The U.S. Dietary Guidelines: A Scientific Fraud

By Edward Archer

Recently, my colleagues and I published research in Mayo Clinic Proceedings that examined dietary data from almost 50 years of nutrition studies. What we found was astounding; these data were physiologically implausible and incompatible with survival. In other words, the diets from these studies could not support human life if consumed on a daily basis. The reason for this is simple; the memory-based data collection methods (M-BMs) used by nutrition researchers are unscientific because they rely on both the truthfulness of the study participant and the accuracy of his or her memory. Stated more simply, these methods collect nothing more than uncorroborated anecdotal estimates of food and beverage consumption. 

Importantly, vast amounts of taxpayer dollars are directed away from rigorous scientific investigations and squandered every year on the collection of uncorroborated anecdotes via M-BMs. Approximately 80% of the data in the USDA’s National Evidence Library consists of uncorroborated anecdotes as well as 100% of the dietary data from every major epidemiologic study over the past 50 years (e.g., Nurses’ Health Study, Health Professionals Follow-Up Study, REGARDS project, and EPIC study). In other words, most of what nutrition researchers call “scientific evidence” is in reality a vast collection of nearly baseless anecdotes. Nevertheless, despite a century of unequivocal evidence that human memory and recall are woefully inadequate for actual scientific data collection, the data from these methods are used to create public health policy.  

To date, no researchers have published data that challenge or attempt to refute our findings and conclusions. The reason for this fact is simple: our science is strong and our findings irrefutable. Nevertheless, this has not stopped government-funded researchers and officials from the National Institutes of Health (NIH) from demonstrating an unscientific intolerance to criticism by using rhetoric and fallacious ad hominems in defense of their pseudoscientific methods. While these attacks do nothing to advance the science of nutrition, the fact that taxpayer-funded NIH officials and researchers are attacking and attempting to bully and censor legitimate scientists serving the public suggests that publicly-funded science is in grave jeopardy.

In September of 2015, prior to the publication of the 2015 Dietary Guidelines for Americans, I was invited by President Obama’s Council of Advisors on Science and Technology to present our research on implausible dietary data. The presentation was short and simple: the dietary data from the National Health and Nutrition Examination Survey, “What We Eat In America” study (NHANES /WWEIA) are incompatible with the survival and therefore cannot be used to inform public policy. Nevertheless, the administration proved impervious to contrary evidence and presented the implausible NHANES/WWEIA data as scientific evidence of the “Current Eating Patterns in the United States” in the recently published 2015 Guidelines. This official presentation is patently false and fraudulent. It should be obvious that dietary data that cannot support human life are not an accurate description of the “Current Eating Patterns” of Americans. 

In response to the misrepresentation of the NHANES/WWEIA data, we recently published evidence on the willful manipulation and doctoring of data by government-funded researchers to support current dietary dogma. Yet perhaps the most egregious example of scientific fraud and misconduct in the Guidelines is the use of these implausible dietary data to create fear and uncertainty in American citizens. In chapter 2, the section entitled, "Underconsumed Nutrients and Nutrients of Public Health Concern," states that vitamins A, C, D, E, and iron are under-consumed. This statement is directly contradicted and refuted by the Government’s own objective data (i.e., serum biomarkers). For example, at the time of the last CDC Biochemical analysis, less than 1% of Americans were at risk for deficiencies in vitamins A and E, and 80% of Americans were not at risk for deficiencies in any of the minerals and vitamins measured (including vitamins C, D, and iron). It should be obvious that Americans could not be under-consuming vitamins A, C, D, E, and iron while at the same time maintaining healthy serum levels of these same vitamins and minerals. As such, the Guidelines present alarmist, subjective, implausible dietary data as scientific fact while ignoring the objective, rigorous, and obvious data that Americans are exceptionally well fed.  

The Executive Branch of our Federal government and the government-funded nutrition community have been aware of the empirical refutation and misrepresentation of dietary data for decades, yet this evidence is ignored. Stated more simply, government officials knew the dietary data used to create the Guidelines were patently false but published them as fact.      

The Dietary Guidelines for Americans direct our attention and research resources towards unscientific and specious “nutrients of concern” and dietary dogma while distracting us away from the actual causes of obesity, diabetes and chronic non-communicable diseases. It is well-established that 80% of Americans are not at risk for any dietary deficiencies, yet more than 95% of Americans do not meet the minimum physical activity guidelines. Because of this simple fact, with each passing generation our children become better fed but less fit, less healthy, and fatter. 

Until we replace the unscientific fiction of “we are what we eat” and the uneducated government-funded rhetoric that ‘food is our foe’ with rigorous scientific facts, many American children will live shorter, less fit and less healthy lives than their parents. Given this reality, it is our hope that in the meantime, the fatal conceit and lack of epistemic humility of the researcher-politicians in our Federal Government are constrained by the dictum “Primum non nocere” (First, do no harm). Retracting the fraudulent 2015 Guidelines will be a good start.             

Edward Archer, PhD, MS, is an Obesity Theorist and Computational Physiologist.

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