Dietary Guidelines for Americans 2000
STATEMENT BY NEAL D. BARNARD, M.D.,
ON THE DIETARY GUIDELINES
ADVISORY COMMITTEE'S
RECOMMENDATIONS AND REPORT

Thank you for the opportunity to comment on the Dietary Guidelines Advisory Committee's recommended revisions to the Dietary Guidelines for 2000. As a health advocacy organization with more than 100,000 members, including physicians and members of the public, which is greatly concerned about the nation's health status, as well as the inadequate emphasis on disease prevention in federal nutritional policies, PCRM asks that you to make the following changes to the Dietary Guidelines for 2000:

First, PCRM supports the Committee's inclusion of soy beverages in the dairy group, as noted in the chart called "What Counts as a Serving?" on page 17. Many people may wish to choose a soy or other nondairy beverage, and there is no scientific reason to insist on the inclusion of cow's milk in anyone's diet. Soy beverages are similar to cow's milk in overall protein and carbohydrate content, but are lower in saturated fat than 2% cow's milk, with only 1 gram, rather than 3 grams, of saturated fat per cup. Soy beverages are far lower in fat than cheddar cheese, one of the other suggested foods in the dairy group, which has 14 grams of fat, including 9 grams of saturated fat in the suggested 1½-ounce serving. Unlike nonfat cow's milk, which derives fully 55% of its calories from lactose sugar, soy beverages are free of lactose, animal proteins, and animal fats.

Second, PCRM strongly discourages removing the clear statement that vegetarian diets are healthful choices from the 1995 Guidelines. Page 8 of the 1995 Guidelines states, "Vegetarian diets are consistent with the Dietary Guidelines for Americans and can meet Recommended Dietary Allowances for nutrients." The Committee—we believe mistakenly—recommended removing this language as well as any other reference to the benefits of eating a vegetarian diet.

The National Nutrition Monitoring and Related Research Act states "the information and guidelines contained in each [Dietary Guidelines for Americans] shall be based on the preponderance of the scientific and medical knowledge which is current at the time the report is prepared. 7 U.S.C. § 5341. The Committee failed to cite any scientific evidence to support removal of language promoting a vegetarian diet. Additionally, the preponderance of the current scientific and medical evidence fails to defend the removal of this section from the Guidelines. In fact, the preponderance of the current scientific and medical evidence requires that vegetarian and vegan diets should be strongly encouraged in the Guidelines.

The adoption of a vegetarian diet is among the most common nutritional choices made by healthy or symptomatic people, either early or later in life. As described in a 1995 review in Preventive Medicine, vegetarians have 40% less cancer risk, as well as substantially lower risk of heart disease, hypertension, diabetes, obesity, gallstones, and other conditions, compared to omnivores.¹

Vegetarian and/or vegan diets are now offered to heart patients as part of insurance-reimbursable treatment programs. As a result, a great many individuals and practitioners may opt for vegetarian diets for either the short or long term. While a low-fat omnivorous diet reduces serum LDL cholesterol levels by only about 5-6 percent, a low-fat vegetarian diet is much more effective, typically reducing LDL cholesterol levels by roughly 20 percent.^2-4 Given that atherosclerosis is present and steadily progressing in most adult Americans and contributes to their leading cause of death, encouragement toward a vegetarian diet is an important provision.

A section on vegetarian diets should note that the only genuine nutritional issue—and one that is easily addressed—is the need for a dietary source of vitamin B₁₂. Convenient sources include fortified cereals or soy beverages, or any common multiple vitamin. There is no justification for exaggerated cautions regarding iron, calcium, or zinc. Plant sources of iron and zinc are more than adequate, and calcium balance is dramatically and positively altered by the exclusion of animal protein and excess sodium from the diet. The fact is, a switch from a meat-based diet to a vegetarian diet often improves intake of dietary fiber, some B-vitamins, vitamin C, and other antioxidants.

We believe the Committee may have omitted this text under the mistaken notion that a vegetarian diet is a life-long choice of a circumscribed group of people defined by religion or philosophy, and that it wished not to credit their practices with a mention in the Guidelines. However, the number of people who are vegetarians—or the reasons they may choose to be vegetarian—is irrelevant to the consideration of whether consumption of a vegetarian diet should be encouraged in the Guidelines. As stated above, the only factor to be considered is the preponderance of the scientific and medical evidence.

Our final recommendation is that the discussion of calcium must focus, not on intake, but on balance. While the Committee mentioned the calcium-depleting effect of sodium, it inexplicably omitted the well-established ability of animal protein to increase urinary calcium losses, apparently due to the effect of sulfate released from their amino acid load.

References
1. Barnard ND, Nicholson A, Howard JL. Medical costs attributable to meat consumption. Prev Med 1995;24:646-55.
2. Hunninghake DB, Stein EA, Dujovne CA. The efficacy of intensive dietary therapy alone or combined with lovastatin in outpatients with hypercholesterolemia. N Engl J Med 1993;328:1213-9.
3. Ornish D, Brown SE, Scherwitz LW, et al. Can lifestyle changes reverse coronary heart disease? Lancet 1990;336:129-33.
4. Barnard ND, Scialli AR, Bertron P, Hurlock D, Edmonds K, Talev L. Effectiveness of a low-fat, vegetarian diet in altering serum lipids in healthy premenopausal women. Am J Cardiol 2000; in press.

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