Speaking at a public meeting held in response to the 2010 Dietary Guidelines Advisory Committee (DGAC) Draft Report, Andrew Shao, PhD, senior vice president, Scientific and Regulatory Affairs, Council for Responsible Nutrition (CRN), presented the following oral comments:

“I’m Dr. Andrew Shao, and I am here today representing the Council for Responsible Nutrition. More than 150 million Americans supplement their diets each year with vitamins and other dietary supplements. 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 (DGAC) 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.

“The primary reasons that consumers take vitamins and minerals are to support overall wellness and to fill nutrient gaps. The failure to recognize the contributions of a multivitamin for the health benefit of achieving nutrient adequacy is a critical weakness of the Draft Report. The Draft Report recognizes a large number of nutrient shortfalls in the population, but concludes these are not of public health concern unless the shortfalls are accompanied by widespread low blood levels of the nutrient or by signs of overt deficiency. Further, by recognizing multiple nutrient shortfalls but discouraging multivitamin use, the Draft Report in effect says that living with shortfalls is preferable to filling nutrient gaps with reasonable dietary supplements.

“While obtaining all essential nutrients from foods may be quote/unquote ‘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 Draft Report convincingly documents that achieving recommended intakes of nutrients without exceeding desirable calorie levels is difficult. While dietary supplements cannot compensate for a poor diet, nor act as a substitute for a healthy diet, they can in fact fill specific nutrient gaps at a low cost per day and without adding significant calories.

“Additionally, we have seen a large reduction in this country in the incidence of neural tube birth defects (NTDs), in part due to mandatory folic acid fortification, but also in part due to the ease, convenience and affordability of taking a multivitamin with folic acid. A multivitamin with 400 mcg of folic acid provides women of childbearing age with a viable, convenient and affordable option to ensure they are getting the folic acid they need to help prevent birth defects, and we urge that the final Dietary Guidelines not discourage these women from options for obtaining necessary folic acid.

“In conclusion, there is no evidence that shows that consumers turn to dietary supplements as a substitute for a healthy diet. In fact, studies show that supplement users are more likely than non-supplement users to try to incorporate other healthy habits into their wellness regimen. We urge you not to take a step backwards with respect to vitamins, but to give Americans reasonable options for staying healthy.”