April 23, 2009
Carol Davis
Co-Executive Secretary of the Dietary Guidelines Advisory Committee
Center for Nutrition Policy & Promotion
U.S. Department of Agriculture
3101 Park Center Drive, Room 1304
Alexandria, VA 22302Dear Secretary and Members of the Advisory Committee:
As the organizations representing the wheat chain, from farm to table, we are writing to share our expertise with you as you develop recommendations for the 2010 Dietary Guidelines for Americans. We commend the Committee for the thoroughness of your work to date and appreciate the opportunity to assist you in the important mission of guiding Americans toward better health through good nutrition.
The American Bakers Association (ABA) is the Washington D.C.-based trade association that has been the voice of the wholesale baking industry since 1897. ABA has a long and dedicated history of representing the interests of the wholesale baking industry before the U.S. Congress, federal agencies, state legislatures and international regulatory authorities. ABA represents approximately 80 percent of the wholesale bakeries in the U.S. and their suppliers.
The North American Millers’ Association (NAMA) is the trade association representing 48 companies that operate 170 wheat, rye, oat and corn mills in 38 states and Canada. Their collective production capacity exceeds 160 million pounds of product each day, more than 95 percent of the total industry production.
The Grain Foods Foundation (GFF), a joint venture of members of the milling, baking and allied industries formed in 2004, is dedicated to advancing the public’s understanding of the beneficial role grain-based foods play in the human diet. Directed by a board of trustees, funding for the Foundation is provided through voluntary donations from private grain-based food companies and is supplemented by industry associations.
The Wheat Foods Council (WFC) is a nonprofit organization formed in 1972 to help increase public awareness of grains, both whole and enriched, complex carbohydrates, and fiber as essential components of a healthful diet. The Council is supported voluntarily by wheat producers, millers, bakers, and related industries.
The National Association of Wheat Growers (NAWG) is a federation of 20 state wheat grower associations that works to represent the needs and interests of wheat producers before Congress and federal agencies. Based in Washington, D.C., NAWG is grower-governed and grower-funded, and works in areas as diverse as federal farm policy, trade, environmental regulation, research and climate change.
The Role of Grains, Both Whole and Enriched, in Healthy Diets
We urge the Committee to give ample recognition of the valuable role of enriched grains in a healthy diet in the 2010 Dietary Guidelines. While continuing to support the recommendation that Americans consume one half of their total grain servings as whole grains, enriched grains also provide important health benefits, especially with the fortification of folic acid. This also supports the longstanding recommendation to consume a variety of foods from all food categories.
Since 1998, when the Food & Drug Administration (FDA) mandated that enriched grains be fortified with folic acid, the incidence of neural tube defects (NTDs) in the US has dropped almost 30 percent. In fact, enriched, fortified grain foods are the primary source of folic acid in Americans’ diets. This is particularly important for women of child-bearing age, the majority of whom do not take folic acid supplements. The U.S. also has a growing Hispanic population, and adequate consumption of folate-rich foods is critical for this increasing group since statistically, Hispanic women are 1.5 to 3 times more likely to have a baby with an NTD. In addition, the Hispanic population is less likely to take supplements making fortified grain foods the primary source of folic acid in their diets. Folic acid fortification may also play a role in preventing strokes, heart disease, cataracts and some cancers.
It is also critically important that the 2010 Dietary Guidelines be aligned with the government mandate for folic acid fortification. A consistent message is vital to retaining the confidence Americans have in our regulatory agencies for dietary advice and guidance. To do otherwise would undermine the important human health achievements gained through folic acid fortification while adding to the existing confusion in consumers’ minds regarding the important roles of enriched and fortified grain products.
Sodium and Bread
In recent years, bread has been identified as a major source of sodium in the diet but only because of the high consumption of breads. Bread is not a high sodium food as defined by FDA as each individual eating occasion would provide minimum sodium to consumers.
When bakers formulate a loaf of bread, they incorporate approximately one percent salt on a total formula basis. The amount of salt used in enriched bread, whole wheat or whole grain breads does not vary due to the variety. Overall, salt is required for quality, flavor, crust color, improved crumb structure, prevention of excessive yeast action and last but not least, salt inhibits acid producing bacteria.
In keeping with previous dietary recommendations that Americans lower their salt consumption, bakers have already made a considerable reduction of sodium in such products as bread, rolls and buns. USDA data indicates that in 1963, there was 254 mg of sodium per slice in enriched white bread, while in 2007, the level dropped to an average of 180 mg – a 29 percent reduction. To decrease the salt level of bread any further would have a detrimental effect on the functionality.
We support the overall goal of lowering sodium consumption in Americans’ diets, and encourage the Committee to focus on sodium intake as a whole, rather than on a particular food or food group. The Committee’s recommendations are particularly important at a time when individual states are seeking to impose new dietary guidance for sodium and other ingredients on food manufacturers and food served in restaurants. A plethora of competing state and/or city dietary standards will only increase consumer confusion and disillusionment with dietary advice.
Glycemic Index (GI), Glycemic Load (GL)
As the Committee discusses Glycemic Index (GI) and Glycemic Load (GL) as a nutrition indicator, we note that this tool remains scientifically questionable and that much research remains to be done to determine beneficial long-term health outcome or consumer-friendly recommendations (see attached 2008-2009 GI/GL studies).
We believe encouraging consumers to follow MyPyramid and increase fiber content, rather than using GI or GL, are the least confusing and most effective ways to achieve health benefits.
Nutrition Education
Nutrition education is critical in guiding Americans to make wise dietary choices, and we encourage the Committee to address and strengthen government outreach and education as part of its final report. Specifically regarding wheat and grain based foods, we continue to find through our own educational outreach, that consumers are confused about the differences between refined, enriched, fortified and whole grains.
Accurate definitions of these products should again be included in the final Dietary Guidelines document to assist consumers in understanding the various grain products and the role each plays in a healthy daily diet. We recommend that accurate definitions include:
Whole grain products contain the entire endosperm, bran and germ found in proportional amounts in the unprocessed grain kernel. There are some whole grain breakfast cereals that are adequately fortified with folic acid on a voluntary basis, but as stipulated in the food additive regulations, no other whole grain products are fortified with folic acid, including whole wheat and whole grain bread.
Refined, unenriched grain products have had the germ and bran removed with only the endosperm remaining. This represents less than 5 percent of the total white flour milled in the U.S. It is primarily used in organic and some artisan products. A small amount goes into mixes for overseas consumption.
Enriched/fortified grain products are refined grain products that have the three major B vitamins and iron replaced in levels that are at least equal to those naturally occurring in whole grain products as defined by the standards of identity. Additionally, enriched products are fortified with folic acid in amounts slightly double that found in whole grain products. This higher level of folic acid fortification makes enriched grain foods also fortified grain foods. This includes such products as enriched white bread, rolls, bagels, tortillas and the majority of other grain foods.
Other fortified grain products are those that have a variety of minerals and vitamins in various amounts, not defined by any set standards. They are added voluntarily according to FDA guidelines. Many breakfast cereals fit into this category.
Achievable, Affordable Recommendations
To be successful, dietary recommendations must be both achievable and affordable. The wheat chain – from growers, to millers, to bakers, to manufacturers – is working hard to encourage demand for whole grain products by expanding the number and variety of innovative, nutritional, affordable and good tasting products available on supermarket shelves to the American public. One such success story is the whole-grain white bread introduced in 2005 in response to the 2005 Dietary Guidelines recommendation to increase consumption of whole grains.
The industry also worked with Congress to include funding in the 2008 Farm Bill for a Grain Purchase Program that expanded the availability of whole grain foods offered this year to schools as part of the School Lunch and Breakfast programs.
Through the Grain Foods Foundation and Wheat Foods Council, the entire wheat chain is reaching out to consumers in a variety of ways to educate them about nutritious grain foods and the role they play in a healthy diet.
Science-Based, Consistent Communication
In conclusion, we urge the Committee to continue to ensure that the 2010 Dietary Guidelines are irrefutably science-based, consistent with advice from other federal agencies, and are communicated in terms easily understood by the public. On a daily basis, Americans are consuming a diet of health misinformation, miscommunication and misinterpretation through the news media, the web and a variety of other sources. We are hopeful that through consistent guidance at the national level, the public may begin to turn away from “fad” diets and sensationalized nutrition information, and make lifestyle choices based on sound science.
On behalf of the wheat chain, we appreciate the opportunity to share our views and look forward to continuing to work with you in developing recommendations for the 2010 Dietary Guidelines.
Sincerely,
American Bakers Association
North American Millers’ Association
Grain Foods Foundation
Wheat Foods Council
National Association of Wheat Growers
Appendix 1
Relevant Recent Research Articles
April 23, 2009
- Dietary Glycemic Index, Glycemic Load, and Risk of Cancer: A Prospective Cohort Study. Am J Epidemiol 2009; 169: 462-472. Stephanie Materese George, Susan T. Mayne, Michael F. Leitzmann, Yikyung Park, Arthur Schatzkin, Andrew Flood, Albert Hollenbeck, and Any F. Subar
- The authors analyzed associations among glycemic index, glycemic load, and risk of cancer in women and men in the national Institutes of Health—AARP Diet and Health Study.
- Conclusion: “These findings suggest that glycemic index and glycemic load are not strong predictors of cancer incidence. The direction and small magnitude of associations might be explained by the manner in which high glycemic index and glycemic load track with overall diet and lifestyle patterns.|
- The Canadian Trial of Carbohydrates in Diabetes (CCD), a 1-y controlled trial if low-glycemic-index dietary carbohydrate in type 2 diabetes: no effect on glycated hemoglobin but reduction in C-reactive protein. Am J Clin Nutri 2008; 87: 114-25. Thomas M.S. Wolever, Alison L. Gibbs, Christine Mehling, Jean-Louis Chiasson, Philip W. Connelly, Robert G. Josse, Lawrence A. Leiter, Pierre Maheux, Remi Rabasa-Lhoret, N. Wilson Rodger, and Edmond A. Ryan
- The study aimed to compare the effects of altering the glycemic index or the amount of carbohydrate on glycated hemoglobin (HbA1c), plasma glucose, lipids, and C-reactive protein (CRP) in T2DM patients.
- Conclusion: “In subjects with T2DM managed by diet alone with optimal glycemic control, long-term HbA1c was not affected by altering the GI or the amount of dietary carbohydrate. However, because of sustained reductions in postprandial glucose and CRP, a low-GI diet may be preferred for the dietary management of T2DM.”
- A role for the glycemic index in preventing or treating diabetes? Am J Clin Nutr 2008; 87: 1-2. John M. Miles
- Conclusion: “The results of these studies will be disappointing to some advocates of low-GI diets. The ADA’s position statement on nutrition concluded that the use of GI and GL may have a modestly greater benefit in controlling diabetes than is observed when total carbohydrate is considered alone. The ADA further stated that information is not sufficient to allow a conclusion that low-GL diets reduce diabetes risk; nevertheless, the consumption of low-GI foods that are rich in fiber is to be encouraged. The 2 studies reported in this issue of the Journal provide no compelling reason to modify those recommendations.
- Glycemic index in early type 2 diabetes. Am J Clin Nutr 2008; 87: 3-4. Xavier Pi-Sunyer
- Commentary on the results of the Canadian Trial of Carbohydrates in Diabetes.
- Conclusion: “The bottom line is that following these 3 diets for 1 yr produced essentially no difference in the subject groups with respect to glycated hemoglobin (HbA1c), lipids, or insulin….It seems unwise at this point to burden type 2 diabetes patients with trying to pick and choose among different high- and low-GI foods.
- A Look at the Glycemic Index. Wheat Foods Council 2009. Julie Miller Jones. Publication pending.
- Review of the latest research on Glycemic Index/Glycemic Load as it relates to appropriate use of measurement and controversies that arise; obesity and weight loss; insulin release, sensitivity and diabetes; cardiovascular disease; cancer.
- Conclusion: The data regarding Glycemic Index/Glycemic Load is conflicting and there is no consensus on the effectiveness of the GI/GL.
- Relation of dietary glycemic index, glycemic load, added sugar intake, or fiber intake to the development of body composition between ages 2 and 7 y. Am J Clin Nutr 2008; 88: 755-62. Anette E. Buyken, Guo Cheng, Anke L.B. Günther, Angela D. Liese, Thomas Remer, and Nadina Karaolis-Danckert
- An examination of whether dietary GI, GL, added sugar intake, or fiber intake between age 2 and 7 y are associated with the development of body composition. If so, the authors aimed to ascertain whether these associations are modified by meal frequency.
- Conclusion: “Dietary GI, GL, or added sugar intake between ages 2 and 7 y does not appear to influence the development of body composition. Potential benefits associated with increasing fiber intake throughout childhood may be limited to toddlers with a lower meal frequency.”
- The metabolic syndrome in relation with the glycemic index and the glycemic load. Physiology & Behavior 94 (2008) 293-299. R. Vrolix, L.E.C. van Meijl, R.P. Mansink
- The metabolic syndrome (MS) is a clustering of metabolic abnormalities that increases the risk to develop chronic diseases such as cardiovascular disease and type 2 diabetes mellitus. Although its precise actiology is unknown, dietary habits play a major role. Nowadays, more and more attention is paid to the glycemic index (GI) and the glycemic load (GL) of a diet.
- Conclusion: “From reviewing the current literature, we conclude that for healthy and/or overweight subjects the importance of low GI or GL diets in relation to the metabolic syndrome has not been established.”
Contact Information
American Bakers Association
Lee Sanders, Senior Vice President, Government Relations & Public Affairs
1300 I St., N.W.
Suite 700 West
Washington, DC 20005
202-789-0300
lsanders@americanbakers.org
North American Millers’ Association
Betsy Faga, President
600 Maryland Avenue, S.W.
Suite 825 West
Washington, DC 20024
bfaga@namamillers.org
Grain Foods Foundation
Judi Adams, MS, RD, President
490 Bear Cub Drive
Ridgway, CO 81432
970-626-5183
Judi.adams@grainsfoundation.org
Wheat Foods Council
Marcia Scheideman, MS, RD, CFCS, President
10841 S. Crossroads Drive
Suite 105
Parker, CO 80134
Mscheideman@wheatfoods.org
National Association of Wheat Growers
W. Daren Coppock, Chief Executive Officer
415 Second St., N.E.
Suite 300
Washington, DC 20002
Dcoppock@wheatworld.org
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