Comments: USDA Food Guidance System Reassessment Team

by Saurabh F. Dalal

Thank you for the opportunity to voice our comments in an area of tremendous importance: the update of the Food Guidance System to educate the public on healthy diets and lifestyles. These comments are presented on behalf of three non-profit organizations:

The International Vegetarian Union (www.ivu.org)
The Vegetarian Union of North America (www.ivu.org/vuna)
The Vegetarian Society of DC (www.vsdc.org)

Vegetarian foods offer powerful advantages and are best for humans. So many studies have shown, and proven, the remarkable health benefits of a vegetarian diet. Animal products are the main source of saturated fats and the only source of cholesterol in the diet. Animal products contain no fiber and we know fiber helps reduce cholesterol levels. We claim that a well-planned, low-fat vegetarian diet - actually a vegan diet where no animal products whatsoever are consumed - is the best diet for humans. Preventing and actually reversing heart disease, preventing certain cancers, preventing and reversing diabetes, lowering blood pressure, and helping manage weight are some of the successes of such a diet, and there are many many more.

The American Dietetic Association in its 2003 position paper on vegetarian diets states:

Well-planned vegan and other types of vegetarian diets are appropriate for all stages of the life cycle, including during pregnancy, lactation, infancy, childhood, and adolescence. Vegetarian diets offer a number of nutritional benefits, including lower levels of saturated fat, cholesterol, and animal protein as well as higher levels of carbohydrates, fiber, magnesium, potassium, folate, and antioxidants such as vitamins C and E and phytochemicals. Vegetarians have been reported to have lower body mass indices than nonvegetarians, as well as lower rates of death from ischemic heart disease; vegetarians also show lower blood cholesterol levels; lower blood pressure; and lower rates of hypertension, type 2 diabetes, and prostate and colon cancer.

The Unified Dietary Guidelines developed by the American Cancer Society, the American Heart Association, the National Institutes of Health, and the American Academy of Pediatrics call for a diet based on a variety of plant foods, including grain products, vegetables, and fruits to reduce the risk of major chronic diseases.

And your group, the USDA in its 5^th ed of the Dietary Guidelines for Americans in 2000, states: "Vegetarian diets can be consistent with the Dietary Guidelines for Americans, and meet Recommended Dietary Allowances for nutrients." They give recommendations on meeting nutrient requirements for those who choose to avoid all or most animal products.

Support for vegetarian diets is established and strong. Contrast this to the trends with animal-based food today: high in saturated fats, trans fats, cholesterol, and food contaminants and the results are heart disease, cancers, strokes, diabetes, obesity, and food illnesses.

If the Food Guide Pyramid is to continue to emphasize specific nutrients, as in the cases of calcium and protein, represented by the Milk (etc) Group and Meat (etc) Group, then the updated pyramid and graphic could demonstrate the above important positions by illustrating plant foods and meat/dairy alternatives more prominently. The groups should be renamed something akin to the Calcium (etc) Group or the Protein (etc) Group. Not only can plant products provide calcium and protein along with all the nutrients needed, they are typically lower in saturated fats and contain no cholesterol. Plant foods are then indeed better sources.

The Food Guide Pyramid could alternatively be updated without emphasizing food groups for any specific nutrient like for calcium or protein. Then a broad variety of plant foods consisting of whole grains, whole fruits, vegetables, legumes, nuts, seeds, and fortified cereals and juices can be depicted to help ensure a healthy, well-balanced diet - more in-line with the way the lower two levels of the pyramid are today with the Bread (etc) Group as well as the Fruit Group and Vegetables Group. An emphasis on consuming a wide variety of plant foods would take care of all nutrients being included in the diet.

The key is removing the emphasis on animal derived foods in favor of plant foods, with a well-represented vegan diet being optimal.

A few reminders on nutrition and health specifics:

1. A diet drawn from varied plant sources easily satisfies protein requirements, without the potential for protein excess. Plant sources provide all essential amino acids, even without intentional combining or "protein complementing" as long as calorie intake is adequate. Good protein sources include cooked beans, tofu, soy yogurt, tempeh, seitan, nuts, seeds, and whole grains. Soy protein has been shown to be nutritionally equivalent in protein value to proteins of animal origin.

2. Many plant-based sources of calcium exist. Examples are fortified soy or rice milk, fortified juices like orange, cranberry, or apple juice; dark leafy greens like collard greens, mustard greens, turnip greens, kale, broccoli; blackstrap molasses; tofu processed with calcium sulfate, and tempeh. The more extensive range of dietary sources of calcium from plant foods would increase intakes of boron, vitamin K, and magnesium, helping reduce the risk of osteoporosis.

Let's not forget that calcium absorption and bio-availability from these foods has been shown to be excellent, better than dairy foods.

Also very important is that each serving of these plant-based sources of calcium also counts towards choices from one of the other food groups, e.g. cooked leafy green vegetables count as a serving from the calcium-rich foods group AND in the vegetable group. This is an added benefit, showing the versatility and benefit of plant-based foods.

3. Animal products force calcium out of the body and so promote bone loss. Again well-planned vegetarian diets can yield a lower risk for osteoporosis.

4. Iron is plentiful in beans, whole grains, and fruits.

5. Flax seeds are an excellent source of omega 3's whereas fish and consumption of other sea animals have the downside of potential mercury content, other contaminants, and significant cholesterol.

Now a few broad observations:

1. Eating patterns are changing and the diets of a great many are more plant-based than a decade ago, including vegetarians (with a proportionately high % of vegans), and many quasi-vegetarians. There is tremendous interest around vegetarianism and the USDA guidelines must address the needs of those moving away from animal products.

2. The eating patterns of many people who do not use milk and dairy products, for ethnic, health, and/or ethical reasons, need to be reinforced by guidance that is more comprehensive in terms of alternatives to animal foods.

3. In the greater societal context, what's better for the individual in terms of vegetarian foods is also what's best for the health of the country and planet. The key characteristics are natural, healthy, sustainable, and economically viable. We must look at our system of food production with its enormous inefficiencies and the tremendous toll it takes on people, increasingly scarce resources, and the living world around us. Let's favor the 12-16 pounds of grain instead of the 1 pound of beef that results; let's favor 25 gallons of water for 1 pound of wheat rather than over 5000 gallons needed for 1 pound of beef; let's favor 40,000 pounds of potatoes on 1 acre of land instead of 250 pounds of beef on that same acre; let's favor soybeans that are 38 times more energy efficient than beef - the numbers are truly this staggering and these are just a few facts to give an indication.

We represent many people, growing greater and greater in numbers, throughout this city, and this country as well as around the world that believe that a simpler, wholesome, well-planned, vegetarian diet that consists of no animal products is the right type of guidance to establishing healthy eating habits through the daily selection of foods. Let's make sure we're doing our utmost to make the lives of our citizens far better and also recognizing and improving on the way we impact the world, and in turn, ourselves.

We urge the Reassessment Team to incorporate even more vegetarian foods, specifically a well-planned, low-fat, vegan diet, with its remarkable benefits in all respects, as you update the Food Guidance System including the Pyramid, and the Dietary Guidelines for Americans.

THANK YOU FOR YOUR CONSIDERATION.

Sincerely,

Saurabh F. Dalal

Secretary, The International Vegetarian Union (www.ivu.org)
Secretary, The Vegetarian Union of North America (www.ivu.org/vuna)
President, The Vegetarian Society of DC (www.vsdc.org)