Consistent with prior Dietary Guidelines revisions, increased seafood consumption was recommended for the general population, in part for its EPA and DHA content. In contrast to the available scientific evidence, there was no recommendation for pregnant or lactating women to increase consumption of seafood (i.e., DHA) above and beyond what is recommended for the general population, GOED noted. Also, low intakes of specific nutrients were cited as posing public health concerns for the first time, but EPA and DHA were not included on this list.
The report makes general recommendations about foods and nutrients that should be increased or decreased in the diet. The Dietary Guidelines typically focus on general food categories, so the fact that any nutrients were highlighted is a positive development, GOED offered.
The main issue for GOED is that the USDA and HHS specifically note that low intakes of fruits, vegetables, whole grains, milk and seafood has led to low enough intakes of potassium, dietary fiber, calcium and vitamin D to create public health concerns. Even though low seafood intakes were called out specifically, EPA and DHA did not make the list of concerns despite documented estimates that more people die from low omega 3 intakes than from low fruit and vegetable consumption in the U.S.
Even though the agencies recommended increased seafood intakes and separately noted that supplements and functional foods can play a valuable role in the diet, the report failed to recognize the benefits of supplements or foods fortified with EPA and DHA. While GOED commends the two agencies for recognizing that ¡°¡fortified foods and dietary supplements may be useful in providing one or more nutrients that otherwise may be consumed in less than recommend amounts,¡± the organization is disappointed in the failure to acknowledge the scientific evidence supporting the need for additional intake of EPA and DHA, for the prevention of chronic disease (i.e., cardiovascular disease).
According to GOED: Recommendations to include the use of supplements and ¡°functional foods¡± with added EPA and DHA to achieve intake targets associated with EPA and DHA and reduced risk of chronic disease are supported by the evidence as reviewed by the Nutrient Adequacy Subcommittee of the Dietary Guidelines Advisory Committee and should have been recognized by inclusion as guidance in the Dietary Guidelines for Americans, 2010.
In its July 14, 2010 written comments to the USDA and HHS, following the release of the Final Report of the Dietary Guidelines Advisory Committee on the Dietary Guidelines for Americans, 2010, GOED strongly encouraged the agencies to consider recommending EPA/DHA dietary supplements and fortified foods in addition to fish in an effort to ensure that consumers can practically meet the advice of the Dietary Guidelines Advisory Committee.