Farm Sanctuary's letter to the USDA
October 15, 2003
Food Guide Pyramid Reassessment Team
USDA Center for Nutrition Policy and Promotion
Room 1034
3101 Park Center Drive
Alexandria, VA 22302
RE: Proposed Food Guide Pyramid
To Whom It May Concern:
I am writing on behalf of Farm Sanctuary to comment on the proposed Food Guide Pyramid daily food intake patterns and technical support data noticed in the Federal Register on September 11, 2003 (Vol. 68, No. 176). Farm Sanctuary is a national non-profit organization dedicated to fighting agricultural abuse of animals and promoting a vegan lifestyle.
Farm Sanctuary supports updating the Food Guide Pyramid and its technical support data to reflect the conclusions reached by a growing body of scientific research into the relationship between diet and disease. America's dietary choices have a profound impact, not only on the health and wellbeing of its citizens, but on the nation's health care costs, the integrity of our natural resources, and the welfare of billions of non-human animals as well.
Importance of the Food Guide Pyramid
The Food Guide Pyramid translates nutritional recommendations into the kinds and amounts of foods the public is to eat every day. Its purpose is to interpret highly technical information about the nutritional composition of various foods into a simple graphic representation of ideal food choices that the average American can relate to and comprehend.
The current Dietary Guidelines for Americans informs readers: "Let the Pyramid guide your food choices. To make sure you get all the nutrients and other substances you need for health, build a healthy base by using the Food Guide Pyramid as a starting point. Choose the recommended number of daily servings from each of the five major food groups." 1
As the Dietary Guidelines instruct individuals to eat a minimum number of servings from each of the major food groups every day, it is imperative that those food groups are in fact beneficial, and not deleterious, to human health.
Role of Diet in Disease
During the past two decades thousands of scientific studies have documented the health benefits of a plant-based diet and the risks of consuming meat and dairy products. Animal-derived diets have been repeatedly linked to the four leading causes of death in the U.S. - heart disease, cancer, diabetes, and stroke/hypertension. In addition, diets that are high in fat and calories and low in fiber have been associated with overweight and obesity, which have reached epidemic proportions in the U.S. According to a "call to action" released by the U.S. Surgeon General in 2001, "Health problems resulting from overweight and obesity could reverse many of the health gains achieved in the U.S. in recent decades." The report goes on to claim that 61 percent of U.S. adults and 13 percent of children and adolescents are now considered overweight.2
The Surgeon General report attributes 300,000 U.S. deaths a year to obesity and sets the price tag for the condition at $117 billion for the year 2000.3 According to the USDA's Center for Nutrition Policy and Promotion, all diet-related health problems cost Americans approximately $250 billion each year in medical costs and lost productivity.4
A small sampling of the many studies correlating diet and disease are summarized below:
Heart Disease
The Seven Countries Study was the first to show a strong relationship
between the consumption of different food groups by cultural populations
and the long-term incidence and mortality from coronary heart disease
(CHD). In the study, higher animal food consumption was associated with
higher CHD death rates, while higher vegetable consumption was associated
with lower CHD death rates. The findings held true for the consumption
of both meat and dairy products.5
In another international survey, death rates from CHD were positively linked country-by-country with milk consumption, specifically with consumption of the non-fat portion of cow's milk.6 An additional study that combined data from five different prospective studies found that mortality from ischemic heart disease was 24 percent lower in vegetarians than in non-vegetarians.7
Cancer
A 1997 report by the American Institute for Cancer Research examined global
evidence of a diet-cancer link using a methodical and comprehensive approach.
It concluded that 30 to 40 percent of all cancers are directly related
to food.8 The report's findings were confirmed by a 2003 document from
the World Health Organization, entitled Diet, Nutrition and the Prevention
of Chronic Diseases, that associated diets rich in plant foods with lower
risk for cancer. According to the American Institute for Cancer Research,
"To date, literally thousands of studies consistently show correlations
between fruit and vegetable consumption and lower cancer risk…. Taken
together, this evidence amounts to proof of a causal relationship beyond
any reasonable doubt."9
Diabetes
In one study, rates of diabetes among Seventh-day Adventists - approximately
40 percent of whom are vegetarian - were less than half those found in
the general population. In the same study, vegetarian Adventists had lower
rates of diabetes than non-vegetarian Adventists. 10
Hypertension
Studies have documented significantly lower rates of hypertension among
vegetarians compared with meat eaters.11 In one study, only 13 percent
of vegetarians were shown to suffer from hypertension versus 42 percent
of those consuming meat.12
Obesity
Following a vegetarian diet has been associated with lower levels of obesity,
as defined by the body mass index (BMI). In the Seventh-day Adventists
Health Study, BMI was associated with meat eating: BMI increased as the
consumption of meat increased.13 Similar findings were documented for
both sexes and all age groups in the Oxford Vegetarian Study.14
Foodborne Illness
Last year the USDA Food Safety and Inspection Service (FSIS) issued 44
recalls for a total of 56 million pounds of meat and poultry, enough to
serve a potentially tainted burger or chicken patty to every man, woman,
and child in America.15 In 1999 the Centers for Disease Control and Prevention
conducted an extensive study of the impact of foodborne diseases on health
in the United States. The study concluded that each year in the U.S. foodborne
disease is responsible for approximately 76 million illnesses, 325,000
hospitalizations, and 5,000 deaths. While many pathogens can be transmitted
through multiple sources including plant foods, water, or from person
to person, the pathogens of greatest concern today (Escherichia coli 0157:H7,
Campylobacter jejuni, Listeria monocytogenes, and Salmonella nontyphoidal)
are all spread through foods derived from animals.16
Support for a Plant-Based Diet
In analyzing a vegetarian lifestyle, the American Dietetic Association concludes, "In general, heart disease, high blood pressure, adult-onset diabetes, obesity and some forms of cancer develop less often among vegetarians than non-vegetarians."17 The American Dietetic Association and the Dietitians of Canada has published the following statement in support of plant-based diets:
It is the position of the American Dietetic Association and Dietitians of Canada that appropriately planned vegetarian diets are healthful, nutritionally adequate, and provide health benefits in the prevention and treatment of certain diseases.18
Due to their demonstrated health benefits, diets rich in vegetables, fruits and grains and low in starches and fat have been endorsed by a number of additional organizations. Some of these groups include:
· American Institute for Cancer Research
· American Cancer Society
· American Heart Association
· Heart and Stroke Foundation of Canada
· National Institutes of Health
· American Academy of Pediatrics19
Recommended Changes to Food Guide Pyramid
The current Food Guide Pyramid recommends a total of 4 to 6 servings
each day from food groups containing foods that have been consistently
linked to heart disease, cancer, and other health problems. This is anything
but a prescription for health and fitness.
Farm Sanctuary makes the following suggestions regarding the food groups
that form the basis of the Food Guide Pyramid:
Replace the "Milk Group" with a "Calcium-rich Group"
The current Food Guide recommends 2 to 3 servings per day of dairy products.
The Guide offers no plant sources for calcium, despite the fact that many
adequate alternatives exist. Fortified soy non-dairy products contain
as much calcium, Vitamin A and D as fortified cow's milk. Some enriched
soy alternatives are superior to cow's milk in providing other nutrients,
including iron, folic acid, Vitamin B12, and Vitamin E.
Replace the "Meat and Beans Group" with a "Protein-rich
Group"
The current Food Guide recommends 2 to 3 servings per day of meat, poultry,
fish, dry beans, eggs, or nuts. Although the Guide does offer beans and
nuts as plant-based alternatives to meat, it does not reflect the fact
that the intake of animal flesh is injurious to human health and should
be minimized, or that legumes provide protein that is nutritionally adequate
and may even protect against the onset of heart disease.20
Revise or Eliminate the "Fats, Oils, & Sweets Group"
Given the current obesity problem in the U.S., it's doubtful a separate
"Fats, Oils & Sweets" food group is prudent, and since sugars
and fats naturally occur in a number of foods, it's questionable whether
a separate category for these nutrients is even necessary.
It has been suggested that the graphic representation of the Food Guide be inverted since many individuals perceive the top tier of a pyramid as being of the highest quality or the most desirable. It may be preferable, in fact, to replace the pyramid itself with an entirely different graphic. Canada, for example, makes use of a rainbow graphic for its food guide.
Several alternative food guide graphics have been developed. One proposed vegetarian food guide pyramid (Attachment 1) and rainbow (Attachment 2) includes five food groups: Grains; Legumes, Nuts and Other Protein-rich Foods; Vegetables; Fruits; and Fats. Both the pyramid and the rainbow feature a segment of each food group dedicated to Calcium-rich foods as opposed to having a separate Calcium group.21
The Plant-based Food Pyramid promoted by EarthSave (Attachment 3) consists of a conventional pyramid design with four tiers. The "Whole Grains, Cereals and Pastas" group occupies the bottom tier; "Vegetables" and "Fruits" are on the second tier; "Calcium-rich Foods" and "Beans and Alternatives" share the third tier; and "Omega 3 Fatty Acids, Vitamins B12 and D" are at the top of the pyramid. This latter group allows a completely plant-based, or vegan, diet to meet all nutritional requirements.22
Conclusion
When the U.S. Food Guide was originally published in 1916 little was known about the connection between the consumption of animal food products and disease. The concern at the time was malnutrition, not "overnutrition," as is the case today. Moreover, vegetarian substitutes for animal foods were not readily available. Today, virtually every grocery store in America, in addition to many restaurants, hotels, airlines, shopping centers, and recreational venues, offer vegetarian and vegan options.
Given the overwhelming empirical evidence linking animal-based foods with various human health conditions, it is irresponsible for the federal government to continue to recommend through its Food Guide the daily consumption of 4 to 6 servings per day of meat and dairy products. Not only are vegetarian and vegan diets nutritionally adequate, they provide significant health benefits in the prevention and treatment of a variety of diseases.
Therefore, Farm Sanctuary recommends that the Food Guide Pyramid and its technical support data be altered by substituting a "Calcium-rich Group" for the current "Milk Group" and a "Protein-rich Group" for the current "Meat and Beans Group." We challenge the USDA to devise a graphic representation of recommended dietary choices that accurately reflects what is known about the health benefits of a plant-based diet, as well as the risks of a diet based on animal-derived foods.
Thank you for the opportunity to comment on this very important issue. We look forward to reviewing the revised Food Guide when it becomes available.
Sincerely,
Gene Bauston, President
Farm Sanctuary, Inc.
