Updating American dietary guidelines

I appreciate the opportunity to comment on the Scientific Report of the 2015 Dietary Guidelines for Americans Committee (DGAC). I’m writing on behalf of the 55,000 member-owners of PCC Natural Markets, the largest consumer-owned grocery retailer in the country with 10 Seattle-area stores and more than $220 million in annual sales. My comments pertain to the report’s recommendations for added sugar, dietary fats and food sustainability.

1. Added Sugar (Chapter 2: Dietary Patterns, foods, and nutrients and health outcomes)
   • We support the emphasis on avoiding sources of added sugar, which currently contributes almost 15% of the calories consumed in the United States.
   • Added sugars need to have their own % Daily Value, rather than being combined with solid fats, as in the 2010 Dietary Guidelines for Americans. We suggest setting the DV for added sugars between 5-10% of calories, as recommend by the American Heart Association and the World Health Organization.
   • Added sugars (grams) should be required on Nutrition Facts Panels, so shoppers easily can determine whether a food contains added sugars, or natural (intrinsic) sugars such as with carrots.
   • We agree with the DGAC that artificial sweeteners (aspartame, saccharin, sucralose) need more research and should NOT be recommended as alternatives for added sugars. Instead, we should emphasize more healthful replacements for added sugars such as water, fruits and vegetables. In addition to the potential carcinogenic effect of aspartame mentioned by the DGAC, new evidence suggests that artificial sweeteners may raise diabetes risk, potentially by their effects on the gut bacteria.
2. Dietary cholesterol and Total fat (Chapter 1: Food and nutrient intakes, and health: current status and trends)
   • We support the de-emphasis on dietary cholesterol and total fat in the diet. We agree with the DGAC that “cholesterol is not a nutrient of concern for overconsumption” because of new evidence that cholesterol in food has a smaller impact on blood cholesterol than the mix of saturated, trans, and unsaturated fatty acids in the diet.
3. Food Sustainability (chapter 5: Food sustainability and safety)
   • We applaud the DGAC for the incorporation of environmental sustainability into the Dietary Guidelines for Americans. While there is some debate about the sustainability of different foods and production methods, it is essential that we all become more aware of the environmental implications of our food system.
   • We support and advocate the findings of the International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD), a four-year study of the intertwined problems of global agriculture, hunger, poverty, power and influence. More than 400 scientists, civil leaders, and corporate and government representatives were involved, working under the auspices of the World Bank, the World Health Organization, the United Nations and the Food and Agriculture Organization.
     1. The IAASTD concluded that investing in small-scale, low-input, agro-ecological and organic farming that makes use of traditional knowledge will be more effective in meeting today’s challenges than the energy- and chemical-intensive industrial agricultural model. It notes that industrial agriculture has degraded the natural resources on which human survival depends and contributes daily to worsening water, energy and climate crises.
     2. The IAASTD report also documents the unfair influence of crop subsidies and transnational agribusiness in what we eat. It advocates farmers having control over resources, more equitable trade agreements, and increasing local participation in policy- and decision-making processes.
   • We support the emphasis on a plant-based-diet because of the many environmental problems attributed to industrially produced animal foods (greenhouse gas emissions, water and energy use, and the increasing threat of antibiotic resistance). It would be beneficial, however to emphasize the benefits of switching from conventional meats (raised in confined feedlots) to antibiotic-free, grass-fed, and pasture-raised meat and dairy products.
   • Seafood sustainability is an important but complex topic for many shoppers to grasp, so we suggest looking to established organizations such as Monterey Bay Aquarium’s Seafood Watch program for guidance on how best to define and emphasize sustainable seafood options. PCC Natural Markets has adhered to Monterey Bay Aquarium sustainable seafood standards for years.
   • We agree with the DGAC that “consumer friendly information that facilitates understanding the environmental impact of different foods should be considered for inclusion in food and menu labeling initiatives.”

We at PCC Natural Markets applaud the DGAC for its work bringing the DGA up-to-date with the current research on food and nutrition, rather than continuing to offer the same “old” advice from previous DGAC reports.

Respectfully,
Nick Rose, MS
Nutrition Educator, PCC Natural Markets
4201 Roosevelt Way NE
Settle, WA 98105