Typically, the scientific report is released in early fall, allowing the mandatory 60-day public comment period to conclude before the outgoing administration finalizes the guidelines. However, in this case, the comment period will extend beyond the Biden administration into the Trump era, shifting responsibility for drafting the guidelines to the newly appointed Secretaries of the USDA and HHS.
While the Secretaries are legally required to issue dietary guidelines, the law sets few constraints on how they proceed. There’s no statutory requirement to promote the guidelines to the public, for instance, and the Secretaries can accept or reject recommendations from the scientific report as they please.
No doubt, any decisions they make will be seen as fueled by political considerations, yet there’s a far better reason to reject a number of the new recommendations: they are not based on rigorous science and, in many cases, would almost certainly harm our health.
Key recommendations in this report include:
- Reducing red and processed meats;
- Replacing poultry, meat, and eggs with peas, beans, and lentils as sources of protein;
- No limits on ultra-processed foods; and
- Continued caps on saturated fats, to be replaced by vegetable (seed) oils.
Controversy over ultra-processed foods
The question of whether the expert committee should set limits on ultra-processed foods (UPF) has sparked controversy ever since the group’s final public meeting, when it revealed it couldn’t make a recommendation to restrict these foods, because the evidence on them was “limited.” Calls for reducing UPF have transcended partisan lines—from Robert F. Kennedy Jr. reportedly advocating for their removal from school lunches to Marion Nestle, NYU professor emerita, calling the committee’s “non-recommendation” a “travesty.”
Indeed, there is, “remarkable, strong bipartisan concern about ultra-processed food,” as Jerold Mande, a former deputy undersecretary for food safety at the Department of Agriculture under two Democratic presidents, told Time magazine.
Nevertheless, the expert committee responsible for yesterday’s report insisted that the evidence for urging reductions in ultra-processed foods (UPF) was “limited.”
It's possible that conflicts of interest on the expert committee may have influenced this decision. Nine out of the 20 members were found to have a tie with food, pharmaceutical or weight loss companies or industry groups with a stake in the outcome of the guidelines, according to a report by the non-profit public interest group, U.S. Right to Know. The most frequently occurring conflicts were with Novo Nordisk and Eli Lilly, makers of weight-loss shots like Ozempic and Wegovy.
Still, it’s important to say that the committee’s assessment of the evidence on UPF as limited is correct. The USDA systematic review of these foods found only one small clinical trial testing the effects of these foods on health outcomes. This trial, conducted at the National Institutes of Health, involved 20 adults for only 28 days (14 days on a UPF diet and 14 days on a whole-food diet). The subjects were found to consume more calories while on the UPF diet, but even so, the test is too small and preliminary to generalize its conclusions to an entire nation. As I’ve written before, we have many more and better studies on some of the components of ultra-processed foods—sugars and starches, for instance—and should act on these, more precise and robust data first.
Marion Nestle acknowledged on her blog that the advisory committee must stick to “evidence-based recommendations,” while giving the strong impression that she wished it weren’t so. She’s also quoted in a STAT article that headlines her comment about the “impossible restrictions” imposed on the guidelines by limiting recommendations to only those supported by strong evidence.
In my view, we should not be arguing for guidelines based on lesser evidence. The near-complete lack of rigorous data for the original guidelines in 1980 set in motion a Titanic of misguided advice that has coincided with our astonishing epidemics in chronic diseases. According to the best available government data, Americans have largely followed the guidelines, and despite this, we have not only become sick but very sick.
Echoing this view is a Congressionally mandated report by the National Academies of Sciences, Engineering, and Medicine, which concluded in 2017 that the US dietary guidelines are not currently “trustworthy,” in part due to a “lack of scientific rigor” in the process. Since then, little has changed (the USDA did not fully adopt even one of the Academies’ 11 recommendations). In this light, advocating for even less rigorous standards based on even weaker evidence seems to me misguided or possibly reckless.
Lower standards for reducing meat, poultry and eggs
Paradoxically, the expert committee was not a stickler for rigorous evidence when it came to advising reductions in meat, poultry, and eggs.
Before getting into the evidence, though, I’d like to revisit the likelihood (as I wrote in an earlier post) that these changes, if adopted, would exacerbate our disease epidemics. This advice does not consider that plant-based proteins are not as complete as those from animals and also not as bioavailable. Plant sources like peas and beans also pack a hefty load of carbohydrates and calories for the same amount of protein, making them a far less healthy option for people with metabolic conditions such as obesity and diabetes who need to be mindful of controlling their blood sugars.
The expert committee also found that reductions in meat, eggs, and poultry would lead to further shortfalls in fiber, and vitamins D and E, a significant fact given that the existing guidelines already fail to meet goals for vitamins D and E, folate, choline, and iron.
Here are the committee’s findings on nutrients announced at its final public meeting:
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