All About the Dietary Guidelines for Americans

The 2015-2020 Report

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The Dietary Guidelines for Americans are generated every 5 years in a two-step process.  My impression is that we would be dealing with a great deal of noise and nonsense on the topic even if that were clear to most people, but it’s not clear - so let’s address that first.

The federal government first convenes a group of expert, independent, meticulously screened nutrition scientists who are nominated by their peers.

Members must disclose and dissociate from any real or potential conflicts.  Then, the group works, mostly in a fish bowl, for roughly two years, reviewing all of the relevant evidence, and generating reports. Those reports are ultimately assembled into the Dietary Guidelines Advisory Committee Report, which is also put in the fish bowl, not only on public display- but with a widely publicized invitation for public reaction and critique.

Only after the final DGAC report is submitted to the USDA does the process of generating the “official” Dietary Guidelines for Americans begin. That process involves no additional science or expertise, but rather intense lobbying of Congress by special interest groups, and then stipulations from those members of Congress to the two federal agencies responsible for the final guidelines: USDA, and DHHS. 

One of the great liabilities in this process is the relative lack of daylight between the two products, the first of public health science, the second of political influence.

The very fact that the two documents are called pretty much the same thing, with the first subordinate to the second, makes it seem as if any criticism well deserved by the political part of the process pertains to the scientific part, too. That is not true.

A closely related problem is that the final Dietary Guidelines for Americans are not, even by the admission of some of my friends at the very federal agencies responsible, really intended as the “best” advice about what all Americans should eat for good health.

Rather, they are what politicians think should be done with the best, expert advice in an effort to balance public health against corporate profits. So they are not really dietary guidelines for Americans at all, but rather food policy guidance of a sort for America. On the basis of this very fact, I have argued that the “Dietary Guidelines for Americans” are misnamed, and that the current name is nothing less than false advertising. 

Frankly, I think it would help avoid at least some of the noise and nonsense we are all dealing with now if the distinction between the work of scientists and the meddling of politicians were clear, and if the “Dietary Guidelines for Americans” were called something more honest.  If you agree, please sign and share my petition for a name change. 

Moving on, now, to the noise and nonsense itself.

I happen to be writing this just after the publication of a commentary in the Annals of Internal Medicine, a prestigious journal, that declared the U.S. Dietary Guidelines (actually, The Dietary Guidelines for Americans, but why quibble) an “Evidence-free Zone.” There’s just one problem: the commentary was an Expertise-free Zone.

The author, a prominent cardiologist who has been enormously important to public health as a drug safety watchdog, has no work whatsoever related to nutrition.  In accord with what seems to be the unique disrespect our culture, apparently up to and including editors of peer-reviewed medical journals, has for nutrition- this commentary is roughly commensurate with asking, say, a dermatologist specializing in acne to write an expert critique of the latest advances in neurosurgery.

The result was entirely predictable. The commentary was overwhelmingly wrong, criticizing aspects of the Dietary Guidelines the author implied were current that had, in fact, been abandoned years ago- or never present at all in some cases. There was, as well, no distinction made between the actual work of nutrition experts, and the abuse of that work by politicians at the behest of lobbyists.

Finally, the author asserted, or at least strongly suggested, that we cannot reliably know anything about nutrition in those areas where we don’t have randomized controlled trials. This somewhat naively overlooks the often profound limits of RCTs themselves, as well as their relative inapplicability to certain important nutrition questions, including the big one: which specific diet is “best”?  I invite you to think about the study necessary to show, for instance, whether an optimal vegetarian diet, an optimal Mediterranean diet, or an optimal Paleo diet is “best” for human health outcomes over the course of a lifetime.  That said, there is a massive confluence of relevant evidence just the same, including, just not limited to, RCTs.

The commentary also overlooks how profoundly RCT results can mislead if misinterpreted by scientists themselves, or hyped by the media. Both happen all the time, sometimes with rather dire consequences.  Most importantly, though, the assertion about randomized trials is just wrong- for reasons obvious to all of us.  Anyone who knows that lightning can start a fire, and rain can put it out, has evidence that understanding- true understanding- is not always dependent on a randomized controlled trial.

The commentary as part of the larger context of nutrition disrespect is very worrisome.  If we carry this tendency to its logical conclusion, we will succeed in convincing the public that there are no experts and there is no expertise in nutrition, and so- they (you) shouldn’t listen to any of us.  At that point, you are simply putty in the hands of Big Food, who seem to know plenty about leveraging nutrition to stimulate your eating and generate profit.  It seems more than a bit odd that despite a complete absence of nutrition expertise to do good, the food industry owns the expertise to do harm, doesn’t it?  If it doesn’t make sense, don’t buy it.

I worry, though, that you may buy it- because selling it is the sport du jour. My aim is to call off the game, by pointing out, per my title, the good, the bad, and the ugly in the Dietary Guidelines- and attempt to leave you with some clarity about who, and what, you can trust. Read on for the Good, Bad, and Ugly.

 What’s Good

Almost everything about the DGAC report- certainly including the emphasis on sustainability.  It’s not perfect, of course, because humans were involved. But it is good, and more than good; it is excellent.

The criticisms, even by very good people with good intentions, have generally been quite misguided.  Consider, for instance, the protest over the DGAC Report conclusion that cholesterol should not be a focus.


The DGAC Report did NOT conclude that cholesterol is harmless, or should be eaten in limitless quantities, or that it cannot raise blood cholesterol in, say, vegans. The conclusion was simply that it does not constitute a current, clear, and present danger to the average American, since the average American is consuming cholesterol well below the recommended upper limit already.  All the DGAC said was that talking about cholesterol, per se, is not especially relevant or helpful, and thus does not warrant a shout out in the guidelines. 

Those concerned that this means cholesterol must be entirely innocuous might take comfort in the fact that the DGAC report did not recommend a shout out for mercury in our diets either. This is not because anyone thinks mercury is harmless, but simply because a focus on avoiding mercury in dietary guidance is not timely, not needed, and not helpful to the average American.

To my knowledge, nobody willfully ingests mercury, so perhaps we need a more realistic, and more mundane example, and the most mundane of all comes readily to mind, namely: mud. People with pica eat dirt and clay. The Dietary Guidelines are silent on the issue of clay ingestion. This is not because limitless mouths-full of daily clay would be harmless; quite the contrary.

Rather, it’s because fists full of dirt for breakfast is not a general, population-wide concern. If ever it becomes so, I fully expect the guidelines to keep pace, and address the matter.

The DGAC Report did not advise Americans to eat more eggs. Rather, the conclusion about cholesterol reduces simply to this: the average American does not require focused, dedicated guidance away from a dietary problem s/he doesn’t currently have.

So, too, with meat- albeit in the other direction. My Paleo colleagues might be right that antelope steaks or venison, as the modern approximations of Stone Age meat, might be a perfectly healthy element in the Homo sapien diet. But the typical American eating meat is not eating antelope; s/he is eating grain fed beef and slop-fed pigs, and processed variations on such themes. The advice to eat less meat was not made in the context of some Paleo fantasy world, but rather pertained- as well it should- to the real world, the real meat real people in it eat, and the real effects on both human health, and the health of the planet.

The DGAC Report got these, and just about everything else, right. As noted, it’s good. It’s very, very good.   It’s also in the public domain, endorsed by diverse, prominent nutrition experts; and in line with the principles supported by a coalition of experts and thought leaders from 30 countries. You may rely on it.


What’s Bad

Almost everything about a process that subordinates what expert public health scientists think is best for health to what politicians think should be done about it, and pretends they are the same.  Commentary by non-experts who don’t seem to recognize their lack of expertise. Commentary by those with an axe to grind who fail to note the axe they are grinding. 

I have considerable respect for some of the people and groups unhappy about details in the DGAC Report (and a lot less respect for some others). But even so, if they are honest, they are obligated to admit the prevailing pattern.

The high-profile nit picking is clearly motivated more by ideology than epidemiology. It’s not a coincidence that objections to lifting the cholesterol cap are coming from vegans, nor that a cabal that wants us all to eat more meat, butter, and cheese is the source of argument that the DGAC report was far too restrictive in those areas. 

Both of these plaintiffs, and others like them, cite bad methods by the DGAC to make their case.  But, let’s be clear. They only cite bad methods where they don’t like the conclusion. Shoddy methods should be objectionable across ideologies, not conveniently align with them. 

If it were really about the quality of methods, then objections would not so clearly align with established preferences. An advocate of eating eggs who happens to be an expert in research methodology should object to flawed methods whether or not the conclusion supports eating eggs.  We are seeing none of that.

All of the criticisms about the DGAC report correspond almost perfectly with the established preferences, priorities, and conclusions of those levying the charges- suggesting quite strongly there is no fundamental problem with methods; folks just don’t like specific aspects of the verdict. If shoddy methods were really an issue, then objections to the DGAC conclusions based on those shoddy methods would NOT be limited to those who would object to those conclusions NO MATTER WHAT the methods. 

Vegans object to egg consumption for many reasons, only partly based on the science of cardiovascular disease, and largely derived form ethical and environmental concerns. Those wanting us to eat more meat and already committed to that proposition, mostly because they’ve got profits on the line, have decided before ever looking at methods that a conclusion to the contrary has to be wrong.

These are not valid criticisms of methods by methodologists. These are folks unhappy with conclusions that differ from the opinions they own.

All such criticism is thus, in my opinion, a noisy distraction from the fundamental merit of the DGAC report, and thus: bad.

And ultimately, every difference between the 2015 DGAC Report, and the official Dietary Guidelines into which that good guidance was adulterated- is bad.


What’s Ugly

Just about everything that has happened since the DGAC report was first released.

We had excellent, science-based guidance.  We have assaulted it, abused it, amputated parts of it, mischaracterized it, and politicized it into virtual meaninglessness. In the process, we have undermined trust in devoted defenders of public health, and all played into the hands of those industries that profit from our befuddlement.  We are, in general, much fatter, sicker, and more confused about why than we should be- and somebody is chuckling about it all the way to the bank.

In the DGAC Report, we had a beautiful baby. Politics added a copious dose of dingy bathwater.  Failure to differentiate- is downright ugly.

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