By Marshall L. Matz and Nathaniel B. Fretz
There is a new question surrounding the Dietary Guidelines for Americans now being drafted for release in 2015. The question is whether the Dietary Guidelines Advisory Committee should continue to focus their review and recommendations on scientific advances in nutrition and diet or should they venture into issues surrounding “sustainability” and all that this term has come to include.

The U.S. Department of Health and Human Services (HHS) and the U.S. Department of Agriculture (USDA) have jointly published the Dietary Guidelines for Americans every 5 years since 1980.  In 1990, the Congress mandated the publication in Section 301 of the National Nutrition Monitoring and Related Research Act of 1990 (7 U.S.C. 5341), requiring that the report “shall contain nutritional and dietary information and guidelines for the general public….”

Beginning with the 1985 edition, HHS and USDA have appointed a Dietary Guidelines Advisory Committee (DGAC) consisting of nationally recognized experts in the field of nutrition and health. The Committee reviews the latest scientific and medical literature and prepares a report for the Secretaries that provide recommendations for the next edition of the Dietary Guidelines based on the preponderance of the scientific evidence available.

This time, as HHS and USDA prepare for the 2015 Dietary Guidelines, the DGAC has created a new subcommittee on “Food Sustainability and Safety.”  The HHS Office of Disease Prevention and Health Promotion has the administrative leadership for the 2015 edition and is supported by USDA’s Center for Nutrition Policy and Promotion.  Leadership on the Dietary Guidelines alternates between HHS and USDA each five years.  The Departments then jointly review the Advisory Committee’s recommendations and develop and publish the revised Dietary Guidelines for Americans policy document.

Where this new dimension will go, with consideration of “Food Sustainability and Safety” as a part of the Dietary Guidelines, remains to be seen.  It is a significant departure from dietary advice based on the science of nutrition and health. Up to this point, the Dietary Guidelines has been confined to micro-nutrient and macro-nutrient recommendations. As there is no legal definition to the term “sustainable” it could go in a number of directions.

Congress has taken notice.  The House Appropriations Committee addressed this development with the following report language that accompanied the FY 2015 Agriculture Appropriations Bill:

“Dietary Guidelines.—The Committee is concerned that the advisory committee for the 2015 Dietary Guidelines for Americans is considering issues outside of the nutritional focus of the panel.  Specifically, the advisory committee is showing an interest in incorporating sustainability, climate change, and other environmental factors and production practices into their criteria for establishing the next dietary recommendations, which is clearly outside of the scope of the panel. The Committee directs the Secretary to ensure that the advisory committee focuses only on nutrient and dietary recommendations based upon sound nutrition science and not pursue an environmental agenda. Should environmental or production factors be included in the panel’s recommendations to USDA and the Department of Health and Human Services, the Committee expects the Secretary to reject their inclusion in the final 2015 Dietary Guidelines for Americans.”

The Dietary Guidelines for Americans was based on the 1977 publication, Dietary Goals for the United States, released by the Senate Select Committee on Nutrition.  In releasing the Dietary Goals, Chairman George McGovern emphasized they were dietary recommendations intended to reduce diet as a risk factor in the etiology of disease and promote nutritional health.  McGovern said at the time: “We must acknowledge and recognize that the public in confused about what to eat to maximize health.  If we as Government want to reduce health costs and maximize the quality of life for all Americans, we have an obligation to provide practical guides to the individual consumer as well as set national dietary goals for the country as a whole.”

The Dietary Goals were the first comprehensive statement by any branch of the Federal Government on dietary recommendations. They were not intended then, and the Dietary Guidelines are not intended now, to address agriculture production procedures or environmental issues.  The issues associated with animal welfare, organic criteria, biotechnology, advertising to children or taxes are clearly beyond the scope of the Dietary Guidelines and should be discussed in a different forum.  

In 2010, when the current edition of the Dietary Guidelines was released, Secretary Vilsack and Secretary Sebelius said:“We are pleased to present the Dietary Guidelines for Americans, 2010. Based on the most recent scientific evidence review, this document provides information and advice for choosing a healthy eating pattern—namely, one that focuses on nutrient-dense foods and beverages, and that contributes to achieving and maintaining a healthy weight.”

The 2015 Subcommittee on Sustainability is chaired by Miriam Nelson, Ph.D., Professor, Friedman School of Nutrition Science and Policy, Boston, MA.

The Subcommittee has two consultants.  Dr. Timothy S. Griffin, Ph.D., is the Director, Agriculture Food and Environment Program; Friedman School of Nutrition Science and Policy; Tufts University; Boston, MA.

Dr. Griffin is a faculty co-director for the Tufts Institute for the Environment and is an associate professor at the Friedman School of Nutrition Science and Policy. His research expertise and interests include the intersection of agriculture and the environment, and the development and implementation of sustainable production systems.

The other consultant to the Subcommittee on Sustainability is Michael W. Hamm, Ph.D. Dr. Hamm is the Mott Professor of Sustainable Agriculture; Departments of Community Sustainability, Food Science and Human Nutrition, and Plant, Soil and Microbial Sciences; Michigan State University (MSU); East Lansing, Michigan.

At MSU he is director of the Center for Regional Food Systems which bolsters MSU’s teaching, research, and outreach around regional, community-based food systems within Michigan and around the world. His current research efforts center on the intersection of environmental sustainability, human health, and economic development in regional food systems.

Doctors Hamm and Griffin have impressive resumes and are clearly experts on the intersection between agriculture and the environment and environmental sustainability, but they are not experts on human nutrition.  Dietary advice is complicated enough.  The DGAC, HHS and USDA should heed the advice of Congress and stick to “dietary recommendations based upon sound nutrition science and not pursue an environmental agenda.” There are other opportunities to discuss how much room pigs and chickens should have or whether genetic modification is safe and should be labeled. 


Marshall Matz and Nathan Fretz are former Senate and House Agriculture Committee Counsel now at OFW Law. Matz was also General Counsel to the Senate Select Committee on Nutrition.; This opinion piece was written June 22, 2014.