June 9, 2020
SUBMITTED ONLINE
https://www.regulations.gov
Kristin Koegal
USDA Food, Nutrition and Consumer Services
Center for Nutrition Policy and Promotion
Braddock Metro Center II
1320 Braddock Place, Room 4094
Alexandria, VA 22314
Re: 2020 Dietary Guidelines for Americans; Docket ID: FNS-2019-0001
Dear. Ms. Koegal:
I am writing to thank you for working on the 2020 Dietary Guidelines and to submit these comments on behalf of Farm Sanctuary and our 1.2 million members and constituents.
The food we ingest has profound impacts on our health and wellbeing, and sadly, the food we consume across the U.S. is making us sick. This is especially true among lower income communities who disproportionately lack access to wholesome food.¹ Our nation’s agriculture system produces massive quantities of cheap food that is high in calories but deficient in nutrients, and this contributes to diet-related illnesses that cost billions of dollars in health care costs every year.² In addition, the irresponsible overuse of antibiotics in animal agriculture leads to the development of antibiotic resistant pathogens, which can render lifesaving drugs useless in treating human infections.³
The scientific evidence is clear and shows that our nation’s health is being undermined by eating too many processed foods and excessive quantities of animal products and by consuming too few fruits, vegetables, legumes and other whole plant foods that are rich in fiber and other valuable nutrients.⁴ The 2020 Dietary Guidelines can help improve our nation’s health, while also incentivizing necessary reforms in U.S. agriculture, by encouraging a shift toward a whole food plant based diet. Accordingly, we urge the Dietary Guidelines Advisory Committee to recommend increased consumption of whole plant foods and to discourage the intake of meat, dairy, eggs, and processed foods.
Hippocrates, the founder of western medicine, advised, “Let food be thy medicine and medicine be thy food.” This guidance has never been more pertinent, especially with overwhelming evidence pointing to the deleterious consequences of our unhealthy food system, which contributes to elevated rates of hypertension and cardiovascular disease, obesity, diabetes, certain cancers, and other food-borne illnesses that sicken and kill millions of Americans every year. Addressing this, a growing number of doctors and health care professionals are using dietary interventions instead of drugs to prevent and reverse chronic illnesses that have plagued our nation.⁵ The 2020 Dietary Guidelines should support this evidence-based approach and lifestyle medicine, which is successfully treating disease through whole foods plant based diets.
The Dietary Guidelines are also important for how they influence food assistance programs, which serve low-income communities who are experiencing higher rates of diet related illness. Health disparities and high-risk populations have become more visible amid the COVID 19 pandemic, which has killed disproportionately more nonwhite Americans because of food induced risk factors and vulnerabilities.⁶
The Dietary Guidelines should recommend and ensure that all Americans eat healthy and nutritious food, instead of empty calories.
Supporting the dairy industry and the consumption of cows’ milk through public food programs is also problematic, since a large percentage of the population, especially among people of color, experience health maladies when they consume dairy due to lactose intolerance.⁷ It is not healthy or appropriate for government mandated food programs, whether in schools or otherwise, to promote the consumption of cows’ milk. Too often, food assistance programs have been used to distribute dairy and other surplus products, serving the interests of agribusiness at the expense of public health.⁸
Industrialized animal production also poses risks to workers and people who live near factory farms. During the COVID 19 pandemic, U.S. slaughterhouses were disease hotspots with thousands of workers infected, and slaughter lines forced to shut down.⁹ Citizens in neighborhoods with CAFOSs (confined animal farming operations) have long reported health concerns associated with toxic pollution, including fecal waste and pathogens that can spread in the environment.
For decades, the meat, dairy and egg industries have wielded undue political influence and obtained preferential treatment in government policies and programs.¹0 Along with exemptions from laws that protect animals, people and the environment, the industry also receives government subsidies amounting to billions of dollars every year, including through food assistance programs.¹¹ This approach is undermining our country’s wellbeing, and it needs to be reformed.
The 2020 Nutritional Guidelines should prioritize the health of our nation over the profits of agribusiness. Accordingly, we urge the Nutritional Guidelines Advisory Committee to incorporate sound science into their recommendations and to encourage U.S. citizens to shift toward eating a whole foods plant based diet.
Thank you for your time and thoughtful consideration.
Sincerely,
Gene Baur
President & Co-Founder
Farm Sanctuary
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¹Dutko, Paula, Characteristics and Influential Factors of Food Deserts, www.usda.gov, June 9, 2020, available at
https://www.ers.usda.gov/webdocs/publications/45014/30940_err140.pdf
²Nesheim MC, Oria M, Yih PT, June 17, 2015, Committee on a Framework for Assessing the Health, Environmental, and Social Effects of the Food System; Food and Nutrition Board; Board on Agriculture and Natural Resources; Institute of Medicine; National Research Council; National Academies Press https://www.ncbi.nlm.nih.gov/books/NBK305175/
³Michael J. Martin, MD, MPH, MBA, Sapna E Thottathil, PhD, and Thomas B. Newman, MD, MPH, Antibiotics Overuse in Animal Agriculture: A Call to Action for Health Care Providers; Am J Public Health. December 2015; 105(12): 2409–2410.
⁴Joel Fuhrman, MD, The Hidden Dangers of Fast and Processed Food, Am J Lifestyle Med. 2018 Sep-Oct; 12(5): 375–381
⁵Philip J Tuso, MD, Nutritional Update for Physicians: Plant-Based Diets; Perm J. 2013 Spring; 17(2): 61–66.
⁶Centers for Disease Control and Prevention, COVID-19 in Racial and Ethnic Minority Groups; www.cdc.gov; Accessed on June 9, 2020. https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/racial-ethnic-minorities.html
⁷Rebecca A Lapides and Dennis A Savaiano, Gender, Age, Race and Lactose Intolerance: Is There Evidence to Support a Differential Symptom Response? A Scoping Review, Nutrients. 2018 Dec; 10(12): 1956.
⁸Anahad O’Connor, How the Government Supports Your Junk Food Habit. www.nytimes.com, accessed June 9, 2020, https://well.blogs.nytimes.com/2016/07/19/how-the-government-supports-your-junk-food-habit/
⁹Eric Slosscher, America’s Slaughterhouses Aren’t Just Killing Animals, www.theatlantic.com, accessed June 9, 2020, https://www.theatlantic.com/ideas/archive/2020/05/essentials-meatpeacking-coronavirus/611437/
¹0 Markham Heid, Experts Say Lobbying Skewed the U.S. Dietary Guidelines, www.time.com, Accessed June 9, 2020, https://time.com/4130043/lobbying-politics-dietary-guidelines/
¹¹Arthur Allen, U.S. touts fruit and vegetables while subsidizing animals that become meat, www.washingtonpost.com, accessed on June 9, 2020 https://www.washingtonpost.com/national/health-science/us-touts-fruit-and-vegetables-while-subsidizing-animals-that-become-meat/2011/08/22/gIQATFG5IL_story.html