IDFA to DGAC: Where Is The Science?

IDFA Calls For Transparency and Accountability in the Dietary Guidelines Process

Ahead of the final public meeting of the Dietary Guidelines Advisory Committee (DGAC), the International Dairy Foods Association (IDFA) is raising concerns about the need for additional transparency and accountability in the DGAC process. In formal comments submitted to the Committee, IDFA urged the DGAC to prioritize the science and ensure open disclosure of the research that informs its recommendations. IDFA called for improvements in the identification of studies considered by the DGAC and the materials presented at public meetings, which should be done alongside the release of draft scientific conclusions for public review and comment.

IDFA, which represents the nation’s dairy manufacturing and marketing industry, highlighted the crucial role that the Dietary Guidelines for Americans (DGA) play in shaping federal nutrition programs and influencing consumer health. With such a broad and significant impact, IDFA emphasized that the DGAC’s work must be fully transparent and rooted in science.

“While we appreciate the DGAC’s efforts to analyze a vast body of scientific evidence, more can and must be done to ensure transparency and accountability in the process,” said Roberta Wagner, senior vice president of regulatory and scientific affairs at IDFA. “The credibility of the Dietary Guidelines depends on the public’s ability to trust that the recommendations are grounded in the best available science.”

IDFA and its members have for months been highlighting transparency concerns with the DGAC process, including in a letter to the Secretaries of the Departments of Health and Human Services and Agriculture and a letter to congressional leaders. The DGAC plans to issue its final Scientific Report to HHS and USDA in the next few weeks. HHS and USDA will use the report to inform the 2025-2030 Dietary Guidelines for Americans report which they are responsible for writing.

IDFA’s key recommendations to the DGAC:

• Real-time Publication of Considered Studies: IDFA urged the DGAC to make publicly available the list of all studies considered for each scientific question as soon as possible, along with the rationale for the inclusion or exclusion of each study.
• Availability of Meeting Materials: IDFA called for the timely release of all materials related to DGAC public meetings, including agendas, scientific study spreadsheets, and slides presented at the meetings, in advance of and immediately following meetings.
• Concurrent Release of Conclusions and Data: IDFA recommended that the DGACs establish processes to release draft scientific conclusions concurrent with the studies that support them, allowing for a more informed public review.

In its comments to the DGAC, IDFA pointed to the September 2024 public meeting, where an additional study led to the upgrading of a scientific conclusion from “limited” to “moderate.” This demonstrated the need for greater stakeholder input to help identify any possibly overlooked studies. Additionally, IDFA expressed concern over the limited time provided for reviewing the draft scientific conclusions on saturated fats and cardiovascular disease, which could have significant implications for full-fat dairy products.

“Transparency is crucial for a science-based process, and IDFA believes that more timely sharing of the studies and conclusions would ensure that the best science is driving the recommendations,” said Wagner.

IDFA also questioned the DGAC’s handling of specific studies, citing examples where review protocols were updated to restrict the inclusion of previously eligible studies. This could affect the final conclusions and IDFA urges the DGAC to clarify the number and types of studies included in its reviews.

As the DGAC prepares its Scientific Report for the 2025-2030 Dietary Guidelines, IDFA called for continued collaboration to ensure the guidelines reflect robust scientific evidence. “We believe that a transparent and rigorous process will result in guidelines that serve the public well and support healthy, evidence-based diets including nutritious dairy,” Wagner concluded.