USDA

United States Department of Agriculture

Research, Education, and Economics Agricultural Research Service

March 10, 2020

Mr. Jeffrey Crane Chairman Hunting and Shooting Sports

Conservation Council U.S. Fish and Wildlife Service 5275 Leesburg Pike Mailstop: EA Falls Church, Virginia 22041

Dear Mr. Crane:

Thank you for your letter of December 20, 2019, to Secretary Perdue, in which you discussed the increasing importance of wild fish and game as a source of food and the request of the Hunting and Shooting Sports Conservation Council to include select wild game nutritional data in the U.S. Department of Agriculture (USDA) Food Composition Databases. Earlier in January, Secretary Perdue sent you an interim reply, and I am sending this letter to address your concerns in more detail. The Agricultural Research Service (ARS) is USDA's largest in-house scientific research agency, and we supported the research and operation of the USDA Food Composition Database; we now administer FoodData Central (FDC).

The scientific understanding of relationships between diet and health continues to evolve to meet the needs of a diverse group of stakeholders, including U.S. consumers. The dynamic nature of the U.S. food supply and the many ways food composition data are used generated a need for more representative, easily accessible, and transparent information about food components and food products. As you may know, the USDA Food Composition Database was superseded in April 2019 by FDC, USDA's new integrated, research-focused data system that provides expanded data on nutrients and other food components, and links to related agricultural and experimental research.

FDC includes a group of data called Foundation Foods. This group contains nutrients and other food component values for a diverse range of foods and food ingredients. It also contains extensive metadata on sampling information, study protocols, production practices, and other factors associated with nutrition information. The enhanced depth and transparency of these data provide valuable insights into the many factors that influence variability in nutrient profiles.

Office of the Administrator Jamie L. Whitten Federal Building, Room 302-A

1400 Independence Avenue, SW Washington, D.C. 20250-0300

USDA is an Equal Opportunity Provider and Employer

Mr. Jeffrey Crane Page 2

This information is essential for conducting clinical studies, developing dietary recommendations, and other associated activities. New food-related data included in this resource must meet many strict criteria and have been developed using scientifically rigorous and relevant methods for analyzing, compiling, and presenting nutrient values and associated information.

Another category of FDC data is called Experimental Foods. Information included in this category includes relevant agricultural research data. Plans are being developed to also include information about foods produced under experimental conditions, such as different field conditions, production sites, processing methods, etc. USDA is also considering expanding the Experimental Foods group to accommodate provisional nutrition data ineligible for inclusion in the Foundation Foods group, because the data were obtained from a small number of samples.

Foundation Foods and Experimental Foods are integrated into the same data system that contains the Standard Reference Legacy Release (SR Legacy), which was the primary source for U.S. food composition data for many decades. The last SR Legacy update was made available in 2018, and this information is available in the final version of Standard Reference. Since then, new food composition data have been transitioned into Foundation Foods.

USDA values its academic and industry collaborations on nutritional studies. The project to study nutritional data associated with wild turkey was a collaboration among USDA, Cornell University Extension Service, and the National Wild Turkey Federation and its regional counterparts. Planning for the project began around 2011, and samples were obtained in 2014. This was part of a larger project to sample, analyze, and maintain U.S. data for "locavore" foods, primarily wild game. The wild turkey data were generated when USDA was transitioning to the new database system, and data collection protocols required to meet FDC standards for inclusion were being developed.

The wild turkey data generated as part of this research do not meet the standards for inclusion in Foundation Foods. However, they will be available on the USDA Methods and Application of Food Composition Laboratory website (https://www.ars.usda.gov/northeast-area/beltsville-md-bhnrc/beltsville-human-nutrition-research-center/methods-and-application-of-food-composition-laboratory/mgcl-site-pages/about-mafc1/) until a future FDC version update; at that time, the wild turkey data will be moved to the Experimental Foods data set. Future sampling of other foods consistent with the wild turkey project, such as white-tailed deer, must be planned and conducted in accordance with new robust USDA requirements for sample size, adequate analytical methodology, and associated research protocols.

Collecting and verifying nutritional data for wild fish and game will continue to be challenging, because it is not possible to adequately assess the many production and environmental variables that affect their nutritional content. However, we always strive to ensure USDA research reflects the needs of U.S. stakeholders and customers. We will carefully consider your request to convene a committee of USDA subject-matter experts and others to discuss opportunities for increasing the study and evaluation of nutritional profiles from wild game.

Mr. Jeffrey Crane Page 3

I hope this information addresses your concerns and appreciate your time in bringing these matters to our attention.

Sincerely,

Mt0—

CHAVONDA JACOBS-YOUNG Administrator