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What’s for Dinner? A Preview of the People, Process and Politics Updating Federal Dietary Guidelines

By Sarah Reinhardt

Months behind schedule, two federal departments have officially kicked off the process for writing the 2020-2025 iteration of the Dietary Guidelines for Americans. Updated and reissued every five years, these guidelines are the nation's most comprehensive and authoritative set of nutrition recommendations. And although the process is meant to be science-based and support population health—and has historically done so, with some notable exceptions—there are plenty of reasons to believe that the Trump administration is preparing to pitch a few curveballs.


First, a little background: The two agencies responsible for issuing the guidelines are the U.S. Department of Agriculture (USDA) and Department of Health and Human Services (HHS). Earlier this month, the agencies released a call for nominations to the advisory committee that will review current nutrition science and write recommendations for the new guidelines. For the first time, the guidelines will include recommendations for maternal nutrition and for infants and toddlers through 24 months—meaning we may see a larger advisory committee and some extra work put into developing these recommendations from scratch.

And that won't be the only change since the last cycle. There was a bitter political battle over the 2015-2020 Dietary Guidelines, in which the advisory committee made mention of environmental sustainability, noting that plant-based diets that include plenty of foods like fruits, vegetables and whole grains are good for both our health and the future of our food supply. These recommendations were ultimately omitted, and the episode culminated in Congress writing new legislation to limit the scope of the guidelines and mandate a so-called critical review of their scientific integrity. The full impact of this anti-science legislation, which was tacked onto a 2016 appropriations bill (despite strong opposition from public health and nutrition groups), will be brought to bear during the coming months.

All that said, there's one thing that's likely to remain the same: the industries that wielded influence over the 2015-2020 guidelines haven't gone anywhere. On the contrary, they may be emboldened by an administration that has repeatedly given preference to corporate interests, sidelining science and sacrificing the public good in the process.

The People: What Will Become of the Scientific Advisory Committee in the Trump Era?

Typically, the first major step in developing new Dietary Guidelines is to identify the group of nutrition and health experts who will form the Dietary Guidelines Advisory Committee (or DGAC). These nominees will be well-known in their fields, and will bring with them more than a decade each of experience as medical or nutrition researchers, academics and practitioners. Members of the DGAC serve the committee for two years, after which they submit a final scientific report to the USDA and HHS with their recommendations.

This part of the process is happening in real time. The 30-day call for nominations is now open and will close on Oct. 6. (Read more about the criteria for nominees here.)

USDA

But the negligence the Trump administration has shown in maintaining existing scientific advisory committees is concerning, to say the least. An analysis by my colleagues here at the Union of Concerned Scientists shows that, during the administration's first year in office, federal science advisory committees met less frequently than in any other year since 1997, when the government began tracking this data. A majority of the committees are meeting less than their charters require, and committee membership has also decreased—with some agencies disbanding entire advisory committees altogether.

Furthermore, what happens after the public submits nominations to the DGAC happens largely behind closed doors. Nominations will be reviewed by USDA and HHS program staff, and the slate of chosen nominees will be evaluated and vetted internally. Formal recommendations for the committee will then be reviewed and approved by the USDA and HHS secretaries. Per their most recent communication, the agencies hope to announce the 2020-2025 DGAC by early next year.

If you're thinking that the committee selection lacks a certain element of transparency, you're not the only one.

In one of two reports released last year examining the Dietary Guidelines process (the result of the aforementioned legislation, passed in 2016 appropriations rider), the National Academy of Medicine recommended that the public have the opportunity to review the provisional committee for bias and conflicts of interest before it's approved.

It's worth repeating that the selection of committees in recent DGA cycles has successfully brought a wealth of knowledge and expertise to the process—resulting, for the most part, in strong evidence-based recommendations. But in an administration where the "D" in USDA has come to stand for DowDuPont, concerns about undue influence on the committee selection may be well warranted. (See "The Politics" below.)

The Process: More to Do, and Twice as Fast

After the advisory committee is appointed, the committee begins to review the current body of nutritional science to generate its recommendations. The recommendations are based on a "preponderance of scientific evidence," which means they consider a variety of research and study designs. (Though randomized controlled trials are typically the gold standard in science, this type of study is incredibly difficult to do with diet.)

The committee won't review everything—there are certain topics that are selected each cycle, based on what new evidence has emerged and what issues are of greatest concern to public health. And here's the first place you'll see the 2020-2025 DGAs break from tradition: rather than identifying topics of interest after the committee is selected, USDA and HHS have developed a list of topics first, soliciting public comments in the process. You can read their list here.

There are immediate glaring absences in the topic list, including fruits, vegetables and whole grains—some of the staples of what we consider a healthy diet. This may just mean that the committee won't be revisiting these topics, and will instead default to existing recommendations—but the lack of clarity here is disconcerting. A brief note at the end of the topic list, perhaps meant to explain the omissions, has left public health and nutrition groups scratching their heads: "Some topics are not included above because they are addressed in existing evidence-based Federal guidance. In an effort to avoid duplication with other Federal efforts, it is expected that these topics will be reflected in the 2020-2025 Dietary Guidelines by referencing the existing guidance. Thus, these topics do not require a review of the evidence by the 2020 Dietary Guidelines Advisory Committee."

USDA

Meanwhile, the topics that have been explicitly named include added sugars; beverages, such as dairy, sugar-sweetened beverages and alcohol; the relationship between certain diets (think: Mediterranean Diet, vegetarian, etc.) and chronic disease; and different dietary patterns across life stages, including infancy and toddlers through 24 months. What didn't make the cut? A mention of red meat or processed meats—which have been linked to certain types of cancer and other health risks. The agencies (predictably) sidestepped this issue, making reference only to types of dietary fats.

If this sounds like a lot to sort through, it will be. And the tentative timeline that the agencies have proposed is ambitious. After the committee is announced in early 2019, it will have just over one year to deliberate before releasing its scientific report. During that time, the committee will hold approximately five public meetings (last cycle, there were seven) and offer an extended period of open public comment. After the DGAC scientific report is released, the public will also have one final opportunity to comment.

But if there's anything we learned from the last DGA cycle, it's that what can happen during that gap—between the release of the DGAC scientific report and the issuance of the DGAs—is critical, and it isn't always clear. Enter "The Politics."

The Politics: When Money Talks

What happened during the 2015-2020 DGA cycle?

The DGAC advisory report, submitted in February 2015, included recommendations for plant-based diets that supported both human health and environmental sustainability—an unprecedented move. Per the report: "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."

But eight months later, the writing was on the proverbial wall, in the form of a blog written by former USDA Secretary Vilsack and HHS Secretary Burwell. Sustainability is outside the scope of the DGAs and would not be included.

Two months after that, the 2016 appropriations bill was passed, stating that any revisions to the Dietary Guidelines for Americans be limited in scope to nutritional and dietary information.

By all appearances, the key concern seemed to be that science-based sustainability recommendations were outside the scope of the DGAs. But you don't have to read too far between the lines to see that many were more concerned about sales—as in, sales of foods that aren't central to a plant-based diet. Like, for example, meat and dairy.

At a Congressional hearing on the matter, Rep. Mike Conaway, current chair of the House Agriculture Committee, put it this way: "[the inclusion of sustainability] could result in misguided recommendations that could have ill effects on consumer habits and agricultural production."

Rep. Glenn Thompson, current chair of the House Agriculture Subcommittee on Nutrition, put a finer point on his interests: "What can we do to remove policies that hinder milk consumption, and to promote policies that could enhance milk consumption?"

It's hardly a stretch to imagine that what happened during the 2015-2020 DGA cycle—and to the advisory committee's recommendations that were seemingly lost in translation—was a direct product of industry influence.

And though efforts to communicate the science behind more sustainable, plant-based diets have been all but stymied, there is still plenty at stake for industry groups in the 2020-2025 DGA cycle. Expect to see some of the usual suspects make an appearance, including the meat industry, dairy industry, and sugar-sweetened beverage associations, as well as formula companies, which will have vested interest in shaping the new recommendations for infants and toddlers. (This may be happening in real-time, too. Just this spring, Gerber announced it would join its parent company, Nestle, at its headquarters in Rosslyn, Virginia—just a stone's throw from the capitol.)

As this process unfolds, the Union of Concerned Scientists will be there—watchdogging and waiting. Stay tuned to learn more about how you can help us stand up for science and make the 2020-2025 Dietary Guidelines for Americans the strongest, most health-promoting edition yet.

Sarah Reinhardt is the food systems and health analyst for the Food & Environment program at the Union of Concerned Scientists.

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