated fats, such as fatty meats, whole milk, and
butter.
The comparatively relaxed stance on cholesterol, however, does not
apply to everyone. Experts warn that people with particular health
problems, such as diabetes, should continue to avoid
high-cholesterol foods. And although the Committee is no longer
making a cholesterol recommendation, this new view does not undo
warnings about high levels of "bad" cholesterol in the
blood, which have been linked to heart disease.
Saturated Fat is Still Bad—But That Conclusion is
Controversial
The Advisory Report recommends unsaturated fat—found in fish,
nuts, and olive and vegetable oils—instead of saturated
fat—found primarily in animal foods. The top three sources of
saturated fat in the American diet are cheese, pizza, and
grain-based desserts like cookies and cakes. Specifically, the
Advisory Report recommends that fewer than 10 percent of calories
should come from saturated fat. Sources of saturated fat should be
replaced with unsaturated fat, particularly polyunsaturated fatty
acids ("PUFAs"), found in vegetable oils.
This recommendation reflects the conventional wisdom dating back to
the 1950s that saturated fat increases total cholesterol and
increases the risk of heart disease and stroke. The Committee
concludes that replacing saturated fat with unsaturated fats,
particularly PUFAs, significantly reduces total and LDL
cholesterol. However, the Committee also notes that while replacing
saturated fats with PUFAs can reduce the risk of cardiovascular
events, replacing total fat with overall carbohydrates does not
lower the risk of cardiovascular disease. Accordingly, the
Committee recommends that dietary advice should stress
"optimizing types of dietary fat and not reducing total
fat." In addition, carbohydrates and added sugars should not
be replaced by foods high in saturated fat, but instead should be
replaced by "healthy sources of carbohydrates," such as
whole grains, legumes, vegetables, and fruit and "healthy
sources of fats," such as non-hydrogenated vegetable oils and
nuts/seeds. In other words, "[t]he consumption of
'low-fat' or 'nonfat' products with high amounts of
refined grains and added sugars should be discouraged." This
advice is echoed by organizations such as the American Heart
Association, which recommends limiting saturated fats, although it
notes that "[s]aturated fats are just one piece of the
puzzle" and "you can't go wrong eating more fruits,
vegetables, whole grains and fewer calories."
While the Committee's advice with respect to avoiding
trans fats and refined carbohydrates is in line with
recent trends, the Committee received some criticism from
scientists and others3 regarding its advice against
saturated fat. A handful of recent studies have found no
significant evidence associating saturated fat with an increased
risk of coronary heart disease or cardiovascular disease. Some also
argue that the Dietary Guidelines' repeated warnings
against saturated fat have simply encouraged increased consumption
of grains and processed foods.
Caffeine is Now Okay
The Advisory Report says that healthy adults can have up to 400
milligrams of caffeine a day, or about three to five cups of
coffee. According to the Committee, consuming this level of coffee
"is not associated with increased long-term health risks among
healthy individuals." Moreover, the Committee says,
"consistent evidence indicates that coffee consumption is
associated with reduced risk of type 2 diabetes and cardiovascular
disease in adults" and also shows a "protective
association between caffeine intake and risk of Parkinson's
disease." But the Advisory Report also warns against added
calories from cream and sugars.
Keep Lowering the Salt
Since its first edition in 1980, the Dietary Guidelines
have consistently recommended a reduced sodium intake due to the
relationship between sodium intake and high blood pressure.
Likewise, the Advisory Report states that "[sodium]
consumption continues to far exceed recommendations" and
identifies sodium as "ubiquitous in the current U.S. food
supply" and a "nutrient of public health concern because
of overconsumption." Adults who need to lower their blood
pressure (about 30 percent of U.S. adults) should eat fewer than
2,300 milligrams of sodium per day (the equivalent of about one
teaspoon of salt), or as low as 1,500 milligrams per day to further
reduce blood pressure. The current average sodium intake in the
United States is 3,478 milligrams per day. Mixed dishes, primarily
burgers and sandwiches, are the largest contributor of sodium
intake, comprising 44 percent of sodium intake in American
diets.
A New Consideration For the Environment
For the first time, the Committee explicitly considers the impact
of our food choices on the environment. In its Advisory Report, the
Committee notes that "[t]he major findings regarding
sustainable diets were that a diet higher in plant-based foods,
such as vegetables, fruits, whole grains, legumes, nuts, and seeds,
and lower in calories and animal-based foods is more health
promoting and is associated with less environmental impact than is
the current U.S. diet." The Advisory Report then specifically
recommends three patterns of eating that can achieve a diet that
has less environmental impact: the Healthy U.S.-style Pattern, the
Healthy Mediterranean-style Pattern, and the Healthy Vegetarian
Pattern. (All three patterns contain two cups of fruit per day, two
and a half cups of vegetables per day, three ounces of whole grains
per day, three ounces of eggs per week, and 27 grams of oils per
day, although the quantities of legumes, dairy, and proteins vary
slightly among the three patterns.) Currently, the average U.S.
diet "has a larger environmental impact in terms of increased
greenhouse gas emissions, land use, water use, and energy use,
compared to the above dietary patterns" due to its intake of
animal-based foods.
The focus on sustainable food choices has garnered criticism from
some politicians and industry groups who feel that the Committee
should refrain from fusing nutrition advice with environmental
outcomes. But other groups and coalitions are urging HHS and USDA
to adopt the Committee's recommendations on lower meat
consumption and more sustainable production.
Opportunities for Public Comment
The public can view the Advisory Report and submit comments at
www.DietaryGuidelines.gov until April 8, 2015. On March 24, 2015,
the public can also offer oral comments at a public meeting in
Bethesda, Maryland.
Footnotes
1 7 U.S.C. § 5341.
2 Food Labeling: Revision of the Nutrition and Supplement Facts Labels, 79 Fed. Reg. 11879 (Mar. 3, 2014).
3 See, e.g., Anahad O'Connor, "Nutrition Panel Calls for Less Sugar and Eases Cholesterol and Fat Restrictions," The New York Times, Feb. 19, 2015.
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