June 3, 2014
Richard D. Olson, M.D., M.P.H.
Prevention Science Lead and Designated Federal Officer, 2015 DGAC
Office of Disease Prevention and Health Promotion, OASH
U.S. Department of Health and Human Services
1101 Wootton Parkway, Suite LL100 Tower Building
Rockville, MD 20852
Colette I. Rihane, M.S., R.D.,
Director, Nutrition Guidance and Analysis Division
Center for Nutrition Policy and Promotion
U.S. Department of Agriculture
3101 Park Center Drive, Room 1034
Alexandria, VA 22302
Filed electronically at: www.health.gov/dietaryguidelines/dga2015/comments/writeComments.aspx
RE:
Comments to the 2015 Dietary Guidelines Advisory Committee Regarding the Importance of
Grains in the Diet
Dear Dr. Olson and Ms. Rihane:
As the organizations comprising the Grain Chain, a grains industry coalition from farm to table, we are
pleased to share our expertise with you as you develop recommendations for the 2015 Dietary
Guidelines for Americans (DGA). We commend the Dietary Guidelines Advisory Committee (DGAC) for
the thoroughness of its work to date and appreciate the opportunity to assist you in the important
mission of guiding Americans toward better health through good nutrition based on sound science.
Nutrition education is critical in assisting Americans to make wise dietary choices, and we encourage the
Committee to address this as part of its final report, as well as to continue to provide attainable goals to
Americans that offer a meaningful impact on health.
In our comments, we will address the following topics:
 Role of enriched and whole grains in the diet
 Other considerations related to grain consumption including vitamin D, fiber, iron, and sodium
 Nutrition education
 Gluten
The crucial role of enriched grains in the diet
The Grain Chain endorses maintaining the 2010 DGAC grain consumption recommendation that
Americans consume six servings daily with at least half of all grains as whole grains. We also urge the
Committee to continue to recognize the valuable role of enriched grains in a healthy diet, a key
component of which is fortification with folic acid, in the 2015 Dietary Guidelines.
Enriched grains, as mandated by the US Government since 1941, have the three major B vitamins and
iron replaced in equal or larger amounts to those in whole grain products as defined by the standards of
identity. These essential B vitamins help maintain a healthy nervous system, increase energy
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production, and may play a role in lowering cholesterol. Due to this enrichment policy, serious diseases,
including pellagra and beriberi, have been eradicated from the US population.
Since 1998, when the Food & Drug Administration (FDA) mandated that enriched grains be fortified with
folic acid, the incidence of neural tube defects (NTDs) in US infants has decreased 36 percent. In fact,
enriched, fortified grain foods are the primary source of folic acid in Americans’ diets. This is particularly
important for women of child-bearing age, the majority of which do not take folic acid supplements.
Furthermore, folic acid is better absorbed by the body than natural folate, almost twice as efficiently. (1)
The U.S. also has a growing Hispanic population, and adequate consumption of folate-rich foods is
critical for this group since statistically, Hispanic women are 1.5 to 3 times more likely to have a baby
with an NTD. (2)
A Centers for Disease Control and Prevention (CDC) proclamation in 2011 named the fortification of folic
acid to enriched grains as one of the top 10 health achievements in the first decade of this century. (3)
This fortification policy has also almost totally eradicated folate-deficiency anemia in older adults in the
U.S. (4) Folic acid fortification may also play a role in preventing strokes and heart disease.
During the 2005 DGAC’s deliberations, the research question was asked: “What is the impact on intake
of folate and other nutrients if all recommended grain intake amounts are selected as whole grains
rather than half whole and half non-whole grains?”(5)
The food pattern modeling analysis cited by CNPP reported that non-whole grain products contribute
25% of folate, 24% of iron, 9% of calcium, 10% of dietary fiber, 27% of thiamine, 16% of riboflavin and
20% of the niacin in an 1800 calorie USDA food pattern.
If some of the non-whole grains were substituted with whole grain-fortified ready-to-eat breakfast
cereals, some of this nutrient inadequacy would be eliminated. However, CNPP concluded the
recommendation to only consume whole grains would lower folate and iron intakes to less than
adequate amounts for populations at risk for these nutrients.
Furthermore, CNPP viewed grains, both whole and enriched, as an affordable source of key nutrients for
all Americans. (6)
The Grain Chain believes that this conclusion clearly points to the value of a balance of both whole and
enriched grains in a healthy and sustainable diet.
It is also critically important that the 2015 dietary guidelines be aligned with the government mandate
for folic acid fortification. A consistent message is key to retaining the confidence Americans have in our
regulatory agencies. To do otherwise would undermine the important achievements gained through
folic acid fortification while adding to the existing confusion in consumers’ minds regarding the
important roles of enriched and fortified grain products.
Benefits of whole grains are widely recognized
We continue to support the recommendation that Americans consume half of their total grain servings
as whole grains. Because Americans have yet to achieve the current Dietary Guidelines
recommendation, the recommendation’s goal is still valid and vital. As well, the science does not show
that there are benefits to higher daily intake. Thus, we recommend keeping the goal at half, or three
daily servings for those on a 2000 calorie diet.
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As recently as 2010, USDA reported males and females over the age of two only consumed
about 12 percent of their grains from whole grain foods – less than the 50 percent
recommended, but an increase of 23.4 percent over 2008. (7)
We are making progress with whole grain consumption. Globally, the U.S. is the leader in whole
grain product introductions, introducing 651 new products in 2010 alone, driven by consumer
demand. (8)
Among the many benefits of whole grains, they are naturally low in fat and may be a good
source of fiber; lower the risk of irritable bowel syndrome and diverticular disease; contain
important nutrients such as selenium, potassium and magnesium; and phytonutrients; vitamins
and minerals in whole grains may help boost immunity, lower blood pressure, and prevent some
forms of cancer. (9)
When analyzing the participants of the Framingham Heart Study, those who consumed approximately
three servings of whole grains and two servings of refined (enriched) grains per day had the least
visceral adipose tissue. (10)
Other considerations related to grain consumption
Vitamin D Yeast
Vitamin D was identified as a nutrient of concern by the 2010 DGA. Currently, it is an optional
fortification to enriched grains. In 2012, the Food and Drug Administration (FDA) increased the amount
allowed in baked goods using vitamin D-fortified yeast from a maximum of 90 IU per 100 g to 400 IU.
(11) By using the vitamin D yeast and also fortifying with calcium (also optional), enriched bread will be
able to make a health claim for the reduction of osteoporosis, as long as it contains 20% of the RDI of
both nutrients. This is another example of enriched grains improving public health. Vitamin D from
grains could also be useful for people following a more plant-based diet.
Fiber
The 2010 DGA labeled fiber as a nutrient of concern. While nutritionists have been trying to increase
fiber intake among Americans for decades, we have seen little progress. NHANES 1999/2000 reported
fiber intake averaged 15.6 g/person for adults 18 and older. The latest report (2007/2008) shows we
have only increased .3 g for that same age group despite increased recommendations for whole grains.
Ninety percent of Americans fall short of meeting the fiber recommendation. (12)
Whole grain foods, while having many important nutritional benefits in addition to fiber, contain a wide
range of fiber. Americans are consuming less than one serving of whole grain foods per day instead of
the recommended three or more which decreases the fiber intake further. (7)
The Institute of Medicine (IOM) recommends 25 g of fiber for women and 38 g for men based on the
fact that 14 g/1000 calories appears to be beneficial for reducing cardiovascular disease. As we struggle
to reduce calorie consumption in the U.S., we may also reduce fiber consumption unless we encourage
consumption of bran and fortification of fiber in whole grains, enriched grains, and bran and germ-based
products. A modeling study showed that by adding 2.5-5 g of fiber to existing grain foods, we could
reach the recommended level without an increase in calories. (13)
The fiber content listed on the front-of-pack declaration of “Whole Grain” or “Made with Whole Grain”
may encourage the consumer to eat more whole grains but not necessarily increase their fiber intake to
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the recommended amount. Grain foods provide 44% of the fiber in the American diet but we could
provide more with added fiber of all types. (14, 15)
Individuals with high BMI (>30) had lower fiber intakes compared with those with BMI < 30. Grain foods
are the largest source of fiber in the U.S. diet (44%), followed by vegetables (21%), fruits (13%), and dry
beans and other legumes (10%). (15)
Intake of cereal fiber, but not fibers from fruit or vegetables, was inversely associated with BMI, body
fat, and trunk fat mass in older adults. (16)
Iron
Many fortified cereals deliver at least 25 percent of the recommended daily value for iron, and one slice
of enriched bread delivers 6 percent. In a vegetarian or Mediterranean diet pattern, the presence of
iron from enriched grain foods is even more vital. (17)
Sodium
On May 15, 2013, the IOM identified a number of research and data gaps that need to be addressed
before recommending specific sodium targets for the general population. (18)
Bakers have pro‐actively reduced the amount of sodium in bread, with USDA data confirming that the
average sodium level in a slice of bread has dropped from 254 mg to 180 mg since 1963. Both cereals
and rice mixes have also decreased their sodium content and many are working to decrease further by
participating in the National Salt Reduction Initiative.
Furthermore, a study recently published in the American Journal of Hypertension, “Compared With
Usual Sodium Intake, Low-and Excessive-Sodium Diets Are Associated With Increased Mortality: A MetaAnalysis,” concluded that 2,645 – 4,945 mg of sodium per day, a range of intake within which the vast
majority of Americans fall, actually results in more favorable health outcomes than the CDC’s current
recommendation of less than 2300mg/day for healthy individuals under 50 years old, and less than 1500
mg/day for most over 50 years. This study was a combined analysis of 25 individual studies, which
measured results from over 274,683 individuals. (19)
Importance of nutrition education
Nutrition education is critical in guiding Americans to make wise dietary choices, and we encourage the
Committee to address this as part of its final report. Members of the Grain Chain continue to find that
consumers are confused about the differences between refined, enriched, fortified and whole grains.
Accurate definitions for grains should again be included in the final Guidelines document to assist
consumers in understanding the various grain products, and the role each plays in a healthy diet. We
recommend that accurate definitions include:

Whole grain products contain the entire endosperm, bran and germ in amounts proportional to
the unprocessed grain kernel.

Refined, unenriched grain products have had the germ and bran removed with only the
endosperm remaining. This represents less than 5 percent of the total white flour milled in the
U.S. It is primarily for organic and artisanal products. A small amount goes into mixes for
overseas consumption.
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Enriched/fortified grain products are refined grain products that have the three major B
vitamins and iron replaced in equal or greater amounts to those in whole grain products as
defined by the standards of identity. They also are fortified with folic acid in amounts slightly
double that found in whole grain products. This includes such products as white bread, rolls,
rice and the majority of other grain foods. At least 95% of the refined grains in the U.S. are
enriched and fortified and are labeled as such. Therefore, it is almost impossible to consume a
diet of “refined” grains in the U.S. that has not been enriched/fortified.
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Other fortified grain products are those that have a variety of minerals and vitamins added in
various amounts, not defined by set standards. They are added voluntarily according to FDA
guidelines. Many breakfast cereals fit into this category.
The Grain Chain also works actively with USDA’s Center for Nutrition Policy and Promotion (CNPP) to
advance knowledge of, and understanding of, the Dietary Guidelines among health professionals and
consumers. USDA appointed our groups as MyPlate Strategic Communications Partners whose mission is
to work with USDA and other Partner groups on a coordinated consumer program to communicate key
education messages of the Dietary Guidelines.
In the fall of 2012, the American Bakers Association, Grain Foods Foundation, National Pasta
Association, USA Rice, and Wheat Foods Council, joined by corporate members General Mills and
Kellogg Company, teamed up to amplify the 2010 DGA message “make at least half your grains whole.”
The overarching goal was to help consumers incorporate whole grains at each meal. The campaign,
which ran September-December 2012, provided consumers with a good understanding of the
importance of balance by also stressing the need for women of child-bearing age to eat sufficient
enriched grains for folic acid, which plays a critical role in helping prevent NTDs.
In addition to individual activities during this timeframe, the group worked with CNPP to develop a
series of consumer-oriented videos on such topics as whole grains for breakfast, budget-friendly whole
grains, and whole grains for the whole family. These were featured on the ChooseMyPlate.gov website
during the September-December timeframe as well as on the websites of other Grain Chain partners. (6)
Another example of industry outreach is the Dietary Guidelines Alliance (DGA), a private-public
partnership among leading food, nutrition and health organizations and societies, food industry
organizations and the government, dedicated to providing consumers with science-based, practical
advice on how to apply the Dietary Guidelines for Americans to their lives. The mission of the Alliance is
to provide positive, simple and consistent messages to help consumers achieve healthy, active lifestyles.
(21) The DGA would welcome additional opportunities to partner on educational endeavors.
Resources for grain-related issues
The topic of gluten was raised by the DGAC at its January 14, 2014, meeting. Members of the Grain
Chain have a great deal of expertise on this subject, as well as access to leading experts in the field of
celiac disease and non-celiac gluten sensitivity, and wheat breeding:
•
•
Glenn Gaesser, PhD, Professor, Arizona State University:
o Role of diet in health; fitness, health, metabolic and cardiovascular responses to acute
and chronic exercise
Shelley Case, RD, Author, “Gluten-Free Diet: A Comprehensive Resource Guide”:
o Nutrition expert on celiac disease and the gluten-free diet
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•
•
•
Julie Miller Jones, PhD, LN, CNS, Distinguished Scholar and Professor Emeritus, St. Catherine
University:
o Whole grains and food-based solutions, whole grains and dietary fiber, sugars, starch
including resistant starch, the glycemic index, fat, vitamins and antioxidants, food safety
issues, and issues affecting women such as dieting and body image
Joanne Slavin, PhD, RD, Professor, Department of Food Science and Nutrition, University of
Minnesota:
o Human metabolic, in vitro, and subjective health effects of food intake studies;
interventions include fiber, carbohydrate, protein and whole food studies. Particularly
interested in the gastrointestinal effects of food intake, including changes in microflora,
short chain fatty acids, and other fecal measures
Brett Carver, PhD, Wheat Genetics Chair in Agriculture, Oklahoma State University:
o Wheat breeding and genetics
The representative for the Grain Chain is Lee Sanders, Senior Vice President, Government Relations &
Public Affairs, American Bakers Association, 202-789-0300, lsanders@americanbakers.org. Please
contact her if we can assist in arranging a briefing for you by one of these experts.
Also, we submitted separately a list of references relating to gluten, celiac disease and non-celiac gluten
sensitivity and have attached an updated version with these written comments.
Conclusion
In conclusion, the Grain Chain urges the DGAC to maintain the recommendation that Americans
consume six servings of grains daily with at least half as whole grains. We also believe it is important for
the 2015 DGA to recognize the valuable role of enriched grains in a healthy diet, a key component of
which is fortification with folic acid.
In addition, we ask that the Committee include among its priorities a commitment to ensuring that the
2015 DGA are irrefutably science-based, consistent with advice from other federal agencies, and are
communicated in terms easily understood by the public. Americans continue to be bombarded by
health misinformation, miscommunication and misinterpretation through the news media, the web, and
a variety of other sources. Consistent guidance at the national level is a critical component in helping to
turn the public away from “fad” diets and sensationalized nutrition information.
We look forward to working with the 2020 DGAC regarding important areas of emerging science
including sustainability, and the microbiome. As noted in our submission to Subcommittee 5 of the 2015
DGAC, the entire Grain Chain is already focused on sustainability and efforts to advance resource
efficiency. We are also supportive of future investigation of the microbiome and its role in diet and
health.
We appreciate the opportunity to share our views and look forward to continuing to work with you in
developing recommendations for the 2015 Dietary Guidelines.
Sincerely,
The Grain Chain:
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American Bakers Association
American Institute of Baking
Grain Foods Foundation
Grains for Health Foundation
Independent Bakers Association
National Association of Wheat Growers
National Pasta Association
North American Millers’ Association
Retail Bakers of America
USA Rice Federation
Wheat Foods Council
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References
1. Pitkin RM. Folate and Neural Tube Defects. Am J Clin Nutr 2007; 85 (suppl): 285S-8S
2. Folic Acid Knowledge and Use Among Hispanic Women.
http://www.cdc.gov/omhd/populations/HL/HHP/Folic.htm
3. CDC. Ten Great Public Health Achievements – U. S. 2001-2010. CDC MMWR. (19) 619-613, May
2011
4. Odewole OA, Williamson RS, Zakai NA, Berry RJ, Judd SE, Qu YP, Adedinsewo DA, Oakley GP.
Near-elimination of folate-deficiency anemia by mandatory folic acid fortification in older US
adults: Reasons for Geographic and Racial Differences in Stroke study 2003-2007. Doi:
10.3945/ajcn. 113.059683. 2013
5. Replacing all Non-Whole Grains with Whole Grains: Food Pattern Modeling Analysis.
http://www.cnpp.usda.gov/Publications/DietaryGuidelines/2010/DGAC/Report/AppendixE-3-7Grains.pdf
6. USDA MyPlate Videos. http://www.choosemyplate.gov/videos.html#grains
7. http://www.ars.usda.gov/SP2UserFiles/Place/12355000/pdf/fped/Table_1_FPED_GEN_0910.pd
f
8. http://wholegrainscouncil.org/newsroom/whole-grain-statistics
9. Birkett AM, Cho, SS. Cereal Fiber and Health: Current Knowledge. CFW Nov-Dec 2013. 58 (6).
10. McKeown NM, Troy M, Jacques PF, Hoffman U, O’Donnell CJ, Fox CS. Whole and
refined-grain intakes are differentially associated with abdominal visceral and
subcutaneous adiposity in healthy adults. Am J Clin Nutr 2010; 92:1165-71
11. Federal Register: Food Additives Permitted for Direct Addition to Food for Human Consumption:
Vitamin D2. https://www.federalregister.gov/articles/2012/08/29/2012-21353/food-additivespermitted-for-direct-addition-to-food-for-human-consumption-vitamin-d2
12. Mobley AR, Slavin SL, Hornick, BA. The future of recommendation on grain foods in dietary
guidance. J Nutr. Sep 2013. 143 (9): 1527@-1532S.
13. Nicklas TA, O’Neil CE, Liska DJ, Almeida NG, Fulgoni III VL. Modeling Dietary Fiber Intakes in US
Adults: Implications for Public Policy. Food and Nutr. Sciences, 2011, 2, 925-931
doi:10.4236/fns.2011.29126 Published Online November 2011.
14. Clemens R, Kranz S, Mobley AR, Nicklas TA, Raimondi MP, Rodriguez JC, Slavin JL, Warshaw H.
Filling America’s fiber intake gap: summary of a roundtable to probe realistic solutions with a
focus on grain-based foods. J Nutr. 2012;142 Suppl:1390S–401S
15. King DE, Mainous III AG, Lambourne CA. Trends in Dietary Fiber Intake in the United States.
1999-2008. JAND 112 (5) 2012.
16. McKeown NM, Yoshida M, Shea MK, Jacques PE, Lichtenstein AH, Rogers G, Booth SL, Saltman E.
Whole-grain intake and cereal fiber are associated with lower abdominal adiposity in older
adults. J Nutr. 2009 Oct;139(10):1950-5. doi: 10.3945/jn.108.103762. Epub 2009 Sep 2.
17. http://ods.od.nih.gov/pdf/factsheets/Iron-HealthProfessional.pdf
18. http://www.iom.edu/Reports/2013/Sodium-Intake-in-Populations-Assessment-of-Evidence.aspx
19. Graudel N, Jurgens G, Baslund B, Alderman, MH. Compared With Usual Sodium Intake, Low- and
Excessive-Sodium Diets Are Associated With Increased Mortality: A Meta-Analysis. Am J
Hypertens. Epub 2014 Mar 20. doi: 10.1093/ajh/hpu028
20. http://www.foodinsight.org/Resources/Detail.aspx?topic=It_s_All_About_You_
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Descriptions of Grain Industry Organizations
American Bakers Association (ABA) is the Washington D.C.-based voice of the wholesale baking
industry. Since 1897, ABA has represented the interests of bakers before the U.S. Congress, federal
agencies, and international regulatory authorities. ABA advocates on behalf of more than 700 baking
facilities and baking company suppliers. ABA members produce bread, rolls, crackers, bagels, sweet
goods, tortillas and many other wholesome, nutritious baked products for America’s families. The
baking industry generates more than $103 billion in economic activity annually and employs 633,000
highly skilled people. RMackie@americanbakers.org
American Institute of Baking International (AIB) is a corporation founded by the North American
wholesale and retail baking industries in 1919 as a technology transfer center for bakers and food
processors. The original mission of the organization was to "put science to work for the baker," which is
still central to all of the programs, products, and services provided by AIB to baking and general food
production industries worldwide. abiane@AIBonline.org.
Grain Foods Foundation (GFF), a joint venture of members of the milling, baking and allied industries
formed in 2004, is dedicated to advancing the public’s understanding of the beneficial role grain-based
foods play in the human diet. Directed by a board of trustees, funding for the Foundation is provided
through voluntary donations from private grain-based food companies and is supplemented by industry
associations. ccochran@grainsfoundation.org
Grains for Health Foundation (GFH) was founded in 2009 to increase the availability of affordable grainbased foods with health benefits to improve public health. Grains for Health forges partnerships with
food and health leaders to develop evidence-based strategies that facilitate the development, delivery,
and consumption of grain-based foods that promote public health, lower the incidence of diet related
chronic disease, and curb health care costs. LMarquart@umn.edu
Independent Bakers Association (IBA) The Independent Bakers Association is a Washington, D.C. based
national trade association of over 400 mostly family owned wholesale bakeries and allied industry
trades. The Association was founded in 1968 to protect the interests of independent wholesale bakers.
NPyle@attglobal.net
National Association of Wheat Growers (NAWG) is a federation of 21 state wheat grower associations
that works to represent the needs and interests of wheat producers before Congress and federal
agencies. Based in Washington, D.C., NAWG is grower-governed and grower-funded, and works in areas
as diverse as federal farm policy, trade, environmental regulation, research and climate change.
jpalmer@wheatgrowers.org
National Pasta Association (NPA) Founded in 1904, NPA is an organization of pasta and pasta-related
product manufacturers, millers and suppliers to the US pasta industry serving as a cohesive industry
advocate, a promoter of pasta and a center of knowledge for its members, the government and the
public. info@ilovepasta.org and CFreysinger@kellencompany.com
North American Millers’ Association (NAMA) is the trade association of the wheat, corn, oat, and rye
milling industries. Member companies operate mills in 38 states and Canada, representing more than 90
percent of total industry production capacity. jmccarthy@namamillers.org
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Retail Bakers of America (RBA) was founded in 1918. Its purpose is assist retail bakers in furthering the
health of the nation by making available delicious bakery foods; to foster a better relationship between
the public and the baking industry; to promote and encourage the production of high quality,
wholesome, healthful bakery foods; and to represent the baking industry, especially its retail branch, to
the government. Bernadette@RetailBakersofAmerica.org
USA Rice Federation is the global advocate for all segments of the U.S. rice industry with a mission to
promote and protect the interests of producers, millers, merchants and allied businesses. Over 20 billion
pounds of long, medium, and short grain, and organic and specialty rice is grown and harvested each
year by farmers in Arkansas, California, Louisiana, Texas, Mississippi and Missouri. bward@usarice.com
Wheat Foods Council (WFC) is a nonprofit organization formed in 1972 to help increase public
awareness of grains, complex carbohydrates, and fiber as essential components of a healthful diet. The
Council is supported voluntarily by wheat producers, millers, and related industries.
jadams@wheatfoods.org
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