Earlier this month, the agencies responsible for the U.S. Dietary Guidelines for Americans (DGA) quietly dismissed improvements suggested by the National Academies of Sciences, Engineering and Medicine, to increase transparency of the DGA Advisory Committee and manage member biases.
This committee, comprised of 13-15 people, is appointed every five years to review the science to update the Dietary Guidelines. Given the DGA’s far-reaching power, the committee might well be the most powerful group of nutrition scientists in the world.
Among the recommendations put forth by the National Academy of Sciences (NASEM) was a rigorous, multi-part process for the management of committee biases. This is important, because, for instance, the review of saturated fats under the last guidelines committee, in 2015, was led by two researchers who both had long histories of publishing articles condemning these fats. These biases could have been managed by appointing someone to this group with a contrary or more flexible approach to the scientific literature—which by that time included numerous studies suggesting that caps on these fats had been in error. (Ultimately, the 2015 Dietary Guidelines committee decided to preserve the longstanding saturated-fats caps.) This is a topic where intellectual biases should have been better managed.
Others’ biases are due to financial conflicts of interest. For instance, one committee member, from the T.S. Chan Harvard School of Public Health, reported receiving research funds from the California Walnut Commission and the Tree Nut Council, as well as vegetable oil giants Bunge and Unilever, all products high in polyunsaturated fats. Yet he was allowed to lead the review of saturated fats, which ultimately called for consuming more polyunsaturated fats. Better DGA oversight might have actively managed this committee member, since his review had an impact on his funders.
The NASEM report also suggested that USDA-HHS should “explicitly disclose financial and non-financial biases and conflicts” of committee members. This would have provided crucial transparency for a committee with so much power over the nation’s nutritional guidance. It is very disappointing that this idea was rejected.
USDA-HHS issued their response without any public notification, 18 months after the NASEM report’s publication. Note that NASEM published two reports: the first one in February 2017, focused on Advisory Committee selection process, and a much larger, second one in September 2017, dealing with every other aspect of the DGA process.
We are very concerned that USDA-HHS will reject this report as well. This would be a loss for both good science and good policy. It would also be a loss for Congress, which, in mandating these reports and paying $1 million for them, aimed to improve a policy that has self-evidently failed to combat obesity and diabetes. More than anything, however, it would be a loss for the public which continues to follow guidelines based on weak science and continues to see their health worsen.
Below is a listing of the National Academies’ recommendations from “Optimizing the Process for Establishing the Dietary Guidelines for Americans: The Selection Process,” along with the USDA-HSS response and our comment.
- The Secretaries of USDA and HHS should employ an external third party to review and narrow the candidate pool to a list of primary and alternate nominees; REJECTED
(We mostly agree: who would that “third party” be? We can’t think of any unbiased group in nutrition.)
- Criteria against which nominees are screened should be developed by USDA and HHS for use by the third party; PARTIALLY ACCEPTED — A substantial list of qualification standards has been posted to the Dietary Guidelines website, but the process will not be handed off to a third party.
- The Secretaries of USDA and HHS should make a list of provisional appointees open for public comment; REJECTED on privacy grounds.
(We like more transparency but are sympathetic to the argument that rejected nominees might not want to be exposed.)
- The Secretaries of USDA and HHS should disclose how provisional nominees’ biases and conflicts of interest are identified and managed by:
- Creating and publicly posting a policy and form to explicitly disclose financial and non-financial biases and conflicts; REJECTED
(We disagree: We think public disclosure of financial and non-financial biases is extremely important for the integrity of this process. See our accompanying article.)
- Developing a management plan for addressing biases and conflicts for the panel as a whole and individuals, as needed; REJECTED
(We disagree: bias management is needed, as we explain in the accompanying article.)
- Certifying that a federal ethics officer independently reviewed and judged the advisory committee’s biases and conflicts of interest; PARTIALLY ACCEPTED
- Documenting how conflicts of interest were managed in the Dietary Guidelines Advisory Committee report; REJECTED
(USDA-HHS claim they will do this but give few specifics.)