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Grain Industry Comments to the 2010 Dietary Guidelines Advisory Committee July 15, 2010

Carole Davis, Co-Executive Secretary
2010 Dietary Guidelines Advisory Committee
Center for Nutrition Policy and Promotion
United States Department of Agriculture
3101 Park Center Drive, Room 1034
Alexandria, VA 22302

Dear Ms. Davis:

On behalf of the partners in the grains industry: American Bakers Association, American Institute of Baking, Grain Foods Foundation, Grains for Health Foundation, Independent Bakers Association, National Association of Wheat Growers, National Pasta Association, North American Millers’ Association, Retail Bakers of America, USA Rice Federation and Wheat Foods Council, we thank you for the opportunity to submit comments regarding the 2010 Dietary Guidelines Advisory Committee’s Technical Report. Our organizations applaud the critical work of the Committee, USDA/CNPP and HHS in reviewing new data and addressing recommendations to enhance public health. Our comments and recommendations are as follows:

  1. Recommendation: The 2010 Dietary Guidelines should use the term “enriched” grains when referencing grains that are not defined as whole grains. While the guidelines policy document is intended for nutrition and medical professionals, the consumer is exposed to them through the media and
    would be confused by the mixture of messages using “refined” and “enriched” terminology. The term “enriched” is more accurate than the term “refined” or milled grains because approximately 95% of all refined/milled grains are enriched with niacin, thiamine, riboflavin and iron in equal amounts found in
    whole grains and folic acid is fortified in twice the amount found in whole grain products. Enrichment was enacted in 1941 when servicemen and women were found to be undernourished. This single health initiative virtually eliminated pellagra and beriberi in the U.S. (The success of this initiative is why enriched grains were chosen to be the vehicle for folic acid fortification to help prevent neural tube birth defects.)In addition, FDA Standards of Identity (1) uses the term “enriched” for milled grains to which these nutrients have been added. “Enriched” is a principle display panel product descriptor and ingredient labeling term consumers are familiar with and look for when purchasing healthy grains. “Refined” is not a principle display panel term. Continuation of the use of “refined” is confusing and
    inaccurate for both the consumer and the nutrition community. Most importantly, the term “refined” is interpreted negatively by both the consumer and the media when, in fact, both whole grains and enriched grains have a valuable place in a healthy, balanced diet.
  2. Recommendation: Continue use of the current guideline: “Make half your grains whole.” Science shows that three servings of whole grain a day can reduce the risk of many chronic diseases and may help in weight management. Thus, daily intake of at least three servings of whole grain is recommended. We realize that most consumers fall short of that recommendation and many grains organizations and companies offer practical consumer education programs to help consumers, foodservice operators and school menu planners increase whole grain consumption. We are committed to furthering these efforts and will support USDA and HHS educational efforts and initiatives as well.
  3. Recommendation: The 2010 Dietary Guidelines should reconsider the blanket recommendation to limit “refined” carbohydrates: Grain products, whole and enriched, are a primary source of energy-providing complex carbohydrates and a source of fiber, the major B vitamins (riboflavin, thiamin, niacin and folic acid) and iron. In fact, they are the primary source of seven essential nutrients (2). Some
    enriched products are also fortified with vitamin D and calcium.We object to the blanket recommendation to limit “refined carbohydrates.” While we understand that it is specifically about enriched grains with added sugar and fat, we are concerned that consumers will not understand that a majority of enriched grain products have no added or limited amounts of sugar or fat. The recommendation unjustly conflates enriched flour with added fat and sugar. (This recommendation could be likened to telling consumers to consume fewer almonds merely because they are a popular ingredient in chocolate bars.) Additionally, the recommendation appears to imply that half of enriched flour consumed in the United States goes into products laden with sugar and fat. Industry sources suggest the figure is far smaller than half. We believe more clarification will be needed in the final Guidelines to ensure that Americans understand the difference between the types of enriched carbohydrates that carry unhealthy levels of added sugar and fat, compared with enriched grains that are
    nutrient-rich and have many health-beneficial qualities.

    Examples of healthful grains:

    Grain products, including bread, cereal, pasta and rice, provide a significant portion of key vitamins and minerals, including folic acid, to current nutrient intakes of the US population.

    One ounce of fortified dry cereal or one slice of bread can provide a healthy daily intake of iron, with fortified cereal delivering 25 percent of the recommended daily value for iron and one slice of enriched bread delivering 6 percent (3). In a plant-based, vegetarian or Mediterranean diet pattern, the presence of iron from enriched grain foods is even more vital.

    Studies show that consumers who eat both enriched white and whole grain rice have healthier diets than non rice eaters, and may have reduced risk for chronic diseases including heart disease and type 2 diabetes (4). For example, the diets of enriched white and whole grain brown rice eaters are more in line with current DGA recommendations. Research shows that compared to people who do not eat rice, people who eat rice consume less added sugar and fat, and consume more nutrients, such as folic acid, potassium and iron that are contained in rice products. In addition, rice eaters are less likely to be overweight, have a 34% reduced risk of high blood pressure, 27% reduced likelihood of having an
    increased waist circumference, and 21% reduced risk of metabolic syndrome. Eating rice may be related to a reduction in risk factors for cardiovascular disease, type 2 diabetes, metabolic syndrome, and overall better diet quality.

    Health benefits of folic acid:

    Other benefits of enriched grains include the unprecedented success of reducing neural tube birth defects since FDA mandated fortification of folic acid in 1998 to all enriched grains. Since that time, CDC estimates that 1,000 babies per year (26 percent fewer babies with NTDs) (5) have been saved from disabling and potentially fatal neural tube birth defects. The March of Dimes encourages women of child- bearing age to eat grain products enriched with folic acid because the majority of them do not take supplements, despite nearly 17 years of advice from the U.S. Public Health Service and international health organizations to do so (6).

    In the January 9, 2009 issue of Morbidity and Mortality Weekly (7), CDC also supports consumption of enriched grains: “Health-care professionals should encourage women who can become pregnant to consume folic acid daily through a vitamin supplement or enriched foods.” According to NHANES 1999- 2000, enriched and fortified grains are the largest source of folic acid in the American diet. In fact, bread, rolls and crackers supply 15.6 percent of daily folate, vegetables provide 12.6 percent, rice and pasta dishes provide 12.4 percent and breakfast cereals 12.1 percent (8).

    In addition, synthetic folic acid found in fortified foods is more bioavailable than its natural counterpart found in whole grains, fruits and vegetables. Naturally occurring folates in foods are highly unstable and easily degraded in storage and during cooking. Folates are poorly absorbed at 50% the rate of a folic acid supplement taken on an empty stomach. Synthetic folic acid (as used in enriched grain products) is considered to be nearly 100% absorbable (9). FDA has authorized a health claim that highlights this distinction.

    While some nutritionists would prefer that whole grain bread, pasta, rice, crackers, pretzels, etc. be fortified with folic acid as are enriched grains, current FDA Food Additive Regulations and Bread Standards of Identity prevent this folic acid fortification with the only exception being for whole grain cereals fortified with folic acid. The reasoning behind this is that FDA is worried about over-fortification in certain populations.

    It is essential that all government agencies coordinate and compliment their policies. If there were two competing policies, it would undermine grain product companies’ enthusiastic compliance and educational efforts with the public health initiative.

  4. Recommendation: The 2010 Dietary Guidelines for Americans should consider and support a voluntary, gradual and incremental approach to the reduction of sodium in foods that is mindful of functional properties and consumer preferences. The important contributions of grain-based foods in the American diet are widely recognized, which is why they are the largest food group. Salt and sodium play a key functional role in these foods and the grain sector has given considerable thought to ways to reduce sodium. Although research and technology on alternative ingredients and technology has expanded, current options are limited and substantial research is required to define physiological mechanisms related to salt, sodium and taste.

    Salt is a critical ingredient in the production of bread. It enhances flavor, crust color and crumb structure; prevents excess yeast action and inhibits acid producing bacteria. It is also a vital ingredient in maintaining the flavor of bread. While we recognize that bread is one of the major contributors of sodium because of the quantity consumed, as an individual serving, it is not a high sodium product. Bakers have already pro!actively reduced the amount of sodium in bread in recent years, with USDA data confirming that the average sodium level in a slice of bread has dropped from 254 mg to 180 mg since 1963. Both cereals and rice mixes have also decreased their sodium content in recent years and many are working to decrease further including participation in the National Salt Reduction Initiative.

    Also, retraining the palate through gradual reductions over a period of time is likely to be most effective since taste, including consumer perception about taste, is still the number one driver for food purchase.

    We believe that the gradual and incremental approach, along with educational efforts from government, industry, health professionals and other stakeholders to encourage a wide-spread change in the dietary intake patterns will effectively help consumers achieve the reduced sodium goals. “

  5. Recommendation: The 2010 Dietary Guidelines should use sound science regarding added sugars. The report concludes that added sugars at all levels are associated with reduced nutrient intakes and uses the recent research by Marriott et al (10) to support that statement. The same research also emphasized that high levels of added sugars only occurred among a small portion of the population which cannot explain the inadequate nutrient intakes of the US population as a whole. In addition, a large number of individuals who were classified as underweight or normal weight reported higher levels of added sugar intake than those who were overweight or obese. This information should be considered in light of the Committee’s concerns about obesity.
  6. Recommendation: The 2010 Dietary Guidelines must continue to recommend physical activity. It is important that all ages are encouraged to engage in physical activities that are appropriate for their age, enjoyable, and offer variety. While exercise is not as effective in reducing weight, it is very effective in preventing weight gain and in preventing re-gaining by those who have lost weight.We also suggest that the Guidelines recommend physical education classes be mandatory for all schools and all grades. Another easy suggestion is for schools to have recess before lunch. A study by Gettlinger et al (11) showed a reduction in plate waste from 35% to 24% just by having recess first. This and other studies have also shown that children may perform better in school if they have recess before lunch.

In summary, there are many valid reasons to continue use of the current guidelines regarding enriched and whole grains: “Make half your grains whole.” But the most compelling reason for not altering the recommendations lies in harmonization of federal nutrition policy and recommendations. It is crucial to not undermine a highly successful public health policy regarding folic acid intake that has demonstrated its success through empirical data – and the very human face of healthier babies. Since 1998, when grain products manufacturers complied with the FDA mandate, our companies have invested extensive resources in education efforts regarding the importance of folic acid for mothers-to-be by partnering with the March of Dimes and the Folic Acid Awareness Council.

Thank you for the opportunity to provide scientific information to USDA and HHS regarding the importance of both whole and enriched grains in the diet. If you have any questions, please feel free to contact any of the below organizations.


American Bakers Association, Robb MacKie, President/CEO
American Institute of Baking, James Munyon, President
Grain Foods Foundation, Judi Adams, MS, RD, President/CEO
Grains for Health Foundation, Len Marquart, President
Independent Bakers Association (IBA), Nick Pyle, President
National Association of Wheat Growers, Dana Peterson, CEO
National Pasta Association, Carol Freysinger, Executive Director
North American Millers Association, Mary Waters, President
Retail Bakers of America, Rick Bittner, Executive Director
USA Rice Federation, Elizabeth C. Ward, President/CEO
Wheat Foods Council, Lynn Holly, Interim Director

American Bakers Association (ABA) is the Washington D.C.- based voice of the wholesale baking industry. Since 1897, ABA has represented the interests of bakers before the U.S. Congress, federal agencies, and international regulatory authorities. ABA advocates on behalf of more than 700 baking facilities and baking company suppliers. ABA members produce bread, rolls, crackers, bagels, sweet goods, tortillas and many other wholesome, nutritious, baked products for America’s families. The baking industry generates more than $70 billion in economic activity annually and employs close to half a million highly skilled people. [email protected]

American Institute of Baking International (AIB) is a corporation founded by the North American wholesale and retail baking industries in 1919 as a technology transfer center for bakers and food processors. The original mission of the organization was to “put science to work for the baker,” which is still central to all of the programs, products, and services provided by AIB to baking and general food production industries worldwide. [email protected]

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. [email protected]

Grains for Health Foundation (GFH) was founded in 2009 to increase the availability of affordable grain-based foods with health benefits to improve public health. Grains for Health forges partnerships with food and health leaders to develop evidence-based strategies that facilitate the development, delivery, and consumption of grain-based foods that promote public health, lower the incidence of diet- related chronic disease, and curb health care costs. [email protected]

Independent Bakers Association (IBA) The Independent Bakers Association is a Washington, D.C. based national trade association of over 400 mostly family owned wholesale bakeries and allied industry trades. The Association was founded in 1968 to protect the interests of independent wholesale bakers. [email protected]

National Association of Wheat Growers (NAWG) is a federation of 21 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. [email protected]

National Pasta Association (NPA) was founded in 1904 and is an organization of pasta manufacturers, millers and suppliers to the US pasta industry which serves as a cohesive industry advocate, a promoter of pasta and a center of knowledge for its members. [email protected]

North American Millers’ Association (NAMA) is the trade association representing 45 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. [email protected]

Retail Bakers of America (RBA) was founded in 1918. Its purpose is assist retail bakers in furthering the health of the nation by making available delicious bakery foods; to foster a better relationship between the public and the baking industry; to promote and encourage the production of high quality, wholesome, healthful bakery foods; and to represent the baking industry, especially its retail branch, to the government. [email protected]

USA Rice Federation is the global advocate for all segments of the U.S. rice industry with a mission to promote and protect the interests of producers, millers, merchants and allied businesses. Over 20 billion pounds of long, medium, and short grain, and organic and specialty rices are grown and harvested each year by farmers in Arkansas, California, Louisiana, Texas, Mississippi and Missouri. [email protected]

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. [email protected]


  1. FDA Standards of Identity PART 137 — CEREAL FLOURS AND RELATED PRODUCTS Subpart B Requirements for Specific Standardized Cereal Flours and Related Products
  2. http://www.cnpp.usda.gov/Publications/FoodSupply/FoodSupply2005Report.pdf
  3. USDA/ARS Nutrient Database for Standard Reference, Release 16
  4. S. Patricia Batres-Marquez, MS; Helen H. Jensen, PhD; Julie Upton, MS, RD. Rice Consumption in the US: Recent Evidence from Food Consumption Surveys. J Am Diet Assoc. 2009;109:1719-1727.
  5. CDC. Morbidity & Mortality Weekly Report. May 7, 2004. 53 (17): 363-365.
  6. Botto LD, Lisi A, Robert-Gnansia E, Erickson JD, Vollset SE, Mastroiacovo P, Botting B, Cocchi G, de Vigan C, de Walle H, Feijoo M, Igens LM, McDonnell B, Scarano G, Siffel C, Metneki J, Stoll C, Smithells R and Goujard J. International retrospective cohort study of neural tube defects in relation to folic acid recommendations: are the recommendations working? BMJ 2005; 330:571
  7. CDC. Morbidity & Mortality Weekly Report. Jan. 9 2009. 57 (53): 1409.
  8. Dietrich M., Brown CJ, Block G. The effect of folate fortification of cereal-grain products on blood folate status and dietary folate sources among adult non-supplement users in the United States. 2005. Journal of the American College of Nutrition, Vol. 24, No. 4, 266–274.
  9. Institute of Medicine. (1998) Dietary reference intakes for thiamin, riboflavin, niacin, vitamin B6, folate, vitamin B12, pantothenic acid, biotin and choline. Last accessed 12/18/08 from http://books.nap.edu/openbook.php?isbn=0309065542&page=196#pagetop
  10. Marriott BP, Olsho L, Hadden L, Connor P. Intake of Added Sugars and Selected Nutrients in the United States, National Health and Nutrition Examination Survey (NHANES) 2003-2006. Critical Rev in Food Sci and Nut. 2010.
  11. Gettlinger MJ, Laughlin CVT, Bell E, Akre C, Arjmandi BH. Food Waste is reduced when elementary-school children have recess before lunch. JADA 1996; 9: 906-908.”
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