Dietary guidelines of ICMR-NIN fail to do due diligence, exhibit food bias

Also read: Dietary guidelines released after 13 years

Relegating ‘ghosts’ to the past

It is surprising that, without any national consultation or consensus, NIN is orchestrating this position; why is there such a hurry to show India in such a good light? This seems to be in keeping with a broader agenda of erasing incriminating data to project India as a superpower where all kinds of malnutrition are relegated to a ghostly past.

Several objections have already been raised to a group of researchers from India who claimed in June 2021 that their analysis of CNNS shows that anaemia is much lower than current levels – another ‘ghost’ relegated to the past!

In reality, is it possible to erase the fact that even before the pandemic, data from the same CNNS shows that 36 percent of children under five in India were stunted and 33 percent underweight? Forty-two percent of children from the Scheduled tribes and 36 percent from the Scheduled castes were underweight. This was 48 percent in children from the poorest wealth quintile compared to 19 percent from the richest quintile. India ranks 111 on the Global Hunger Index (GHI)ing

, with 125 being the poorest performance.

Is it also possible to erase the fact that only 21 percent of children aged 6-23 months were fed an adequately diverse diet, that just six percent had received a minimum acceptable diet, and only nine percent had received iron-rich foods? In most states, cereals were the most commonly consumed food group (over 85 percent), while eggs, fish, chicken or meat were least commonly consumed ( less than five percent) among school-age children and adolescents.

Questionable indicators chosen by DGI

Instead of time-tested indicators of weights and heights, which provide easily measurable data to assess undernutrition, food adequacy, affordability and diversity, the DGI has chosen to foreground data on cholesterol, triglycerides, diabetes, hypertension, etc. First, cholesterol is no longer a nutrient of concern, so referring to it here only shows a failure to examine current research. Secondly, one cannot treat children like adults regarding fats. Thirdly, even adults have to correlate lab tests with clinical findings. Why not extend this rationale to children?

The DGI defines a healthy meal/food as including only vegetables, whole grains, pulses or beans, nuts or seeds, fruits, and yoghurt with no sugar and minimal oils/fats. Eggs, fish, meat, poultry, etc., appear sometimes in footnotes, almost like an afterthought, and sometimes disappear completely.

As per the CNNS, the deficiency of vitamin A was 16-22 percent, of Vitamin D 14-24 percent, of zinc 17–32 percent, of vitamin B12 14-31 percent, and of folate 23-37 percent, pointing to high levels of malnutrition. An important solution would be recommending nutrient-dense animal-source foods (ASF), which provide all nutrients in a digestible and bioavailable form.

Plant foods contain nutrients, but anti-nutritional factors like lectins, phytates, tannins, oxalates, etc., may limit digestibility and absorption. As mentioned in the DGI, processes such as germination and fermentation can improve absorption. The DGI acknowledges – “Due to the limited availability and high cost of pulses and meat, a significant proportion of the Indian population relies heavily on cereals, resulting in poor intake of essential macronutrients and micronutrients.’

Anti-meat stance

A young scientist from NIN said that getting their committees to include adequate amounts of milk, eggs, poultry and meat in the recommended diets is difficult. “While milk is still not a taboo subject in the institute, recommendations made in the past to include meat, including beef, did not make it even to the minutes of meetings.”

NIN seems to be proving exactly this point in its DGI. In one place, it mentions that meat, poultry, fish, and eggs are the best protein sources and that the protein in pulses and nuts lacks some essential amino acids. On another page, it mentions the weekly consumption of 700 -900 gm of meat/eggs/fish or poultry.

Then, they leave out these foods in their balanced diet recommendations. In fine print below the table, they refer to substituting ‘30 gm of pulses/dal’ with ‘fish, chicken, meat or egg for non-vegetarians’ as though these are all nutritionally interchangeable. How can 30 gm pulses be equivalent to meat nutritionally? Vitamin B12, of which there is a deficiency as per the CNNS data, can only come from animal-source foods.

In their dietary recommendations, they only mention the consumption of ‘non-veg items like fish, egg, and chicken as per social acceptability and availability’ in the fine print. How will this ‘social acceptability and availability’ translate to the mid-day meals currently being provided by Sattvik NGOs? Clearly, the foods downplayed by the NIN do not find social acceptability even by the organisation!

Attempts to erase anaemia

The DGI claims that anaemia is now ‘sub-clinical’. However, anaemia is 24–41 percent, most prevalent in children from the scheduled tribes/castes. Anaemia is, in fact, a moderate or severe public health problem in almost 27 states. The CNNS doesn’t even estimate anaemia beyond 19 years, so how did NIN decide it is subclinical? Should obstetricians relegate anaemia-related pregnancy complications to the ‘sub-clinical’? Has there been a study by NIN on this?

The dietary guidelines blame unhealthy, ultra-processed foods for anaemia and folic acid deficiency rather than inadequate consumption of haem-iron-rich foods like red/organ meats because of the over-consumption of monotonous cereal-based diets. They mention that whole grains, pulses, beans, nuts, fresh vegetables, and fruits are ‘micro-nutrient dense foods’ while acknowledging that iron’s bioavailability is better from animal rather than plant sources – all in all, a very garbled document.

Animal-source food link to undernutrition ignored

The guidelines expose the experts’ ignorance about most people’s lives in India. They assume that India is a ‘vegetarian‘ country where all animal foods other than milk are not socially acceptable. They have relegated nutrient-dense foods like meats, poultry, eggs, and fish to the footnotes or small print. Concerningly, they also suggest that undernutrition, stunting, and other deficiencies are a thing of the past and separate from bigger issues such as obesity and non-communicable diseases.

Do people making policies and guidelines really believe that Indians would not have sunk further into undernutrition during and after the pandemic? What is the urgency to bring out dietary guidelines without even having the courage to ask for a National Nutritional survey post-Covid?

Vinod Paul, member of the Niti Ayog, in his foreword, and the DGI claim to be diverse and flexible. In reality, they seem to cater mainly to the country’s 20 percent self-identified vegetarians, the government, which wants to look good, and corporate-led bodies like the Eat Lancet Commission, which is pushing for plant-based foods.

Erasing anthropometry and denying data only makes malnutrition invisible on paper, not in reality. The DGI influences not only personal choice but also educational policies, food schemes, and ‘health education’ messages. The NIN must legitimise nutrient-dense animal-source foods to manage stunting, undernutrition, and anaemia rather than relegate them to ‘subclinical’ issues. The NIN needs to act like a responsible organisation that can affect the nutritional and health outcomes of thousands in the country.

(Dr Sylvia Karpagam, a public health doctor, with inputs from members of the Working Group on Health and Nutrition. Views are personal.)