January 27, 2000
FSIS Docket Clerk
US Department of Agriculture
Docket #99-050IF
Room 102
Cotton Annex Building
300 12th Street, SW
Washington, DC 20250-3700
RE: Food Labeling: Nutrient Content Claims, Definition of Term: Healthy
The Salt Institute supports the interim final rule delaying until 2003 the effective date for the lowered, second tier, sodium limits used to define a "healthy" food. In fact, the Salt Institute would suggest that USDA use the intervening time to conduct a review of the science on this issue to establish the basis for removing altogether any sodium-related disqualification for the term "healthy." Attached is a powerful article published by the American Academy for the Advancement of Science suggesting that there is more "politics" than "science" in maintaining the current approach1 and that the current policy of general sodium restriction be revised.
The public health intent of this rule is to lower the incidence of cardiovascular events associated with hypertension. Coincidentally, this week, the Department of Health and Human Services released the Healthy People 2010 national health objectives and they contain neither any cardiovascular disease objectives, nor even cross-references to dietary sodium. In all six studies2 of the incidence of heart attacks relative to dietary sodium intake levels, no association has been found to suggest people who consume higher sodium diets are at greater risk – instead, about half those studies suggest the exact opposite: that low-sodium diets confer a higher risk of heart attacks.
Experts were convened by the National Heart, Lung and Blood Institute a full year ago and registered conflicting opinions on the proper public policy. Disappointingly, the promised publication of an article summarizing the discussion has not yet appeared in the literature.
More recently, our northern neighbor, Canada, has completed a policy review of this issue. It is enclosed. A joint declaration of the Canadian Hypertension Society, Canadian Coalition for High Blood Pressure Prevention and Control, Health Canada Laboratory Centre for Disease Control, and the Heart and Stroke Foundation of Canada stated unequivocally:
"Restriction of salt intake for the normotensive population is not recommended at present because of insufficient evidence demonstrating that this would lead to a reduced incidence of hypertension."3
We would ask with authors of the most recent scientific review of this evidence: "Dietary Salt Reduction in Hypertension – What is the Evidence and Why Is it Still Controversial?"4
Thus, rather than use the next three years to browbeat the food industry into somehow overcoming enduring consumer preferences for foods with "normal" amounts of sodium, USDA would be well-served to use this time to reconsider, independently, the wisdom of its entire approach.
Thank you for your consideration.
Sincerely,
Richard L. Hanneman
President, Salt Institute
References:
1 Taubes, G. "The (Political) Science of Salt," Science 281: 898-907 (1998).2
Alderman, M.H. et. al. "Low Urinary Sodium Is Associated With Greater Risk of Myocardial Infarction Among Treated Hypertensive Men," Hypertension, 25: 1144-1152 (1995). Cutler, J. May 30, 1997 at American Society of Hypertension annual meeting (unpublished). Alderman, M.H. "Dietary sodium intake and mortality: The National Health and Nutrition Examination Survey (NHANES I), Lancet, 351: 781-785 (1998). Tunstall-Pedoe, et al. "Comparison of the prediction by 27 factors of coronary heart disease and death in men and women of the Scottish Heart Health Study: Cohort Study," British Medical Journal, 315: 722-729 (1997).Valkonen, V-P. "Sodium and Potassium Excretion and the Risk of Acute Myocardial Infarction" October 15, 1998 at American Heart Association Scientific Sessions, Dallas (unpublished). Cohen, J.D. January 28, 1999 at NHLBI Workshop on Sodium & Blood Pressure (unpublished). 3 Fodor, J.G. et al, "Recommendations on dietary salt." Canadian Medical Association Journal, 160 (Suppl) S29-S34 (1999). 4 Chrysant, G.S. et al. "Dietary Salt Reduction in Hypertension – What Is the Evidence and Why Is it Still Controversial" in Progress in Cardiovascular Diseases 42: 23-38 (1999).