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May 4, 2015

Richard D. Olson, M.D., M.P.H.

Designated Federal Officer, 2015 Dietary Guidelines Advisory Committee

Office of Disease Prevention and Health Promotion, Office of the Assistant Secretary for

Health, U.S. Department of Health and Human Services

Kellie Casavale, Ph.D., R.D.

Deputy Designated Federal Officer, 2015 Dietary Guidelines Advisory Committee,

Nutrition Advisor; Office of Disease Prevention and Health Promotion, Office of the

Assistant Secretary for Health, U.S. Department of Health and Human Services

Colette I. Rihane, M.S., R.D.

Lead USDA Co-Executive Secretary, 2015 Dietary Guidelines Advisory Committee,

Director, Office of Nutrition Guidance and Analysis, Center for Nutrition Policy and

Promotion, U.S. Department of Agriculture

Shanthy A. Bowman, Ph.D.

USDA Co-Executive Secretary, Nutritionist, Food Surveys Research Group, Beltsville

Human Nutrition Research Center, Agricultural Research Service, U.S.D.A.

Re: The Dietary Guidelines for Americans, 2015

Dear Dr. Olson, Dr. Casavale, Ms. Rihane, and Dr. Bowman:

We submit these comments on the expert report prepared for the eighth edition of the

Dietary Guidelines for Americans (DGA) by the Dietary Guidelines for Americans

Committee (DGAC). Overall, we strongly support the conclusions and recommendations

in the report. The signers represent the nation’s leading plant-based food companies.

We support the DGAC’s assessment that the overall body of evidence identifies a

healthy dietary pattern as one that is:

higher in fruits, vegetables, whole grains, legumes, nuts, and seeds;

lower in red and processed meats; and

low in sugar-sweetened foods and drinks and refined grains.

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We strongly support the DGAC in concluding that higher intakes of fruits, vegetables,

legumes, whole grains, nuts, seeds, and lower intakes of added sugars, saturated fat,

sodium, and red and processed meats reduce the risk of chronic diseases, including

cancer, type 2 diabetes, and cardiovascular disease.

Both the American Institute for Cancer Research (AICR)’s Recommendations for

Cancer Prevention1 and the American Cancer Society’s guidelines on nutrition and

physical activity for cancer prevention2 call for consuming an overall healthy diet with an

emphasis on plant foods, and overlap considerably with the DGAC recommendations,

which are based on a thorough review of current science.

All of the dietary patterns the DGAC mentioned (Vegetarian, Mediterranean, and

healthy American) are plant-centered diets and we support this approach to healthy,

nutrient-dense, and sustainable eating. We are especially pleased the committee

included a “healthy vegetarian” dietary pattern for optimum health. Indeed, vegetarian

diets are associated with improved glycemic control in type 2 diabetes,3 while meat

consumption is a consistent risk factor for type 2 diabetes.4

Recommendations for plant-based diets support consumer trends: approximately four

percent of United States consumers and one in ten Millennials are strictly vegetarian.5

And it’s not just vegetarians who are seeking healthier foods. Research suggests 36

percent of U.S. consumers prefer milk and meat alternatives, and that between 26 and

41 percent of Americans have eaten less meat over the past year.6 The trend toward

“flexitarian” diets indicates that more Americans need guidance on how to eat less meat

and more plant-based foods.

In addition to supporting this overall dietary pattern, we wish to comment specifically on

the need to emphasize eating less meat and more plants, on the importance of plant

proteins, and on the need to include more specific messages about which foods to

avoid or minimize, as well as which foods to emphasize.

1 World Cancer Research Fund / American Institute for Cancer Research, 2007.

2 Kushi, L. H., Doyle, C., McCullough, M., Rock, C. L., Demark‐Wahnefried, W., Bandera, E. V., ... &

Gansler, T. (2012). American Cancer Society guidelines on nutrition and physical activity for cancer prevention. CA: A Cancer Journal for Clinicians, 62 (1), 30-67. 3 Yokoyama, Y, Barnard, N, Levin S, and Watanabe, M. “Vegetarian diets and glycemic control in

diabetes: a systematic review and meta-analysis.” Cardiovasc Diagn Ther 4, no. 5 (2014): 373-82. 4 Barnard, N., Levin M., and Trapp, C. “Meat Consumption as a Risk Factor for Diabetes.” Nutrients 6, no.

2 (2014): 897-910. 5 Nutrition Business Journal. “The Food Tribe Landscape in 2015.” Accessed online, March 30, 2015,

http://newhope360.com/node/1050881. 6 Food Navigator. “Vegan is going mainstream, trend data suggests.” Accessed online, April 1, 2015,

http://www.foodnavigator-usa.com/Markets/Vegan-is-going-mainstream-trend-data-suggests.

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1. Food Groups and Nutrients of Concern

Plant-based diets can help solve the nation’s nutrient deficiencies.

According to the DGAC report:

“On average, the U.S. diet is low in vegetables, fruit, and whole grains, and high in

sodium, calories, saturated fat, refined grains, and added sugars. Under-consumption of

the essential nutrients vitamin D, calcium, potassium, and fiber are public health

concerns for the majority of the U.S. population, and iron intake is of concern among

adolescents and premenopausal females.”

A plant-based diet is the best solution to these concerns, as such diets encourages the

consumption of vegetables, fruits, whole (unrefined) grains, legumes, and discourages

most processed foods (the largest source of sodium and added sugars). Further, plant-

based diets naturally contain low levels of saturated fats and are fiber and nutrient-

dense while being lower in calories.

The DGAC noted that mixed dishes account for a substantial intake of under-consumed

(28% of calories from fiber, 29% calcium, 24% potassium, 16% vitamin D) nutrients. At

the same time, however, mixed dishes - especially burgers and sandwiches (13.8% of

total calories) are the largest contributors to intake of saturated fat and sodium, two

nutrients of concern for overconsumption.

Thus, the DGA can advise Americans to swap out their burgers and fill their sandwiches

instead with plant-based foods to adequately meet under-consumed nutrient needs

while lowering intake of overconsumed nutrients.

Also, according to the DGAC, data indicate under-consumption of nutrients such as

vitamins A, E, and C, folate, magnesium, potassium, and fiber. Plant-based diets tend to

be higher in dietary fiber, magnesium, potassium, vitamins C and E, folate, carotenoids,

flavonoids, and other phytochemicals.7 And fiber is exclusive to plants; animal products

contain zero fiber.

Specifically, calcium and vitamin D are nutrients of concern for under-consumption.

Fortified plant-based milks contain the same amounts of - sometimes more - calcium

and vitamin D as dairy products. Plant-based milks are accessible and nutritious foods

that are important for those avoiding dairy products for lactose intolerance, dairy

allergies, or other reasons.

7 Academy of Nutrition and Dietetics. “Position of the American Dietetic Association: Vegetarian Diets.” J

Am Diet Assoc 109 (2009): 1266-82.

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Tofu is another excellent source of calcium, while almonds and almond butter, broccoli,

leafy green vegetables, dried figs, and beans also offer this nutrient of concern. The

bioavailability of calcium from kale has been shown to be even greater than that of

milk.8 Such plant foods are excellent options for anyone and should be recommended

especially to those who need to avoid dairy products.

We also appreciate that the committee found that dietary “patterns emphasizing

vegetables, fruits, legumes, nuts, dairy, and cereals/grains/pasta/rice, and unsaturated

fats were generally associated with more favorable bone health outcomes. Patterns

higher in meats and saturated fats have been associated with increased risk of adverse

bone health outcomes.”9 Optimal bone health can be achieved with adequate intakes of

multiple nutrients, including calcium, vitamin D, potassium, and vitamin K, which are

ideally consumed from fruits and vegetables, soy foods, and other legumes.

The majority of under-consumed nutrients of concern are found primarily in plant

foods. The vast majority of the population is not consuming recommended

amounts of fiber; an increase in vegetables, fruits, legumes, whole grains, nuts,

and seeds will help solve this problem.

2. Fruits and Vegetables

We concur with the DGAC report that additional measures are needed to

encourage consumption of fruits and vegetables as part of a healthy diet.

Americans currently eat a diet that is low in vegetables and fruits, and this dietary

pattern contributes to increased risk of chronic disease and poor health. Among the

U.S. population, 90 percent do not eat the daily recommended amount of vegetables,

and 80 percent do not eat the daily recommended amount of fruit. Even more troubling,

consumption has declined by about 10 percent since 2003.10

Fresh, frozen, and canned fruits and vegetables contribute many important nutrients of

public health concern, including fiber, potassium, iron, folate, and vitamin A. A diet rich

in fruits and vegetables is associated with a decreased risk of cardiovascular disease.11

High intakes of vegetables and fruits were the only dietary characteristics consistently

associated with many positive health outcomes. Therefore, the DGAC recommends that

8 Heaney, R. and Weaver, C. “Calcium absorption from kale.” Am J Clin Nutr 51 (1990): 656-7.

9 Mangels, Ann Reed. “Bone nutrients for vegetarians.” Am J Clin Nutr 100 (2014): 469S-75S.

10 U.S. Department of Agriculture, Economic Research Service. (2014). Food Availability (Per Capita)

Data System: Loss-Adjusted Food Availability Documentation. Accessed online, April 25, 2015, http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/loss-adjusted-food-availability-documentation.aspx. 11

Wang, X., Ouyang, Y., Liu, J., Zhu, M., Zhao, G., Bao, W., & Hu, F. B. (2014). Fruit and vegetable consumption and mortality from all causes, cardiovascular disease, and cancer: systematic review and dose-response meta-analysis of prospective cohort studies.

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the U.S. population be encouraged to eat a diet rich in fruits and vegetables.

However, the DGA should recognize the problem of displacement and how less

healthful foods such as meats and refined grains are crowding out vegetables and

whole grains on the plate. According to a recent article by Harvard nutrition professor

Walter Willett12 (emphasis added):

“The current diets of Americans have a huge potential for improvement, with a

high consumption of highly processed and animal-based foods at the expense of

plant-based foods. The average American consumes 45% more meat per week

than is recommended by the US Department of Agriculture.”

Therefore, simply telling Americans to “eat more” without saying what to “eat less” of is

not constructive, as there is only so much room on one’s plate.

The DGA should emphasize the importance of increased consumption of fruits

and vegetables specifically by coupling the recommendation with a decrease in

foods that are less health-promoting such as animal products and refined grains

and sugars.

3. Fats

The DGA should continue to advise Americans to replace foods rich in saturated

fat with ones higher in monounsaturated or polyunsaturated fats.

In 2010, the DGA recommended limiting saturated fat intake to less than 10 percent of

total calories based on evidence from controlled trials and prospective cohort studies

showing that saturated fat intake raises serum total and LDL-cholesterol levels, which

increase the risk of cardiovascular disease. Replacing saturated fats with

polyunsaturated and monounsaturated fat sources and unrefined carbohydrate sources

can help reduce risk for chronic disease (especially coronary artery disease, type 2

diabetes, and multiple cancers).

We support the committee in continuing to recommend a concerted effort towards

lowering saturated fat consumption to no more than 10 percent of total calories. The

12

Rocktrom, J, Willett W, and Stordalen, G. (March 26, 2015) “An American Plate That Is Palatable for Human and Planetary Health”. Huffington Post, Accessed online April 25, 2015, http://www.huffingtonpost.com/johan-rockstrom/post_9225_b_6949716.html

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American Heart Association, however, advises an intake of no more than 5 to 6 percent

of calories from saturated fat for a heart healthy diet. 13

The DGA should continue to advise Americans to replace foods rich in saturated

fat with ones higher in monounsaturated or polyunsaturated fats.

Moreover, because the majority of saturated fat intake comes from animal

products, it’s best to emphasize plant-based foods while minimizing animal

products. The DGA needs to be more explicit on foods to minimize. Consumers

don’t shop for “saturated fat” but for meats, eggs, and dairy.

4. Dietary Cholesterol

The committee’s recommendation on cholesterol has caused confusion.

The 2015 DGAC’s conclusions regarding dietary cholesterol have received considerable

attention in the media and are already being trumpeted in an egg industry marketing

campaign.14 However, the DGAC’s conclusion on dietary cholesterol is inconsistent with

the American Heart Association / American College of Cardiology (AHA/ACC)

guidelines and inconsistent with the overall dietary pattern recommended by the DGAC.

The DGAC states that it "will not bring forward [the previous recommendation to limit

cholesterol to 300 mg/day] because available evidence shows no appreciable

relationship between consumption of dietary cholesterol and serum cholesterol,

consistent with the conclusions of the AHA/ACC report.” However, the AHA/ACC did not

conclude that there is no appreciable relationship between dietary and serum

cholesterol. It concluded that “there is insufficient evidence to determine whether

lowering dietary cholesterol reduces LDL-C.”15 The DGAC report did not present

evidence that there is “no appreciable relationship” between dietary cholesterol and

serum cholesterol.

13

American Heart Association. “Saturated Fats.” Accessed online, March 30, 2015, http://www.heart.org/HEARTORG/GettingHealthy/NutritionCenter/HealthyEating/Saturated-Fats_UCM_301110_Article.jsp. 14

Tinker, B. (February 19, 2015). “Cholesterol in food not a concern, new report says.” CNN. Accessed online, March 20, 2015 http://www.cnn.com/2015/02/19/health/dietary-guidelines/; Whoriskey, P. (February 10, 2015). The U.S. government is poised to withdraw longstanding warnings about cholesterol. The Washington Post. Accessed online, March 20, 2015, http://www.washingtonpost.com/blogs/wonkblog/wp/2015/02/10/feds-poised-to-withdraw-longstanding-warnings-about-dietary-cholesterol/ 15

Eckel RH, Jakicic JM, Ard JD, de Jesus JM, Houston Miller N, Hubbard VS, Lee I-M, Lichtenstein AH, Loria CM, Millen BE, Nonas CA, Sacks FM, Smith SC Jr, Svetkey LP, Wadden TA, Yanovski SZ. 2013 AHA/ACC guideline on lifestyle management to reduce cardiovascular risk: a report of the American College of Cardiology/American Heart Association Task Force on Practice Guidelines. Circulation. 2014;129 (suppl 2): S76–S99.

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Moreover, most of the foods containing cholesterol come with saturated fat and

carcinogenic properties from the cooking process. Saturated fat-laden foods are well

established in promoting cardiovascular disease, type 2 diabetes, and other chronic

diseases. It is confusing to the public when they hear that consuming dietary cholesterol

is fine. In recent weeks, the media glowed with support for foods such as butter and

bacon as if they were suddenly redeemed from the list of unhealthy foods. Furthermore,

the DGAC’s conclusion on dietary cholesterol threatens to undermine the DGAC’s

advice to increase plant-based foods while lowering red and processed meats.

The DGA should continue its recommendation to limit cholesterol intake to avoid

misinterpretation by the public and the media.

5. Red and Processed Meats

We support the DGAC Report’s conclusion that the DGA should include a

recommendation to “lower red and processed meats.” This recommendation has

great potential to improve the country’s health.

We agree with the DGAC that the current dietary guidelines language regarding meat

intake should change from “choose lean meat and poultry” to “lower red and processed

meats.” That is an important and necessary change, borne out by clear, consistent, and

mounting evidence of the link between regular consumption of red and processed

meats and certain types of cancer.

The evidence that diets high in red meat (beef, pork, lamb) and processed meats (hot

dogs, bacon, sausage, deli meats, etc.) increase the risk for colorectal cancer is

convincing.16 Many epidemiologic studies have reported a significant association

between high intakes of processed meats and red meats and increases in cancer

incidence and mortality in a dose-dependent relationship.17

Since the 2010 Dietary Guidelines for Americans were issued, the evidence supporting

the link between red meat and processed meat consumption and colorectal cancer has

increased. In 2011, a Continuous Update Project report on colorectal cancer was

published, in which new evidence was added to the existing evidence base. The expert

panel concluded:

16

World Cancer Research Fund/American Institute for Cancer Research. (2011). Continuous Update Project Report. Food, Nutrition, Physical Activity, and the Prevention of Colorectal Cancer. Accessed online, April 13, 2015, http://www.dietandcancerreport.org/cancer_resource_center/downloads/cu/Colorectal-Cancer-2011-Report.pdf. 17

Kushi et al., 2012; WCRF/AICR, 2007; Sinha, R., Cross, A. J., Graubard, B. I., Leitzmann, M. F., & Schatzkin, A. (2009). “Meat intake and mortality: A prospective study of over half a million people.” Archives of Internal Medicine, 169 (6), 562-571.

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A substantial amount of data from cohort studies showed a dose-response

relationship, supported by evidence for plausible mechanisms operating in

humans…red meat is a convincing cause of colorectal cancer.

There is a substantial amount of evidence, with a dose-response relationship

apparent from cohort studies. There is strong evidence for plausible mechanisms

operating in humans…processed meat is a convincing cause of colorectal

cancer.18

Current evidence indicates approximately a 15 to 20 percent increased risk of cancers

of the colon and/or rectum per 100 grams of red meat or 50 grams of processed meats

consumed per day.19 The American Cancer Society recommends limiting consumption

of both red and processed meats.20

We are concerned that a message to “eat less meat and processed meat” is not explicit

enough for consumers to understand. The DGA should specifically say to limit red meat

such as steak, hamburgers, roast beef, pork, and lamb, and to avoid processed meats

such as ham, bacon, corned beef, salami, bologna, pastrami, and hot dogs.

We urge that the 2015 DGA include a recommendation to lower or even limit red

meat and processed meat intake. We also suggest explicitly listing common food

names as found in the supermarket to guide consumers.

We also urge the DGA to not include the message to “choose lean meats” as to

do so would only undermine the important health-promoting message to lower

red meat and processed meats.

Similarly, guidance in the DGA to increase non-animal protein sources, including

legumes, soy products, wheat gluten, seeds, and nuts, should be coupled with

the recommendation to reduce red and processed meats.

6. Power of Plant Proteins

We applaud the DGAC for recommending that consumption of healthier protein

sources—including plant protein sources—be increased.

18

WCRF/AICR, 2011. 19

WCRF/AICR, 2007; Chan, D. S., Lau, R., Aune, D., Vieira, R., Greenwood, D. C., Kampman, E., & Norat, T. (2011). Red and processed meat and colorectal cancer incidence: meta-analysis of prospective studies. PloS One, 6 (6), e20456; WCRF/AICR, 2011. 20

Kushi et al., 2012.

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Beyond animal products, there are many other options for protein sources. These foods

are often nutritionally superior due to their enhanced nutrient profile. Plant-based

proteins can provide key nutrients of concerns, including dietary fiber, magnesium,

vitamin E, and potassium.

While most plant proteins (except for soy and quinoa) are “incomplete” because they

are low in, or lack, one or more of the nine essential amino acids, research has

demonstrated that as long as different types of plant proteins (i.e.: grains, legumes,

vegetables, and nuts/seeds) are consumed within the same day, all essential amino

acid requirements are easily met.21

Although heme iron (found in animal products) is absorbed at a higher rate than non-

heme iron (found in plant-based and fortified foods) absorption of non-heme iron can be

increased by pairing plant-based protein sources with foods high in vitamin C.22 Also,

research suggests that excess iron may increase colorectal cancer risk,23 promote

atherosclerosis,24 and reduce insulin sensitivity.25

Legumes/Pulses/Soy Foods

Legumes (pulses) include all beans, lentils, and peas. Excellent sources of both soluble

and insoluble fibers, legumes help promote gastrointestinal function, serum cholesterol

lowering, blood sugar regulation, and protect against certain cancers. Their protein

content is comparable to animal products. Additionally, legumes contain calcium, iron,

zinc, and selenium. Legumes are also highly versatile in terms of culinary options and

thereby make excellent, more nutrient-dense alternatives to animal proteins.

Included in the legume category are soy foods, as mentioned by the DGAC. They have

an excellent nutrient profile including alpha linolenic acid, protein, and phytoestrogens.

Because soy foods have been shown to reduce risk of recurrence of or death from

breast cancer and may reduce risk of prostate cancer, the American Institute for Cancer

21

American Dietetic Association and Dietitians of Canada: Vegetarian diets. JADA, 2003; 103(6) 748 – 765. 22

National Institutes of Health. “Iron: Dietary Supplement Fact Sheet.” Accessed online, April 12, 2015, http://ods.od.nih.gov/factsheets/Iron-HealthProfessional/. 23

Bastide, N. M., F. H. F. Pierre, and D. E. Corpet. “Heme iron from meat and risk of colorectal cancer: a meta-analysis and a review of the mechanisms involved.” Cancer Prev Res 42, no. 2 (2011): 177-84. 24

Ahluwalia, N., A. Genoux, J. Ferrieres, B. Perret, M. Carayol, L. Drouet, and J. B. Ruidavets. “Iron status is associated with carotid atherosclerotic plaques in middle-aged adults.” J Nutr 140, no. 4 (2010): 812-6. 25

Hunt, JR. “Bioavailability of iron, zinc, and other trace minerals from vegetarian diets.” Am J Clin Nutr 78, no. 3 (2003): 633S-639S.

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Research and American Cancer Society concluded in 2012 that soy does not show

harmful effects to breast cancer survivors or the general population.26

Soy foods are versatile, affordable, convenient, and can be used as a health-promoting

and nutrient-dense alternative to animal protein and should be explicitly encouraged.

Wheat gluten (which also contains iron) is another versatile and readily available protein

source to be encouraged as a substitute for red and processed meats.

Nuts and Seeds

Nuts and seeds provide plentiful amounts of protein, fiber, healthful fats (omega-3

polyunsaturated fatty acids, omega-6 polyunsaturated fatty acids, and monounsaturated

fatty acids) vitamin E, minerals (including magnesium, iron, and zinc) and

phytochemicals.

Due to this nutritional profile, nuts have been shown to have protective benefits against

hypertension, coronary heart disease, and gallstone formation.27 The high content of

lignans in flaxseeds has been found to reduce both cardiovascular risk28 and breast

cancer risk.29

Nuts and seeds are also satiating foods (making you feel full), due to their unique

combination of protein, fiber, and fat. They can be included in diets in many ways (e.g.,

as snacks, added to salads, spread on bread or fruit in “butter” form). Nuts and seeds

are convenient and portable snacks, as they do not require refrigeration and have long

shelf lives.

Major health organizations already support these recommendations for protein foods.

For example, the American Cancer Society supports consuming a healthy diet with an

emphasis on plant foods.30 It is essential that the DGA contain clear, consistent, and

actionable guidance for consumers regarding the types of protein foods that should and

should not be a regular part of their diet.

The DGA should explicitly recommend consuming these specific types of protein

sources such as legumes, soy products, wheat gluten, seeds, and nuts, in place

of red and processed meats.

26

American Institute for Cancer Research. Soy is Safe for Breast Cancer Survivors. Accessed online, April 2, 2015, http://www.aicr.org/press/press-releases/soy-safe-breast-cancer-survivors.html. 27

Ros, E. “Health benefits of nut consumption.” Nutrients 2, no. 7 (2010): 652-82. 28

Peterson J. et al. “Dietary lignans: physiology and potential for cardiovascular disease risk reduction.” Nutr Rev 68, no. 10 (2010): 571-603. 29

Lowcock E. C. et al. “Consumption of flaxseed, a rich source of lignans, is associated with reduced breast cancer risk.” Cancer Causes Control 24, no. 4 (2013): 813-6. 30

Kushi et al., 2012.

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7. Nutrient Density: Meat v. Plants

Claims that red meat and processed meats are “nutrient dense” are misleading

because they ignore all the harmful components of meat, and the fact that plants

are often nutritionally superior.

We want to take this opportunity to respond to some of the criticism of the DGAC for

recommending lowered red meat consumption; specifically regarding the claim that

meat is “nutrient dense” and essential to good health.

Nutrient density refers to nutrients per calorie. Plant foods contain some similar (and

typically more) nutrients as animal foods, and additionally contain fibers, additional

micronutrients and antioxidants, as well as thousands of phytochemicals – compounds

made by plants that offer a wide variety of health advantages including reducing

inflammation, protecting the cardiovascular system, and acting as antioxidants.31

A plant-centered diet provides all essential amino acids (when a variety of plant foods

are consumed) antioxidants, and a substantial amount of the DGAC’s identified

nutrients for under-consumption: vitamin A, vitamin C, vitamin E, calcium, magnesium,

potassium, and folate. In addition, plant foods contain hefty doses of fiber and

phytochemicals - the two most crucial nutrient groups for promoting optimal health,

which are not found at all in animal foods.

Fiber reduces risk for cardiovascular disease, hypertension, type 2 diabetes, obesity,

and certain gastrointestinal cancers. It also improves lipid profiles, blood pressure,

blood sugar control, and gastrointestinal issues such as constipation, hemorrhoids,

reflux, and more. In addition, fiber aids in satiety.32 Feeling satiated with fewer calories

is crucial for long-term weight management.

Relatedly, claims that lowered red meat consumption has resulted in higher obesity

rates are just a distraction. Although red meat intake may have declined in recent years,

consumption of other types of meat, cheese, and highly refined foods have significantly

increased,33 thereby providing plenty of empty calories and influencing the steady

incline of obesity rates.

Perhaps more importantly, meat contains health-damaging components, such

as saturated fats and cholesterol, along with the following:

31

Heneman, K. and S. Zidenberg-Cherr. “Nutrition and Health Info-Sheet for Health Professionals: Some Facts About Phytochemicals.” Accessed online, April 7, 2015, http://nutrition.ucdavis.edu/content/infosheets/fact-pro-phytochemical.pdf. 32

Burton-Freeman, B. “Dietary Fiber and Energy Regulation.” J Nutr 130 (2000): 272S-75S. 33

Barnard, N. “Trends in food availability, 1909-2007.” Am J Clin Nutr 91 (2010): 1530-36.

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Antibiotics: The vast majority (70 to 80 percent) of antibiotic use34 in the United

States is given to healthy livestock animals to avoid infections inherent in the

types of environments under which they are kept. This is the number-one

contributor to the increasingly virulent antibiotic-resistant infections that sickened

2 million and killed 23,000 Americans in 2013.35

IGF-1: Insulin-like growth factor 1 (IGF-1) is a hormone naturally found in animals

(including humans). This hormone promotes growth. When we consume it, we

are not only taking in extra but the amino acid profile typical of animal protein

stimulates our body’s production of IGF-1.36 Fostering growth as a full-grown

adult is unhealthy and can accelerate the growth of hormone-dependent cancers.

Trimethylamine N-Oxide (TMAO): This compound is converted by gut bacteria

with consumption of carnitine, found in meat. High levels of TMAO are

associated with inflammation, atherosclerosis, heart attack, stroke, and death.37

Neu5GC: This meat compound promotes chronic inflammation.38, 39

Toxins from cooked animal products: When meat is cooked, compounds called

polycyclic aromatic hydrocarbons (PAHs),40 heterocyclic amines (HCAs),41 and

advanced glycation end products (AGEs)42 are formed. These compounds are

carcinogenic, pro-inflammatory, pro-oxidative, and contribute to chronic disease.

34

The Pew Charitable Trusts. “Record-High Antibiotic Sales for Meat and Poultry Production.” Accessed online, April 7, 2015, http://www.pewtrusts.org/en/about/news-room/news/2013/02/06/recordhigh-antibiotic-sales-for-meat-and-poultry-production. 35

Center for Disease Control and Prevention. “Antibiotic/Antimicrobial Resistance.” Accessed online, April 7, 2015, http://www.cdc.gov/drugresistance/threat-report-2013/. 36

Allen, N. E., P. Appleby, G. K. Davey, R. Kaaks, S. Rinaldi, and T. J. Key. “The Associations of Diet with Serum Insulin-like Growth Factor I and Its Main Binding Proteins in 292 Women Meat-Eaters, Vegetarians, and Vegans. Cancer Epidemiology, Biomarkers, & Prevention 11 (2002): 1441-48. 37

Koeth, R. A. “Intestinal microbiota metabolism of L-carnitine, a nutrient in red meat, promotes atherosclerosis.” Nat Med 19, no. 5 (2013): 576-85. 38

Hedlund, M., V. Padler-Karavani, N. M. Varki, and A. Varki. “Evidence for a human-specific mechanism for diet and antibody-mediated inflammation in carcinoma progression.” Proc Natl Acad Sci USA 105, no. 48 (2008): 18936-41. 39

Taylor, R. E. C. J. Gregg, V. Padler-Karavani, D. Ghaderi, H. Yu, S. Huang, R. U. Sorenson, X. Chen, J. Inostroza, V. Nizet, and A. Varki. “Novel mechanism for the generation of human xeno-autoantibodies against the nonhuman sialic acid N-glycolylneuraminic acid.” J Exp Med 207, no. 8 (2010): 1637-46. 40

European Commission Health and Consumer Protection Directorate. “Polycyclic Aromatic Hydrocarbons - Occurrence in foods, dietary exposure and health effects.” Accessed online, April 7, 2015, http://ec.europa.eu/food/fs/sc/scf/out154_en.pdf. 41

National Cancer Institute at the National Institutes of Health. “Chemicals in Meat Cooked at High Temperatures and Cancer Risk.” Accessed online, April 7, 2015, http://www.cancer.gov/cancertopics/causes-prevention/risk/diet/cooked-meats-fact-sheet. 42

Uribarri, J., S. Woodruff, S. Goodman, W. Cai, X. Chen, R. Pyzik, A. Young, G. E. Striker, and H. Vlassara. “Advanced glycation end products in foods and a practical guide to their reduction in the diet.” J Am Diet Assoc 110, no. 6 (2010): 911-16.

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Finally, a word about vitamin B12, which is only found in animal products: The Institute

of Medicine recommends a mere 2.4 micrograms per day for adults, which is easy to

get on the dietary patterns recommended by DGAC. Also, many plant-based foods

(especially ready-to-eat cereals and plant-based milks) are now fortified with vitamin

B12, so animal products are not an essential source.

Simply put, you get more nutritional bang for the caloric buck with plant foods.

8. Sustainability

We strongly endorse the DGAC’s recognition of sustainability as an essential

component of federal dietary guidance.

We applaud the DGAC’s conclusion that, “linking health, dietary guidance, and the

environment will promote human health and the sustainability of natural resources.” The

DGAC’s findings reflect a substantial body of science that illustrates the synergies

between a healthy diet and a sustainable food system.

We specifically endorse the conclusion of the DGAC that “the availability and

acceptability of healthy and sustainable food choices will be necessary to attain food

security for the U.S. population over time.” We commend the DGAC’s careful

consideration of the scientific evidence on this topic and its recognition of sustainability

as an essential component of federal dietary guidance.

The Committee’s findings on sustainability reflect a rigorous and comprehensive

assessment of the latest scientific evidence and were prepared in close consultation

with experts spanning nutrition, agricultural, and environmental sciences. Its

prioritization of sustainability is consistent with a range of scientific consensus

organizations, including the National Research Council, a committee of the Institute of

Medicine, and the Academy of Nutrition and Dietetics.43 Furthermore, the DGAC’s

findings on sustainability are well aligned with dietary guidance published by the

governments of Germany, Sweden, the Netherlands, Australia, and Brazil.44

43

Institute of Medicine. (2014). Sustainable Diets: Food for Healthy People and a Healthy Planet: Workshop Summary. Washington, DC: The National Academies Press; National Research Council. (2010). Toward sustainable agricultural systems in the 21st century. Washington, DC: The National Academies Press; Nordin, S. M., Boyle, M., & Kemmer, T. M. “Position of the Academy of Nutrition and Dietetics: Nutrition security in developing nations: Sustainable food, water, and health.” J Acad Nutr Diet, 113, no. 4 (2013): 581-95. 44

Health Council of the Netherlands. (June 2011). Guidelines for a healthy diet: the ecological perspective. Publication no. 2011/08E; Nordic Council of Ministers, Nordic Council of Ministers Secretariat. (2012). Nordic Nutrition Recommendations 2012: Integrating nutrition and physical activity; German Council for Sustainable Development. (2013). The Sustainable Shopping Basket: A guide to better shopping.

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Less resource-intensive dietary patterns support nutrition and reduce greenhouse-gas

emissions, land, water, and energy use, and ecosystem harm. Our nation’s ability to

meet future food needs will depend on those environmental outcomes, particularly in the

context of a changing climate, with more extremes in weather such as drought, resource

shortages, changes in global dietary patterns, and population growth.45

The DGA should reflect the committee’s specific conclusion 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.”

In conclusion, we support the Dietary Guidelines Advisory Committee’s overall

recommendations that Americans consume less meat and more plant-based foods.

With more specific guidance, such as using commonly used terms consumers can

recognize, the Dietary Guidelines for Americans has the potential to become a powerful

tool for health promotion.

Thank you for the opportunity to comment on this important matter.

Sincerely,

Michele Simon, JD, MPH, author and public health attorney

On behalf of:

Allison Burgess, President, AB Foods / Match Hannah Kullberg, The Better Bean Company Ryan Howard and Dan Ziegler, Founders, Chicago Vegan Foods

Terry Tierney, CEO, Daiya Foods Bob Goldberg, CEO, Earth Island / Follow Your Heart Samantha Abrams, President, Emmy’s Organics David Lee, CEO, Field Roast Grain Meat Co.

45

Nellemann, C. (Ed.). (2009). The environmental food crisis: the environment's role in averting future food crises: a UNEP rapid response assessment. UNEP/Earthprint.

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Joel Henry, Founder, Fig Food Company Susan Leone, President, Fruit Bliss Heidi Lovig, CEO, Heidi Ho Organics

Roy Lebetkin, CEO, Lightlife Foods Miyoko Schinner, CEO, Miyoko’s Kitchen Matthew de Gruyter, CEO, Next Level Burger Sadrah Schade and Mike Woliansky, Co-Founders, No Evil Foods Greg Van Ullen, Co-Founder, OMilk Meg Carlson, President and CEO, Prosperity Organic Foods / Melt Ann Gentry, CEO, Real Food Daily Brian Swette, President, Sweet Earth Natural Foods Jessica Taft, CEO, Taft Foodmasters Jaime Athos, Ph.D., President and CEO, The Tofurky Company James Corwell, CEO, Tomato Sushi Daniel Staackmann, President and Nicole Sopko, Vice President, Upton’s Naturals