March 26, 2010 Carole Davis CoRExecutive Secretary of the Dietary Guidelines Advisory Committee Center of Nutrition Policy and Promotion U.S. Department of Agriculture 3101 Park Center Drive, Room 1034 Alexandria, VA 22303 RE: 2010 Dietary Guidelines for Americans Dear Ms. Davis and the Dietary Guidelines Advisory Committee: The American Meat Institute (AMI) is the nation's oldest and largest meat packing and processing industry trade association. AMI members slaughter and process more than 90 percent of the nation's beef, pork, lamb, veal, and a majority of the turkey produced in the United States. On behalf of AMI and its member companies, we appreciate the opportunity to comment on the 2010 Dietary Guidelines for Americans (or the Guidelines). AMI has and will continue to support the use of sound science as the foundation for nutritional public policy. AMI would like to commend the Dietary Guidelines Advisory Committee (the Committee) for its structured approach in compiling the data, modifying proposed nutritional targets, and working with the food industry in a partnered approach to improve consumer public health. The health of our customers is the driving force in the production of meat and poultry products, not only with respect to improving the safety of meat and poultry products, but also in offering diverse nutritional products to consumers so they can make an educated decision in choosing the food that best fits their personal lifestyle and family needs. The following comments address specific concerns that require further clarification and/or additional consideration prior to finalizing the Guidelines. Sodium Plays an Important Role in Meat Production and Safety Salt or sodium chloride plays a critical role in the production of meat products -- whether used by large commercial processors, local butchers, or even within the consumer’s home -- to improve the flavor, texture, and safety of those products. Specifically, adding sodium chloride improves the functionality of the muscle proteins. The change in ionic strength increases hydration of the proteins, improving the binding of fat by the muscle protein in products like bologna and sausages. Sodium chloride also improves tenderness during cooking. The water binding of meat proteins caused by sodium stabilizes the delicate protein matrix during cooking, thus producing a final product that has improved texture, tenderness, and palatability. Consumer health is paramount to successfully processing meat and poultry products. Sodium reduction is an issue the meat and poultry industry has been actively working on since the 1980s. In the last 20 years, the industry has learned much through its efforts to reduce sodium in meat and poultry products, including a greater understanding of pathogenic bacterial risks presented by Listeria monocytogenes, Salmonella, and pathogenic Escherichia coli in processed meat and poultry items. Listeria monocytogenes is of particular concern in ready-to-eat processed meat and poultry items because it is very difficult to eradicate from the environment and if products are contaminated, the organism will survive and grow (even at refrigerated temperatures) unless growth inhibitor systems are used. Three common ingredients used for this purpose are sodium chloride, sodium or potassium lactate, and sodium diacetate. These inhibitors are used in up to 70% of processed items in the U.S. marketplace. Reduction in the use of one requires a concomitant increase in another in order to maintain the same degree of safety. Alternatives to these ingredient approaches exist, but are not widespread due to ease of use, economic, and product quality reasons. As an ingredient in meat products, sodium is used as a preservative, which is one aspect of a multi-hurdle approach toward maintaining the safety of products. Sodium also contributes to the overall palatability of a food product. Reductions in sodium would produce meat products that would be unacceptable in texture, tenderness, and flavor to consumers. These products may ultimately never be purchased, or of greater concern, purchased with consumers adding salt ad libim, thus defeating any recommendations the Committee might make regarding daily sodium intake. For the foregoing reasons, with respect to the decision-making process regarding sodium intake recommendations, AMI respectfully requests that the Committee consider the unforeseen possible food safety consequences of those recommendations. Protein-Based Diet is a Component of a Healthy Diet It is in Americans’ best health interest to encourage them to consume meat and poultry products as a nutrient dense food that complements a varied and balanced diet, which includes fruits, vegetables, nuts, dairy products, legumes, and grains. AMI is concerned that the Committee is overemphasizing its recommendations to make grains, fruits, and vegetables the core of a plant-based diet as the foundation of a “healthy” diet for Americans. Although each of those food groups play an important and critical part in a healthy diet, AMI is concerned that there may be a negative bias by the Committee toward animal proteins and more specifically beef and pork products. Regardless that the studies evaluated found limited data to support the hypothesized better health outcomes for plant-based and vegan diets, the Carbohydrate and Protein subcommittee appears to be actively seeking a link between adverse health outcomes and animal proteins. Meat and poultry products are an excellent source of high-quality protein, B-vitamins, zinc, and iron, all of which play a critical role in meeting the daily nutritional needs of Americans. AMI strongly recommends that the Committee evaluate its data based on sound science and a scientifically based risk assessment, not nutrition publication bias, as the foundation for nutrition public policy. AMI recommends that the guidelines be worded to include a fair and balanced recommendation for inclusion of an animal-based diet as a foundation for a healthy American diet. Consuming Animal-based Proteins as Part of a Healthy Diet is Not a Health Risk A number of submissions have commented on the controversial discussion concerning whether red meats and processed meats pose an increased public health risk for Americans, specifically as to development of cancer. AMI ardently supports the submissions of Dr. Dominik Alexander (#000539, 06/30/2009), Dr. Andy Milkowski (#000765, 11/23/2009), and Dr. Douglass Weed (#000510, 05/58/2009). During the April 2009 meeting, the Committee stated it would defer to the WCRF/AICR Expert Report, Food, Nutrition, Physical Activity and the Prevention of Cancer: A Global Perspective (or the WCRF report) for a variety of diet and cancer research questions. Drs. Weed and Alexander, however, have highlighted significant errors, omissions, and flaws in the analysis and conclusions of the WCRF report. Dr. Milkowski eloquently describes inaccuracies inherent in the myths regarding red meat and processed meat products being the dietary sources of the carcinogenic polycyclic aromatic hydrocarbons and heterocyclic amines, nitrosamines and of nitrite, which despite popular belief is not a carcinogen. The common concern of meat-acquired nitrite consumption as a carcinogen is unwarranted, which was supported by the 2000 National Toxicology Program Report TR495 that found nitrite levels typically used in meat products are not toxic or carcinogenic. These errors concerning the inaccurate causal relationship between red meats, processed meats, and cancer are the basis for the WCRF report, which recommends limiting intake of red meats and processed meat in the human diet. AMI strongly believes that the WCRF report does not accurately reflect the body of scientific evidence in this area and should not be used as a default resource and source for diet and cancer research questions. Summary Meat is an important component of a healthy human diet because it provides essential amino acids, minerals such as iron, vitamins, and other dietary requirements. Processed and enhanced meat products in the market place today are available to consumers at very affordable prices. As previously stated, the health of consumers is the driving force in the production of our products. AMI looks forward to working with the Committee to set achievable, practical, and meaningful nutrition policy for the American people and in that regard, AMI appreciates the opportunity to comment on the development of the 2010 Dietary Guidelines for Americans. AMI would be pleased to work with the Committee regarding each of these concerns and requests that AMI’s recommendations be considered before finalizing the 2010 Dietary Guidelines for Americans. Thank you for your consideration of the comments provided above. If there are any questions about the above comments, please do not hesitate to contact me at [email protected] or 202-587-4249. Sincerely, Betsy Booren, Ph.D. Director, Scientific Affairs cc: J. Patrick Boyle Jim Hodges Susan Backus March 31, 2010 Carole Davis CoRExecutive Secretary of the Dietary Guidelines Advisory Committee Center of Nutrition Policy and Promotion U.S. Department of Agriculture 3101 Park Center Drive, Room 1034 Alexandria, VA 22303 RE: 2010 Dietary Guidelines for Americans Dear Ms. Davis and the Dietary Guidelines Advisory Committee: The American Meat Institute (AMI) is the nation's oldest and largest meat packing and processing industry trade association whose members slaughter and process more than 90 percent of the nation's beef,