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Australian Dietary Guidelines submission

Personal Details
Organisation Name: 
Department of Nutrition and Dietetics, Monash University
Online comments
Specific comments: 
General comments

Guideline 1: "vegetables and fruit"- no guideline is given about highly processed products advertised to contain fruit/vegetables that are high in salt/sugar/fat. Suggest change eg: 'fruit alone is preferable to composite foods containing fruit"

"lean meat and poultry…" query why meat heads this list when meat consumption (especially in men) is high

"milk, yoghurt, cheese….mostly reduced fat" is not consistent with new evidence on the effects of saturated fats in dairy products on health.

For example:Soedamah-Muthu et al (2011) Milk and dairy consumption and incidence of cardiovascular diseases and all-cause mortality: dose-response meta-analysis of prospective cohort studies Am J Clin Nutr 93(1):158-71.

Dong et al (2011) Dairy consumption and risk of breast cancer: a meta-analysis of prospective cohort studies. Breast Cancer Res Treat 127(1):23-31.

German et al (2009) A reappraisal of the impact of dairy foods and milk fat on cardiovascular disease risk Eur J Nutr. 48(4):191-203.

Tong et al (2011) Dairy consumption and risk of type 2 diabetes mellitus: a meta-analysis of cohort studies Eur J Clin Nutr 65(9):1027-31.

 For yoghurt-there should be some differential between the recommendation for low fat and consideration of carbohydrate load and total energy content.  Many reduced fat yoghurts contain more calories than a standard full fat yoghurt (Walker et al (2010) Yoghurt and dairy snacks presented for sale to an Australian consumer: becoming less healthy?  Public Health Nutrition, 13 (7) 1036-1041). Advice to limit total cheese consumption is more practical than to select low fat cheese.

This guideline should contain advice about the fats and oils group eg:" and cook in oil rather than use solid fats"

The advice to limit "added sugars" is difficult for consumers while Australian food labels only refer to "total sugars"

"Include small amounts of foods that contain unsaturated fats" provides no indication of what a "small amount" means and does not differentiate between different types of unsaturated fat. Food advice (ie types of oils and high fat foods to choose) rather than nutrient advice on fats would mean more to consumers.

Guideline 3: "you should be physically active" would be better as "all people should be physically active"

"and choose amounts of nutritious foods and drinks to meet energy needs" should be changed to "and choose amounts of nutritious foods to meet energy needs. Drink mainly water to quench thirst" to align with guideline 1 "and drink water" as to satisfy thirst -drinks should be predominantly non-caloric in nature.


The strong evidence cited  of "the probable association between consumption of a Mediterranean dietary pattern and reduced mortality (Grade B)", Section 20.1 is not reflected in the guidelines. It is also disappointing that none of the evidence statements relate to consumption of highly processed foods.

There are also no statements on two factors known to contribute to obesity: ie: the increase in portion sizes and the high energy density of many processed foods.

 In terms of the strength of the supporting evidence, guideline 4 should be guideline number 1.

Guideline 2 which gives predominantly advice on nutrients could direct consumers to consult food labels to guide food purchases and to compare foods

The guidelines do not address social aspects of eating and the importance of enjoyment of foods. The guidelines also do not acknowledge the multi-cultural aspects of Australian eating habits- for example advice could be given that some traditional food patterns should be highly valued and retained where possible  

Page reviewed: 3 January, 2013