INCA 2020 DGAC Nominations Letter

October 6, 2018

Brandon Lipps

Acting Deputy Under Secretary

Food, Nutrition, and Consumer Services

U.S. Department of Agriculture

1400 Jefferson Drive SW

Washington, DC 20024


Admiral Brett P. Giroir

Assistant Secretary for Health

Office of the Assistant Secretary for Health

U.S. Department of Health and Human Services

200 Independence Avenue SW

Washington, DC 20201


RE: Announcement of Intent to Establish the 2020 Dietary Guidelines Advisory Committee and Solicitation of Nominations for Membership


Dear Mr. Lipps and Admiral Giroir:

The Infant Nutrition Council of America (INCA) is an association of manufacturers of infant formula, follow-up formula and growing up milks in the United States. Our members* produce over 95% of the infant formula that is consumed in the U.S. and we work closely with regulatory agencies including FDA, USDA and CDC to ensure infant formula is safe, nutritious and of the highest quality. As INCA members have decades of experience in infant feeding research, we are well positioned to help inform the B-24 Guideline development process, particularly with regard to nominating experts to serve on the Dietary Guidelines Advisory Committee (DGAC).

As stated in previous INCA comments regarding the 2020 Dietary Guidelines for Americans (DGA), we strongly support expanding the Dietary Guidelines for Americans to include recommendations for 0 to 24 month olds (B-24). This presents a significant opportunity to promote healthy growth and development as well as enhance nutrition and feeding experiences of all infants and young children. INCA strongly recommends that the B-24 Guidelines are:

  • Evidence-based, reflecting the current body of literature as well as reflecting the limitations within the current state of the science;
  • Balanced by reflecting cultural sensitives, and addressing the full spectrum of infant feeding (i.e., breastfeeding, pumped and donor milk feeding, and infant formula feeding); and
  • Developed by experts with specific expertise in pediatric and infant nutrition.

To address properly the topics and questions, which the 2020 DGAC will examine, experts are needed in many disciplines including pediatric nutrition, nutritional epidemiology, nutrition related to growth and development and evidence-based or systematic review methodology. Therefore, INCA would like to nominate the following individuals to address these areas of expertise. They have accepted the nomination from INCA as well as other organizations.

Pediatric Nutrition – Ronald Ellis Kleinman, MD
Massachusetts General Hospital for Children
175 Cambridge Street, 5th Floor
Boston, MA 02114-2696
Telephone: (617) 724-2911

Dr. Kleinman is a Pediatrician and Physician-in-Chief at Massachusetts General Hospital for
Children and former Chair of the Committee on Nutrition of the American Academy of
Pediatrics. Dr. Kleinman’s major areas of research interest and expertise include gastrointestinal
immunology, nutrition support of infants and children, and nutrition and public health policy. Dr.
Kleinman’s specific understanding of infant feeding practices and their impact on health, growth
and development will be critical in answering questions under review for the B-24 population.
INCA is aware that a number of other organizations are nominating Dr. Kleinman.

Nutritional Epidemiology – Regan Bailey PhD, RD, MPH, CPH
Associate Professor of Nutrition Science
Faculty Associate, Center of Aging and the Life Course
Stone Hall, Room 143A
700 West State Street
West Lafayette, IN 47907
Telephone: (765) 494-2829

Dr. Regan Bailey is a nutritional epidemiologist serving as Associate Professor of Nutrition
Science at Purdue University. Prior to Purdue, Dr. Bailey served as a Nutritional Epidemiologist
and Director of Career Development and Outreach at the NIH in the Office of Dietary
Supplements, Office of Disease Prevention. Some of Dr. Bailey’s current research is focusing on
understanding the role of nutrition in early childhood. She is working with the 2016 Feeding
Infants and Toddlers Study (FITS), a national, cross-sectional survey to evaluate the diets and
feeding practices of U.S. infants and children <48 months. Dr. Bailey’s perspective as nutritional
epidemiologist, registered dietitian, and her understanding of the limitations of dietary intake will
bring an important perspective to the committee allowing for the development of realistic
recommendations for all life stages, but particularly the B-24 population.
INCA is aware that a number of other organizations are nominating Dr. Bailey.

Evidence-Based and Systematic Review Methodology

INCA understands that a number of individuals with expertise in evidence-based medicine,
systematic review methodology, study design and analysis and reproducibility of research have
been nominated by other organizations. INCA strongly supports the inclusion of nominees with
expertise in these areas. The ability to make evidence-based recommendations requires critical
review of the quality of evidence that exists. When there is limited, high-quality evidence
available, related recommendations should reflect this. Individuals without specific nutrition
expertise should be considered.

INCA is aware that a number of organizations submitted full nomination packages, including CVs and
AD-755 forms for Dr. Kleinman and Dr. Bailey. We strongly support their nominations. Finally, INCA
appreciates the opportunity to provide nominations to serve on this important Advisory Committee and
we look forward to continued transparency during the development of the 2020 DGAs and participating
in public meetings and providing further comment throughout the DGA review process.

* INCA members are Abbott Nutrition, Gerber Products Company, Perrigo Nutritionals, and Reckitt Benckiser.


Mardi K. Mountford, MPH
(678) 303-3027
3200 Windy Hill Road SE
Suite 600W
Atlanta, GA 30339

Raymond DeVirgiliis, MPH
Scientific and Nutrition Affairs
(202) 207-1104
750 National Press Building
529 14th Street NW
Washington, DC 20045