Food industry leaders who keep a close watch on meetings of the Dietary Guidelines Advisory Committee are fiercely advocating for their products as the committee works to complete the scientific report that will be used to develop the final guidelines.

The DGAC held its next-to-last meeting in September. It meets again Oct. 21-22 for the last time to wrap up the scientific underpinning of the 2025 edition of the Dietary Guidelines for Americans, issued every five years since 1980. The guidelines ultimately will be approved by Health and Human Services Secretary Xavier Becerra and Secretary of Agriculture Tom Vilsack.

But as the process comes to a close, meat, dairy and plant-based foods representatives specified areas where they feel the DGAC has come up short. The Center for Science in the Public Interest said it is generally pleased with the way the process has played out, praising the committee’s focus on low-income populations that may not have adequate access to the food needed for a healthy diet. 

“We hope policymakers will take note of that,” Grace Chamberlin, a policy associate at CSPI, said of the committee’s discussion of how environmental and socioeconomic factors contribute to whether people can eat a healthful diet.

“I really think that so much of this comes back to food availability and then the food environment,” said Deirdre Tobias, a DGAC member and professor of nutrition at the Harvard T.H. Chan School of Public Health. “I love the idea of thinking of individual behaviors and how we can help in a more clear and, I guess, easier daily-life way.”

Grace Chamberlin headshot_0.jpgGrace Chamberlin, CSPI

However, some groups are concerned the committee is not adequately considering the health benefits and nutrients in their foods.

The American Meat Institute, for example, took note of draft conclusion statements from one of the DGAC subcommittees. “Dietary patterns with positive health outcomes were routinely characterized [as] having higher intakes of vegetables, fruits, legumes or beans, nuts, fish and/or seafood, unsaturated vegetable oils/fats, and lower intakes of red and processed meats, among other foods and beverages,” AMI Vice President for Scientific and Regulatory Affairs Susan Backus said in an Oct. 7 letter to the DGAC.

She added concern that dietary patterns associated with negative health outcomes were associated with “relatively higher intakes of meat (red and processed).”

Those statements, Backus said, “could be misunderstood to support removing lean red meat and processed meat from diets. Including references to ‘lower’ or ‘relatively higher’ intakes are confusing because there are no reference consumption levels included. Advising people to consume lower and less of something without providing a tangible measure is confusing and misleading within the context of nutrient-dense food choices.”

The dairy industry, while continuing to advocate for milk and other forms of dairy in the guidelines, again also submitted comments to the committee seeking more transparency in the process.

Roberta Wagner, senior vice president, regulatory and scientific affairs at the International Dairy Foods Association, said in an Oct. 4 letter that “while some draft scientific conclusions have been shared, the DGAC’s scientific review process does not include disclosing what studies have been considered, which of these have been included or excluded from the scientific review, or the committee’s rationale for such decisions until after the DGAC Scientific Report is published.”

But that’s too late, Wagner said, “to address any potential oversight of omitted studies that could have added to the body of science on a particular scientific question, which could affect the recommendations of the DGAC in its scientific report, and ultimately the final DGA.”

“It's very cloudy about how they've come to some of the conclusions that they've drawn, or the science that they've chosen to eliminate or include,” said Matt Herrick, the group’s executive vice president and chief impact officer. In the last meeting, he said, the committee “references dairy a few different times and began to sort of shine a more positive light on the nutritional contributions it makes to a healthy diet.”

The Plant Based Foods Association had other concerns. “The overall committee discussion and draft recommendations still trend towards support of plant-based foods,” Marjorie Mulhall, PBFA senior director of policy, said in response to written questions. However, she said PBFA questions recent modeling and analysis that looks at the impact of removing animal foods without replacing them with plant-based foods. 

The “healthy vegetarian dietary pattern” that was used as the starting point for the analysis “was designed specifically as a framework for individuals to meet the Dietary Guidelines recommendations.” Mulhall said. “Removal of dairy and eggs from that meal pattern without replacing them with plant-based foods in and of itself results in calories and nutrient intakes below the Dietary Guidelines recommendations.”

She called the analysis “inconsistent with previous methodology that based dietary patterns on the ‘types and proportions of foods Americans of all ages, genders, races, and ethnicities typically consume.’”

“When individuals decide to consume fewer animal foods, they typically replace those foods, either with similar plant-based foods, such as plant-based milks, or with other plant-based foods from other food groups,” Mulhall said.

CSPI's Chamberlin defended the committee process, calling it “overwhelmingly scientifically rigorous and transparent.”

But she noted the committee has run up against a lack of research in many areas. 

“There is such a clear and resounding need for more diverse samples in research studies so that the DGAC can do its job and generate strong conclusion statements,” Chamberlin said. “And I feel that that came up again and again, and the DGAC can only make recommendations based on the research that exists. Unfortunately, the current research lacks evidence on, for example, pregnancy and postpartum, on children and adolescents and, critically, on many racial and ethnic subgroups.”

This iteration of the DGAC has for the first time focused on health equity.

Chamberlin said that the DGAC's latest draft conclusions “really showed a clear association between dietary patterns with lower red and processed meat intake and reduced risk of multiple health outcomes such as cognitive decline, cardiovascular disease [and] breast cancer.”

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