U.S. Dietary Guidelines: Our Public Comments

Posted May 21st, 2015

Every five years, the U.S. Department of Health and Human Services (HHS) and the U.S. Department of Agriculture (USDA) jointly publish a new edition of the Dietary Guidelines for Americans. A new edition is due out in December 2015.

The Dietary Guidelines provides advice for making food and physical activity choices that promote good health, a healthy weight, and help prevent disease for Americans ages 2 years and over, including Americans at increased risk of chronic disease. The recommendations are based on a rigorous review of relevant scientific evidence. The Dietary Guidelines serves as the cornerstone for all federal nutrition education and program activities.

As part of its development, a Dietary Guidelines Advisory Committee (DGAC) of third-party nutrition experts reviewed the latest scientific research and recently issued a report of recommendations [link: http://www.health.gov/dietaryguidelines/2015-scientific-report/]. The HHS and USDA are reviewing those recommendations and accepting public comments as they begin to consider what the Dietary Guidelines for Americans 2015 should say.

To that end, last week the Almond Board of California (ABC) submitted public comments on three topics – fat, dietary patterns and sustainability – based on current research into the health benefits of almonds. Here’s some of what we said.

On Fat

The DGAC notes in its report that Americans consume too much saturated fat (SFA); “from 67 percent to 92 percent of females and from 57 percent to 84 percent of males consume more than 10 percent of calories from SFA.”[1]

ABC supports the DGAC recommendation that sources of saturated fat should be replaced with unsaturated fat. Almonds have 13 grams of unsaturated fats including 9 grams of monounsaturated fatty acids (MUFA) and only 1 gram of saturated fat in a 1 ounce serving. Almonds can be used in place of other foods higher in saturated fat to help Americans decrease the amount of saturated fat they eat.

Almonds can also play a role in supporting heart health due to their high concentration of monounsaturated fatty acids. While recognizing the need for future research to examine the effects that replacing saturated fat with monounsaturated fat has on cardiovascular disease risk, a number of studies demonstrate the role of plant-based monounsaturated fats in heart disease risk reduction, including 17 studies on the heart health benefits of almonds supported by ABC.

On Dietary Patterns

The 2015 DGAC placed more emphasis on healthy eating patterns and less on individual foods. The USDA defines three eating styles including the “Healthy U.S.-style Pattern,” the “Healthy Mediterranean-style Pattern,” and the “Healthy Vegetarian-style Pattern.” While almonds are a nutrient-dense food on their own, they can also contribute to meeting recommendations for food group intake in each of these USDA Food Patterns as source of vegetable protein and oils.[2]

The DGAC recognizes tree nuts role in a healthy diet, by concluding, “Consistent evidence indicates that, in general, a dietary pattern that is higher in plant-based foods, such as vegetables, fruits, whole grains, legumes, nuts, and seeds, and lower in animal-based foods is more health promoting and is associated with lesser environmental impact than is the current average U.S. diet.”[3] Specifically, almonds are naturally low in sodium and an important source of protein (6 g/oz.), monounsaturated fats (MUFA), fiber, vitamin E, calcium, magnesium, potassium, and several trace minerals[4] and almonds are also among the top 100 richest sources of polyphenols,[5] including proanthocyanidins, flavonoids, and phenolic acids.[6]

On Sustainability[7]

The DGAC noted that future dietary guidance should reflect both the nutrition and human health aspects of the diet as well as the optimization of natural resources and minimization of environmental impacts. In addition to providing nutrients Americans need and delivering benefits that support the health of the population, almonds are also a sustainable commodity.  Achieving sustainability takes individualized care and consideration of resources, so we have contributed to these efforts by investing $2 million a year to research production and environmental issues to continually evolve best practices. The steps we’ve taken to ensure a sustainable crop include the following:

Established in 2009, the California Almond Sustainability Program (CASP) is a self-assessment program which helps growers to evaluate their own orchard practices, based on the past 40 years of grower innovation and research supported by the ABC, the University of California and the USDA. The data collected from these assessments allows ABC to document and quantify sustainable practices in four main areas:  Energy, Air Quality, Water (usage and quality) and Land (nutrient management, pest management and bee health). To date, there have been more than 1,000 individual participants, with more than 600 orchards and 100,000 acres assessed; the farming operations participating represent approximately one-third of California’s acreage.

Overall, the CASP program confirms that California almond growers have been leaders particularly in conserving water. Almonds occupy 12 percent of California’s irrigated farmland, but only use 8 percent of its agricultural water[8] and CASP has helped almond growers reduce water use by 33 percent in the last two decades. Most almond growers conserve water by using efficient irrigation practices, including the proper scheduling of irrigation and optimal maintenance of irrigation system infrastructure. A majority of almond growers also minimize the chances of contamination of water resources by nitrate and pesticides by effectively combining irrigation and fertilization, and by implementing cultural pest controls, such as removing nuts remaining on trees during the winter. More than 70% of assessed almond orchards conserve and protect water by having micro-irrigation systems, despite the significant capital investment it requires. 

Starting in 2010, the Almond Board has funded a study lead by University of California researchers into the greenhouse gas (GHG) emissions and energy footprint of our industry. The Life Cycle Assessment (LCA) of California Almond Production Phase 1 (2010-2014) is focused on conducting California-specific assessments of climate impact and energy use of almond production in California from nursery to farm gate, instead of relying solely on global calculations of climate footprints from food products.

Using an LCA approach to assess energy use and greenhouse gas emissions in almond production, the study shows that energy production from almond waste biomass (prunings and cleared trees) has the potential to further improve the environmental performance of almond production systems, and even make the almond industry carbon neutral, or carbon negative, if fully exploited. Almond production systems in California have the potential to contribute to global CO2 sequestration and carbon-neutral energy production. It is likely that many individual almond production operations where certain conditions for biomass-based electricity cogeneration are met, may already be greenhouse gas negative.

In Stage 2, this research will look at almond processing and distribution -- from farm gate to consumer. That work is ongoing.

ABC scientific staff and its external Scientific Advisory Panel are also currently evaluating how best measure the complex relationships between the environmental and health effects for almonds in the U.S. food system for California almonds. This baseline knowledge is needed as there is currently no generally agreed upon framework for assessing the health, environmental and social effects of the food system.[9]

More information about this research is available through the UCD Agricultural Sustainability Institute website: http://www.sarep.ucdavis.edu/sfr/almond-study.

Since 1995, ABC has invested almost $1.6 million in bee health research -- more than any other U.S. crop. These investments leverage additional research dollars from other groups, government agencies and universities. Additionally, ABC works with Project Apis m. and others to encourage almond growers to provide blooming plants or bee pastures as additional sources for honey bees prior to and after almond bloom. ABC research has been able to improve bee health by improving honey bee genetic stock to better manage Varroa mite (a parasite mite) and supporting the development of a nutritional supplement to ensure adequate nutrition when sources of pollen are low. More recently, ABC has received praise from leading bee health experts based on published Honey Bee Best Management Practices.

The full text of our comments is available by visiting: http://www.health.gov/dietaryguidelines/dga2015/comments/



[1] Dietary Guidelines Advisory Committee. 2015. Report of the Dietary Guidelines Advisory Committee on the Dietary Guidelines for Americans, 2015, to the Secretary of Agriculture and the Secretary of Health and Human Services. U.S. Department of Agriculture, Agricultural Research Service, Washington, DC.

[2] Dietary Guidelines Advisory Committee. 2015. Report of the Dietary Guidelines Advisory Committee on the Dietary Guidelines for Americans, 2015, to the Secretary of Agriculture and the Secretary of Health and Human Services. U.S. Department of Agriculture, Agricultural Research Service, Washington, DC.

[3] Dietary Guidelines Advisory Committee. 2015. Report of the Dietary Guidelines Advisory Committee on the Dietary Guidelines for Americans, 2015, to the Secretary of Agriculture and the Secretary of Health and Human Services. U.S. Department of Agriculture, Agricultural Research Service, Washington, DC.

[4] Richardson DP, et al. The nutritional and health benefits of almonds: a healthy food choice. Food Sci Tech Bull: Funct. Foods. 2009. 6(4):1-10.

[5] Perez-Jimenez J, et al. Identification of the 100 richest dietary sources of polyphenols: an application of the Phenol-Explorer database. Eur J Clin Nutr. 2010;64:S112-S120.

[6] Bolling BW, et al. Polyphenol content and antioxidant activity of California almonds depend on cultivar and harvest year. Food Chem. 2010;122:819-825.

[7] California Almond Sustainability definition: Sustainable almond farming utilizes production practices that are economically viable and are based upon scientific research, common sense and a respect for the environment, neighbors and employees. The result is a plentiful, nutritious, safe food product.

[8] 2012 USDA Census of Agriculture

[9] Heller M, et al. Towards a Life-Cycle Based, Diet-level Framework for Food Environmental Impact and Nutritional Quality Assessment: A Critical Review. Env Sci Tech 2013;47:12632-12647.