World Health Organization Report Faces Data Quality Challenge

The Center for Regulatory Effectiveness (CRE) filed a request for correction Sept. 8 to the U.S. Department of Agriculture (USDA) and the Department of Health and Human Services (HHS) under the agencies' data quality guidelines. The petition challenges the World Health Organization (WHO) Technical Report 916 called Diet, Nutrition and the Prevention of Chronic Diseases. USDA and HHS plan to base part of their 2005 Dietary Guidelines on the report. CRE claims that the report qualifies as influential information under the data quality guidelines and fails to meet guideline standards for objectivity and utility; specifically, the petition claims the report is neither transparent nor reproducible. CRE maintains that the data quality guidelines apply to the WHO report because USDA and HHS plan to disseminate the report. Currently the report is disseminated through WHO's website but not from either agency. Therefore, this challenge seems premature since the data quality guidelines would not apply to the report unless either of the agencies actually disseminates it. There are two specific recommendations in the report that CRE finds to be flawed. The first is the WHO's recommendation that to sustain a healthy diet, total carbohydrates should comprise 55-75 percent of the diet. CRE argues that this recommendation contradicts many successful low carbohydrate diets in the U.S. The second recommendation the group disputes is that free sugars should stay below 10 percent of the total energy goal. They cite other dietary intake guidelines that suggest a maximum level of 25 percent sugar. It is unclear why CRE is targeting these numbers specifically. The CRE proposes the following corrective steps:
  • USDA and HHS should review the WHO report prior to dissemination to determine what corrections are needed and publish a corrected supplement to the report..
  • The USDA/HHS press release suggesting that the 2005 dietary guidelines will incorporate recommendations from the WHO report should be retracted.
  • The agencies should inform WHO and the U.N. Food and Agriculture Organization of non-compliance and explain that the report cannot be used until the data meets U.S. standards.
CRE makes a weak argument for being an affected party, stating that the 2005 Dietary Guidelines will affect all Americans, including employees of CRE. The petition states, "Americans run the risk of being less healthy than if these recommendation were based on impartial scientific facts and analyses that met the U.S. Government's data quality standards." However, this assertion does not explain how the CRE is affected by the WHO report, only how they will be affected by the future dietary guidelines.
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