The Salt Institute has penned an April 11, 2016, letter asking the U.S. Department of Agriculture (USDA) and Department of Health and Human Services (HHS) to withdraw the sodium provisions included in the 2015-2020 Dietary Guidelines for Americans, which advise individuals to consume less than 2,300 milligrams (mg) per day of sodium.

According to the Salt Institute, these provisions—in addition to those that appear in the 2010 Dietary Guidelines for Americans—violate the statutory mandate that requires them to reflect “the preponderance of the scientific and medical knowledge which is current at the time the report is prepared.” In particular, the letter argues that both the 2010 and 2015 Dietary Guidelines Advisory Committees (DGACs) based their sodium recommendations on a 2004 Institute of Medicine (IOM) report that failed to contain enough evidence to set a recommended dietary allowance.

“Rather than thoroughly assessing the current scientific and medical knowledge, the Agencies reached a conclusion in 2005 based on insufficient evidence and then repeated the error in 2010 and again in 2015,” states the Salt Institute. “To cure this defect, the Agencies should withdraw the flawed sodium provisions and subject the topic of appropriate sodium limits to rulemaking under the Administrative Procedures Act to ensure that all interested parties are permitted to participate in a public forum and that decision making is supported by sound and current scientific evidence.”

The letter also deems the procedure for determining these recommendations “fundamentally flawed” because the DGACs not only “injected personal bias into both the 2010 and 2015-2020 processes,” but failed to consider any negative effects of dietary sodium reduction. Among other things, the committees disregarded studies suggesting that consumers will eat larger portions of low-sodium foods “to satisfy their innate salt appetites,” and did not grapple with conflicting evidence regarding the impact of sodium intake on blood pressure.

But despite the lack of research backing population-wide sodium reduction, the U.S. Food and Administration (FDA) is poised to set voluntary salt reductions in food products—a move that the Salt Institute describes as little more than a capitulation to the Center for Science in the Public Interest. “A call for voluntary salt reduction in food products holds clear dangers for consumers,” concludes the letter, which also calls attention to the effects of regulation on food producers. “It is troubling that the Agencies have, to this point, adopted a mentality of continuous justification of a preordained conclusion rather than doing their statutory duty and setting standards based upon a rigorous assessment of all available scientific and medical evidence. However, we encourage you to change this practice and abandon the sodium provisions in the Dietary Guidelines in favor of an open, transparent rulemaking proceeding. Continuing to build policy and regulation on a fatally flawed foundation is both bad government and does nothing to protect our citizenry.”