How to Submit a Public Comment on the Dietary Guidelines

The U.S. Department of Agriculture (USDA) is currently soliciting public comments about a list of key issues for the 2020-25 U.S Dietary Guidelines for Americans. This was the first time that the USDA or the U.S Department of Health and Human Services (HHS), the two agencies tasked with developing the Guidelines, took this unusual step.

Notably, among the issues listed by USDA as needing review are saturated fats and low-carbohydrate diets. This is an unprecedented opportunity to contribute your thoughts about whether the current guidelines are based on the most up-to-date reviews of the current science.

The comment period is set to run through March 30, 2018. You can submit your comment here.

Click here to get updates on the Dietary Guidelines process and to learn what else you might do to help.

Here is some guidance for what to include in your comments:

On the Low-Carbohydrate Diets:

Existing USDA guideline recommendation:
The low-carbohydrate diet is not recommended.

Our view:
Low-carbohydrate diets have now been tested in at least 70 clinical trials on nearly 7,000 people, including a wide variety of sick and well populations, mainly in the U.S. Thirty-two of these studies have lasted at least six months and six trials went on for two years, enough time to demonstrate the lack of any negative side effects. In virtually every case, the lower-carb, higher-fat diets did as well or better than competing regimens. The cumulative evidence shows that low-carb diets are safe and effective for combating obesity, highly promising for the treatment of Type 2 diabetes, and they improve most cardiovascular risk factors.

On Saturated Fats:

Existing USDA guideline recommendation:
Americans are advised to limit saturated fats to 10% of calories and instead to eat 27 grams/day of polyunsaturated vegetable oil.

Our view:
The data do not support the existing caps on saturated fats.

Regarding the (more rigorous) clinical trial data, at least 8 major review papers in recent years have concluded that saturated fats do not have an effect on cardiovascular mortality or total mortality. While saturated fats can be shown to raise the “bad” LDL-cholesterol, this elevated risk factor does not result in higher mortality rates, reflecting a more complicated pathway for cardiovascular disease than simply LDL-C. Note that saturated fats also consistently raise the “good” HDL-cholesterol, which may be a compensating effect.

Regarding the (weaker) observational evidence, meta-analyses of this data consistently find no association between saturated fat and cardiovascular disease. Moreover, there is a substantial observational finding that low consumption of saturated fats is associated with higher mortality and higher rates of stroke.

Moreover, officials risk doing harm to populations by limiting saturated fats. These fats consistently raise the “good” HDL-C and are the only food known to do so. They are also part of many natural, unprocessed, “whole” foods, such as milk, meat, cheese, etc. that are not only rich in the nutrients considered necessary by health authorities to sustain human life, but also contain these nutrients in their most “bioavailable” form.

For any naturally occurring food, the default judgement must be that it is innocent until proven guilty. Saturated fats were condemned in the 1950s based on what we now know to be weak and unreliable evidence. Large clinical trials have since failed to support the diet-heart hypothesis. Thus, despite being rigorously tested, this hypothesis cannot be confirmed. Saturated fats cannot be considered guilty, as charged, and therefore, the limits on them should be lifted.

For a full look at the current evidence, click here.

Beyond commenting on the science, you might consider telling your success story about how you achieved good health by ignoring the dietary guidelines.

The Nutrition Coalition (TNC) does not promote any one diet, nor does it promote a “one size fits all” model for all people. Yet it is an undeniable fact that the high-carbohydrate approach enshrined in the Dietary Guidelines for Americans has not produced good health for the majority of Americans.

Again, comments can be submitted here.

Please take the time to comment! Now is our chance to have guidelines based on the best and most current science!!