FDA, USDA, MyPlate, oh my! The lack of evidence in U.S. nutrition policy

I didn’t pass the qual last month.

My initial reaction was hurt, frustration, and anger. I didn’t want to tell anyone.

I pride myself on academic excellence, so being asked to retake the Nutritional Sciences Ph.D. qualifying exam because I didn’t know enough nutrition policy was a hard blow.

But it’s true. I’d been so focused on learning the intricacies of evidence-based nutrition science and how it can be applied to help people through functional medicine that I hadn’t paid a lick of attention to politics.

A few weeks have passed and I’ve started to think: “What’s the opportunity in this?”

I’ve shifted my perspective, and have nothing but respect and deep gratitude for the committee’s decision. I’ve realized that this will simply raise the standards by which I can communicate (and more importantly, refute and actively work to reform) nutrition policy, ultimately making me a better nutrition scientist and physician.

Now that I’ve unloaded that…

One of the reasons I love writing is that it forces me to engage with and learn material at a deeper level. So, I wrote this article to help myself better understand nutrition policy, unsure of whether I would end up publishing it, but ultimately decided it was worthwhile to my readers. If you’d like to learn along with me and hear my take on the government guidelines for nutrition, please read on.

The U.S. agencies that shape nutrition policy

governing agencies

FDA:

Established in 1938, the Food and Drug Administration (FDA) is a federal agency of the United States Department of Health and Human Services (DHHS) that regulates more than $2.4 trillion worth of consumer products.1 The FDA oversees food safety, dietary supplements, vaccines, prescription and over-the-counter drugs, blood transfusions, medical devices, and animal feeds.

The FDA also has the authority to monitor claims made in labeling about the composition and health benefits of foods and carries out research and development activities to develop standards that support its regulatory role.

In 2009, nine FDA scientists came forward to report pressures from FDA managers to manipulate data and appealed to President Obama to restructure the agency. In their words: the FDA was “corrupted and distorted by current FDA managers, thereby placing the American people at risk”.  Similar concerns were highlighted in a 2006 report on the agency.2 As of April 2017, 42.5% of the $4.7 billion FDA budget is funded by industry.

USDA

The United States Department of Agriculture (USDA) is a U.S. federal executive department responsible for federal law related to farming, agriculture, forestry, and food. The economy of the early U.S. was mostly agrarian, and many government officials sought new and improved varieties of seeds, plants, and animals for import to the U.S. 

Today, about 80% of the $140 billion budget goes to fund the Food and Nutrition Service Program, the largest component of which is the Supplemental Nutrition Assistance Program (SNAP). SNAP provides food to over 40 million people each month, though a 2015 systematic review found that it’s not enough to support healthy food choices.3 The USDA also regulates the standards of organic products and plays a role in overseas aid by providing developing countries with surplus foods.

It also assists farmers and food producers with the sale of crops on both the domestic and global markets through farm subsidies, which supplement the income of farmers to influence the crops and supply. Among the top subsidized crops are corn, wheat, soybeans, dairy, and sugar. Meanwhile, unequivocally healthy foods, like fruit and vegetables, are not subsidized. Is it really any wonder why chronic disease is on the rise, when the government is subsidizing the primary ingredients in processed junk foods?

 

National Academy of Medicine

Founded in 1970, the National Academy of Medicine (NAM), previously called the Institute of Medicine (IoM) is a non-governmental, non-profit organization. The NAM provides advice on issues of national importance relating to medicine, health, and biomedical science and “aims to provide unbiased, evidence-based, and authoritative information and advice concerning health and science policy to policy-makers, professionals, leaders in every sector of society, and the public at large.“

NAM expert volunteer scientists serve without compensation, and every attempt is made to avoid bias or conflict of interest. Committee reports undergo extensive review by a group of external experts, and reports are freely available to the public.

Within the NAM, the Food and Nutrition Board (FNB), established in 1940, is responsible for studying the safety and adequacy of the U.S. food supply. The FNB regularly publishes guidelines for what they deem to be good nutrition. While they are technically a non-government entity, most FNB studies are funded by federal, state, and local governments. Private industry and foundations can also request and initiate studies.

Means of communicating nutrition policy to the public

Each agency has its own role in communicating nutrition policy to the public. Here, I’ll discuss each in turn and give my take on their benefits and shortcomings.

DRIs

The Food and Nutrition Board of the NAM is responsible for establishing the Dietary Reference Intakes (DRIs) for vitamins and minerals. DRI is a general term for a set of reference values used to advise nutrient intake for health. The reference values include:

Estimated Average Requirements (EAR): the amount of a nutrient that is adequate for 50% of Americans to avoid risk of inadequacy

Recommended Dietary Allowances (RDA): the amount of a nutrient that is adequate for 98.5% of Americans to avoid risk of inadequacy

Tolerable Upper Intake Level (UL): a level set a safe fraction below amounts that are toxic and shown to cause health problems. The FNB has set ULs for seven vitamins.

Adequate intake (AI): approximates nutrient intake believed to be adequate for healthy people for nutrients in which an EAR or RDA has not been determined.

The figure below summarizes the DRI reference values. DRIs are specific for age, sex, and pregnancy status. The DRI documents also describe the signs and symptoms of nutrient deficiencies.

Source: National Academies Press

My take: Established by the NAM, we can largely trust the DRIs to be evidence-based. However, it’s important to note that the RDA is often NOT sufficient for optimal health.

Take Vitamin C, for instance. The RDA for Vitamin C is set at 60 mg/day, which is sufficient to prevent scurvy. However, Vitamin C is an incredibly important antioxidant, and amounts of 120mg/day to upwards of 1,000 mg/day are more aligned with optimal health and disease prevention.4

 

Food labeling:

While the NAM makes suggestions for which information is presented on nutrition facts, food labeling is ultimately regulated by the FDA. To make things more complicated, the FDA has a few terms that it uses that are different from DRIs:

Reference Daily Intake/Recommended Daily Intake (RDI): an estimation of nutrient needs based on a 2,000 calorie diet for everyone, regardless of age, sex, or pregnancy status.

Percent Daily Values (%DV): the amount of a nutrient in one serving of a food, relative to the RDI. This is the number you see on nutrition facts labels.

The FDA recently proposed several changes to food labeling for the first time in over 20 years, based on “trends of consumption of nutrients of public health importance”. The proposed changes included:

  • A new design requiring beverages with more than one serving to more accurately reflect how many calories an individual is actually consuming
  • Removing “calories from fat” and instead focusing on total calories and type of fats in a product
  • Requiring product labels to list added sugar
  • Declaring the amount of Vitamin D and potassium in a product, such that the nutrients of public interest (iron, calcium, potassium, and Vitamin D) appear on the label.

The Final Rule was issued in May 2016, moving the deadline from July 2018 to January 2021 for manufacturers to comply with the new labeling guidelines.

Several changes to the DVs were also issued in 2016:

Health claims:

The FDA also regulates health claims made on food packages, which are allowed for ten diet and health relationships “based on proven scientific evidence”. These include:

  • Calcium, Vitamin D, and osteoporosis
  • Fiber-containing grain products, fruits, and vegetables and cancer
  • Dietary fat and cancer
  • Fruits, vegetables, and grain products that contain soluble fiber and heart disease
  • Soy protein and heart disease
  • Stanols/sterols and heart disease
  • Saturated fat and cholesterol and heart disease
  • Sodium and hypertension
  • Non-cariogenic sweeteners and dental caries
  • Folate and neural tube defects

My take: I can’t remember the last time I looked at the number of calories or the amount of saturated fat in a packaged food. I may occasionally look at the amount of sugar or fiber in a product, but ultimately, nothing on a nutrition facts label is as important as the ingredients. Three grams of high-fructose corn syrup and three grams of cane sugar have WIDELY different effects on human metabolism. Besides, we should be focusing on eating REAL FOOD, and real foods don’t come in a package with a nutrition facts label.

That being said, I do think that overall, the 2016 labeling changes will be beneficial. At least they’ve become a little more relaxed about fat consumption, increased the daily value for fiber, and required added sugar to be listed. Too bad it’s going to take another four years for any of these changes to be implemented!

As for the health claims, the only people who stand to benefit from these claims are the food companies. Many claims are lobbied for by industry and the “evidence” for them is based on systematic reviews conducted by industry-funded research.

Lastly, I’d like to see more regulation and formal definitions for terms like “natural”, “pastured”, “free-range” and “grass-fed”. These terms regarding crop and animal production methods can greatly influence the nutrient content of a product.

MyPlate

In the U.S., nutritional recommendations are established jointly by the US Department of Health and Human Services and the USDA. The Four Food Groups was the reigning nutrition guidelines from 1956-1992, and was replaced by the Food Guide Pyramid in 1992. The Food Pyramid was replaced by MyPlate in 2011. The plate concept was believed to be superior because of its simplicity, showing relative quantities of the food groups in a place setting.

Source: USDA

Until 2011, the fats group represented a tiny fraction of MyPyramid, under the direction to eat as little as possible. With the introduction of MyPlate, fats lost a place altogether.

My take: Frankly, I’m not sure what business the Department of Agriculture has in determining the appropriate diet for Americans in the first place, but it’s no surprise that they encourage Americans to eat the very crops that they subsidize.

If you’ve read some of my previous articles, you know that I don’t endorse grains as a health food. While many traditional cultures consumed grains, they went to extensive lengths to soak, ferment, and sprout them to increase their nutrient availability and inactivate plant toxins like lectins and phytates. A food plate based on science would have vegetables as the largest component.

The inclusion of milk as an essential part of a healthy diet is puzzling, given that many people are lactose intolerant, and a number of traditional cultures have historically consumed little to no dairy products yet maintained health. The dairy industry has been accused of pressuring the USDA to increase recommendations for milk consumption in the food pyramid, and now in MyPlate.5

The avoidance of fat is also highly problematic, as fat is essential for cell membrane integrity and cognitive function, and is also beneficial for blood sugar regulation. More on that later.

Dietary Guidelines for Americans

In addition to MyPlate, the USDA and DHHS also jointly release a document called the Dietary Guidelines for Americans (DGA) every five years. The 2015 guidelines can be summarized as follows:

1) Follow a healthy eating pattern across the lifespan. Choose a healthy eating pattern at an appropriate calorie level.

2) Focus on variety, nutrient density, and amount. Choose a variety of nutrient-dense foods across all food groups.

3) Limit calories from added sugars and saturated fats and reduce sodium intake.

4) Shift to healthier food and beverage choices.

5) Support healthy eating patterns for all. Everyone has a role in helping to create and support healthy eating patterns.

They further define a healthy eating pattern as including:

  • A variety of vegetables from all the subgroups – dark green, red and orange, legumes, starchy, and other
  • Fruits, especially whole fruits
  • Grains, at least half of which are whole grains
  • Fat-free or low-fat dairy, including milk, yogurt, cheese, and/or fortified soy beverages
  • A variety of protein foods, including seafood, lean meats and poultry, eggs, legumes, and nuts, seeds, and soy products
  • Oils

According to the 2015 DGAs, a healthy eating pattern also limits saturated fats, trans fats, added sugars, and sodium. Alcohol should only be consumed in moderation. They further suggest that Americans should meet the Physical Activity Guidelines for Americans to help maintain a healthy body weight.

Lastly, they identified five nutrients of public health concern for underconsumption (vitamin D, calcium, potassium, iron, and fiber) and two nutrients of public health concern due to overconsumption (saturated fat and salt).

My take: The DGAs are so far from evidence-based its laughable. Before the 2010 DGA committee meeting, the USDA set up the Nutrition Evidence Library (NEL) to help conduct systematic reviews using a standardized process for selecting and evaluating relevant studies. This was supposed to reduce bias in developing the DGAs. However, in the committee’s 2015 report, NEL reviews were not used for more than 70% of the topics, including some of the most controversial issues in nutrition science! An investigation conducted by the British Medical Journal found:

“The expert report underpinning the next set of US Dietary Guidelines for Americans fails to reflect much relevant scientific literature in its reviews of crucial topics and therefore risks giving a misleading picture […]. The omissions seem to suggest a reluctance by the committee behind the report to consider any evidence that contradicts the last 35 years of nutritional advice.”6

In place of NEL reviews, the committee relied on systematic reviews from the American College of Cardiology (ACC) and the American Heart Association (AHA), both of which are heavily influenced by the food and drug industries. Let’s look at a few of the issues they glazed over in the most recent DGAs:6,7

Saturated fat: Prior to 2015, several meta-analyses and systematic reviews failed to confirm a relationship between saturated fat and heart disease.8–10  However, DGA committee members did not request an NEL review that would review this new literature, instead relying on a review by the ACC and AHA and the NEL review. They concluded that the evidence linking saturated fat to cardiovascular disease was “strong” and recommended extending the current 10% of total calories limit on saturated fats.

Low-carb diets: Despite increasing evidence that low carbohydrate diets are effective for weight loss, reducing heart disease risk, and controlling type 2 diabetes,11–14 the 2015 committee did not request an NEL systematic review on the topic. Instead they reported that they conducted “exploratory searches” (i.e. cherry picked studies).of literature from the past decade and a half.

Plant-based diets: Perhaps the most significant shift in the committee’s recommendations has been an increased emphasis on plant-based diets. An NEL review concluded that evidence for vegetarianism to fight disease is “limited”, yet the committee introduced a “healthy vegetarian diet” as one of the three recommended diet, the other two being “healthy Mediterranean-style” and “healthy US-style”. In fact, none of the “healthy” diet patterns had strong evidence for protecting against osteoporosis, diabetes, or neurological or psychological illnesses!

Salt: The committee concurred with a recent NAM report that stated that the evidence is “inconsistent and insufficient to conclude that lowering sodium intakes below 2300 mg/day will have any effect on cardiovascular risk or overall mortality”. Yet the report still recommends that sodium intake should be less than 2300 mg/day!

Head committee member Barbara Millen told The BMJ:

 “’You don’t simply answer these questions on the basis of the NEL. Where we didn’t feel we needed to, we didn’t do them. On topics where there were existing comprehensive guidelines, we didn’t do them. We used those resources and that time to cover other questions. The notion that every question that we posed should have a NEL is flawed.’ She said she would ‘go to the mat’ to defend the committee’s approach. ‘That’s why you have an expert committee . . . to bring expertise,’ including ‘our own original analyses.’”

Those “original analyses” were likely influenced by members own biases. Guideline committee members were not required to list potential conflicts of interest. According to the BMI investigation, at least one member is known to have received research funding from vegetable oil corporations Bunge and Unilever, and another received funding from Lluminari, which produces media content for General Mills, and PepsiCo.6

If all this isn’t enough, a recent study shows that Americans have followed the Dietary Guidelines in recent years, but it hasn’t helped rates of obesity or diabetes.15

We desperately need evidence-based nutritional advice

Hopefully this has given you a glimpse into the convoluted, industry-influenced, sickness-subsidizing atrocity that is U.S. nutrition policy. It’s hard to stomach, I know.

With obesity, diabetes, heart disease, and other chronic diseases reaching epic proportions, we desperately need evidence-based nutritional advice. A quote often attributed to Albert Einstein says:

The definition of insanity is doing the same thing over and over again and expecting a different result.”

Sarah Hallberg, the executive director of the Nutrition Coalition, a non-profit organization dedicated to ensuring nutrition policy is based on sound scientific evidence, has said:

“I find my patients get healthier—lose weight and even reverse their diabetes—by doing what the current science says, which is the complete opposite of what the Guidelines tell them. It’s obvious to me, as a practitioner, that these Guidelines do not reflect the best and most current science.16

So what does the current unbiased science say? Well, for starters, anthropological evidence suggests that hunter-gatherer populations are free of heart disease, cancer, obesity, and diabetes.17–19 Blaming meat, dietary cholesterol, or saturated fat for the epidemic of chronic disease implies that we have somehow become more susceptible to these nutrients in the last 10,000 years; the same nutrients that allowed for the evolution of our species. Furthermore, randomized controlled trials have found that a low carbohydrate, paleolithic-type diet has been shown to reduce caloric intake, induce weight loss, and improve glucose tolerance and cardiovascular risk factors.20–24 A recent study even showed that an autoimmune paleolithic-type diet was effective for inducing clinical remission in IBD patients.25 These studies had no reported conflicts of interest and were not industry-funded. Can we really argue with that?

To sum up, industry and conflicts of interest aren’t leaving nutritional science anytime soon, but they can and should be excluded from government guidelines that affect the health of Americans. We  need an unbiased panel of scientists that are willing to see the data for what it is, take on industry, and make some evidence-based waves.

Until then, you can be darn sure that the only nutrition policy I’ll be communicating to the public is this: it’s all bulls**t.

Thanks for reading! Please let me know what you thought in the comments, and be sure to subscribe below!

Sources:

  1. Commissioner, O. of the. FDA Basics – Fact Sheet: FDA at a Glance. Available at: https://www.fda.gov/AboutFDA/Transparency/Basics/ucm553038.htm. (Accessed: 25th October 2017)
  2. Henderson, D. Panel: FDA needs more power, funds. Boston.com (2006).
  3. Andreyeva, T., Tripp, A. S. & Schwartz, M. B. Dietary Quality of Americans by Supplemental Nutrition Assistance Program Participation Status:A Systematic Review. American Journal of Preventive Medicine 49, 594–604 (2015).
  4. Carr, A. C. & Frei, B. Toward a new recommended dietary allowance for vitamin C based on antioxidant and health effects in humans. Am J Clin Nutr 69, 1086–1107 (1999).
  5. Beyerstein, L. Dairy Industry Milks New ‘MyPlate’. Big Think (2011). Available at: http://bigthink.com/focal-point/dairy-industry-milks-new-myplate. (Accessed: 30th October 2017)
  6. Teicholz, N. The scientific report guiding the US dietary guidelines: is it scientific? BMJ 351, h4962 (2015).
  7. Report Index – 2015 Advisory Report – health.gov. Available at: https://health.gov/dietaryguidelines/2015-scientific-report/. (Accessed: 30th October 2017)
  8. Siri-Tarino, P. W., Sun, Q., Hu, F. B. & Krauss, R. M. Meta-analysis of prospective cohort studies evaluating the association of saturated fat with cardiovascular disease. Am. J. Clin. Nutr. 91, 535–546 (2010).
  9. Siri-Tarino, P. W., Sun, Q., Hu, F. B. & Krauss, R. M. Saturated fat, carbohydrate, and cardiovascular disease. Am. J. Clin. Nutr. 91, 502–509 (2010).
  10. Hooper, L. et al. Reduced or modified dietary fat for preventing cardiovascular disease. Cochrane Database Syst Rev CD002137 (2001). doi:10.1002/14651858.CD002137
  11. Feinman, R. D. et al. Dietary carbohydrate restriction as the first approach in diabetes management: critical review and evidence base. Nutrition 31, 1–13 (2015).
  12. Ajala, O., English, P. & Pinkney, J. Systematic review and meta-analysis of different dietary approaches to the management of type 2 diabetes. Am J Clin Nutr 97, 505–516 (2013).
  13. Johnston, B. C. et al. Comparison of weight loss among named diet programs in overweight and obese adults: a meta-analysis. JAMA 312, 923–933 (2014).
  14. Santos, F. L., Esteves, S. S., da Costa Pereira, A., Yancy, W. S. & Nunes, J. P. L. Systematic review and meta-analysis of clinical trials of the effects of low carbohydrate diets on cardiovascular risk factors. Obes Rev 13, 1048–1066 (2012).
  15. USDA ERS – U.S. Trends in Food Availability and a Dietary Assessment of Loss-Adjusted Food Availability, 1970-2014. Available at: http://usda.proworks.com/publications/pub-details/?pubid=111031. (Accessed: 30th October 2017)
  16. Nutrition Coalition Reacts to National Academies of Medicine Report on Broken Process Behind the U.S. Dietary Guidelines for Americans. Nutrition Coalition (2017). Available at: https://www.nutrition-coalition.org/2017/09/14/nutrition-coalition-reacts-to-national-academies-of-medicine-report-on-broken-process-behind-the-u-s-dietary-guidelines-for-americans/. (Accessed: 30th October 2017)
  17. Cordain, L., Eaton, S. B., Miller, J. B., Mann, N. & Hill, K. The paradoxical nature of hunter-gatherer diets: meat-based, yet non-atherogenic. Eur J Clin Nutr 56 Suppl 1, S42-52 (2002).
  18. Walker, A. R. P., Walker, B. F. & Adam, F. Nutrition, diet, physical activity, smoking, and longevity: From primitive hunter-gatherer to present passive consumer—How far can we go? Nutrition 19, 169–173 (2003).
  19. Cordain, L. et al. Origins and evolution of the Western diet: health implications for the 21st century. Am J Clin Nutr 81, 341–354 (2005).
  20. Lindeberg, S. et al. A Palaeolithic diet improves glucose tolerance more than a Mediterranean-like diet in individuals with ischaemic heart disease. Diabetologia 50, 1795–1807 (2007).
  21. Frassetto, L. A., Schloetter, M., Mietus-Synder, M., Morris, R. C. & Sebastian, A. Metabolic and physiologic improvements from consuming a paleolithic, hunter-gatherer type diet. Eur J Clin Nutr 63, 947–955 (2009).
  22. Ryberg, M. et al. A Palaeolithic-type diet causes strong tissue-specific effects on ectopic fat deposition in obese postmenopausal women. J. Intern. Med. 274, 67–76 (2013).
  23. Jönsson, T. et al. Beneficial effects of a Paleolithic diet on cardiovascular risk factors in type 2 diabetes: a randomized cross-over pilot study. Cardiovasc Diabetol 8, 35 (2009).
  24. Osterdahl, M., Kocturk, T., Koochek, A. & Wändell, P. E. Effects of a short-term intervention with a paleolithic diet in healthy volunteers. Eur J Clin Nutr 62, 682–685 (2008).
  25. Konijeti, G. G. et al. Efficacy of the Autoimmune Protocol Diet for Inflammatory Bowel Disease. Inflammatory Bowel Diseases 23, 2054–2060 (2017).
  26. Payne-Palacio, J. R. & Canter, D. D. The Profession of Dietetics. (Jones & Bartlett Learning, 2016).
  27. Gratzer, W. Terrors of the Table: The curious history of nutrition. (OUP Oxford, 2006).
  28. Wegener, G. ‘Let food be thy medicine, and medicine be thy food’: Hippocrates revisited. Acta Neuropsychiatrica 26, 1–3 (2014).
  29. Ahrens, R. William Prout (1785-1850). A biographical sketch. J. Nutr. 107, 17–23 (1977).
  30. Rosenfeld, L. Vitamine—vitamin. The early years of discovery. Clinical Chemistry 43, 680–685 (1997).
  31. McCoy, R. H., Meyer, C. E. & Rose, W. C. Feeding Experiments with Mixtures of Highly Purified Amino Acids Viii. Isolation and Identification of a New Essential Amino Acid. J. Biol. Chem. 112, 283–302 (1935).
  32. Mccance, R. A. & Widdowson, E. M. An Experimental Study of Rationing. An Experimental Study of Rationing. (1946).
  33. Recommended Dietary Allowances. (National Research Council, 1941).

FDA, USDA, MyPlate, oh my! The lack of evidence in U.S. nutrition policy

I didn’t pass the qual last month.

My initial reaction was hurt, frustration, and anger. I didn’t want to tell anyone.

I pride myself on academic excellence, so being asked to retake the Nutritional Sciences Ph.D. qualifying exam because I didn’t know enough nutrition policy was a hard blow.

But it’s true. I’d been so focused on learning the intricacies of evidence-based nutrition science and how it can be applied to help people through functional medicine that I hadn’t paid a lick of attention to politics.

A few weeks have passed and I’ve started to think: “What’s the opportunity in this?”

I’ve shifted my perspective, and have nothing but respect and deep gratitude for the committee’s decision. I’ve realized that this will simply raise the standards by which I can communicate (and more importantly, refute and actively work to reform) nutrition policy, ultimately making me a better nutrition scientist and physician.

Now that I’ve unloaded that…

One of the reasons I love writing is that it forces me to engage with and learn material at a deeper level. So, I wrote this article to help myself better understand nutrition policy, unsure of whether I would end up publishing it, but ultimately decided it was worthwhile to my readers. If you’d like to learn along with me and hear my take on the government guidelines for nutrition, please read on.

The U.S. agencies that shape nutrition policy

governing agencies

FDA:

Established in 1938, the Food and Drug Administration (FDA) is a federal agency of the United States Department of Health and Human Services (DHHS) that regulates more than $2.4 trillion worth of consumer products.1 The FDA oversees food safety, dietary supplements, vaccines, prescription and over-the-counter drugs, blood transfusions, medical devices, and animal feeds.

The FDA also has the authority to monitor claims made in labeling about the composition and health benefits of foods and carries out research and development activities to develop standards that support its regulatory role.

In 2009, nine FDA scientists came forward to report pressures from FDA managers to manipulate data and appealed to President Obama to restructure the agency. In their words: the FDA was “corrupted and distorted by current FDA managers, thereby placing the American people at risk”.  Similar concerns were highlighted in a 2006 report on the agency.2 As of April 2017, 42.5% of the $4.7 billion FDA budget is funded by industry.

USDA

The United States Department of Agriculture (USDA) is a U.S. federal executive department responsible for federal law related to farming, agriculture, forestry, and food. The economy of the early U.S. was mostly agrarian, and many government officials sought new and improved varieties of seeds, plants, and animals for import to the U.S. 

Today, about 80% of the $140 billion budget goes to fund the Food and Nutrition Service Program, the largest component of which is the Supplemental Nutrition Assistance Program (SNAP). SNAP provides food to over 40 million people each month, though a 2015 systematic review found that it’s not enough to support healthy food choices.3 The USDA also regulates the standards of organic products and plays a role in overseas aid by providing developing countries with surplus foods.

It also assists farmers and food producers with the sale of crops on both the domestic and global markets through farm subsidies, which supplement the income of farmers to influence the crops and supply. Among the top subsidized crops are corn, wheat, soybeans, dairy, and sugar. Meanwhile, unequivocally healthy foods, like fruit and vegetables, are not subsidized. Is it really any wonder why chronic disease is on the rise, when the government is subsidizing the primary ingredients in processed junk foods?

 

National Academy of Medicine

Founded in 1970, the National Academy of Medicine (NAM), previously called the Institute of Medicine (IoM) is a non-governmental, non-profit organization. The NAM provides advice on issues of national importance relating to medicine, health, and biomedical science and “aims to provide unbiased, evidence-based, and authoritative information and advice concerning health and science policy to policy-makers, professionals, leaders in every sector of society, and the public at large.“

NAM expert volunteer scientists serve without compensation, and every attempt is made to avoid bias or conflict of interest. Committee reports undergo extensive review by a group of external experts, and reports are freely available to the public.

Within the NAM, the Food and Nutrition Board (FNB), established in 1940, is responsible for studying the safety and adequacy of the U.S. food supply. The FNB regularly publishes guidelines for what they deem to be good nutrition. While they are technically a non-government entity, most FNB studies are funded by federal, state, and local governments. Private industry and foundations can also request and initiate studies.

Means of communicating nutrition policy to the public

Each agency has its own role in communicating nutrition policy to the public. Here, I’ll discuss each in turn and give my take on their benefits and shortcomings.

DRIs

The Food and Nutrition Board of the NAM is responsible for establishing the Dietary Reference Intakes (DRIs) for vitamins and minerals. DRI is a general term for a set of reference values used to advise nutrient intake for health. The reference values include:

Estimated Average Requirements (EAR): the amount of a nutrient that is adequate for 50% of Americans to avoid risk of inadequacy

Recommended Dietary Allowances (RDA): the amount of a nutrient that is adequate for 98.5% of Americans to avoid risk of inadequacy

Tolerable Upper Intake Level (UL): a level set a safe fraction below amounts that are toxic and shown to cause health problems. The FNB has set ULs for seven vitamins.

Adequate intake (AI): approximates nutrient intake believed to be adequate for healthy people for nutrients in which an EAR or RDA has not been determined.

The figure below summarizes the DRI reference values. DRIs are specific for age, sex, and pregnancy status. The DRI documents also describe the signs and symptoms of nutrient deficiencies.

Source: National Academies Press

My take: Established by the NAM, we can largely trust the DRIs to be evidence-based. However, it’s important to note that the RDA is often NOT sufficient for optimal health.

Take Vitamin C, for instance. The RDA for Vitamin C is set at 60 mg/day, which is sufficient to prevent scurvy. However, Vitamin C is an incredibly important antioxidant, and amounts of 120mg/day to upwards of 1,000 mg/day are more aligned with optimal health and disease prevention.4

 

Food labeling:

While the NAM makes suggestions for which information is presented on nutrition facts, food labeling is ultimately regulated by the FDA. To make things more complicated, the FDA has a few terms that it uses that are different from DRIs:

Reference Daily Intake/Recommended Daily Intake (RDI): an estimation of nutrient needs based on a 2,000 calorie diet for everyone, regardless of age, sex, or pregnancy status.

Percent Daily Values (%DV): the amount of a nutrient in one serving of a food, relative to the RDI. This is the number you see on nutrition facts labels.

The FDA recently proposed several changes to food labeling for the first time in over 20 years, based on “trends of consumption of nutrients of public health importance”. The proposed changes included:

  • A new design requiring beverages with more than one serving to more accurately reflect how many calories an individual is actually consuming
  • Removing “calories from fat” and instead focusing on total calories and type of fats in a product
  • Requiring product labels to list added sugar
  • Declaring the amount of Vitamin D and potassium in a product, such that the nutrients of public interest (iron, calcium, potassium, and Vitamin D) appear on the label.

The Final Rule was issued in May 2016, moving the deadline from July 2018 to January 2021 for manufacturers to comply with the new labeling guidelines.

Several changes to the DVs were also issued in 2016:

Health claims:

The FDA also regulates health claims made on food packages, which are allowed for ten diet and health relationships “based on proven scientific evidence”. These include:

  • Calcium, Vitamin D, and osteoporosis
  • Fiber-containing grain products, fruits, and vegetables and cancer
  • Dietary fat and cancer
  • Fruits, vegetables, and grain products that contain soluble fiber and heart disease
  • Soy protein and heart disease
  • Stanols/sterols and heart disease
  • Saturated fat and cholesterol and heart disease
  • Sodium and hypertension
  • Non-cariogenic sweeteners and dental caries
  • Folate and neural tube defects

My take: I can’t remember the last time I looked at the number of calories or the amount of saturated fat in a packaged food. I may occasionally look at the amount of sugar or fiber in a product, but ultimately, nothing on a nutrition facts label is as important as the ingredients. Three grams of high-fructose corn syrup and three grams of cane sugar have WIDELY different effects on human metabolism. Besides, we should be focusing on eating REAL FOOD, and real foods don’t come in a package with a nutrition facts label.

That being said, I do think that overall, the 2016 labeling changes will be beneficial. At least they’ve become a little more relaxed about fat consumption, increased the daily value for fiber, and required added sugar to be listed. Too bad it’s going to take another four years for any of these changes to be implemented!

As for the health claims, the only people who stand to benefit from these claims are the food companies. Many claims are lobbied for by industry and the “evidence” for them is based on systematic reviews conducted by industry-funded research.

Lastly, I’d like to see more regulation and formal definitions for terms like “natural”, “pastured”, “free-range” and “grass-fed”. These terms regarding crop and animal production methods can greatly influence the nutrient content of a product.

MyPlate

In the U.S., nutritional recommendations are established jointly by the US Department of Health and Human Services and the USDA. The Four Food Groups was the reigning nutrition guidelines from 1956-1992, and was replaced by the Food Guide Pyramid in 1992. The Food Pyramid was replaced by MyPlate in 2011. The plate concept was believed to be superior because of its simplicity, showing relative quantities of the food groups in a place setting.

Source: USDA

Until 2011, the fats group represented a tiny fraction of MyPyramid, under the direction to eat as little as possible. With the introduction of MyPlate, fats lost a place altogether.

My take: Frankly, I’m not sure what business the Department of Agriculture has in determining the appropriate diet for Americans in the first place, but it’s no surprise that they encourage Americans to eat the very crops that they subsidize.

If you’ve read some of my previous articles, you know that I don’t endorse grains as a health food. While many traditional cultures consumed grains, they went to extensive lengths to soak, ferment, and sprout them to increase their nutrient availability and inactivate plant toxins like lectins and phytates. A food plate based on science would have vegetables as the largest component.

The inclusion of milk as an essential part of a healthy diet is puzzling, given that many people are lactose intolerant, and a number of traditional cultures have historically consumed little to no dairy products yet maintained health. The dairy industry has been accused of pressuring the USDA to increase recommendations for milk consumption in the food pyramid, and now in MyPlate.5

The avoidance of fat is also highly problematic, as fat is essential for cell membrane integrity and cognitive function, and is also beneficial for blood sugar regulation. More on that later.

Dietary Guidelines for Americans

In addition to MyPlate, the USDA and DHHS also jointly release a document called the Dietary Guidelines for Americans (DGA) every five years. The 2015 guidelines can be summarized as follows:

1) Follow a healthy eating pattern across the lifespan. Choose a healthy eating pattern at an appropriate calorie level.

2) Focus on variety, nutrient density, and amount. Choose a variety of nutrient-dense foods across all food groups.

3) Limit calories from added sugars and saturated fats and reduce sodium intake.

4) Shift to healthier food and beverage choices.

5) Support healthy eating patterns for all. Everyone has a role in helping to create and support healthy eating patterns.

They further define a healthy eating pattern as including:

  • A variety of vegetables from all the subgroups – dark green, red and orange, legumes, starchy, and other
  • Fruits, especially whole fruits
  • Grains, at least half of which are whole grains
  • Fat-free or low-fat dairy, including milk, yogurt, cheese, and/or fortified soy beverages
  • A variety of protein foods, including seafood, lean meats and poultry, eggs, legumes, and nuts, seeds, and soy products
  • Oils

According to the 2015 DGAs, a healthy eating pattern also limits saturated fats, trans fats, added sugars, and sodium. Alcohol should only be consumed in moderation. They further suggest that Americans should meet the Physical Activity Guidelines for Americans to help maintain a healthy body weight.

Lastly, they identified five nutrients of public health concern for underconsumption (vitamin D, calcium, potassium, iron, and fiber) and two nutrients of public health concern due to overconsumption (saturated fat and salt).

My take: The DGAs are so far from evidence-based its laughable. Before the 2010 DGA committee meeting, the USDA set up the Nutrition Evidence Library (NEL) to help conduct systematic reviews using a standardized process for selecting and evaluating relevant studies. This was supposed to reduce bias in developing the DGAs. However, in the committee’s 2015 report, NEL reviews were not used for more than 70% of the topics, including some of the most controversial issues in nutrition science! An investigation conducted by the British Medical Journal found:

“The expert report underpinning the next set of US Dietary Guidelines for Americans fails to reflect much relevant scientific literature in its reviews of crucial topics and therefore risks giving a misleading picture […]. The omissions seem to suggest a reluctance by the committee behind the report to consider any evidence that contradicts the last 35 years of nutritional advice.”6

In place of NEL reviews, the committee relied on systematic reviews from the American College of Cardiology (ACC) and the American Heart Association (AHA), both of which are heavily influenced by the food and drug industries. Let’s look at a few of the issues they glazed over in the most recent DGAs:6,7

Saturated fat: Prior to 2015, several meta-analyses and systematic reviews failed to confirm a relationship between saturated fat and heart disease.8–10  However, DGA committee members did not request an NEL review that would review this new literature, instead relying on a review by the ACC and AHA and the NEL review. They concluded that the evidence linking saturated fat to cardiovascular disease was “strong” and recommended extending the current 10% of total calories limit on saturated fats.

Low-carb diets: Despite increasing evidence that low carbohydrate diets are effective for weight loss, reducing heart disease risk, and controlling type 2 diabetes,11–14 the 2015 committee did not request an NEL systematic review on the topic. Instead they reported that they conducted “exploratory searches” (i.e. cherry picked studies).of literature from the past decade and a half.

Plant-based diets: Perhaps the most significant shift in the committee’s recommendations has been an increased emphasis on plant-based diets. An NEL review concluded that evidence for vegetarianism to fight disease is “limited”, yet the committee introduced a “healthy vegetarian diet” as one of the three recommended diet, the other two being “healthy Mediterranean-style” and “healthy US-style”. In fact, none of the “healthy” diet patterns had strong evidence for protecting against osteoporosis, diabetes, or neurological or psychological illnesses!

Salt: The committee concurred with a recent NAM report that stated that the evidence is “inconsistent and insufficient to conclude that lowering sodium intakes below 2300 mg/day will have any effect on cardiovascular risk or overall mortality”. Yet the report still recommends that sodium intake should be less than 2300 mg/day!

Head committee member Barbara Millen told The BMJ:

 “’You don’t simply answer these questions on the basis of the NEL. Where we didn’t feel we needed to, we didn’t do them. On topics where there were existing comprehensive guidelines, we didn’t do them. We used those resources and that time to cover other questions. The notion that every question that we posed should have a NEL is flawed.’ She said she would ‘go to the mat’ to defend the committee’s approach. ‘That’s why you have an expert committee . . . to bring expertise,’ including ‘our own original analyses.’”

Those “original analyses” were likely influenced by members own biases. Guideline committee members were not required to list potential conflicts of interest. According to the BMI investigation, at least one member is known to have received research funding from vegetable oil corporations Bunge and Unilever, and another received funding from Lluminari, which produces media content for General Mills, and PepsiCo.6

If all this isn’t enough, a recent study shows that Americans have followed the Dietary Guidelines in recent years, but it hasn’t helped rates of obesity or diabetes.15

We desperately need evidence-based nutritional advice

Hopefully this has given you a glimpse into the convoluted, industry-influenced, sickness-subsidizing atrocity that is U.S. nutrition policy. It’s hard to stomach, I know.

With obesity, diabetes, heart disease, and other chronic diseases reaching epic proportions, we desperately need evidence-based nutritional advice. A quote often attributed to Albert Einstein says:

The definition of insanity is doing the same thing over and over again and expecting a different result.”

Sarah Hallberg, the executive director of the Nutrition Coalition, a non-profit organization dedicated to ensuring nutrition policy is based on sound scientific evidence, has said:

“I find my patients get healthier—lose weight and even reverse their diabetes—by doing what the current science says, which is the complete opposite of what the Guidelines tell them. It’s obvious to me, as a practitioner, that these Guidelines do not reflect the best and most current science.16

So what does the current unbiased science say? Well, for starters, anthropological evidence suggests that hunter-gatherer populations are free of heart disease, cancer, obesity, and diabetes.17–19 Blaming meat, dietary cholesterol, or saturated fat for the epidemic of chronic disease implies that we have somehow become more susceptible to these nutrients in the last 10,000 years; the same nutrients that allowed for the evolution of our species. Furthermore, randomized controlled trials have found that a low carbohydrate, paleolithic-type diet has been shown to reduce caloric intake, induce weight loss, and improve glucose tolerance and cardiovascular risk factors.20–24 A recent study even showed that an autoimmune paleolithic-type diet was effective for inducing clinical remission in IBD patients.25 These studies had no reported conflicts of interest and were not industry-funded. Can we really argue with that?

To sum up, industry and conflicts of interest aren’t leaving nutritional science anytime soon, but they can and should be excluded from government guidelines that affect the health of Americans. We  need an unbiased panel of scientists that are willing to see the data for what it is, take on industry, and make some evidence-based waves.

Until then, you can be darn sure that the only nutrition policy I’ll be communicating to the public is this: it’s all bulls**t.

Thanks for reading! Please let me know what you thought in the comments, and be sure to subscribe below!

Sources:

  1. Commissioner, O. of the. FDA Basics – Fact Sheet: FDA at a Glance. Available at: https://www.fda.gov/AboutFDA/Transparency/Basics/ucm553038.htm. (Accessed: 25th October 2017)
  2. Henderson, D. Panel: FDA needs more power, funds. Boston.com (2006).
  3. Andreyeva, T., Tripp, A. S. & Schwartz, M. B. Dietary Quality of Americans by Supplemental Nutrition Assistance Program Participation Status:A Systematic Review. American Journal of Preventive Medicine 49, 594–604 (2015).
  4. Carr, A. C. & Frei, B. Toward a new recommended dietary allowance for vitamin C based on antioxidant and health effects in humans. Am J Clin Nutr 69, 1086–1107 (1999).
  5. Beyerstein, L. Dairy Industry Milks New ‘MyPlate’. Big Think (2011). Available at: http://bigthink.com/focal-point/dairy-industry-milks-new-myplate. (Accessed: 30th October 2017)
  6. Teicholz, N. The scientific report guiding the US dietary guidelines: is it scientific? BMJ 351, h4962 (2015).
  7. Report Index – 2015 Advisory Report – health.gov. Available at: https://health.gov/dietaryguidelines/2015-scientific-report/. (Accessed: 30th October 2017)
  8. Siri-Tarino, P. W., Sun, Q., Hu, F. B. & Krauss, R. M. Meta-analysis of prospective cohort studies evaluating the association of saturated fat with cardiovascular disease. Am. J. Clin. Nutr. 91, 535–546 (2010).
  9. Siri-Tarino, P. W., Sun, Q., Hu, F. B. & Krauss, R. M. Saturated fat, carbohydrate, and cardiovascular disease. Am. J. Clin. Nutr. 91, 502–509 (2010).
  10. Hooper, L. et al. Reduced or modified dietary fat for preventing cardiovascular disease. Cochrane Database Syst Rev CD002137 (2001). doi:10.1002/14651858.CD002137
  11. Feinman, R. D. et al. Dietary carbohydrate restriction as the first approach in diabetes management: critical review and evidence base. Nutrition 31, 1–13 (2015).
  12. Ajala, O., English, P. & Pinkney, J. Systematic review and meta-analysis of different dietary approaches to the management of type 2 diabetes. Am J Clin Nutr 97, 505–516 (2013).
  13. Johnston, B. C. et al. Comparison of weight loss among named diet programs in overweight and obese adults: a meta-analysis. JAMA 312, 923–933 (2014).
  14. Santos, F. L., Esteves, S. S., da Costa Pereira, A., Yancy, W. S. & Nunes, J. P. L. Systematic review and meta-analysis of clinical trials of the effects of low carbohydrate diets on cardiovascular risk factors. Obes Rev 13, 1048–1066 (2012).
  15. USDA ERS – U.S. Trends in Food Availability and a Dietary Assessment of Loss-Adjusted Food Availability, 1970-2014. Available at: http://usda.proworks.com/publications/pub-details/?pubid=111031. (Accessed: 30th October 2017)
  16. Nutrition Coalition Reacts to National Academies of Medicine Report on Broken Process Behind the U.S. Dietary Guidelines for Americans. Nutrition Coalition (2017). Available at: https://www.nutrition-coalition.org/2017/09/14/nutrition-coalition-reacts-to-national-academies-of-medicine-report-on-broken-process-behind-the-u-s-dietary-guidelines-for-americans/. (Accessed: 30th October 2017)
  17. Cordain, L., Eaton, S. B., Miller, J. B., Mann, N. & Hill, K. The paradoxical nature of hunter-gatherer diets: meat-based, yet non-atherogenic. Eur J Clin Nutr 56 Suppl 1, S42-52 (2002).
  18. Walker, A. R. P., Walker, B. F. & Adam, F. Nutrition, diet, physical activity, smoking, and longevity: From primitive hunter-gatherer to present passive consumer—How far can we go? Nutrition 19, 169–173 (2003).
  19. Cordain, L. et al. Origins and evolution of the Western diet: health implications for the 21st century. Am J Clin Nutr 81, 341–354 (2005).
  20. Lindeberg, S. et al. A Palaeolithic diet improves glucose tolerance more than a Mediterranean-like diet in individuals with ischaemic heart disease. Diabetologia 50, 1795–1807 (2007).
  21. Frassetto, L. A., Schloetter, M., Mietus-Synder, M., Morris, R. C. & Sebastian, A. Metabolic and physiologic improvements from consuming a paleolithic, hunter-gatherer type diet. Eur J Clin Nutr 63, 947–955 (2009).
  22. Ryberg, M. et al. A Palaeolithic-type diet causes strong tissue-specific effects on ectopic fat deposition in obese postmenopausal women. J. Intern. Med. 274, 67–76 (2013).
  23. Jönsson, T. et al. Beneficial effects of a Paleolithic diet on cardiovascular risk factors in type 2 diabetes: a randomized cross-over pilot study. Cardiovasc Diabetol 8, 35 (2009).
  24. Osterdahl, M., Kocturk, T., Koochek, A. & Wändell, P. E. Effects of a short-term intervention with a paleolithic diet in healthy volunteers. Eur J Clin Nutr 62, 682–685 (2008).
  25. Konijeti, G. G. et al. Efficacy of the Autoimmune Protocol Diet for Inflammatory Bowel Disease. Inflammatory Bowel Diseases 23, 2054–2060 (2017).
  26. Payne-Palacio, J. R. & Canter, D. D. The Profession of Dietetics. (Jones & Bartlett Learning, 2016).
  27. Gratzer, W. Terrors of the Table: The curious history of nutrition. (OUP Oxford, 2006).
  28. Wegener, G. ‘Let food be thy medicine, and medicine be thy food’: Hippocrates revisited. Acta Neuropsychiatrica 26, 1–3 (2014).
  29. Ahrens, R. William Prout (1785-1850). A biographical sketch. J. Nutr. 107, 17–23 (1977).
  30. Rosenfeld, L. Vitamine—vitamin. The early years of discovery. Clinical Chemistry 43, 680–685 (1997).
  31. McCoy, R. H., Meyer, C. E. & Rose, W. C. Feeding Experiments with Mixtures of Highly Purified Amino Acids Viii. Isolation and Identification of a New Essential Amino Acid. J. Biol. Chem. 112, 283–302 (1935).
  32. Mccance, R. A. & Widdowson, E. M. An Experimental Study of Rationing. An Experimental Study of Rationing. (1946).
  33. Recommended Dietary Allowances. (National Research Council, 1941).