How to Submit a Public Comment on the Dietary Guidelines

The U.S. Department of Agriculture (USDA) is currently soliciting public comments on a list of key issues for the 2020-25 U.S Dietary Guidelines for Americans. This is the first time that the USDA,  the agency that oversees the guidelines, has taken this unusual step.

Notably, among the issues USDA lists as needing review are saturated fats and low-carbohydrate diets. This is an unprecedented opportunity to contribute your thoughts about whether the current guidelines are based on the most up-to-date reviews of the current science.

The comment period is set to run through March 30, 2018. You can submit your comment here.

Click here to get newsletter updates on the Dietary Guidelines process and to learn what else you might do to help.

Here is some guidance on what you might consider including in your comment:

Please note that links will NOT be accepted in the comment form unless you attach as a document.

On the Low-Carbohydrate Diets:
Existing USDA guideline recommendation:
The low-carbohydrate diet is not recommended.

Our view:

Low-carbohydrate diets have now been tested in at least 70 clinical trials[1] on nearly 7,000 people, including a wide variety of sick and well populations, mainly in the U.S. Thirty-two of these studies have lasted at least six months and six trials went on for two years, enough time to demonstrate the lack of any negative side effects. In virtually every case, the lower-carb, higher-fat diets did as well or better than competing regimens.[2] The cumulative evidence shows that low-carb diets are safe and effective for combating obesity,[3] highly promising for the treatment of Type 2 diabetes,[4] and they improve most cardiovascular risk factors.[5]

[1] Click here to download the 70 clinical trials PDF. Then attach it to your comment.

[2] Johnston BC, Kanters S, Bandayrel K, Wu P, Naji F, Siemieniuk RA, Ball GDC, Busse JW, Thorlund K, Guyatt G, Jansen JP, Mills EJ. Comparison of Weight Loss Among Named Diet Programs in Overweight and Obese AdultsA Meta-analysis. JAMA. 2014;312(9):923–933. doi:10.1001/jama.2014.10397

[3] Bueno, N., De Melo, I., De Oliveira, S., & Da Rocha Ataide, T. (2013). Very-low-carbohydrate ketogenic diet v. low-fat diet for long-term weight loss: A meta-analysis of randomised controlled trials. British Journal of Nutrition, 110(7), 1178-1187. doi:10.1017/S0007114513000548

[4] Dietary carbohydrate restriction as the first approach in diabetes management: Critical review and evidence base Feinman, Richard D. et al. Nutrition , Volume 31 , Issue 1 , 1 – 13

[5] Obes Rev. 2012 Nov;13(11):1048-66. doi: 10.1111/j.1467-789X.2012.01021.x. Epub 2012 Aug 21.

On Saturated Fats:
Existing USDA guideline recommendation:
Americans are advised to limit saturated fats to 10% of calories and instead to eat 27 grams of polyunsaturated vegetable oil per day.

Our view:
The data do not support the existing caps on saturated fats.

Regarding the (more rigorous) clinical trial data, at least 8 major review papers in recent years have concluded that saturated fats do not have an effect on cardiovascular mortality or total mortality. While saturated fats can be shown to raise the “bad” LDL-cholesterol, this elevated risk factor does not result in higher mortality rates, reflecting a more complicated pathway for cardiovascular disease than simply LDL-C. Note that saturated fats also consistently raise the “good” HDL-cholesterol, which may be a compensating effect.

Regarding the (weaker) observational evidence, meta-analyses of this data consistently find no association between saturated fat and cardiovascular disease. Moreover, there is a substantial observational finding that low consumption of saturated fats is associated with higher mortality and higher rates of stroke.

Moreover, officials risk doing harm to populations by limiting saturated fats. These fats consistently raise the “good” HDL-C and are the only food known to do so. They are also part of many natural, unprocessed, “whole” foods, such as milk, meat, cheese, etc. that are not only rich in the nutrients considered necessary by health authorities to sustain human life, but also contain these nutrients in their most “bioavailable” form.

For any naturally occurring food, the default judgement must be that it is innocent until proven guilty. Saturated fats were condemned in the 1950s based on what we now know to be weak and unreliable evidence. Large clinical trials have since failed to support the diet-heart hypothesis. Thus, despite being rigorously tested, this hypothesis cannot be confirmed. Saturated fats cannot be considered guilty, as charged, and therefore, the limits on them should be lifted.

Here are the references for the eight major review papers:

  1. Dietary Fat and Coronary Heart Disease: Summary of Evidence From Prospective Cohort and Randomised Controlled Trials” (review of observational data and clinical trials) Annals of Nutrition and Metabolism (2009) Skeaff CM, PhD, Professor, Dept. of Human Nutrition, the University of Otago, Miller J.
  2. Effects on Coronary Heart Disease of Increasing Polyunsaturated Fat in Place of Saturated Fat: A Systematic Review and Meta-analysis of Randomized Controlled Trials” PLOS Medicine (2010) Mozaffarian D, Department of Epidemiology, Harvard School of Public Health, Micha R, Department of Epidemiology, Harvard School of Public Health, and Wallace S, Department of Epidemiology, Harvard School of Public Health.
  3. Reduced or Modified Dietary Fat For Preventing Cardiovascular Disease” (Systematic Review and Meta-analysis) (Analysis of clinical trials) Cochrane Database Syst Review (2012 Hooper L, Norwich Medical School, University of East Anglia, Summerbell CD, Thompson R, et al.
  4. Association of Dietary, Circulating, and Supplement Fatty Acids with Coronary Risk: A Systematic Review and Meta-analysis” (on observational data on all fatty acids and RCTs on supplementation with polyunsaturated fats, o3s or o6s) Annals of Internal Medicine (2014) Rajiv Chowdhury, MD, PhD, University of Cambridge, Samantha Warnakula, University of Cambridge, et al.
  5. “Dietary fatty acids in the secondary prevention of coronary heart disease: a systematic review, meta-analysis and meta-regression,” (on clinical trials) BMJ Open (2014) Lukas Schwingshackl and Georg Hoffman, Faculty of Life Sciences, Department of Nutritional Sciences, University of Vienna, Vienna, Austria
  6. Reduction in saturated fat intake for cardiovascular disease,” (systematic review and meta-analysis of randomized, controlled clinical trials) Cochrane Database Systematic Review, 2015 Hooper, L. et al.
  7. Evidence from prospective cohort studies does not support current dietary fat guidelines: a systematic review and meta-analysisBritish Journal of Sports Medicine (2016) Harcombe, Z., Baker, JS, Davies B.
  8. ‘The effect of replacing saturated fat with mostly n-6 polyunsaturated fat on coronary heart disease: a meta-analysis of randomized, controlled trials.” Nutrition Journal (2017) Steve Hamley

For a full look at the current evidence, click here.

Beyond commenting on the science, you might consider telling your success story about how you achieved good health by ignoring the dietary guidelines.

The Nutrition Coalition (TNC) does not promote any one diet, nor does it promote a “one size fits all” model for everyone. Yet it is an undeniable fact that the high-carbohydrate approach enshrined in the Dietary Guidelines has not produced good health for the majority of Americans.

Again, comments can be submitted here.

Please take the time to comment! Now is our chance to have nutrition guidelines based on the best and most current science!!

Suggested tweets to promote comments on the Guidelines:

Tweet 1: Click here to tweet this
USDA is asking for public comments on our outdated #DietaryGuidelines. If you have regained yr health by ignoring the guidelines, tell yr story here.

Tweet 2: Click here to tweet this 
We have an opportunity to reform our #DietaryGuidelines! USDA is asking for public comment on low-carb diets, saturated fats. Ideas and how to submit comments found here:

Tweet 3: Click here to tweet this 
Has backing out of USDA low-fat diet improved your health? Now’s yr chance to tell your story by submitting a public comment. Info here:

Tweet 4: Click here to tweet this (If you plan to or have submitted a comment):
I told the USDA that our #DietaryGuidelines need to be reformed to reflect the latest science on low-carb diets & saturated fats. Learn how to submit your public comment here:

Suggested Facebook Posts

Facebook Post 1
We have an opportunity to reform our #DietaryGuidelines! USDA is asking for public comment on low-carb diets, saturated fats. Here is all the info you need on how to submit a comment and ideas on what to include

Facebook Post 2
USDA is asking for public comments on our outdated Dietary Guidelines. If you have regained your health by ignoring the guidelines, submit your story as a public comment here:

Facebook Post 3 (If you plan to or have submitted a comment):
I told the USDA that our Dietary Guidelines need to be reformed to reflect latest science on low-carb diets & saturated fats.