For Immediate Release

May 10, 2023
Contact: Press@nutritioncoalition.us

Experts Say Conflict-of-Interest Disclosure for the USDA-HHS Dietary Guidelines Advisory Committee is Inadequate, Lacks Transparency

The Nutrition Coalition and other experts expressed surprise and disappointment in the recent disclosure of conflicts of interest (COI) for the 2025 Dietary Guidelines Advisory Committee, by the Departments of Agriculture and Health and Human Services (USDA-HHS).

The disclosures are highly unusual in that they do not list conflicts by individual committee member. Instead, the conflicts are combined together, without attribution to any particular person.

Gordon Guyatt, one of the world’s most cited researchers and Distinguished Professor at McMasters University, stated the following: 

 “The USDA's disclosure doesn't meet basic standards of scientific practice. Conflicts need to be listed for each individual by name. Without this information, the public can't understand the particular influences on each committee member and the possibility that individual members are inappropriately included. Furthermore, because the Dietary Guidelines Advisory Committee is broken up into subcommittees to answer different questions, the public has no idea whether each subcommittee is comprised of people with a balanced set of viewpoints. This disclosure by USDA may be legal according to federal regulations, but it does not comply with widely accepted standards for any group making guidelines for practioners, patients, or the public. If the USDA is trying to convey the message that they have something to hide and are doing their best to hide it, they are doing an excellent job.”

Nina Teicholz, journalist and founder of the Nutrition Coalition, added:

“I have never seen this type of collective disclosure where individual relationships are anonymized. In the many thousands of scientific papers and guidelines I’ve read, conflicts-of-interest (COI) are always listed by name. Further, by listing COI in this way, the USDA-HHS fail to comply with a clear recommendation, by the National Academies of Sciences, Engineering and Medicine, which stated in a 2017 Congressionally mandated report, that the USDA-HHS should be "publicly posting a policy and form to explicitly disclose financial and nonfinancial biases and conflicts’ of committee members.”

To date, the USDA-HHS have failed to fully adopt even one of the National Academies’ 11 recommendations.

The lack of proper disclosure also means that the USDA-HHS cannot comply with the NASEM’s recommendation to manage COI by “Creating and publicly posting a policy and form to explicitly disclose financial and nonfinancial biases and conflicts” of committee members.

Conflicts of interest on the DGAC have long been a concern and were accentuated last year by the publication of the first-ever systematic review of a DGAC’s financial ties, by Teicholz and co-authors. Published by the University of Cambridge Press, the paper documented that 95% of the 2020 DGAC had at least one tie with a food or pharmaceutical company and that half of the committee members had 30 such ties or more. Kellogg, Abbott, Kraft, Mead Johnson, General Mills, and Dannon were found to have the most frequent and durable connections to the committee.

Lead author on that paper, Dr Mélissa Mialon BSC, MSc, PhD, a Research Assistant Professor at Trinity Business School, Trinity College Dublin, Ireland and an expert on COI research, commented on this recent disclosure:

"These disclosures of COI by USDA-HHS are quite an unusual approach. Usually, one would declare his or her individual conflicts of interest, for better transparency and to provide information that could reveal biases on certain topics. With the current disclosure, there is no possibility to understand which person has a COI and therefore might have a bias. For instance, in our analysis of the 2020 DGAC, we found that some members overseeing the science on infant feeding issues were receiving money from Abbott and other actors in the baby food industry, which is a clear conflict of interest for that discussion. Normally, experts with that kind of COI would recuse themselves from such discussions. With the current document shared by USDA-HHS, there’s no way for the public or anyone to know if the right mechanisms are being put in place to protect decision-making from biased judgements. There is no way to hold those experts accountable for their decisions in light of their COI.”

Another co-author on the paper, Ashka Naik, Director, Research and Policy at Corporate Accountability, commented:

"The seminal nutrition guidance informing the health of the country should be subject to the highest level of transparency and public accountability. While it is good to see progress toward what advocates have long-demanded, disclosures should be de-anonymized. If members cannot publicly stand behind their affiliations, they should not be informing our children’s diets or be responsible for our nation's well-being. What is more, while this disclosure may demonstrate a shift away from a Committee steeped-in ties to industry groups like the International Life Sciences Institute (ILSI), it is still replete with ties to Big Pharma and the food industry. Disclosure as such is not a substitute for freeing the guidelines from these unnecessary and potentially problematic entanglements with the industry.”

Further, the USDA-HHS appear to have violated regulations for the Federal Committee Advisory Act (FACA), which governs the DGAC, by not even registering the committee’s basic information in the FACA database, hosted by the General Services Administration.

We are calling on the USDA-HHS to take immediate action to address these shortcomings by releasing individual disclosures of potential conflicts of interest for each DGAC member, including any financial or non-financial relationships with industry groups, as recommended by the NASEM.

We believe that it is imperative for the DGAC to operate with complete transparency, with the aim of ensuring that the guidelines are based solely on scientific evidence and not influenced by industry interests.