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Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens submission

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Bill Shrapnel

Dietitian-Nutritionist    B App Sc, Grad Dip Nutr & Diet, MHP


31 October 2012

 Project Officer – Emma Breen
Public Health Section
Research Translation Group


 Re: Draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens

Thank you for the opportunity to comment on the above document.

Environmental issues are particularly topical at present. As a non-expert in the field of sustainability and environment, I find it difficult to distinguish scientific fact from ambit claim in this contested area. Through the Draft Appendix, the NHMRC has an opportunity to present a state-of-the-art scientific review of this topic and to provide some advice based on this evidence.

 Review of evidence

 Scientific review requires the development of sound arguments, substantiated by research. This aspect of the Draft Appendix is disappointing. The Draft Appendix fails to develop any strong arguments based on the scientific studies presented in Section G5. This is difficult for the reader to interpret. Does the scientific review lack the expected rigor, or is the evidence base simply inadequate to draw any firm conclusions? As this document is to be published under the auspices of the NHMRC the review must be rigorous and evidence needs to be graded. If, consequently, the evidence base proves to be weak, this needs to be clearly stated.

Having read the Draft Appendix I am still unclear as to whether commonly suggested dietary changes to improve environmental outcomes e.g. eating more plant foods and less animal foods, have any firm basis in science.

Dietary recommendations

Given the apparently weak evidence base caution needs to be applied in relation to any dietary recommendations, yet the Draft Appendix devotes Section G3 to this purpose. Predictably, the recommendations are vague and largely unsubstantiated.

Lean meat, poultry and fish. This is the most contentious area. If some protein sources are to be advocated over others on environmental grounds it is important that (1) thisbe clearly based on science and (2) there be no nutritional detriment to the advice.

It would appear that white meats and plant foods are preferred to red meats but no case is made to support this. However, red meats have a nutritional advantage over the other options, particularly in relation to bioavailable iron. Surely this is the rationale for including a specified amount of red meat in the Foundation Diets. As about one-third of young Australian women have some degree of iron deficiency this recommendation appears to be a case of poorly substantiated environmental concerns taking precedence over nutritional need. If the evidence base for this recommendation cannot be strengthened the advice should be withdrawn.

Food variety. Section G3 states that choosing a variety of foods MAY minimize environmental impact.  No supporting evidence is provided for this weak recommendation.

Grains. Section 3 states that choosing a variety of grain foods MAY reduce their overall environmental impact. This lacks an evidence base.

Dairy foods. Section 3 states that consuming a mixture of dairy foods WILL help minimise the environmental burden. This recommendation is made with more conviction but it is not supported by the evidence presented in Section G5.

Fruit and vegetables.  The recommendation in Section 3 to ‘Choose a variety of seasonal and local fresh fruit and vegetables to reduce environmental impact’ is not consistent with Section G5 which says ‘Little Australian information is available on the environmental impact of fruit’.

Given that the Australian Dietary Guidelines have always encouraged the consumption of a variety of foods, most of the above recommendations appear superfluous.

Guiding Principles

Section G2 concludes that the stage is set to begin developing ‘informed, pragmatic and guiding principles to reduce the environmental impact of the food system’. If the guiding principles are yet to be developed it would make sense to use the Appendix to commence this process rather than jumping to dietary recommendations based on assumptions.

There are two issues that are regularly agreed upon at professional meetings in relation to diet and environment – the need to limit overconsumption of food and the need to minimize waste. This could form the basis of a re-drafted Appendix and it is likely that there would be a consensus on these issues.

Summary and recommendations

This Draft Appendix appears to be shaped by white hat bias i.e. the distortion of information in the service of righteous ends. It lacks scientific rigor and the recommendations are vague and unsubstantiated.

 It is recommended that:

  1.  Section G5 be re-written as a scientific review with firm conclusions, based on graded evidence.
  2. All the vague dietary recommendations based on weak evidence in Section G3 be deleted.
  3. The recommendation on choosing between protein foods on environmental grounds be reviewed as it appears to be based on little evidence and is inconsistent with the dietary modelling.
  4. The Draft Appendix be re-focussed on the development of guiding principles to reduce the environmental impact of the food system, especially in relation to overconsumption and wastage.


Page reviewed: 4 February, 2013