Talking Conflicts of Interest, Bias, and Sunshine in the Dietary Guidelines

, science and policy analyst, Center for Science and Democracy | October 18, 2016, 4:19 pm EST
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The Dietary Guidelines for Americans is a policy document that is updated every five years and includes key recommendations for healthy eating patterns for children and adults aged two and older. It informs the dietary advice for health professionals and provides a framework off of which various federal food programs base nutrition standards. Graphic: DHHS and USDA.

Yesterday, I testified at a meeting of the National Academy of Medicine advisory committee to review the process to update the Dietary Guidelines for Americans. You might remember that Congress mandated the formation of this committee earlier this year. Their first charge is to write a report with recommendations on how the Dietary Guidelines Advisory Committee (DGAC) selection process can be improved to provide more transparency, minimize bias, and include committee members with a range of viewpoints. This is a topic we’ve thought a lot about here at the Center for Science and Democracy.

The conversation at the meeting was very interesting and encouraging, considering that the agencies are receptive to the inclusion of disclosure and sunshine measures that would help strengthen the science basis of and public trust in the Dietary Guidelines. The DGAC is a federal advisory committee made up of independent experts in the fields of nutrition and chronic disease. Its technical report is translated into a policy document intended for use by health professionals and members of the public, which is what we know as the Dietary Guidelines for Americans. In the past, some of the DGAC’s recommendations have been lost in translation, resulting in weaker guidelines that prioritize industry interests rather than public health protections.

Ensuring the scientific integrity of the Dietary Guidelines is especially crucial in the next iteration, since it will be covering infants, toddlers and pregnant women for the first time. As my recent report illustrates, a series of policy shortfalls, including the Dietary Guidelines’ exclusion of this age group, has led to inadequate protection of infants and toddlers from preventable chronic health problems. The food and beverage industry has a vested interest in maintaining the status quo and avoiding strong recommendations that would limit certain foods or nutrients. Since the first couple years of life are a crucial period during which dietary preferences are set, the DGAC has a considerable task in determining sufficient recommendations to set infants and toddlers up for a healthy life. The panel must be committed to serving the public good with strong, objective, and science-based guidelines, not serving the food industry’s interest in selling sugar, fat and salt-laden foods to Americans.

Our recommendations to the National Academy of Medicine committee can be found below in my testimony. (For more information on ways the next administration can ensure that federal advisory committees minimize bias and produce science-based policy recommendations, watch for our new blueprint, Strengthening Federal Science for the Public Good, which we’ll be releasing soon.)


Good afternoon and thank you for the opportunity to comment on the process of forming the Dietary Guidelines Advisory Committee.  I am Genna Reed, science and policy analyst in the Center for Science and Democracy at the Union of Concerned Scientists. Working with citizens and scientists across the country, we strengthen the role that science plays in policy making.

The advisory committee selection process can be improved to provide more transparency and legitimacy, acknowledge and minimize bias, and include committee members with a range of scientific expertise and viewpoints.

We applaud the excellent work of the 2015 DGAC to ensure that the dietary recommendations and their provenance were rigorous, open and transparent. In order to ensure that the next Dietary Guidelines process is based on scientific analysis, rather than political opinion, and to ensure that conflicts of interest are acknowledged and minimized, we recommend the following:

First, the committee’s charter should include a statement about encouraging diversity on the committee in terms of expertise and affiliation, especially ensuring the important role of individuals with expertise in the dietary needs of infants, toddlers, pregnant women and other more vulnerable groups.

Second, the committee should make all preliminary nominations publicly available on the web, with information about scientific expertise, institutional affiliation, and funding.

Third, the US Department of Agriculture (USDA) and the US Department of Health and Human Services (DHHS) should make public a description of the process for selecting committee members after nominations. The roster of selected committee members should be made public and comments should be solicited regarding the candidates’ potential conflicts of interest or other disqualifying information before finalizing committee membership.

Fourth, final committee member selections should be made by prioritizing experts without financial conflicts. If a committee member with a specific conflict of interest is selected, a fully detailed waiver should be submitted to the USDA, DHHS, and the Office of Government Ethics and made public.

Fifth, all final committee members should be listed publicly along with a description of each member’s qualifications and background, disclosure of past employers and funding sources for the previous five years, along with conflict of interest waivers.

Finally, there should be public reporting of individual committee member votes for or against specific recommendations.

Thanks again for the opportunity to comment here today and for this committee’s commitment to help to inform a fair, balanced, and transparent process for the Dietary Guidelines Advisory Committee.

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