September 27, 2004
Attn: Kathryn McMurray
2005 Dietary
Guidelines Advisory Committee
HHS Office of Disease Prevention and Health Promotion
Room 738-G
200 Independence Avenue SW
Washington DC 20201
Dr. Eric Hentges
Executive Director
Center for Nutrition and Policy Planning
U.S. Department of Agriculture
Alexandria, VA
Re: Federal Register Notice
Announcement of...a Public Comment Period...
Vol. 69, No. 166, August 27, 2004
Dear Ms. McMurray and Dr. Hentges:
The North American Millers' Association (NAMA) appreciates the opportunity to comment on the Report of the Dietary Guidelines Advisory Committee. NAMA is the national association for the wheat, corn and oat milling industry. Our 47 member companies operate 170 milling facilities in 38 states. Their aggregate production capacity exceeds 160 million pounds of milled grain products each day, more than 95 percent of the industry total.
After understanding the charge given to the committee, attending several of their meetings, and reading the report; we want to commend the committee for the time and expertise they put into the science based review of the current guidelines and the latest research. It is now your task to blend science, reality and practicality into the final 2005 Dietary Guidelines for Americans.
We would like to comment on the portions of the report related to carbohydrates and grain based products:
Committee Recommendations:
- “Daily intake of
three or more servings of whole grains per
day is recommended, preferably by
substituting whole grains for refined
grains.”
- “Special nutrient recommendations are warranted for adolescent females and women of childbearing age for iron and folic acid.”
NAMA Comments:
- Add the word “products” whenever “whole grain,” “enriched grain,” “fortified grain,” or “refined grain” is used.
Throughout the report reference is made to “whole grains.” While nutritionists, dieticians and others with a science based background understand that “whole grains” refer to milled products, the general public does not. They consider “whole grains” to be wheat, corn, and oat kernels in their unprocessed form. Therefore, it is important to refer to “whole grain products.”
- As you consider the guidelines for grain based foods, please emphasize a common understanding of the terminology for refined, enriched, fortified and whole grain products in order to avoid any potential confusion among consumers as they strive to make educated choices.
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 other whole grain products are not.
Refined unenriched grain products have had the germ and bran removed with only the endosperm remaining. This represents less than 5% of the total white flour milled in the U.S. It is used primarily for organic and 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 equal amounts to those in whole grain products as defined by the standards of identity. They also are fortified with folic acid in amounts twice that found in whole grain products. This higher level of folic acid fortification now makes enriched grain products also fortified grain products. This includes such things as white bread, rolls, family flour, and the majority of other grain products. This represents approximately 95% of the total white flour milled in the U.S.
Other fortified grain products are those that have a variety of minerals and vitamins not defined by any set standards in various amounts. They are added voluntarily following FDA (Food and Drug Administration) guidelines. Many breakfast cereals fit into this category.
- Replace the current statement “Thus, daily intake of three or more servings of whole grains per day is recommended, preferably by substituting whole grains for refined grains” with “It is recommended that of the daily servings of grain products, three or more be in the form of whole grain products.”
We understand the desire to encourage Americans to increase the consumption of whole grain products. NAMA supports that initiative. In the process, it is critical to retain a positive view of enriched grain products so the consumer does not believe it is detrimental to eat them.
We believe the phrase “preferably by substituting whole grains for refined grains” denigrates the role of enriched grain products and perpetuates the confusion surrounding enriched versus refined grain products. We, therefore, strongly encourage you to make statements that are positive to both whole and enriched grain products.
A statement in the document that acknowledges the historical benefits of enriched and fortified grain products in the American diet would help accomplish this objective.
Grain products have been enriched since 1941 with iron and the B vitamins, riboflavin, niacin and thiamine. With this enrichment, pellegra and beriberi have been eradicated from the United States.
In 1998 folic acid was added to the enrichment formula. Enriched grain products have more than twice the amount of folic acid as whole grain products. A slice of enriched white bread has 37 mcg versus whole-wheat at 17.5 mcg. As a result, neural tube birth defects have decreased almost 30 percent in the U.S., 50 percent in Canada and 41 percent in Chile, two other countries who began this public health initiative. Neuroblastomas, a deadly brain cancer in infants, has decreased 60 percent in Canada during the same period. This has been attributed to folic acid fortification.
A 1999 study found that 77 percent of low-income women could consume adequate amounts of folic acid through enriched grain products. The cost of supplements can be expensive, and are often not taken by low-income women.
In a paper given at the American Heart Association conference in March 2004, the CDC (Centers for Disease Control and Prevention) gave FDA's mandated folic acid fortification of enriched grain products credit for preventing 31,000 deaths annually from stroke and 17,000 deaths annually from ischemic heart disease.
- Maintain a consistent message throughout all government agencies.
A consistent message among government agencies is key to retaining the confidence Americans have in our regulatory agencies. FDA mandated the inclusion of folic acid in enriched grain products. The CDC has undertaken a universal flour fortification initiative that encourages enrichment of flour worldwide. It is critical that the Dietary Guidelines be consistent in communicating that both enriched and whole grain products support good health.
- Strive to change eating habits gradually.
From the milling industry's practical experience; taste, custom, cost, and convenience are strong influences in shaping eating habits. Efforts to change eating habits by persuasion will succeed very slowly and only incrementally.
This is evidenced in the following excerpt from the book “Millers National Federation: A History” by Herman Steen (copyright 1975, Library of Congress Catalog Card #75-10154): “During and preceding this period (1939-40) white flour and its products had been under harsh attack...These groups (leaders in the field of human nutrition) turned to whole wheat as the remedy, but after a generation or more of activity they had little to show for their efforts, for the proportion of whole wheat never reached three percent of all flour.”
Research conducted for NAMA this past year by Wirthlin Worldwide, Reston, VA identifies a continuum important to the consumption of grain based products. The research findings demonstrate that consumers, as they become more health aware, migrated from eating white bread to whole wheat bread. If, however, the consumer doesn't like the taste of whole wheat bread, they choose to eliminate bread entirely. As more emphasis is placed on the value of whole grain products, the consumer is ill served if led to believe that enriched products are of lesser nutritional value.
The reasons most people should, and do, eat significant amounts of enriched grain products are:
- They are inexpensive.
- They are accessible, sold
everywhere in a wide variety of forms.
- They serve as a convenient
carrier for many other foods, contributing to
dietary diversity even while enabling the
casual, high-activity lifestyle most
Americans today value.
- They have flavor and
texture characteristics that encourage
consumption, i.e., people are used to them
and like them.
- They are a major source of energy for the brain.
Whole grain products share several of these characteristics; and contain several minerals, vitamins, phytonutrients, and insoluble fiber that enriched grain products lack. However, looking realistically at changing eating habits, it is important to remember the following about whole grain products:
- They are not as much a
part of our culture as are enriched grain
products. Many people, especially children,
find the flavor or texture unappealing.
- They are not nearly as
available as enriched grain products.
- They tend to be significantly more expensive, resulting in a strain on many household budgets.
Committee Conclusion:
“Weight maintenance depends on a balance of energy intake and energy expenditure, regardless of the proportions of carbohydrate, fat and protein in the diet. Popular weight-loss diets encompassing a very wide range of carbohydrate/fat ratios have not been tested adequately over the long term and are best followed only for short periods of time.”
NAMA Concurs
Committee Conclusion:
“The glycemic index and/or glycemic load are of little utility for providing dietary guidance for Americans.”
NAMA Concurs
The milling industry is joining with the baking industry to launch a campaign that will educate the consumer about the nutritional benefits of grain based products. We believe that program will complement the dietary guidelines. We look forward to working with you in promoting a lifestyle that includes healthy eating and exercise.
Sincerely,
Betsy Faga
President
bfaga@namamillers.org
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