Are the Data Underlying the U.S. Dietary Guidelines Flawed?


By Will Block

Y ears in the making, a battle has broken out into the open in the pages of the journal, Mayo Clinic Proceedings. Leading the charge is Edward Archer, PhD, along with Gregory Pavela, PhD and Carl J. Lavie, MD, authors of a new paper, “The Inadmissibility of What We Eat in America and NHANES Dietary Data in Nutrition and Obesity Research and the Scientific Formulation of National Dietary Guidelines.”1

Taking up the defense in an editorial in the same issue are Brenda M. Davy, PhD, RD and Paul A. Estabrooks, PhD: “The Validity of Self-reported Dietary Intake Data: Focus on the ‘What We Eat In America’ Component of the National Health and Nutrition Examination Survey Research Initiative.2

Pseudoscientific and Inadmissible in Scientific Research

At the conclusion of their review study, Archer and his colleagues have written:

In this critical review, we argued that the essence of science is the ability to discern fact from fiction, and we presented evidence from multiple fields to support the position that the data generated by nutrition epidemiologic surveys and questionnaires are not falsifiable. As such, these data are pseudoscientific and inadmissible in scientific research. Therefore, these protocols and the resultant data should not be used to inform national dietary guidelines or public health policy, and the continued funding of these methods constitutes an unscientific and major misuse of research resources [Emphasis added].

False and Deceptive; A Huge Scandal

Wow! If this is true, then the conclusions published by all of the National Health and Nutrition Examination Survey (NHANES) studies and the What We Eat In America (WWEIA) studies are not only misleading, they are false and deceptive. This would represent a huge scandal falsifying many if not most of the nutrition disease relationships and conclusions that dominate the thinking of much of the biomedical community.

No only that: According to the new study, the vast majority of the NHANES/WWEIA data are physiologically implausible (i.e., incompatible with life) and therefore are not valid estimates of food, beverage, and concomitant nutrient consumption. NHANES—harbored at the National Center for Health Statistics, a principal agency of the U.S. Federal Statistical System, which provides statistical information to guide actions and policies to improve the health of the American people—is a program of studies designed to assess the health and nutritional status of adults and children in the United States.

One of the applications of the data from the NHANES studies is to determine whether Americans are deficient in any of the nutrients of which they measure, including:

Vitamin A (μg), Retinol (μg), Carotenoids: Carotene, alpha (μg), Carotene, beta (μg), Cryptoxanthin, beta (μg), Lycopene (μg), Lutein + zeaxanthin (μg), Vitamin E as alpha-tocopherol (mg), added vitamin E (mg), Vitamin D (μg), Vitamin K as phylloquinone (μg), Vitamin C (mg), Thiamin (mg), Riboflavin (mg), Niacin (mg), Vitamin B6 (mg), Folate, total (μg), Folate as dietary folate equivalents (μg), Folic acid (μg), Food folate (μg), Vitamin B12 (μg), Choline, total (mg), Calcium (mg), Iron (mg), Magnesium (mg), Phosphorus (mg), Potassium (mg), Sodium (mg), Zinc (mg), Copper (mg), Selenium (μg), and omega-3 fatty acids (mg)

The Real Issue Is Nutrient Deficiencies

This could mean that instead of the finding—as indicated by prior NHANES studies—that Americans are “Getting Inadequate Amounts of Some Vitamins and Minerals” (see Durk Pearson & Sandy Shaw’s Life Extension News in the November 2011 issue of this publication), that Americans are getter “fewer” amounts of the measly Daily Value amounts deemed adequate. This data alone could change the Pyramid (or “Plate” as of 2011) of recommended daily servings, increasing it in many instances, and causing the federal government to spend a lot more money to insure that school programs and a great many other federal programs achieve food adequacy. Because food is not particularly dense in nutrients and is very costly compared to supplements, this could amount to billions of dollars in increased costs. Then there is also the gigantic amount of money doled out for research that is supportive and consistent with the NHANES protocols.

According to Dr. Edward Archer, first author of the study, the core vice of the NHAMES studies is that they use memory-based dietary assessment methods (M-BMs) (e.g., interviews and surveys). Unequivocal evidence over the years has shown that M-BM data bear little relation to actual energy and nutrient consumption. Data from M-BMs are defended as valid and valuable despite no empirical support and no examination of the foundational assumptions regarding the validity of human memory and retrospective recall in dietary assessment.

The new study asserts that uncritical faith in the validity and value of M-BMs has wasted substantial resources and constitutes the greatest impediment to scientific progress in obesity and nutrition research. In the paper, the researchers present evidence that M-BMs are fundamentally and fatally flawed owing to well-established scientific facts and analytic truths.

The Argument Against Memory-Based Dietary Assessment Methods

According to Archer, et al, “First, any assumptions that human memory provides accurate or precise reproductions of past ingestive behavior are indisputably false.

“Second, M-BMs require participants to submit to protocols that mimic procedures known to induce false recall.

“Third, the subjective (i.e., not publicly accessible) mental phenomena (i.e., memories) from which M-BM data are derived cannot be independently observed, quantified, or falsified; as such, these data are pseudoscientific and inadmissible in scientific research.

“Fourth, the failure to objectively measure physical activity in analyses renders inferences regarding diet-health relationships equivocal.”

Given the overwhelming evidence in support of their position, Archer et al conclude that M-BM data cannot be used to inform national dietary guidelines and that the continued funding of M-BMs constitutes an unscientific and major misuse of research resources.

The Defense Uses the “Foundation” Argument

Defending against the Archer et al review in the same issue of the Mayo Clinic Proceedings, Davy and Estabrooks criticize the review for scientific doublespeak. They quote what they regard as a defining paper authored by the Dietary Guidelines Advisory Committee (DGAC) rooted in two other federal agencies, the US Department of Health and Human Services and US Department of Agriculture.3

As stated by the 2015 DGAC, “repeated 24- hour recalls remain the backbone of dietary assessment and monitoring.”3 Here the editorialists chime in,

The [NHANES/WWEIA] dietary data represent the only comprehensive source of information on the food and nutrient intake of the US population—the survey includes a nationally representative sample of US residents, and dietary intake data are collected using standardized, validated protocols.

These and other sources of broad population assessments of dietary intake and physical activity are the foundation of many seminal articles and research findings that have linked dietary intake and physical activity as key determinants of health. To argue that these data represent a waste of resources, while concurrently citing scientific findings that those same data collection methods were used to document the importance of diet and activity in health, is scientific doublespeak—and an impediment to scientific progress in obesity and nutrition research.

Summarizing Davy and Estabrooks, the NHANES/WWEIA studies use “standardized, validated protocols” which even challengers Archer et al use (clear evidence for this is lacking). Therefore the protocols are valid. Furthermore, there is no other way without being invasive or increasing the costs. The first is not true, the second is doubtful.

Then again the issues of data that cannot be independently observed, quantified, or falsified are handled by Davy and Estabrooks, by making a unfulfilled claim:

[Archer et al] suggest Popper’s criteria for scientific Inquiry—independently observable, measurable, falsifiable, valid, and reliable—as the standard by which to judge recall-based assessments. In this editorial, we provide empirical examples that suggest that, by Popper’s criteria, recall measures can be scientifically sound.

The empirical examples are all special cases, far less likely to be biased than a berated obese persons’ memory about what was eaten. If the subject matter of the NHANES /WWEIA dietary data did not involve the health of millions of Americans, we could cut Davy and Estabrooks some slack. By the way, their work was supported in part by National Institutes of Health grants R21 HD078636 (B.M.D.) and R24 MD008005 (P.A.E.). The federal government is around every corner.

References

  1. Archer E, Pavela G, Lavie CJ. The Inadmissibility of What We Eat in America and NHANES Dietary Data in Nutrition and Obesity Research and the Scientific Formulation of National Dietary Guidelines. Mayo Clin Proc. 2015 Jun 5. pii: S0025-6196(15)00319-5. doi: 10.1016/j.mayocp.2015.04.009. [Epub ahead of print] Review. PubMed PMID: 26071068.
  2. Davy BM, Estabrooks PA. The Validity of Self-reported Dietary Intake Data: Focus on the “What We Eat In America” Component of the National Health and Nutrition Examination Survey Research Initiative. Mayo Clin Proc. 2015 Jun 5. pii: S0025-6196(15)00394-8. doi: 10.1016/j.mayocp.2015.05.009. [Epub ahead of print] PubMed PMID: 26071069.
  3. Dietary Guidelines Advisory Committee. Scientific Report of the 2015 Dietary Guidelines Advisory Committee. Washington, DC: US Dept of Health and Human Services and US Dept of Agriculture; 2015.


Will Block is the publisher and editorial director of Life Enhancement magazine.

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