The Salt Institute has penned an April 11, 2016, letter asking the U.S.
Department of Agriculture (USDA) and Department of Health and
Human Services (HHS) to withdraw the sodium provisions included
in the 2015-2020 Dietary Guidelines for Americans, which advise individuals
to consume less than 2,300 milligrams (mg) per day of sodium.

According to the Salt Institute, these provisions—in addition to those
that appear in the 2010 Dietary Guidelines for Americans—violate the
statutory mandate that requires them to reflect “the preponderance of
the scientific and medical knowledge which is current at the time the
report is prepared.” In particular, the letter argues that both the 2010
and 2015 Dietary Guidelines Advisory Committees (DGACs) based their
sodium recommendations on a 2004 Institute of Medicine (IOM) report
that failed to contain enough evidence to set a recommended dietary
allowance.

“Rather than thoroughly assessing the current scientific and medical
knowledge, the Agencies reached a conclusion in 2005 based on insufficient
evidence and then repeated the error in 2010 and again in 2015,”
states the Salt Institute. “To cure this defect, the Agencies should withdraw
the flawed sodium provisions and subject the topic of appropriate
sodium limits to rulemaking under the Administrative Procedures Act to
ensure that all interested parties are permitted to participate in a public forum and that decision making is supported by sound and current
scientific evidence.”

The letter also deems the procedure for determining these recommendations
“fundamentally flawed” because the DGACs not only “injected
personal bias into both the 2010 and 2015-2020 processes,” but failed to
consider any negative effects of dietary sodium reduction. Among other
things, the committees disregarded studies suggesting that consumers
will eat larger portions of low-sodium foods “to satisfy their innate salt
appetites,” and did not grapple with conflicting evidence regarding the
impact of sodium intake on blood pressure.

But despite the lack of research backing population-wide sodium reduction,
the U.S. Food and Administration (FDA) is poised to set voluntary
salt reductions in food products—a move that the Salt Institute describes
as little more than a capitulation to the Center for Science in the Public
Interest. “A call for voluntary salt reduction in food products holds clear
dangers for consumers,” concludes the letter, which also calls attention
to the effects of regulation on food producers. “It is troubling that the
Agencies have, to this point, adopted a mentality of continuous justification
of a preordained conclusion rather than doing their statutory duty
and setting standards based upon a rigorous assessment of all available
scientific and medical evidence. However, we encourage you to change
this practice and abandon the sodium provisions in the Dietary Guidelines
in favor of an open, transparent rulemaking proceeding. Continuing
to build policy and regulation on a fatally flawed foundation is both bad
government and does nothing to protect our citizenry.”

About The Author

For decades, manufacturers, distributors and retailers at every link in the food chain have come to Shook, Hardy & Bacon to partner with a legal team that understands the issues they face in today's evolving food production industry. Shook attorneys work with some of the world's largest food, beverage and agribusiness companies to establish preventative measures, conduct internal audits, develop public relations strategies, and advance tort reform initiatives.

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