The Council for Responsible Nutrition (CRN), Washington, D.C., feels that the final guidelines should provide American consumers with a more balanced perspective on the scientific evidence relating to the benefits of the appropriate and rational use of dietary supplements. Speaking at a public meeting held in July in response to the draft report, Andrew Shao, PhD, senior vice president, Scientific and Regulatory Affairs, CRN, said, “Americans need practical guidance on improving their personal dietary habits and avoiding nutrient shortfalls, including the beneficial and supporting role that vitamin and mineral supplements play in a nutrition program. Unfortunately, the 2010 Dietary Guidelines Advisory Committee Draft Report takes a step backward—without scientific justification—when it comes to vitamin and mineral supplements, by failing to recognize how the multivitamin can address dietary inadequacies for nutrients.”

Dr. Shao later added: “While obtaining all essential nutrients from foods may be ‘optimal,’ it is neither realistic nor practical. Further, waiting until deficiencies are evident before recommending nutritional support is not in the best interest of consumers.”

The Global Organization for EPA & DHA Omega 3s (GOED), Salt Lake City, UT, also submitted comments that touch on nutrient adequacy, as well as fatty acids and cholesterol, and food safety and technology. As it applies to EPA and DHA, GOED disagrees that there is limited evidence to support a recommendation for the use of EPA and DHA supplements in the prevention of chronic disease (i.e., cardiovascular disease) in a general, healthy population. To that end, GOED strongly encourages USDA and HHS to consider recommending dietary supplements and EPA/DHA fortified foods in addition to fish to ensure that consumers can practically meet the advice of the DGAC.

The Organic Trade Association (OTA) has also called for revisions to the draft guidance to reflect the value organic foods have for public health. OTA’s executive director and CEO Christine Bushway pointed out serious concerns with statements in Resource 3, titled “Conventional and Organically Produced Foods.” For one, although the Dietary Guidelines statement on organic foods references only limited research on nutrient density, it draws the broad conclusion that “Our current understanding of conventional and organically produced foods indicate that their nutritional value and contributions to human health are similar.”

“These conclusions are neither grounded in current science nor relevant to the mandate of the dietary guidelines,” Ms. Bushway said. Also, the conclusions of the draft dietary guidelines are in direct conflict with the advice put forth by the recent President’s Cancer Panel report regarding ways to reduce environmental cancer risk. In its recent report, that scientific panel recommended that “Exposure to pesticides can be decreased by choosing, to the extent possible, food grown without pesticides or chemical fertilizers.”