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Prepared by Sally Fallon Morell, President
The Weston A. Price Foundation

Comments on the new USDA Dietary Guidelines

SUMMARY

Current USDA dietary guidelines are based on the flawed notion that cholesterol and saturated fat are unhealthy. They are unrealistic, unworkable, unscientific and impractical; they have resulted in widespread nutrient deficiencies and contributed to a proliferation of obesity and degenerative disease, including problems with growth, behavior and learning in children. The US government is promoting a lowfat, plant-based diet that ignores the vital role animal protein and fats have played in human nutrition throughout the ages.

The pyramid with its strictures against fat consumption does not recognize variations in human metabolism. Recommendations for fat restriction are predicated on the assumption that fat causes weight gain and heart disease; several recent studies have shown that that restriction of natural fats actually leads to more obesity in both children and adults, while the refined carbohydrates, polyunsaturated and trans fats that frequently replace natural saturated fats contribute to weight gain and chronic disease. Restriction of animal fats in children leads increased markers for heart disease and to deficiencies of vitamins A, D and K2, needed for growth, strong bones, immunity, neurological function, and protection from tooth decay.

See special article in Nutrition here: http://www.nutritionjrnl.com/article/S0899-9007%2810%2900289-3/fulltext ^[2] [Adele H Hite, MAT; Richard D Feinman, PhD; Gabriel E Guzman, PhD; Morton Satin, MSc; Pamela Schoenfeld, RD; Richard J Wood, PhD. “In The Face Of Contradictory Evidence: Report Of The Dietary Guidelines For Americans Committee,”Nutrition, October 2010 (Volume 26, Issue 10, Pages 915-924), published by Elsevier. DOI: 10.1016/j.nut.2010.08.012.]

RECOMMENDED NEW GUIDELINES:

The Weston A. Price Foundation strongly urges the USDA Dietary Guidelines committee to scrap the food pyramid and replace it with the following Healthy 4 Life guidelines, based on four groups of whole foods.

Every day, eat high quality, whole foods to provide an abundance of nutrients, chosen from each of the following four groups:

1. Animal foods: meat and organ meats, poultry, and eggs from pastured animals; fish and shellfish; whole raw cheese, milk and other dairy products from pastured animals; and broth made from animal bones.
2. Grains, legumes and nuts: whole-grain baked goods, breakfast porridges, whole grain rice; beans and lentils; peanuts, cashews and nuts, properly prepared to improve digestibility.
3. Fruits and Vegetables: preferably fresh or frozen, preferably locally grown, either raw, cooked or in soups and stews, and also as lacto-fermented condiments.
4. Fats and Oils: unrefined saturated and monounsaturated fats including butter, lard, tallow and other animal fats; palm oil and coconut oil; olive oil; cod liver oil for vitamins A and D.

Avoid: foods containing refined sweeteners such as candies, sodas, cookies, cakes etc.; white flour products such as pasta and white bread; processed foods; modern soy foods; polyunsaturated and partially hydrogenated vegetable oils and fried foods.

SATURATED FATS

The demonization of saturated fats is unscientific and has had an extremely detrimental effect on the health of the whole nation, particularly on growing children. The human body contains high levels of saturated fat in the cell membranes and in protective fat around the organs. When saturated fat is not available in the diet, the body very efficiently turns refined carbohydrates into saturated fat;¹ thus restriction of saturated fat can often lead to cravings for refined carbohydrates.

Saturated fatty acids are said to cause cancer, heart disease and obesity. Yet these diseases were rare at the turn of the century when consumption of saturated fats was much higher than it is today. The likely culprits for these conditions are polyunsaturated fatty acids and trans fats, which came into widespread use after WWII.²

Saturated fats play many important roles in the body chemistry:

• As saturated fats are stable, they do not become rancid easily, do not call upon the body’s reserves of antioxidants, do not initiate cancer and do not irritate the artery walls.³
• Vitamins A and D, which are vital for proper growth and for protein and mineral assimilation, are found only in mostly saturated animal fats.
• Saturated fats enhance the immune system, thereby protecting us against infection and cancer.⁴
• Saturated fats help the body lay down calcium in the bones and help prevent osteoporosis.⁵
• Saturated fats provide energy and structural integrity to the cells.⁶ At least 50 percent of many, if not most, of the cell membrane must be saturated fat for the cells to work properly.
• Saturated fats protect the liver from alcohol, drugs, pesticides and other poisons.⁷
• Saturated fats enhance the body’s use of essential fatty acids, which the body needs in small amounts and obtains from whole foods.⁸
• Stearic acid, found in beef tallow and butter, has cholesterol-lowering properties and is a preferred food for the heart.⁹
• Saturated fats are needed for the kidneys to work properly.¹⁰
• The lung surfactants are composed of saturated fatty acids.¹¹ The lungs cannot work without adequate amounts of saturated fats.

Warnings against dietary saturated fats are predicated on the assumption that saturated fats contribute to atherosclerosis and therefore to heart disease; yet, as saturated fat consumption has declined in the U.S. over the last one hundred years, heart disease has increased. Recent epidemiological evidence from Europe does not support a correlation of saturated fat with heart disease, as shown in the charts below.¹²

What happens when children are put on lower fat diets? When researchers prominently associated with the American Heart Association fed children lower fat diets and measured some of the markers they consider important predictors of heart disease, they found that these lower fat diets were causing the very problems they wanted to prevent. The children whose genes would normally have been producing the desirable light and fluffy form of LDL started to make the dangerous small and dense form of LDL.¹³ Thus the US dietary recommendations are likely to be causing heart disease, not preventing it.

SATURATED FAT AND WEIGHT GAIN

The USDA Dietary Guidelines have led to the restriction of saturated fat in children’s diets; pediatricians now advise parents to put their children on reduced-fat dairy products and avoid meat and dairy fats starting at the age of two; and school children no longer have the option of whole milk in school lunches.

Authorities justify these restrictions of nutritious foods by claiming that fat, especially saturated fat, results in weight gain. Yet a recent study from Sweden found that a higher intake of fats, including saturated fats, in childhood resulted in lower body weight; children on reduced fat diets had higher body mass and greater insulin resistance.¹⁴

Furthermore, in a study of Swedish adults, consumption of whole fat milk and cheese was linked to lower weight gain;¹⁵ and dairy fat was not linked with weight gain in a longitudinal study of adolescents.¹⁶

Individuals who try to restrict saturated animal fats according to the USDA guidelines often end up consuming more trans fats. Yet animal research indicates that in calorie-restricted diets containing the same number of calories, those diets containing trans fats result in increased weight gain.¹⁷

CHOLESTEROL

Restriction of saturated animal fats is also justified with the argument that animal fats contain cholesterol, and therefore cause heart disease. Yet even the amount of cholesterol found in three to four eggs per day produces no change in blood cholesterol levels in 70 percent of the population, as shown in randomized, placebo-controlled trials; in the other 30 percent, dietary cholesterol increases both LDL-cholesterol and HDL-cholesterol equally and turns small, dense “pattern B” LDL into light, buoyant “pattern A” LDL, changes that are widely regarded by promoters of the cholesterol theory as beneficial.¹⁸

Cholesterol restriction is particularly harmful for pregnant women and growing children. Pregnant women need extra levels of cholesterol for the formation of the fetus, and cholesterol-lowering drugs can lead to extremely serious birth defects.¹⁹ Growing children cannot produce all the cholesterol they need for the formation of the brain and gut, but need to obtain it from a cholesterol-rich diet. Just a few decades ago, experts on child feeding agreed that the best foods for infants were cholesterol-rich foods such as egg yolk, liver, butter and whole milk; today, thanks to the USDA Dietary Guidelines, children are denied these nutrient-dense foods so important for growth and neurological development.

Roles of cholesterol include:

• Along with saturated fats, cholesterol in the cell membrane gives our cells necessary stiffness and stability. When the diet contains an excess of polyunsaturated fatty acids, these replace saturated fatty acids in the cell membrane, so that the cell walls actually become flabby. When this happens, cholesterol from the blood is “driven” into the tissues to give them structural integrity. This is why serum cholesterol levels may go down temporarily when saturated fats are replaced with polyunsaturated oils in the diet.²⁰
• Cholesterol acts as a precursor to vital corticosteroids, hormones that help us deal with stress and protect the body against heart disease and cancer; and to the sex hormones like androgen, testosterone, estrogen and progesterone.
• Cholesterol is a precursor to vitamin D, a very important fat-soluble vitamin needed for healthy bones and nervous system, proper growth, mineral metabolism, muscle tone, insulin production, reproduction and immune system function.
• The bile salts are made from cholesterol. Bile is vital for digestion and assimilation of fats in the diet.
• Research shows that cholesterol acts as an antioxidant.²¹ This is the likely explanation for the fact that cholesterol levels go up with age. As an antioxidant, cholesterol protects us against free radical damage that leads to heart disease and cancer.
• Cholesterol is needed for proper function of serotonin receptors in the brain.²²Serotonin is the body’s natural “feel-good” chemical. Low cholesterol levels have been linked to aggressive and violent behavior, depression and suicidal tendencies.
• Mother’s milk is especially rich in cholesterol and contains a special enzyme that helps the baby utilize this nutrient. Babies and children need cholesterol-rich foods throughout their growing years to ensure proper development of the brain and nervous system.
• Dietary cholesterol plays an important role in maintaining the health of the intestinal wall.²³ This is why low-cholesterol vegetarian diets can lead to leaky gut syndrome and other intestinal disorders.

OTHER NUTRIENT DEFICIENCIES

It is very difficult, if not impossible, to construct a diet based on the USDA Dietary Guidelines that meets the nutritional requirements of either adults or growing children.²⁴ Meals based on the dietary guidelines will not only contain an excess of carbohydrates and not enough fat (or high levels of processed fat), they are also likely to be deficient in a number of nutrients:

• Vitamin A: Since USDA Guidelines severely restrict animal fats and do not specifically recommend liver and other organ meats, meals based on these guidelines will be virtually devoid of vitamin A. USDA has recognized this problem and tried to solve it by insisting that adequate vitamin A can be obtained from vitamin A precursors found in fruits and vegetables; in fact, contrary to statements in biochemical textbooks and the Merck Manual, USDA falsely labels these carotenes as vitamin A. Yet the precursors to the true animal form of vitamin A are very poorly converted, especially in babies and children who need vitamin A the most.²⁵ Vitamin A is an extremely important nutrient, needed for growth, hormone production, healthy bones, skin and eyes and protection against infection.
• Vitamin D: A consensus is building that vitamin D deficiency is widespread in the U.S. population. According to advocates for supplements, adequate vitamin D cannot be obtained from food. This is certainly a true statement if one is following the USDA Guidelines. Yet there are many food sources of vitamin D including butter, whole milk, egg yolks, organ meats, lard and other animal fats from animals raised in sunlight, cod liver oil, shellfish and oily fish. The problem is that the Guidelines have demonized these high-fat, nutrient-dense foods and they have largely disappeared from the American diet.
• Vitamin K₂: Recent research indicates that the animal form of vitamin K is needed for numerous processes, not just the clotting factor in the blood. Vitamin K₂ is needed for healthy bones, normal growth, freedom from tooth decay, proper neurological function, reproduction and protection against heart disease. The USDA Dietary Guidelines result in a diet largely devoid of vitamin K₂, which is found in meat fats, organ meats, whole cheeses and butterfat.²⁶
• Zinc: A critical nutrient for reproduction and neurological function. The best sources are red meat and shellfish. Diets high in whole grains—recommended in the USDA Guidelines—tend to block absorption of zinc.
• Vitamin B₁₂: A critical nutrient for healthy blood, neurological function, protection against depression and other psychological disorders, and protection against heart disease, cancer, anemia and multiple sclerosis. Best sources are organ meats like liver and shellfish.

CONCLUSION

As formulated, the USDA Dietary Guidelines and Food Pyramid have resulted in widespread nutrient deficiencies and have had the effect of conferring official approval on very unhealthy processed foods containing trans fats, processed vegetable oils, refined carbohydrates and neuro-toxic additives such as MSG. These Guidelines have undermined the traditional healthy diets of the various populations that have immigrated to the United States, Most seriously, they have influenced the makeup of baby formula, allowing manufacturers to use vegetable oils and sucrose rather than the animal fats and lactose that mother’s milk provides.

The consequences of the flawed guidelines are extremely serious; we are already seeing the tragic effects in the current epidemic of chronic disease in adults and low birth weight, growth problems and learning disabilities in our children.

The Weston A. Price Foundation urges the committee to start over, scrap the unworkable food pyramid, abandon the strictures against saturated fats and cholesterol, and provide useful, science-based guidelines that will steer Americans towards a diet of nutrient-dense whole foods.

Prepared by Sally Fallon Morell, President
The Weston A. Price Foundation
Washington, DC
(202) 363-4394
www.westonaprice.org

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