Searching for Scientific Integrity in the Dietary Guidelines Report Process

, food systems & health analyst | February 22, 2016, 2:30 pm EDT
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Last Friday, on behalf of the Union of Concerned Scientists, I testified at the USDA about the Dietary Guidelines for Americans. The USDA invited stakeholders to comment on the process for developing the next Dietary Guidelines for Americans—which are updated every five years. Our comments centered around scientific integrity and the need to protect agency scientists from political interference.

The session was recorded and shared with the National Academy of Medicine before their upcoming review of the Dietary Guidelines development process. As you may recall, after a highly politicized debate regarding the 2015 Dietary Guidelines for Americans, Congress appropriated $1 million to the Academy to study how the guidelines are compiled.

So, what does UCS think about the Dietary Guidelines process? To find out, read our testimony below:


Good afternoon and thank you for the opportunity to comment on the process for developing future editions of the Dietary Guidelines. I am Dr. Lindsey Haynes-Maslow, food systems and health analyst at the Union of Concerned Scientists. The Union of Concerned Scientists puts rigorous, independent science to work to solve our planet’s most pressing problems. Working with citizens and scientists across the country, we combine technical analysis and advocacy to create practical solutions for a healthy environment.

Today I will be focusing on six points regarding the purpose and process for the Dietary Guidelines.

First, we need to determine and clearly communicate the purpose of the Dietary Guidelines. Should the Guidelines serve as scientific dietary advice for the American public or are they a public policy statement for various stakeholders, including but not limited to federal food programs, schools, healthcare, and the food industry? The National Nutrition Monitoring and Related Research Act states that the Dietary Guidelines shall contain nutritional information for the general public. However, as demonstrated by the process surrounding the 2015 Dietary Guidelines Report, Congress and industry lobby groups actively worked to reshape the Guidelines as a statement of policy, rather than a statement of science.

Second, we commend the 2015 Committee that developed the guidelines, in a two-year process that was scientifically rigorous, open and transparent. We advise the USDA to educate all stakeholders, including congressional leaders, about the robustness of this process, early on and consistently throughout, to limit the corporate and political interference to which the 2015 Guidelines were subject. The Committee did critically important work to bring together various aspects of evidence-based dietary recommendations, and as scientists with food and agriculture expertise, we concur with the Committee’s assessment that the overall body of evidence identifies a healthy dietary pattern as one that is higher in fruits, vegetables, and whole grains; lower in red meat and sugar-sweetened beverages; and must include environmental sustainability considerations.

Third, to assure impartiality and respect for the scientific process, there is a need for greater transparency once the Dietary Guidelines leave the Committee and go to USDA’s administrators for review. Analysis of 29,000 public comments on the 2015 Committee’s report found that 75 percent of the comments submitted supported the recommendations tying nutrition with sustainability. However, the much weaker recommendations actually seen in the Dietary Guidelines Report clearly show that in the current framework there is a scientific phase of the process, followed by a political phase, and that in the latter, industry interests displace rigorous science as well as the interests of the public and other stakeholders.

Fourth, in the implementation phase of the 2015 Dietary Guidelines (as well as in the development of the next Guidelines) the public agencies involved should prioritize their responsibility to the public at large. They should focus on highlighting the differential impacts of diet-related chronic disease on vulnerable populations, especially children, people of color, and lower-income individuals, and consider the ways that Dietary Guidelines can be disseminated and implemented to the benefit of the most vulnerable.

Fifth, in response to the 2020 edition of the Dietary Guidelines expanding to include nutrition guidance for infants from birth to 24 months, the USDA should include experts to advise on the dietary needs for this age group, a crucial period for child development.

Lastly, there is an urgent need for the USDA to adopt a scientific integrity policy that will protect the Advisory Committee and agency scientists from political interference. The committee plays an important role in our democracy by providing critical expertise to policymakers and the American public. To fulfill this responsibility, they must be able to communicate freely with the media, the public, and their peers. Last year, the Union of Concerned Scientists evaluated 17 federal agencies’ media policies and practices, and we concluded that the USDA’s policies were the weakest among all the agencies. Therefore, we encourage the USDA to create a scientific integrity policy that will offer agency scientists and the Advisory Committee clear guidance and protections against political interference.

Thank you again for the opportunity to comment today, and for the Dietary Guidelines Advisory Committee’s excellent scientific work.


Special thanks to my UCS colleagues Andrew Rosenberg, Pallavi Phartiyal, Ricardo Salvardo, Doug Boucher, and Michael Lavender for their input on our testimony.

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