April 27, 2015
Richard D. Olson, M.D., M.P.H.
Prevention Science Lead and Designated Federal Officer, 2015 DGAC
Office of Disease Prevention and Health Promotion, OASH
U.S. Department of Health and Human Services
1101 Wootton Parkway, Suite LL100 Tower Building
Rockville, MD 20852
Angie Tagtow, M.S., R.D.
Executive Director, Nutrition Guidance and Analysis Division
Center for Nutrition Policy and Promotion
U.S. Department of Agriculture
3101 Park Center Drive, Room 1034
Alexandria, VA 22302
Filed Electronically at:
www.health.gov/dietaryguidelines/dga2015/comments/writeComments.aspx
RE: Comments of the Michigan Agri-Business Association, Michigan Bean Shippers and
Michigan Bean Commission for consideration by the U.S. Department of Agriculture and U.S.
Department of Health and Human Services
Dr. Olson and Ms. Tagtow:
On behalf of the Michigan Bean Commission, Michigan Agri-Business Association and
Michigan Bean Shippers, we are writing to share comments for consideration by the U.S.
Department of Agriculture and U.S. Department of Health and Human Services regarding the
final report of the Dietary Guidelines Advisory Committee (DGAC).
First, we ask that beans be included in the definition of protein foods, particularly in light of their
status as one of the few plant-based sources of protein. Our organizations support the
Committee’s emphasis on the benefits of plant-based foods in healthy dietary patterns for
Americans. However, we are concerned that the final report of the DGAC omits beans from the
definition of protein foods: “a broad group of foods including meat, poultry, fish/seafood, eggs,
soy, nuts and seeds.” Not only are beans an excellent plant-based protein source, they provide a
cost-effective protein source, providing additional benefits within the school lunch and WIC
programs.
Second, we encourage the consistent promotion of nutrient-dense beans to consumers. We ask
that beans continue to be classified in both the Vegetable Food Group and the Protein Food
Group, consistent with the 2005 and 2010 Dietary Guidelines. In addition to their protein value,
beans are excellent sources of folate and fiber, and good sources of potassium, magnesium, iron,
copper, and manganese, and should continue to be included both within the Vegetable Food
Group and Protein Food Group.
Third, our organizations suggest an increased specific emphasis on beans as an excellent source
of fiber and folate, and a good source of potassium, iron and magnesium. Many of these
nutrients, especially fiber, are under consumed by Americans. While beans are an excellent
source of fiber, and typically provide twice the amount of fiber per serving than whole grains,
recommendations for fiber intake in the Guidelines typically highlight whole grains instead of
beans.
Finally, when discussing beans, it is critical that the Guidelines use terminology that consumers
understand – and we request the consistent use of the term “beans” be used throughout the
Dietary Guidelines. Canned beans are purchased by 78.8% of U.S. households, while bagged
beans are only purchased by 20.3% of US households[1], and canned beans outsell bagged beans
by 11-1[2]. Consumer research shows, however, that more than 9 out of 10 consumers exclude
canned beans when asked to associate food products that are “dry” or “dried” beans. Other
terms, such as “pulses” and “legumes” are frequently misunderstood and misinterpreted by
consumers. Consumer research has shown that the best term to use is “beans” followed by a
descriptor of the top-selling types, i.e., “beans, such as black-beans, kidney beans, and pinto
beans.” This term maximizes consumer understanding and is inclusive of all packaging forms.
We recommend the consistent use of the phrase “beans, such as black-beans, kidney beans, and
pinto beans” throughout the Dietary Guidelines.
Once again, we appreciate the work of the Dietary Guidelines Advisory Committee and the
opportunity to share our comments. We hope they are considered and reflected in the 2015
Dietary Guidelines for Americans.
Sincerely,
Jim Byrum
President, Michigan Agri-Business Association
President, Michigan Bean Shippers
Joe Cramer
Executive Director, Michigan Bean Commission
[1]
Nielsen Consumer Panel Services, Calendar Year 2014
Nielsen Scantrack Expanded All Outlets Combined, Based on Units (million) for the 52 weeks ending 2/14/15
[2]