Dietary Guidelines for Americans 2000
PCRM'S COMMENTS ON THE
DIETARY GUIDELINES ADVISORY COMMITTEE'S
RECOMMENDATIONS AND REPORT

The Dietary Guidelines Advisory Committee released its Report of the Dietary Guidelines Advisory Committee on the Dietary Guidelines for Americans, 2000 to the Secretaries of the U.S. Department of Agriculture and the U.S. Department of Health and Human Services, who will rely on the report in developing and issuing new Dietary Guidelines. The Committee's report includes ten Guidelines with accompanying text to explain each one.

The following is a review and comment of the Committee's report based on the ten Guidelines suggested by the Committee.

I. "AIM FOR A HEALTHY WEIGHT" GUIDELINE

A. Pages 5 and 8: "Advice for Today"
Page 5, paragraph 2 states: "Eating mainly vegetables, fruits, and grains helps you feel full, achieve good health, and manage your weight." Page 8 states: "Build a healthy base by eating vegetables, fruits, and grains…."

These recommendations should be adopted; however, legumes (beans, peas, and lentils) should be included as part of the foundation for a healthy diet, rather than being subsumed in the vegetable and meat group. Moreover, these statements should emphasize that a diet of fruits, vegetables, grains, and legumes is sufficient for a healthful and satisfying diet.

B. Page 6, paragraph 2
Paragraph 2 reads: "If you choose fish, poultry, or lean meat, ask that it be grilled rather than fried."

If this statement is adopted, it should include tofu, such that: "If you choose tofu, fish, poultry, or lean meat, ask that it be grilled rather than fried."

II. "BE PHYSICALLY ACTIVE EACH DAY" GUIDELINE

A. Box 5: "Health Benefits of Regular Physical Activity"
An additional bullet should be added to Box 5 which says: physical activity "slows bone loss and maintains bone health."

B. Page 12, paragraph 2
The idea set forth in the last sentence of paragraph 2—"Calcium and other nutrients are needed to build and maintain strong bones, but physical activity is needed as well"—is appropriate, but needs to be strengthened. The statement should be more straightforward and conclusive in stating the relationship between physical activity and bone health. For example, the statement should read, "Calcium and other nutrients, including vitamin D, potassium, magnesium, and phytochemicals, are needed to build and maintain strong bones, as is reducing sodium and animal protein intake. Additionally, exercise slows bone loss and is one of the most important factors in maintaining bone health."

III. "LET THE PYRAMID GUIDE YOUR FOOD CHOICES" GUIDELINE

A. Page 14, introductory paragraph
The last sentence of the introductory paragraph states: "If you avoid all foods from any of the five food groups, seek guidance to help ensure that you get all the nutrients you need." This remark implies that people who consume a vegetarian or vegan diet are at greater risk of not getting enough vitamins and minerals. Such statement is not supported by the scientific evidence, is therefore unnecessary, and must be removed.

1. The fourth edition of the Dietary Guidelines did not include this statement. In fact, the fourth edition of the Dietary Guidelines states: "Vegetarian diets are consistent with the Dietary Guidelines for Americans and can meet Recommended Dietary Allowances for nutrients. You can get enough protein from a vegetarian diet as long as the variety and amounts of foods consumed are adequate."

2. The Committee did not provide any new scientific evidence or other support to justify inclusion of this statement. In particular, there is no study cited by the Committee which establishes that vegetarians or vegans are at any greater risk of not getting adequate amounts of vitamins and minerals in their diet than those who consume a meat-and-dairy-based diet.

3. The modification to the "dairy group" recommended by this Committee makes this statement unnecessary and inappropriate as vegetarians and vegans could, and most likely would, consume foods from each of the five food groups: fruits, vegetables, grains, beans, nuts, and soymilk/soy cheese/soy yogurt with added calcium.

B. Box 7: "How Many Servings Do You Need Each Day?"

1. The foods included in the "Milk, Yogurt, and Cheese (Dairy) group," set forth in Box 7, are inconsistent with all other references to the dairy group. In particular, soy-based beverages with added calcium must be included in the "dairy group" in Box 7.

2. The "dairy group" should be renamed the "dairy and soymilk group" or the "calcium-rich food group" to be accurate and consistent with the Committee's recommendations.

3. The Committee's recommendation to re-order the food items in the "beans and meat group," listing dry beans first, should be adopted. Further, this change should be made to all other references to the "beans and meat group."

C. Pages 15-16: "Use Plant Foods as the Foundation of Your Meals"

1. The Committee's recommendation to use plant foods as the foundation of one's meals should be adopted. However, legumes (beans, peas, and lentils) should be included as part of the foundation for a healthy diet. Moreover, this statement should more strongly emphasize that a diet based on fruits, vegetables, grains, and legumes is not only sufficient for a healthy and fulfilling diet, but reduces the risk of a broad range of health concerns:

a. Vegetarians have much lower serum cholesterol levels than meat-eaters.

b. Heart disease is uncommon among vegetarians because vegetarian meals are typically low in saturated fat and usually contain little or no cholesterol.

c. Vegetarians have lower blood pressure than non-vegetarians.

d. Vegetarians have lower diabetes prevalence and, when it occurs, are better able to control the disease than non-vegetarians.

e. A vegetarian diet helps prevent cancer. Studies of vegetarians show that death rates from cancer are only about one-half to three-quarters of those of the general population.

f. Vegetarians have significantly less colon cancer and breast cancer in some studies.

g. Vegetarians are less likely to form either kidney stones or gallstones.

2. The last sentence of page 15 continued to page 16 should be revised. Presently, it reads: "Enjoy meals that have rice, pasta, tortillas, or whole grain bread at the center of the plate, accompanied by plenty of fruits and vegetables and moderate amounts of low-fat foods from the dairy group and the meat and beans group."

In particular, this statement should be consistent with the inclusion of soy-based beverages in the "dairy group" (which, as previously stated, should be renamed throughout the Guidelines as the "dairy and soymilk group" or the "calcium-rich food group"). Further, this statement should be changed to reflect that a plant-food diet based on fruits, vegetables, grains, and legumes is sufficient for a healthful and satisfying diet.

For example, this statement should read: "Enjoy meals that have rice, pasta, tortillas, whole grain bread, or legumes at the center of the plate, accompanied by plenty of fruits and vegetables. Low-fat foods from the dairy group as well as meat should be considered an optional food source."

3. Box 8: "What Counts as a Serving?"

a. The Committee's recommendation to add soy-based beverage with added calcium to the "dairy group" should be adopted. However, in light of this addition and to be consistent, this food group should be renamed the "dairy and soymilk group" or the "calcium-rich food group." Soymilk is not a dairy product, and it may be confusing to consumers if this fact is not clearly pointed out by renaming this food group. Finally, this food group should never be identified as the "Milk, Yogurt, and Cheese (Dairy Group)."

b. "Meat, Poultry, Fish, Dry Beans, Eggs, and Nuts Group (Meat and Beans Group)"

i. To be consistent with Box 7, as well as to emphasize the healthiest diet, this group should be referred to as the "dry beans, eggs, nuts, fish, and meat and poultry group."

ii. The Committee's recommendation to measure a serving of plant-based sources of protein—dry beans, tofu, soyburger, peanut butter, and nuts—by ounces of lean meat rather than by protein content or product specific servings is confusing. Further, the Committee did not give any explanation or rationale for identifying the serving size in this manner.

4. "Vegetarian/Vegan Diets"

The Guidelines should include a section on vegetarian and vegan diets as they did in the fourth edition.

a. The Committee removed any reference to a vegetarian diet based on the rationale that 1) "many different eating styles can provide adequate nutrition" and 2) there are "members of groups who avoid dairy products and/or most meats as a part of their cultural heritage and do not necessarily think of themselves as vegetarians." These rationales do not provide scientific support, as required by statute, for removing this section of the Guidelines. Further, these rationales in and of themselves do not justify the removal of the "Vegetarian/Vegan Diets" section from the fourth edition of the Dietary Guidelines.

b. The Dietary Guidelines are "recommendations based on current scientific knowledge about how dietary intake may reduce risk for major chronic diseases and how a healthful diet may improve nutrition." Current scientific evidence suggests that a plant food diet is the best diet for the prevention of chronic disease, a fact which is implicitly recognized by the Committee. Accordingly, the Guidelines should recognize the health benefits of eating vegetarian and vegan diets and promote consumption of such eating patterns.

c. The section on "Vegetarian/Vegan Diets" should be strengthened and developed to include the following concepts:

i. Definition of a vegetarian and vegan (pure vegetarian) diet.

ii. Promotion of the benefits of a vegetarian and vegan diet.

iii. Lower rates of chronic disease from consuming a vegetarian and vegan diet.

iv. Discussion on the "thrifty gene complex" and the disparate effect of consuming a meat-and-dairy-based diet on people of color.

v. The relationship between a diet high in animal protein and calcium depletion from the bones.

d. In light of the inclusion of soy-based beverages with added calcium in the "dairy group," the Guidelines should acknowledge that vegan diets are consistent with the Dietary Guidelines for Americans and can meet Recommended Dietary Allowances for nutrients.

5. Page 18: "Growing children, teenagers, women, and older adults have higher needs for some nutrients."

The sentence, "When selecting dairy products to get enough calcium, choose those that are low in fat or fat free to avoid getting too much saturated fat" should start with the word "If" not "When." Also, this paragraph should include a statement that a person can get the recommended levels of calcium without consuming any dairy products.

6. Box 9: "Some Sources of Calcium"

Presently, Box 9 is shown as follows:

This box on calcium sources should be changed as indicated below in bold and the order of the food items should be rearranged as set forth: