May 8, 2015

Secretary Tom Vilsack
U.S. Department of Agriculture
1400 Independence Ave. SW
Washington, DC 20250
Secretary Sylvia Mathews Burwell
U.S. Department of Health and Human Services
200 Independence Ave. SW
Washington, DC 20201
Dear Secretaries Vilsack and Burwell:
Thank you for the opportunity to comment regarding Docket No. 2015-03552: Announcement of the Availability of the Scientific Report of the 2015 Dietary Guidelines Advisory Committee.
The North Dakota Stockmen’s Association is an 85-year-old trade organization representing more than 3,000 cattle-ranching families in our state – families committed to producing the safest, most nutritious and affordable beef products in the world. Cattle producers take their role in producing safe and wholesome beef very seriously, and have a long history of supporting nutrition research to address the needs of consumers who enjoy beef as part of a healthy and balanced diet.
The Stockmen’s Association was disappointed that, despite overwhelming scientific evidence indicating that lean red meat plays an important role in a healthy dietary pattern, the Advisory Committee failed to review strong evidence from gold standard studies like the Beef in an Optimal Lean Diet (BOLD) study. The BOLD study was published by the American Journal of Clinical Nutrition in 2012. Additionally, we were disappointed that the Advisory Committee made the decision to remove lean meats from the overall message of a healthy dietary pattern for Americans in its recommendations, reducing their mention to a mere footnote in the report. Both the 2010 Dietary Guidelines for Americans and the 2010 Advisory Committee recognized the important role lean red meat contributes to a healthful diet as being a nutrient-rich food Americans should increase. Since the 2010 Dietary Guidelines for Americans were published, nutritional studies such as the BOLD study and at least 10 other randomized controlled trials have shown that balanced diets with 4 to 5.5 ounces of lean beef daily improve health. The current Advisory Committee, however, chose to base its conclusions on outdated and weaker forms of evidence and disregarded significant scientific evidence that supports the inclusion of lean red meat as part of a healthy dietary pattern.
It is important to note that the Advisory Committee endorsed a Mediterranean-style diet as a dietary pattern for Americans to consider, yet did not translate the dietary pattern consumed in the evaluated Mediterranean studies into its recommendations. Recommending that Americans further reduce their red meat intake to achieve a healthy dietary pattern directly contradicts with the evidence reported by the Advisory Committee. Based on the evidence reviewed, red meat recommendations in the Healthy Mediterranean-style Pattern should be increased within calorie limits. Therefore, Americans should be encouraged to choose lean red meat more often – not less – as part of a healthy dietary pattern. In the past, advising people to cut back on their red meat intake has resulted in harmful consequences: Americans are consuming more empty calories and obesity rates have steadily increased. Additionally, a reduce-red-meat recommendation can have adverse health outcomes for young females and other age groups who do not eat enough meat to meet their high-quality protein and iron recommendations. A general population message could be misinterpreted by age groups already underconsuming meat. These are situations we should work very hard to avoid.
The Stockmen’s Association was also disappointed that the 2015 Advisory Committee included topics beyond its scope of nutrition and health expertise in its final report. While the beef industry has a great story to tell in terms of its sustainability, as evidenced by results from the Beef Industry Lifecycle Assessment, the most detailed examination of a commodity value chain ever completed, it is inappropriate for the Advisory Committee to base its recommendations on information outside its health and nutrition charge and know-how. Clearly, the Advisory Committee does not have the background or expertise to evaluate the complex relationship between food production and the dietary needs of a growing American and international population. The major findings in the report regarding sustainability do not take into account the multi-faceted disciplines with proper expertise to develop a framework that includes environmental and animal scientists among many other experts. It is not appropriate for the Advisory Committee to provide recommendations on a topic like sustainability, where much of the research is in development and outside of its expertise and in which there is not an established, agreed-upon definition of “sustainability.” The Dietary Guidelines are intended to address nutrition and should strictly adhere to this singular focus.
It should be noted that the beef industry has made great strides in improving its product and responding to consumers’ requests for leaner beef over time. Since the Dietary Guidelines for Americans were first issued in 1980, for example, external fat on retail beef cuts has decreased by an impressive 81 percent. Similarly, total fat has been reduced by 44 percent, and more than 30 cuts of beef are now considered “lean” by the government’s own standards. Currently, total beef consumption contributes just 5 percent of the total calories and 10 percent or less of the total and saturated fat in American diets. The conclusions in the Advisory Committee’s report with respect to lean meat are inconsistent with more than three decades of scientific evidence on the benefits of lean red meat in healthy diets. The recommendations are also in direct conflict with all previous editions of the Dietary Guidelines for Americans, and, therefore, need attention.
The Stockmen’s Association urges your agencies to finish the scientific review of red meat’s role in a healthy diet; reinstate the recommendations related to lean meat from the 2010 Dietary Guidelines; and reject recommendations based on subjective information outside the Advisory Committee’s health and nutrition charge.
Lean beef is a delicious and healthy food choice. Naturally nutrient-rich, beef helps people get more essential nutrients, like zinc, iron, protein and B-vitamins, just to name a few, in fewer calories. Beef plays a critical role in health – helping maintain a healthy weight, sustain weight loss and cognitive health, build muscles and healthy bones, heal wounds, maintain the immune system, promote healthy skin and nerves, aid digestion, and reduce heart disease, among other things. What’s even better is that beef tastes great, and Americans can achieve their health and nutrition goals by eating a food that tastes great and that they love.
The Dietary Guidelines is a guiding document for Americans. Consumers deserve accurate information that reflects the latest nutrition evidence so that they can make sound decisions regarding food choices for themselves and their families. Anything less is a disservice that will send the wrong message to consumers and negatively affect the health of our nation for generations.
Please consider our comments and the changes we suggested above as you finalize the 2015 Dietary Guidelines for Americans.
Thank you for this opportunity to comment. Feel free to contact our office at (701) 223-2522 if you have any questions.
Steve Brooks