Regulatory Comments
Submitted by the National Restaurant Association
To: U.S. Department of Agriculture, Agricultural Research Service
Date: March 12, 1999
Topic: Dietary Guidelines for Americans

Ms. Shanthy Bowman
U.S. Department of Agriculture
Agricultural Research Service
Nutrient Data Laboratory
4700 River Road Unit 89
Riverdale, MD 20737

Re: FR Docket No. 99-1612

Dear Ms. Bowman:

The National Restaurant Association, representing more than 37,000 members and 175,000 restaurant outlets, would like to comment on the second Dietary Guidelines Advisory Committee meeting. The National Restaurant Association shares the interest in enhancing the public's growing awareness of diet and nutrition. However, we believe that important Dietary Guidelines and nutrition education should continue to be solely nutrition-based and remain absolutely separate from important food safety messages.

As the Dietary Guidelines Committee is aware, the charge to develop the Dietary Guidelines originates from a title in the National Nutrition Monitoring and Related Research Act of 1990 (Pub. L. 101-445). The activities described in this legislation were designed to provide timely information "…about the role and status of factors that bear on the contribution that nutrition makes to the health of the people of the United States." Title I of the Act established a coordinated program and a 10-year comprehensive plan. Data from this coordinated nutrition monitoring program are to be made available and used for the revisions of the Dietary Guidelines for Americans. The organizations designated to prepare relevant reports for this Committee were selected for their recognized involvement with nutrition issues, not food safety.

We support the clear focus of the Dietary Guidelines exclusively on diet and nutrition issues. The suggestion to incorporate food safety messages in the Dietary Guidelines is inherently confusing to the public and thus counterproductive to food safety education. It was also clearly not the intent of the nutrition monitoring legislation. This would duplicate the decades long efforts by industry and other federal agencies that have a long history of developing food safety programs and messages. The recently formed Partnership for Food Safety Education and the FightBac public education campaign is a good example of industry, government and consumer organizations working together to build specific public awareness and understanding of safe food.

The areas of nutrition and food safety have been traditionally funded and professionally addressed by different organizations, albeit within the same agencies. Any attempt to combine these two very different sciences and messages under one set of guidelines would be cumbersome for Committee members and ultimately very confusing to consumers. For example, the inclusion of recommended temperatures for storing food in the Dietary Guidelines when this issue is open to professional discussion would necessitate consultation with food safety experts, and perhaps an overhaul of the Dietary Guidelines Committee itself to incorporate food safety experts. This issue calls into question the appropriateness and legal authority of adding food safety education in the Dietary Guidelines requirements outlined in the original Nutrition Monitoring Act.

Thank you for considering our comments on this issue, and please call on us if we can be of any assistance with your process in formulating these important guidelines for the American public.

Sincerely,

Steven F. Grover, R.E.H.S.
Vice President
Technical Services, Public Health and Safety

Cc: Herman Cain, Stephen Caldeira, Peter Kilgore