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January 22, 2020

Kristin Koegel USDA Food and Nutrition Service, Center for Nutrition Policy and Promotion Re: Comments from the Grain Chain to the 2020 Dietary Guidelines Advisory Committee, Docket FNS-2019-0001 Filed electronically at www.regulations.gov

Dear Ms. Koegel: The organizations comprising the Grain Chain, a grains industry coalition from farm to table, appreciate the opportunity to provide additional comments to the Dietary Guidelines Advisory Committee (DGAC) as it continues developing the 2020 Dietary Guidelines for Americans (DGAs). This document supports and adds to our comments filed in July 2019, providing new published research for the Committee’s consideration.

Grains Serve as the Cornerstone of a Healthful, Plant-Based Diet

In the July 2019 comments from the Grain Chain, we supported, at a minimum, maintaining the

2015 DGA recommendation of carbohydrate intake within the Acceptable Macronutrient

Distribution Range (AMDR) of between 45-65% of calories and the grain consumption

recommendation of six servings daily of traditional grains with at least half of all grains

consumed as whole grains.(1) In addition, we recommend adding a whole grain serving to

bolster educational information and messaging for consumers around the nutritional benefits

of higher whole grain consumption.

To briefly recap the key health benefits of grain foods from our previous comments:

Both Whole and Enriched Grains Play a Leading Role in Diet Quality. Cumulatively, research

shows that a variety of grain choices consumed across all age groups contribute to nutrient

density in the total diet and have the potential to increase consumption of shortfall nutrients as

identified by the 2015–2020 DGAs, particularly dietary fiber, folate, and iron.(2-11)

Enrichment and Fortification of Grain Foods Have Made Lasting Contributions to Public Health. Enriched grains have the three major B vitamins and iron added to levels in equal or larger amounts to those in whole grain products. These essential B vitamins help maintain healthy cardiovascular and nervous systems and support energy production.(12) Likewise, with this enrichment policy, pellagra and beriberi have been eradicated from the US population.

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• Since folic acid fortification became required in 1998, the prevalence of babies born with neural tube defects (NTDs) has decreased by 35% in the U.S., leading the Centers for Disease Control & Prevention (CDC) to name folic acid fortification one of the top 10 public health achievements of the first decade of the 21st century. https://www.cdc.gov/mmwr/preview/mmwrhtml/mm6019a5.htm

• Other grain products are frequency fortified, such as ready-to-eat (RTE) cereal. RTE cereal is the one of the leading sources of several key nutrients in the diets of American children and adults. For example, RTE cereal is within the top 5 sources of folate, iron, niacin, riboflavin, thiamin, vitamin A, vitamin B12, vitamin B6, and zinc for children and adults, and within the top 5 sources of vitamin D, vitamin C, and fiber for adults [National Health and Nutrition Examination Survey 2015-2016 data].

Grain Consumption Results in Positive Health Outcomes. Meta-analyses on the health benefits

of whole grains are numerous and consistently positive. They show inverse relationships

between whole-grain consumption and risk of major chronic diseases such as cancer, diabetes,

cardiovascular disease and stroke, in addition to a lower risk of dying prematurely from any

cause.(13-32)

Total grain consumption, both refined (enriched) and whole grains, is associated with lower risk

of all-cause mortality and incidence of type 2 diabetes, and not associated with higher risk of

cardiovascular disease, coronary heart disease, stroke or cancer.(33)

In our previous comments, The Grain Chain also noted that Americans continue to under

consume whole grains, so we would support increasing whole grain serving recommendations,

while maintaining at least three servings daily of enriched grains. The body of scientific

evidence, as referenced above, continues to support grain consumption because of its

substantial nutritional contributions and its positive impact on health outcomes.

While the benefits of whole grains are widely recognized, recommending an additional serving

would provide the 2020 DGAs with an opportunity to educate consumers about the importance

of grains in the diet. This could be helpful in “moving the needle” when it comes to Americans

taking action to increase whole grain consumption.

Moreover, such support for whole grains at the federal level could further incentivize food

manufacturers as they invest in whole grain product research, development, and marketing.

This policy could also resonate with the restaurant and food service communities, with the

opportunity for consumers to be introduced to a greater variety of whole grain offerings for

meals and snacks eaten away from home.

The DGA should help consumers in identifying top sources of whole grain in the American diet.

RTE cereal is the number one source of whole grains in the diets of infants and toddlers 6 to 24

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months, and children 2 to 17 years and it is the number two source after breads for adults 18 to

54 years and adults 55 years and over (see Figure 1 for top sources of whole grains in the

American Diet).

Figure 1- Top Sources of Whole Grains in the American Diet, NHANES 2015-2016

Data source: National Health and Nutrition Examination Survey (NHANES) 2015-2016;

excludes pregnant and lactating women. Based on day 1 24 hr dietary recall.

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Historical Dietary Pattern Data and Newly-Published Research Supports Grain Food Consumption at all Life Stages

The health benefits of grain foods are firmly established along with their important nutritional and health contributions to the dietary intake of all Americans.(34, 35, 36).

Study Demonstrates Significant Impact of Federal Policy on Whole Grain Consumption in School Meals

Recent analysis from the US Department of Agriculture’s Economic Research Service (ERS) provides valuable insight into the potential impact of federal nutrition policy on consumer behavior – in this case involving children and school meals.

Published in July 2019 in The American Journal of Preventive Medicine, the study examined changes in whole grain consumption since publication of the 2005 DGAs, and the 2012 school meal standards which required at least half of all grain foods in school lunches be whole grain−rich (i.e., at least 50% whole grains).(37)

During 1994−2006, the whole grain/total grain ratio of schoolchildren’s diets declined. However, following the 2012 USDA school meal regulations, both the propensity (proportion of students consuming whole grains) and intensity (amount consumed by whole grain consumers) of whole grain consumption from school rose significantly.

Specifically, the whole grain/total grain ratio from all sources fell from 9.7% (1994−1998) to 7.6% (2005−2006) before climbing to 13.5% (2013−2014). Home-prepared foods topped the whole grain/total grain ratio among all sources until surpassed by school foods in 2013−2014 (17.2 vs 21.5%).

Overall, the whole grain/total grain ratio from school rose from 4.0% to 21.5% during 1994−2014. The study concluded that, among those consuming school foods, increased intensity contributed more than propensity to increases in whole grain intake from school between 2005−2010 and 2011−2012. The opposite occurred between 2011−2012 and 2013−2014 because of increasing propensity, from one in four to one in two students consuming whole grains.

This analysis shows that federal policy can and does affect consumer behavior. Thus, as Americans continue to under consume whole grains, the recommendation of an additional whole grain serving, while maintaining the current recommendation of three servings of enriched grains, could provide new momentum to whole grain consumption in the US.

Moderate to High CHO Diets Containing Grains Should Be Encouraged, Especially for Young Children

We also urge the Committee to encourage moderate to high carbohydrate diets containing grain foods, especially for young children, who are learning to eat nourishing foods as part of a healthful eating pattern with emphasis on plant-based foods.

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Grain foods are essential to growth and development in infants and children. Cereal and rice

are among the first solid foods eaten by infants, providing key nutrients for growth and

development. Enriched grains are an especially important source of iron, a shortfall nutrient, as

well as several B vitamins. These grain foods also aid in the transition to solid foods for infants.

Furthermore, incorporating whole grains into the diets of toddlers and young children will help

them adapt to the taste and texture of whole grains, which in turn, may result in the adoption

of whole grains at an earlier age while moving young children toward meeting the whole grain

intake recommendation.

New Data Illustrates Benefits of Grain Consumption in 6-23-Month-Old Children

There are limited data on dietary patterns of infants and toddlers, and even less evidence

addressing the role of grain foods in this population. However, we are able to provide the DGAC

with newly-published data examining grain food consumption in American infants and toddlers

aged six to 23 months, based on NHANES data from 2001-2016.(38) This is the first study in

infants using data from NHANES 2001-2016 to examine grain consumption and associations to

nutrient intakes, diet quality and food group intakes.(39)

Key study conclusions for Infants 6-23 months:

• Grain food consumers have higher daily intakes of protein and dietary fiber – 60% and 67% more, respectively – while having a higher daily caloric intake versus non-consumers.

• Grain food consumers have higher daily calcium, magnesium, phosphorus, potassium, and zinc intake than non-consumers. Further, infant grain consumers have higher daily folate, niacin, riboflavin, thiamin, choline, B12, and B6 intakes.

• Consumers of all grain foods, cooked grains, breads/rolls/tortillas, ready-to-eat cereals, cooked cereals, yeast breads, breads, and tortillas/rolls all have better diet qualities, as measured by USDA’s Healthy Eating Index (2015), versus non-consumers in each of these grain categories.

• Consumers of all grain food categories (except crackers) have higher total fruit intake versus non-consumers. Further, infants consuming all grain foods and cooked cereals consume higher amounts of total vegetables versus non-consumers.

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• Consumers of bread, rolls, and tortillas consume about 54% more whole grains versus non-consumers of bread, rolls, and tortillas.

The study concludes that eliminating or reducing grain foods in the diets of American infants

and toddlers 6-23 months old may have unintended nutrient/food group and diet quality

consequences. As stated by the study authors: “While staying within caloric needs and

recommendations, and being sensitive to added sugars, saturated fat, and sodium intake,

caregivers are encouraged to select whole and enriched grain foods that contribute nutrient

density.”

This research provides data that is important to understanding the role and contributions of

grain foods in the diet of the B-24 age group. We urge the Committee to consider this data as

part of its scientific review.

FDA Dietary Fiber Definition Positively Impacts Consumers Through Grain Product Innovation

In an important development since publication of the 2015 DGAs, the Food and Drug

Administration (FDA) in May 2016 published the Nutrition and Supplement Facts Label Final

Rule establishing a definition for the term “dietary fiber” to ensure that only fibers with a

beneficial physiological effect on human health could be declared as dietary fiber on the food

label. The new definition includes naturally occurring fibers like those found in fruits,

vegetables, and whole grains, and seven isolated (i.e., extracted from plant sources) or

synthetic non-digestible carbohydrates (NDCs), each having a physiological health benefit.(40)

As part of the final rule, FDA identified seven of these fibers as meeting the dietary fiber

definition. However, FDA added that manufacturers may submit a citizen petition for its

consideration to add a given isolated or synthetic NDC to the FDA’s regulatory definition of

“dietary fiber.”

As a result of such manufacturer petitions, as of the date of these comments, FDA has identified

a total of 17 categories of non-digestible carbohydrates (including a broad category of mixed

plant cell wall fibers) that are either included in the definition of dietary fiber, or are non-

digestible carbohydrates that FDA intends to propose to be added to the definition of dietary

fiber (see Questions and Answers on Dietary Fiber on FDA’s website for a list).

Given that dietary fiber was classified as a shortfall nutrient in the 2015 DGAs as well as listed

as a nutrient of concern in the 2010 DGAs, this is a very positive development for consumers. As

illustrated by the number of new categories of dietary fiber already identified by the agency as

a result of citizen petitions, the food industry is responding favorably to the new rule through

innovation and product development to explore the functionality of these recently-approved

fiber sources to increase the dietary fiber content of their products. This change reinforces the

importance of dietary fiber and the need to educate consumers on the new definition and how

it appears on the food label.

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Pasta Research Provides Further Evidence of Healthfulness of Grains

We wish to bring to the Committee’s attention research being performed on behalf of the US

pasta industry regarding nutrient intake and diet quality which could be useful in future DGAC

proceedings.

When published, the Grain Chain will submit more detailed information for the DGAC’s

consideration. The abstracts for each presentation listed below are included in Appendix A.

• Adult Nutrient Intakes and Diet Quality and Pasta Intake – abstract presented by Yanni Papanikolaou, The Obesity Society’s Annual 2016 Meeting, New Orleans, LA, November 4, 2016.

o Key Finding: Pasta consumption is associated with higher diet quality including higher intakes of whole grains, total vegetables and the nutrients dietary fiber, folate, iron, magnesium (considered shortfall nutrients), vitamin E and vitamin C and lower intakes of added sugar and saturated fat than non-pasta consumption in adults. Lower body weights and reduced waist circumferences were seen in adult females with increasing tertile pasta consumption compared to non-pasta consumption. No association related to body weight and pasta consumption was found in adult men.

• Children Nutrient Intake and Diet Quality and Pasta Intake – abstract presented by Yanni Papanikolaou, Experimental Biology 2017 annual conference for the American Society of Nutrition (ASN), April 23, 2017, Chicago, IL.

o Key Finding: Pasta consumption is associated with higher diet quality including greater intakes of total vegetables and higher intakes of dietary fiber, folate, iron, magnesium (considered shortfall nutrients) and vitamin E and lower intakes of added sugar and saturated fat than non-pasta consumption in children. No significant associations were seen with body weight, waist circumference and body mass index in children and adolescents.

• Pasta Consumption is Associated with Lower Fat Intake and Higher Consumption of Foods to Encourage in US Adults – abstract presented by Yanni Papanikolaou, Academy of Nutrition and Dietetics Association 2017 Food and Nutrition Conference and Expo, October 24, 2017, Chicago, IL

o Key Finding: Pasta consumption is associated with improved intake of several foods to encourage as recommended by US dietary guidance, including higher consumption of total vegetables, red/orange vegetables, tomatoes and whole grains in the US adult population. Concurrently, pasta consumption is also linked to lower intake of solid fat, which aligns with nutrition recommendations to promote public health. Similar findings were also found in children.

• Pasta Foods are Associated with Improved Nutrient Intakes, Increased Whole Grain and Vegetable Consumption and Nutrient Adequacy in US Adults – abstract presented by Yanni Papanikolaou, Academy of Nutrition and Dietetics

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Association 2019 Food and Nutrition Conference and Expo, October 29, 2019, Philadelphia, PA

o Key Finding: Pasta consumption is associated with improved nutrient adequacy and increased dietary fiber, whole grains and vegetable consumption in US adults. Removal of pasta foods from the diet may lead to unintended nutrient intake and public health consequences.

In conclusion, The Grain Chain appreciates the opportunity to share this information with the

Committee and looks forward to working with you as the process of developing the 2020

Dietary Guidelines continues.

Sincerely,

The Grain Chain: American Bakers Association American Institute of Baking Cereal and Grains Association Grain Foods Foundation Independent Bakers Association National Pasta Association National Association of Wheat Growers North American Millers Association Retail Bakers of America Wheat Foods Council USA Rice Federation

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33. Gaesser G. Perspective: Refined Grains and Health: Genuine Risk, or Guilt by Association?. Advances in

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34.Papanikolaou Y, Fulgoni V. Grain Foods Are Contributors of Nutrient Density for American Adults and Help Close Nutrient Recommendation Gaps: Data from the National Health and Nutrition Examination Survey, 2009-2012. Nutrients. 2017. Aug 14;9(8). pii: E873. doi: 10.3390/nu9080873.

35. Papanikolaou Y, Fulgoni V. Grains Contribute Shortfall Nutrients and Nutrient Density to Older US Adults: Data from the National Health and Nutrition Examination Survey, 2011⁻2014. Nutrients. 2018 Apr 25;10(5). pii: E534. doi: 10.3390/nu10050534.

36. Papanikolaou Y, Fulgoni V. Certain Grain Foods Can Be Meaningful Contributors to Nutrient Density in the Diets of U.S. Children and Adolescents: Data from the National Health and Nutrition Examination Survey, 2009-2012. Nutrients. 2017 Feb 20;9(2). pii: E160. doi: 10.3390/nu9020160

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37. Lin B, Guthrie J, Smith T. Dietary Guidance and New School Meal Standards: Schoolchildren’s Whole Grain

Consumption Over 1994-2014. Amer J Prev Medicine. July 2019, Vol 57, Issue 1, 57-67.

DOI: https://doi.org/10.1016/j.amepre.2019.01.010

38.Papanikolaou, Y, Fulgoni, V. Grain Foods in US Infants are Associated with Greater Nutrient Intakes, Improved

Diet Quality and Increased Consumption of Recommended Food. Nutrients. 2019, 11, 2840;

doi:10.3390/nu11122840. https://res.mdpi.com/d_attachment/nutrients/nutrients-11-

02840/article_deploy/nutrients-11-02840.pdf

39. The study defined grain consumers as those infants consuming grain foods (with the exclusion of mixed dishes)

and breastfeeding during the 24-hour dietary recall as defined by the USDA’s Food Patterns Equivalents Database.

Bowman, S.A.; Clemens, J.C.; Friday, J.E.; Lynch, K.L.; Moshfegh, A.J. Food Patterns Equivalents Database 2013–

2014: Methodology and User Guide [Online]. Food Surveys Research Group, Beltsville Human Nutrition Research

Center, Agricultural Research Service; U.S. Department of Agriculture: Beltsville, MD, USA, 2017.

40.81 FR 33742 - Food Labeling: Revision of the Nutrition and Supplement Facts Labels

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Appendix A

Pasta consumption is associated with greater intake of 2015 Dietary Guidelines’ shortfall

nutrients, a better diet quality and lower added sugar in American adults: Results from the

National Health and Nutrition Examination Survey, 2001-2012

Yanni Papanikolaou

Background: The purpose of this study was to examine associations between pasta

consumption, shortfall nutrient intakes as defined by the 2015 Dietary Guidelines (2015 DG),

and diet quality in comparison to non-pasta consumption in US adults ≥19 years-old; N=400).

Methods: A secondary analyses was completed using datasets from the National Health and Nutrition Examination Survey, 2001-2012. Diet quality was measured using USDA’s Healthy Eating Index-2010. Pasta consumption was defined as all dry domestic and imported pasta/noodle varieties made with only wheat and no egg.

Results: No significant differences were seen in energy intake when comparing adult pasta

consumers vs. non-consumers (2240±63 vs. 2180±8.4 kcal/d). When considering 2015 DG

shortfall nutrients, pasta consumption was significantly associated with increased intake of

dietary fiber (21±0.8 vs. 16±0.1 g/d, p<0.0001), folate, DFE (733±42 vs. 546±4 µg/d, p<0.0001),

iron (18±0.9 vs. 16±0.1 mg/d, p=0.01), magnesium 327±12 vs. 297±2 mg/d, p<0.02), vitamin E

as α-tocopherol (10.0±0.4 vs. 7.7±0.1 mg/d, p<0.0001) and vitamin C (107±8.5 vs. 87±1.2 mg/d,

p=0.019), in comparison to non-pasta consumption. No significant associations were seen for

vitamins A and D, calcium, and potassium intake. Of nutrients to limit, adults consuming pasta

had significantly lower added sugar (16±0.8 vs. 19±0.2 tsp eq/d, p=0.0003) and saturated fat

(25±1.2 vs. 27±0.2 g/d, p=0.04) intake, while no differences were observed for sodium intake

compared to non-pasta consumption. Pasta consumers had a significantly better diet quality

compared to non-pasta consumers (48.9±0.2 vs. 51.0±0.9, p=0.024). Body weight (-1.8 kg,

p=0.027) and waist circumference (-1.7 cm, p=0.009) were significantly reduced with increasing

tertile of pasta consumption compared to non-pasta consumption only in women 19-50 years-

old with no associations seen in males.

Conclusions: Pasta consumption was associated with a better diet quality, improved 2015 DG

shortfall nutrient intakes and lower intake of nutrients to limit relative to non-pasta

consumption in American adults. Lower body weights and reduced waist circumferences were

seen in adult females with increasing tertile pasta consumption compared to non-pasta

consumption.

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Pasta Consumption in American Children and Adolescents is Associated with Greater Daily

Intake of Shortfall Nutrients as Defined by the 2015 Dietary Guidelines, Improved Diet Quality

and Lower Added Sugar Intake

Yanni Papanikolaou

Pasta remains a popular food choice with American children and adolescents, but limited data

is available on the nutritional relevance of pasta consumption. The purpose of this study was to

examine associations between pasta consumption, shortfall nutrient intakes as defined by the

2015-2020 Dietary Guidelines for Americans (2015-2020 DG), and diet quality in comparison to

non-pasta consumption in US children and adolescents 2-18 years-old; N=323). A secondary

analysis was completed using datasets from What We Eat in America, the dietary component of

the National Health and Nutrition Examination Survey, 2001-2012. Diet quality was measured

using USDA’s Healthy Eating Index-2010. Pasta consumption was defined as all dry domestic

and imported pasta/noodle varieties made with only wheat and no egg. No significant

differences were seen in energy intake when comparing adult pasta consumers vs. non-

consumers (2029±52 vs. 1985±9 kcal/d). When considering 2015-2020 DG shortfall nutrients,

pasta consumption was significantly associated with increased intake of dietary fiber (16±0.6 vs.

13±0.1 g/d, p<0.0001), folate, DFE (701±30 vs. 528±5 µg/d, p<0.0001), iron (15.8±0.5 vs.

14.4±0.1 mg/d, p=0.01), magnesium (249±7 vs. 231±1 mg/d, p=0.006), and vitamin E as α-

tocopherol (7.1±0.4 vs. 6.0±0.1 mg/d, p=0.012), in comparison to non-pasta consumption. No

significant associations were seen for vitamins A and D, calcium, and potassium intake. Of

nutrients to limit, adults consuming pasta had significantly lower saturated fat (23±1 vs. 26±0.2

g/d, p=0.007) and total fat (66±2.4 vs. 73±0.5 g/d, p=0.009) intake, while no differences were

observed for sodium, total and added sugar intake compared to non-pasta consumption. Pasta

consumers had a significantly better diet quality compared to non-pasta consumers (48.6±1.0

vs. 45.5±0.2, p=0.0021). No significant associations were seen with body weight, waist

circumference and body mass index. Pasta consumption in children and adolescents was

associated with a better diet quality as measured by USDA’s Healthy Eating Index-2010,

improved 2015 DG shortfall nutrient intakes and lower intake of nutrients to limit (saturated

and total fat), relative to non-pasta consumption.

Pasta Consumption is Associated with Lower Fat Intake and Higher Consumption of Foods to

Encourage in US Adults: Data from the National Health and Nutrition Examination Survey,

2001-2012

Background: The present study examined associations between pasta consumption and US

Department of Agriculture food group intakes in US children/adolescents (2-18 years-old; N=).

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Methods: A secondary analyses was completed using datasets from the National Health and

Nutrition Examination Survey, 2001-2012. Pasta consumption was defined as all dry domestic

and imported pasta/noodle varieties made with only wheat and no egg.

Results: Adults consuming pasta had significantly lower solid fat intake compared to pasta non-

consumers (34.12 ± 1.89 vs. 39.65 ± 0.30 g, p=0.0045). When considering total vegetable intake,

adults consuming pasta had higher daily consumption when compared to adult non-consumers

(1.85 ± 0.10 vs. 1.60 ± 0.02 cup eq., p=0.0096). Pasta consumers had higher consumption of

red/orange vegetables (including tomatoes) when they consumed pasta relative to non-

consumers (0.74 ± 0.1 vs. 0.40 ± 0.01 cup eq., p≤0.0001). Pasta intake was associated with

increased consumption of tomatoes in comparison to adult non-pasta consumers (0.65 ± 0.1 vs.

0.32 ± 0.01 cup eq., p≤0.0001). Pasta consumers also had greater whole grain consumption vs.

non-pasta consumers (1.06 ± 0.12 vs. 0.76± 0.02 oz. eq., p=0.016). There were no significant

association seen when comparing pasta consumers vs. non-consumers for dairy foods and

legume consumption.

Conclusion: Pasta consumption was associated with improved intake of several foods to

encourage as recommended by US dietary guidance, including higher consumption of total

vegetables, red/orange vegetables, tomatoes and whole grains in the US adult population.

Concurrently, pasta consumption was also linked to lower intake of solid fat, which aligns with

nutrition recommendations to promote public health.

Pasta Consumption is Associated with Improved Nutrient Intakes, Increased Whole Grain and

Vegetable Consumption and Nutrient Adequacy in US Adults

Background: Popular diets are encouraging consumption of low carbohydrate diets which may

negatively contribute to nutrient adequacy.

Methods: Usual nutrient intakes and food group intakes were determined in pasta consumers

vs. non-consumers using data from NHANES 2001-2016. Additionally, a modeling analysis was

completed to estimate nutrient adequacy following the removal of 50 and 75% of pasta foods

from the diet (N=1,199; ≥19 yrs-old).

Results: Eliminating 50 and 75% of pasta resulted in a greater percentage of adults not meeting

recommendations for dietary folate and magnesium. For folate DFE, 12.3±0.5% of adult non-

consumers and 4.5±1.4% of pasta consumers were below the Estimated Average Requirement

(EAR). Removing 50% of currently consumed pasta from the diet resulted in a significant

increase in the percentage of adults below the EAR for folate, DFE (8.3±1.7% vs. 4.5±1.4%;

p=0.02). For magnesium, 56.7±0.7% of adult non-consumers and 46.0±2.3% of consumers were

below the EAR. Removing 50 and 75% of pasta currently consumed from the diet resulted in a

significant increase in the percentage of adults below the EAR for magnesium (49.5±2.2% and

51.3±2.2, respectively, vs. 46.0±2.3%, p=0.002 and p=0.018, respectively). Pasta consumers had

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significantly greater protein, dietary fiber, iron, potassium, whole grain, tomatoes and total

vegetable intake vs. non-consumers. No significant differences were seen when examining

intake for added sugar, total sugar, solid fats, total fats, and total fruit intake.

Conclusion: Pasta consumption is associated with nutrient adequacy and increased dietary

fiber, whole grains and vegetable consumption in US adults. Removal of pasta foods from the

diet may lead to unintended nutrient consequences.