The Center for a Livable Future
May 8, 2015
To the Dietary Guidelines Advisory Committee:
The Johns Hopkins Center for a Livable Future (CLF) is an interdisciplinary academic
center based within the Johns Hopkins Bloomberg School of Public Health. CLF investigates the
interconnections among diet, food production, public health, and environment.
We commend the Dietary Guidelines Advisory Committee (DGAC) for its recognition of
the importance of addressing environmental sustainability in the Dietary Guidelines, as part of its
Scientific Report to the Secretary of Health and Human Services and the Secretary of Agriculture.
On behalf of the Center for a Livable Future and 31 faculty, staff, CLF-Lerner Fellows, and
research assistants who have signed below, we are pleased to submit the following comment. The
DGA can and should guide American diets to promote individual and population health while
simultaneously promoting the sustained capacity of our food system to provide the healthy and
nutritious foods that should be available to all Americans, now and for future generations.
The DGAC’s consideration of sustainability in the context of population-level dietary
patterns is timely, scientifically rigorous, and appropriate to assure food security for present and
future generations. The CLF further endorses the scientific merit of the DGAC’s finding that, “a
dietary pattern higher in plant-based foods, such as vegetables, fruits, whole grains, legumes,
nuts, and seeds, and animal-based foods is more health promoting and is associated with lesser
environmental impact than is the current average U.S. diet.”[1] The DGAC’s finding reflects a
rigorous and comprehensive assessment of the latest peer-reviewed research in its Nutrition
Evidence Library, which it prepared in consultation with experts spanning nutrition, agriculture,
and environmental sciences.[1][2] The fifteen studies included in the DGAC’s review rely on
high-quality epidemiological, life cycle assessment, and mathematical modeling methods.
Additional peer-reviewed studies published since the close of the DGAC’s analysis support its
primary findings.[3-7]
This DGAC’s findings are consistent with a large and growing body of evidence that
indicates that less resource-intensive dietary patterns support optimal nutrition and reduce
greenhouse gas emissions, ecosystem harm, and land, water, and energy use. Our ability to meet
future food needs will depend on these critical environmental factors, particularly in the context
of climate change, resource shortages, changes in global dietary patterns, and population
growth.[13]
The DGAC’s findings are closely aligned with language included in the 2010 DGAC’s
Scientific Report: “Population growth, availability of fresh water, arable land constraints, climate
change, current policies, and business practices are among some of the major challenges that need
to be addressed in order to ensure that these recommendations can be implemented nationally.”[8]
The DGAC’s findings also match recent reports published by domestic non-governmental
organizations such as the Institute of Medicine, the Academy of Nutrition and Dietetics, and the
National Research Council.[9-12] The DGAC’s inclusion of sustainability additionally fits into a
tradition in which past advisory committees considered contextual factors related to dietary
guidance, such as food safety, food affordability, and sedentary behavior.[8]
Beyond our core recommendation that sustainability belongs in the Dietary Guidelines
for Americans, CLF is pleased to make the following more specific recommendations:
1. Emphasize the benefits of diets high in plant-based foods and low in animal-based
foods
2. Encourage a shift to more sustainable seafood consumption
3. Encourage a reduction in waste of food
We also strongly agree that federal dietary guidance should incorporate sustainability
messaging in its communication strategies and that these messages should be relayed through
related policy and programmatic activities.
The discussion below outlines our rationale and suggested strategy for each.
1) Emphasize the benefits of diets high in plant-based foods and low in animal-based foods
We support the DGAC’s recommendation that Americans increase consumption of plantbased foods and reduce intake of animal-based foods.
Rationale: The DGAC’s review of fifteen studies published between 2003 and 2014
indicates that a broad range of dietary patterns high in plant-based foods and low in animal-based
foods are more nutritious and sustainable than average dietary patterns in the U.S. and
elsewhere.[1] As noted in the DGAC’s report, a wide variety of dietary patterns meet these
criteria; this includes the Mediterranean Diet, vegetarian diets, guidelines-based diets, and other
diets low in animal-based foods. Diets high in plant-based foods provide essential amino acids,
antioxidants, phytochemicals, fiber, and appropriate amounts of the DGAC’s nutrients of concern
for under-consumption, including vitamins C and E, calcium, magnesium, potassium, and
folate.[14-15] The DGAC also found that sustainable dietary patterns are comparable to usual
dietary patterns in terms of affordability.[16-19] Importantly, the DGAC’s chapter on
sustainability neither calls for the elimination of any particular food group, nor does it advocate
for specific dietary patterns over others.
As per the DGAC’s report, the average American continues to consume significantly
more meat than recommended by previous U.S. Department of Agriculture guidelines despite
mounting evidence of the negative health and environmental impacts of our high-meat diet.[1]
The vast majority of these animal products are produced in a manner that places unsustainable
demands on finite resources and presents what the Pew Commission on Industrial Farm Animal
Production characterized as “…an unacceptable level of risk to public health and damage to the
environment.”[20]
A growing body of research suggests diets high in animal-based foods may be
nutritionally unhealthy. There is strong evidence from prospective studies and meta-analyses that
moderate to high consumption of red meat and/or processed meat is associated with risk of
ischemic stroke, heart failure, colorectal cancer, and hypertension.[21-26] In a recent doseresponse meta-analysis, red meat and processed meat consumption was significantly associated
with all-cause mortality.[27] In addition to these environmental and health impacts that threaten
current and future nutrition and food security, great risk is posed by the use of antimicrobial drugs
in livestock for purposes other than treating illness. Eighty percent of all antimicrobials sold in
the US are sold for use in animal agriculture.[28] Misuse of antimicrobials in animal agriculture
for purposes other than disease treatment contributes to the selection, generation, propagation and
spread of antibiotic-resistant bacteria, which can result in life-threatening infections in
humans.[29] Together, these findings support dietary guidance that promotes lower intake of
animal-based foods.
The substantial body of research referenced in the DGAC’s report relies on a variety of
high quality research methods. Several studies referenced in the DGAC’s report use robust
measures of health and nutrition, such as validated dietary indices (e.g., Brazilian Healthy Eating
Index, U.S. Department OF Agriculture’s Healthy Eating Index), widely-accepted indicators of
nutritional quality (e.g., energy density, levels of saturated fat and free sugars), and health
outcomes strongly associated with nutrition (e.g., modeled deaths delayed/averted, reduced risk
of cancer and chronic disease).[30-34] Similarly, environmental outcomes included in this body
of research rely on high-quality life cycle assessment and modeling methods.[35] The studies
included in the DGAC’s review demonstrate that food production and distribution methods
associated with healthier diets produce fewer greenhouse gas emissions, are more bio-diverse,
and require fewer land, water and energy resources.[1] These findings are important given the
high environmental cost of food production in the U.S. (i.e., 50% of the total US land area, 80%
of the fresh water, and 10% of the fossil energy).[36-37] Importantly, the DGAC’s findings
indicate that sustainable dietary patterns are comparable to usual dietary patterns in terms of
affordability.[38-41]
Strategies: We strongly encourage an emphasis on the benefits of dietary patterns high in
plant-based foods. To advance acceptance of the plant-based diet already recommended in the
2010 guidelines, we advise that the U.S. Department of Health and Human Services and the U.S.
Department of Agriculture use language and graphics that emphasize alternative protein sources,
especially protein sources that are lower on the food chain. Given that current consumption
drastically exceeds the RDA for protein, we urge the U.S. Department of Health and Human
Services and the U.S. Department of Agriculture to inform consumers that a plant-based diet can
provide adequate protein. To this end, we recommend that the new guidelines provide more
explicit guidance on how to adopt plant-based diets. Strategies such as eliminating meat one day
per week, as recommended by the Meatless Monday campaign among others, provide consumers
clear and simple steps to reduce meat consumption and consume more plant-based proteins.[53]
2) Encourage a shift to more sustainable seafood consumption
We commend the DGAC’s emphasis on sustainable seafood production in the context of
federal dietary guidance. The DGAC found that a wide variety of wild-caught and farm-raised
seafood is safe and nutritionally beneficial, and suggested that aquaculture products could be a
sustainable solution to the overfishing crisis. We note that there is great diversity in the
environmental sustainability of different aquaculture products, and recommend that federal
dietary guidance include messaging on how to choose sustainably produced seafood, particularly
species lower on the aquatic food chain and those associated with sustainable production
practices.
Rationale: We commend the DGAC’s consideration of seafood production methods in
terms of nutrition and contaminants. The DGAC’s report correctly notes that, “seafood
production is in the midst of rapid expansion to meet growing worldwide demand, but the
collapse of some fisheries due to overfishing in past decades raises concerns about the ability to
produce safe and affordable seafood to supply the U.S. population and meet current dietary intake
recommendations.”[1] This emphasis is critical, as current federal dietary recommendations to
more than double Americans’ seafood intake may dramatically reduce the availability of seafood
and threaten food security in the future. Wild caught seafood harvests peaked in the 1980s, and
currently 85% of the world’s fisheries are fully exploited, overexploited, depleted, or
recovering.[46] Some scientists predict that if current trends continue, humans could completely
overfish the oceans by 2048.[47] Aquaculture, or farmed seafood, has rapidly emerged as a viable
alternative, growing at an average rate of 8.8% from 1980-2010.[46]
Approximately half of the seafood consumed in the US and around the globe comes from
aquaculture. However, aquaculture includes a vast array of production methods and species,
which may have significant impacts on marine ecology, food safety, food security, and public
health. Many current fishing practices are unsustainable, and recommending increased seafood
consumption with no guidance on sustainable choices could further contribute to these problems
and lead to drastic decreases in the amount of wild-caught seafood for human consumption in the
future. Encouraging Americans to eat lower on the aquatic food chain more often would be better
for sustainability, and in the future, fish lower on the food chain may be the only species
remaining in the oceans. In addition, because contaminants bio-accumulate, fish lower on the
food chain also have lower levels of contaminants.[48] To ensure future generations’ access to a
variety of seafood, dietary guidelines must include information on how seafood choices impact
sustainability and food security for future generations.
Strategies: 1. Advise consumers to choose products lower on the aquatic food chain such
as shellfish, sardines, anchovies, and herring. Refrain from recommending species that are
associated with harmful fishing or farming practices (e.g., bottom trawling or dredging, largescale near- and off-shore finfish farming). 2. Distinguish between farmed and wild seafood,
including in any tables and figures, and provide information on practices that threaten or promote
health and ecological sustainability; 3. Present seafood consumption advice developed in
consultation with experts in the fields of fisheries, aquaculture, and environmental health to
ensure that the recommendations are realistic and achievable based on current aquatic food
resources and trends; and 4. Provide links to references and guides on wild and farmed seafood
for consumers to seek additional information on this complicated topic (i.e., NOAA FishWatch
and/or Monterey Bay Aquarium Seafood Watch).
3) Encourage reduced waste of food
Although the DGAC’s report did not include a major recommendation about addressing
wasted food, CLF believes the impacts for food security are sufficient to merit additional
attention in the final Dietary Guidelines. In addition, CLF supports the DGAC’s recommendation
to “Develop a robust understanding of how production practices, supply chain decisions,
consumer behaviors, and waste disposal affect the environmental sustainability of various
practices across the U.S. Department of Health and Human Services and the U.S. Department of
Agriculture food components of MyPlate.”[1] There is also a need for action based on that
understanding.
Rationale: In the United States, 31 to 40 percent of all food produced is wasted from
farm to fork.[42-43] This waste increases the costs of a healthy diet & reduces food security.
Current dietary guidelines may unintentionally contribute to consumer behaviors related to food
waste by inspiring Americans to purchase more produce than they can realistically eat.[44]
Dietary Guidelines can play a role in reducing this source of food waste, while still improving
diet quality. Dietary guidelines that include specific recommendations to help consumers reduce
food waste are consistent with existing U.S. Department of Agriculture efforts to address food
waste, including through the joint U.S. Department of Agriculture/Environmental Protection
Agency Food Waste Challenge.
Strategies: We suggest placing a statement about avoiding food waste on the main
dietary guidelines graphic, and having additional available information that emphasizes the
following messages: 1. Plan in advance: Consumers should be advised that planning meals and
snacks prior to shopping is beneficial not only for reducing waste (and reducing unnecessary
impulse purchases of less-healthy foods) but also for helping consumers to adhere to their dietary
intentions and save money. 2. Be realistic: The guidelines should advise consumers that even as
they seek to increase their consumption of produce, they should still be realistic -- plan in
advance and shop intentionally. Further, they can be reminded to think realistically before making
bulk purchases such as at superstores, and to recognize that an apparent money-saver can lead to
money lost if they cannot use the food before it spoils. 3. Use what you have: The guidelines
should advise consumers to save money and food by “shopping their refrigerator first.” They
should be aware of what food they have on hand and what is close to spoiling or losing appeal. 4.
Use frozen and canned foods: Consumers can be reminded that if they will not be able to eat
foods soon enough, many foods can be frozen and saved for a later date. Purchasing frozen and
canned foods to supplement fresh purchases helps assure produce is available when needed while
reducing the chance of spoilage. 5. Watch portion sizes: Another sound dietary strategy that also
helps reduce food waste is encouraging attention to portion sizes. In restaurants, eating meals of
appropriate size provides the opportunity to take home leftovers for an extra “free” meal. 6.
Ignore sell-by dates: Many consumers are confused about the meaning of sell-by and use-by dates
on food packages.[45] Clear guidance could help consumers reduce waste while maintaining
appropriate food safety.
Additional consumer-level waste prevention strategies are available on the U.S.
Department of Agriculture website (http://www.U.S. Department of
Agriculture.gov/oce/foodwaste/resources/consumers.htm) and elsewhere. To help motivate these
and other waste prevention strategies, the DG could share information with consumers about the
average amount of money thrown in the trash through food waste – about the equivalent of
$1,560 per family of four and $165 billion in the US in total, annually.[42] For implementation, it
could be valuable to create educational materials on reducing food waste to help consumers,
nutrition educators, schools, and those working with recipients of federally funded food
assistance programs.
In addition to the above recommendations, we urge the U.S. Department of Health and
Human Services and the U.S. Department of Agriculture to remind consumers that minimallyprocessed and -packaged foods do double-duty in working towards individual health and the
health of future food systems. The U.S. Department of Health and Human Services and the U.S.
Department of Agriculture might adopt language and strategies similar to those used in Brazil’s
draft dietary guidelines, which urge consumers to choose fresh and staple foods.
Conclusion
We strongly support the DGAC’s conclusion that, “linking health, dietary guidance, and
the environment will promote human health and the sustainability.” The DGAC’s findings are
consistent with a substantial body of science that illustrates the synergies between healthy dietary
choices and a sustainable food system. Diet is one part of a larger system of environmental,
social, and economic sustainability. The guidelines have the power to inform Americans of how
their food choices impact food security and environmental sustainability for future generations.
The nutrition of our children and grandchildren depends on us getting it right today and
continuing to do so tomorrow. For additional information and/or assistance with incorporating
messages to improve the sustainability of individual diets into the dietary guidelines, please
contact Roni Neff, PhD, MS, at [email protected] or (410) 614-6027.
Sincerely,
Robert S. Lawrence, MD
Center for a Livable Future Professor
Professor of Environmental Health Sciences, Health Policy, and International Health
Johns Hopkins Bloomberg School of Public Health
Shawn Mackenzie, MPH
Associate Director, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Roni Neff, PhD, MS
Program Director, Food System Sustainability and Public Health, Center for a Livable Future
Assistant Scientist, Department of Environmental Health Sciences
Johns Hopkins Bloomberg School of Public Health
Sameer Siddiqi, BS
Doctoral Student, Department of Health Policy and Management
Research Assistant, Food System Sustainability and Public Health, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Robert Martin
Program Director, Food System Policy, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Anne Palmer, MA
Program Director, Food Communities and Public Health, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Mark Winne, MS
Senior Advisor, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Pamela Rhubart Berg, MPH
Education Program Manager, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Claire Fitch, MSPH
Program Officer, Food Systems Policy, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Elena Broaddus, MSPH
Doctoral Student, Department of International Health
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Raychel Santo, BA
Program Coordinator, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Julia Wolfson, MPP
Doctoral Student, Department of Health Policy and Management
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Allison Righter, MSPH, RD
Program Officer, Food Communities and Public Health Program, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Ryan Lee, MHS
Doctoral Student, Department of Health, Behavior and Society
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Marie Spiker, MSPH, RD
Doctoral Student, Department of International Health
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Angela Smith, MA
Project Advisor, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Natalie Reid, MPH, MBA
Doctoral Student, Department of Health Policy and Management
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Karina Christiansen, MPP
Doctoral Student, Department of Health Policy and Management
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Margaret Burke, MA
Sr. Academic Program Coordinator, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Sarah Rodman-Alvarez, MPH
Doctoral Student, Department of Health Policy and Management
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Carrie Burns, MSPH
Sr. Project Coordinator, Food System Mapping, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Megan L. Clayton, MPH, PhD
Department of Health, Behavior and Society
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Jillian P. Fry, PhD, MPH
Project Director, Public Health and Sustainable Aquaculture Project, Center for a Livable Future
Assistant Scientist, Department of Environmental Health Sciences
Johns Hopkins Bloomberg School of Public Health
Philip McNab, MPH, MA, CPH
Department of Health, Behavior and Society
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Yukyan Lam, JD
Doctoral Student, Department of International Health
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
Amanda Buczynski, MPH, MS
Senior Program Officer, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Caitlin Fisher, MPH
Data Specialist, Food System Mapping, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Leo Horrigan, MHS
Food System Correspondent, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Alana Ridge, MPH, CPH
Program Officer, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Kate McCleary, MS, CHES
Senior Project Coordinator, Center for a Livable Future
Johns Hopkins Bloomberg School of Public Health
Benjamin Davis, BA
Doctoral Student, Department of Environmental Health Sciences
Center for a Livable Future-Lerner Fellow
Johns Hopkins Bloomberg School of Public Health
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