May
27, 2003Honorable
Claude A. Allen
Deputy Secretary
Department of Health and Human
Services
Washington, D.C. 20201Honorable
James R. Moseley
Deputy Secretary
Department of Agriculture
Washington, D.C. 20250 |
|
Dear
Mr. Allen and Mr. Moseley:
The
purpose of this letter is to request that the Department
of Agriculture (USDA) and the Department of Health and
Human Services (HHS) further incorporate the large body
of recent public health evidence linking food consumption
patterns to health and disease as the Dietary Guidelines
for Americans is revised for its scheduled 2005 release
and to update the Food Guide Pyramid, which was
introduced in 1992.
Secretary
Thompson has made it clear that both childhood overweight
and adult obesity and the associated chronic health problems
such as heart disease are widespread in the United State,
and have become one of our nation' s most important public
health problems. However, recent studies suggest that adherence
to the Dietary Guidelines has only modest impact
on the risk of cardiovascular disease and no significant
impact on other chronic diseases such as cancer. OMB believes
that these and other studies should play a prominent role
as USDA and HHS revise the guidelines. Given the wide reach
of the federal nutrition guidelines, we believe that good
nutrition habits fostered by improved information on the
links between diet and health will have a significant health
impact, especially in reducing heart disease. Coronary
heart disease (CHD) is our nation' s largest cause of premature
death for both men and women, killing over 500,000 Americans
each year. Even a modes t improvement in dietary habits
may lead to significant reductions in the number of premature
deaths from CHD.
We
recognize that the 2000 Dietary Guidelines made
some changes in recommendations that may reduce cardiovascular
risk. We nonetheless urge you to reconsider all available
nutritional and medical evidence as you develop the new
guidelines. For example, in a previous letter addressed
to HHS, we encouraged the Food and Drug Administration
(FDA) to finalize a rule to require a product' s Nutrition
Facts panel to include the amount of trans fatty
acids present in foods. As you know, there is a growing
body of scientific evidence, both experimental and epidemiological,
that suggests consumption of trans fatty acids increases
the risk of CHD. Another important risk factor is the omega-3
fatty acid content of food. both epidemiological and clinical
studies find that an increase in consumption of omega-3
fatty acids results in reduced deaths due to CHD. The recent
revision of the American Heart Association' s (AHA' s)
dietary guidelines recognizes this evidence by recommending
consuming fish, which is high in omega-3 fatty acids, at
least twice weekly to reduce the risk of CHD. In addition,
the AHA recommends the inclusion of oils and other food
sources high in omega-3 fatty acids.
The
current Dietary Guidelines targets only the reduction
of saturated fat and cholesterol, with only a brief reference
to the risk from trans fatty acids and the benefits
of omega-3 fatty acids. We encourage you to consider strengthening
the language in the guidance and to modify the Food
Guide Pyramid to better differentiate the health benefits
and risks from foods. As noted in the Report of the
Dietary Guidelines Advisory Committee on the Dietary Guidelines
for Americans (2000), consumers find the Food Guide
Pyramid to be the most useful part of the Guidelines and
the Guidelines itself encourages readers to "let
the pyramid guide your food choices." Yet the current Food
Guide Pyramid, for example, groups meat, poultry, fish,
dry beans, eggs, and nuts into a single "Meat and
Beans Group" when research suggests that these foods
may not be equivalent in terms of their health effects.
Given
the significant potential improvement in public health
suggested by current evidence, we urge you to consider
revising the Dietary Guidelines and Food Guide
Pyramid to emphasize the benefits of reducing foods
high in trans fatty acids and increasing consumption
of foods rich in omega-3 fatty acid.
We
would like to set up a meeting with your agencies in the
next few weeks to discuss this issue. As always, the OIRA
staff stands ready to assist you in these efforts.
Sincerely,
John D. Graham
Administrator
Office of Information and Regulatory
Affairs