May 8, 2015

The Sugar Association (SAI) has filed comments in response to the Dietary Guidelines Advisory Committee’s (DCAC) recent recommendations, raising concerns about new guidance on “added sugars” and the manner by which these recommendations were derived.

In its comments to the Secretaries of Agriculture and Health and Human Services, The Association emphasizes that any dietary guidance should be based on a robust evaluation of the totality of scientific evidence, as mandated by Congress in Public Law 101-445, and strongly contends that the recommendations on “added sugars” put forth in the DGAC report do not meet these important scientific standards.

Looking at the details of the process used to support the recommendations by the Added Sugars Working Group of the Committee could certainly put the scientific integrity of the 2015 Dietary Guidelines process in jeopardy.

“Intake recommendations and conclusions that lead the American public to believe any dietary component is a causal factor in a serious disease outcome should only be made based on significant scientific agreement due to a robust review of the entire body of scientific literature by experts in the field of investigation. Such scientific agreement does not exist for the 2015 DGAC ‘added sugars’ recommendations,” the comments state.

The Sugar Association expressed a number of specific concerns with the DGAC’s report, outlined below:

• The 2015 DGAC bypassed the established Nutrition Evidence Library (NEL) review process and, instead, subjectively selected published systematic reviews, raising red flags of selection bias;
• The 2015 DGAC used an abundance of poor-quality evidence to form conclusions;
• The 2015 DGAC provided no credible science-based evidence to support its recommendation to limit “added sugars” to 10 percent of total energy intake;
• The 2015 DGAC aligning with the controversial World Health Organization’s (WHO) Guideline on Sugars is a step back for U.S. standards of scientific evidence;
• Calories are the real issue. In fact, the body of evidence actually indicates that any observed effect of “added sugars” on body weight is a function of total calories, from all sources, and not any unique obesogenic property of “added sugars.”
• The use of hypothesis-based dietary patterns studies to link or associate dietary components with serious disease outcomes or set intake recommendations is not a valid scientific methodology;
• There are unintended consequences of the 2015 DGAC recommendations to reduce “added sugars” intake to these proposed historical low levels;
• The 2015 DGAC “Added Sugars” policy recommendations went far beyond the Congressional mandate and DGAC Charter with no evidence-based support;
• USDA has undue influence on the DGAC processes relating to its role in food patterns modeling.

SAI points out that the DGAC’s bypassing of the standard process ultimately resulted in conclusions and recommendations for “added sugars” that contradict major evidence-based reviews by authoritative scientific bodies, including the European Food Safety Authority (2010) and the U.K.’s Scientific Advisory Committee draft Carbohydrate and Health report (2014) and also conflict with advice in position statements of the American Diabetes Association (2014), American Dental Association (2001), and the American Heart Association/American Stroke Association (2014).

“Dietary Guidelines for Americans are too important not to get them right. We have seen changing scientific agreement and dietary guidance on other dietary targets over the years, i.e. dietary cholesterol (eggs) and fats. This shifting dietary guidance that targets basic staples of the American diet has an economic impact on Americas’ farmers, food and beverage manufactures and ultimately causes consumer confusion and apathy,” the comments state.

“…We ask that the Secretaries maintain the 2010 Dietary Guidelines advice on ‘added sugars’ intake until a thorough review of the scientific literature on ‘added sugars’ intake is conducted by an authoritative body, such as the Institute of Medicine,” the comments conclude.

To view the comments in their entirety, click here.

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