Public Comments - 60d FRN

Att. 3b Summary of Public Comments from 60-Day FRN.pdf

Costs of Implementing Community-Based Sodium Reduction Strategies

Public Comments - 60d FRN

OMB: 0920-1259

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Document Metadata:CDC-2018-0029-0002

Document Details
Docket ID:

CDC-2018-0029

Docket Title:

Evaluation of the Sodium Reduction in Communities Program

Document File:
Docket Phase:

Notice

Phase Sequence:

Original Document ID:

CDC-2018-0029-DRAFT-0002

Current Document ID:

CDC-2018-0029-0002

Title:

Comment from (Anonymous Anonymous)

Number of Attachments:

Document Type:

PUBLIC SUBMISSIONS

Document Subtype:
Comment on Document ID:

CDC-2018-0029-0001

Comment on Document Title: Evaluation of the Sodium Reduction in Communities Program
2018-11789
Status:

Posted

Received Date:

06/09/2018

Date Posted:

06/13/2018

Posting Restriction:

No restrictions

Submission Type:

Web

Number of Submissions:

Document Optional Details
Status Set Date:

06/13/2018

Current Assignee:

Status Set By:

Burroughs-Stokes, Kennya LaTrice (CDC)

Tracking Number:

1k2-93mf-3e0e

Page Count:

Total Page Count
Including Attachments:

Submitter Info

Comment:

ISSUE china and India; Why is Air pollution monitoring only
available in one quarter of the population in China and only a
few percent of the population in India, and in both countries,
PM2.5 monitoring networks have only been created very
recently, so long-term trends cannot be assessed. India
pollution levels have kept creeping upwards, 2015 was the
worst year on record. Out of India 89 cities only 17 are
covered by the continuous air quality monitoring system,
Durgapur, Gorakhpur, Asansol, Shiliguri, Bareilly and Ludhiana
are among the most polluted cities without. Therefore, the
2009 Air rules on the USA should not apply since the report
failed to account for all countries. EPA reliance on IPCC an
international organization, this in not fair to America. China
has passed United States in 2011 as the largest global GHG
emitter and China, India, do not ascribe to international GHG
reduction agreements. The emission of the nitrogen dioxide
pollutant has gone up significantly in the South Asia region,
Chhattisgarh region of India, largest increases occurred over
Jamnagar (India), Dhaka (Bangladesh) had the largest increase
(79 per cent) of any world city. Example in city of Ludhiana
India PM 2.5 108 VERY BAD PM 10 Pollution Level: 201 VERY BAD
Extremely High Pollution Index: 89.65 HIGH Pollution Exp
Scale: 162.21 Extremely High Air Pollution 85.42Very High
Drinking Water Pollution 61.05 High , Bad Water Pollution
70.24 High Air quality14.58 Very Low Drinking Water
Quality38.95 Low Water Quality 29.76 Low Mexico, Mexico City
Air pollution data from World Health Organization Info Last
update: March 2018 The air in Mexico City has an annual
average of 20 g/m3 of PM2.5 particles. Thats 100% Worse than
WHO safe level. (WHO recommends PM2.5 at 10 ) PM10 42 Bad
unhealthy PM2.5 20 Red Pollution Index: 85.32Bad unhealthy
Pollution Exp Scale: 153.63 high numbers for very polluted
cities RED Air Pollution 83.33 Very High Drinking Water
Pollution 61.02 High RED unhealthy Water Pollution71.61
HighRedunhealthy Air quality 16.67 Very Low Red unhealthy
Drinking Water Quality38.98 Low Bad unhealthy Water Quality
28.39 Low Bad unhealthy Compare to the USA TEXAS HOUSTON The
air has an annual average of 10 g/m3 of PM2.5 particles. Thats
at the WHO safe level. Healthy, GREEN ALABAMA, Birmingham The
air quality has annual average of 11 g/m3 of PM2.5 particles.
Thats 10% BETTER than WHO safe level. GREEN KENTUCKY ,
Louisville annual average of 11 g/m3 of PM2.5 particles. Thats
10% BETTER than WHO recommended safe level. GREEN
PENNSYLVANIA, Pittsburgh, air quality has an annual average of
10 g/m3 of PM2.5 particles. Thats at the WHO safe level. GREEN
Agency needs to ensure only scientific studies with data
available to the public are used when creating policy.
increase transparency at the EPA and the BLM, boost confidence
in the agencys decision making. improve transparency for the
cost of each decision. Tariffs are needed to protect America
and resend and or cancel the 2009 GHG Regulations.

First Name:

Anonymous

Last Name:

Anonymous

ZIP/Postal Code:
Email Address:

Organization Name:
Cover Page:

Document Optional Details
Submitter Info
Comment:

First Name:

Anonymous

Last Name:

Anonymous

ZIP/Postal Code:
Email Address:
Organization Name:
Cover Page:

Document Metadata:CDC-2018-0029-0003

Document Details
Docket ID:

CDC-2018-0029

Docket Title:

Evaluation of the Sodium Reduction in Communities Program

Document File:
Docket Phase:

Notice

Phase Sequence:

Original Document ID:

CDC-2018-0029-DRAFT-0003

Current Document ID:

CDC-2018-0029-0003

Title:

Comment from (alexi.meredith34@gmail.com)

Number of Attachments:

Document Type:

PUBLIC SUBMISSIONS

Document Subtype:
Comment on Document ID:

CDC-2018-0029-0001

Comment on Document Title: Evaluation of the Sodium Reduction in Communities Program
2018-11789
Status:

Posted

Received Date:

07/14/2018

Date Posted:

07/16/2018

Posting Restriction:

No restrictions

Submission Type:

Web

Number of Submissions:

Document Optional Details
Status Set Date:

07/16/2018

Current Assignee:

Status Set By:

Burroughs-Stokes, Kennya LaTrice (CDC)

Tracking Number:

1k2-94a3-9s14

Page Count:

Total Page Count
Including Attachments:

Submitter Info

Comment:

See attached file(s)

First Name:

Alexi

Last Name:

Meredith

ZIP/Postal Code:

84604

Email Address:

alexi.meredith34@gmail.com

Organization Name:
Cover Page:

Document Optional Details
Submitter Info
Comment:

See attached file(s)

First Name:

Alexi

Last Name:

Meredith

ZIP/Postal Code:

84604

Email Address:

alexi.meredith34@gmail.com

Organization Name:
Cover Page:

July 14, 2018
Jeffrey M. Zirger
Information Collection Review Office
Centers for Disease Control and Prevention
1600 Clifton Road NE, MS–D74
Atlanta, Georgia 30329
RE: Evaluation of the Sodium Reduction in Communities Program 2018-11789
Docket No. CDC–2018–0029
To Whom It May Concern:
Thank you for the opportunity to comment on the proposed Evaluation of the Sodium Reduction in
Communities Program (SRCP). I have a degree in dietetics from Brigham Young University and I am a
nutrition and dietetic technician, registered (NDTR). I am currently completing a dietetic internship
through Utah State University, which allows me to gain supervised practice hours in a variety of
community and health settings in preparation to becoming a registered dietitian nutritionist (RDN). I
have a strong interest in helping individuals attain optimum health, and I believe sodium reduction will
help individuals prevent health complications caused by high sodium intake.
In the US, about 90% of the population consumes too much sodium.1 Children and teens ages 2 to 19
consume an average of over 3,000 mg daily, while adults consume an average of over 3,500 mg daily.2
The way in which food is prepared greatly influences sodium intake. Recent research has shown that
sodium added to food outside the home, including processed and restaurant foods, may account for
over two-thirds (71%) of sodium intake in adults.3 Not all products or food dishes are offered in lowsodium variations, which makes it more difficult for consumers to reduce sodium intake.
A diet lower in sodium can lead to improved cardiovascular health. According to the American Heart
Association (AHA), individuals should eat less than 2,400 mg daily to lower blood pressure, but even
reducing intake by 1,000 mg per day can help.4 If food service organizations even make small changes in
reducing sodium, those changes could help Americans lower their overall sodium intake. Several Healthy
People 2020 goals are also related to reducing sodium intake, including reducing sodium consumption
for ages 2 years and older to 2,300 mg per day (NWS-19) and increasing the proportion of adults with
prehypertension and hypertension who meet sodium intake recommendations (HDS-9.3 and HDS-10.3).5
America needs sodium reduction programs to help meet these important health goals.
Concern 1: Evaluate whether the proposed collection of information is necessary for the proper
performance of the functions of the agency, including whether the information will have practical utility.
The work completed by the SRCP is valuable in helping food service organizations reduce sodium for the
health of the population. The collection of information from grantees and partners will help the CDC
evaluate how the programs are progressing, what strategies have been implemented, and the amount
of resources required for the programs, including cost, time and staff. The information gained from the

evaluation will have practical use in evaluating the success of such programs and giving new
organizations useful information for getting started with their own sodium reduction programs.
There are many food organizations that can benefit from knowing how to implement sodium reduction
programs. AHA is working to achieve a 20% decrease in sodium intake among Americans by encouraging
consumers to write letters and sign petitions to convince large food companies to reduce sodium.6 The
implementation of a new program can be an overwhelming task for any organization to undertake. With
successful programs serving as models, other organizations could have access to strategy ideas and
estimates for cost and other resources so they can effectively implement their own programs. Gathering
information from as many programs as possible will allow for more diverse data, as factors like the size
of the organization and region of the US may influence certain aspects of program implementation.
Evaluating the current programs will only further the nationwide sodium reduction effort.
Thank you for considering my comment on this important matter. I believe the Evaluation of the SRCP
will provide very useful information for current and future sodium reduction programs.
Sincerely,
Alexi Meredith
USU Dietetic Intern

1. Jackson SL, Coleman King SM, Zhao L, Cogswell ME. Prevalence of sodium intake in the United
States. MMWR Morb Mortal Wkly Rep. 2016;64:1394–1397.
2. U.S. Department of Agriculture, Agricultural Research Service. Nutrient intakes from food and
beverages: Mean amounts consumed per individual, by gender and age, in the United States,
2013-2014. Available at:
https://www.ars.usda.gov/ARSUserFiles/80400530/pdf/1314/Table_1_NIN_GEN_13.pdf.
Accessed July 10, 2018.
3. Harnak, LI, Cogswell ME, Shikany JM, et al. Sources of sodium in US adults from 3 geographic
regions. Circulation. 2017;135:1775-1783.
4. American Heart Association. The American Heart Association's diet and lifestyle
recommendations. Available at:
http://www.heart.org/HEARTORG/HealthyLiving/HealthyEating/Nutrition/The-American-HeartAssociations-Diet-and-Lifestyle-Recommendations_UCM_305855_Article.jsp#.W0bDzdJKiuU.
Accessed July 11, 2018.
5. Office of Disease Prevention and Health Promotion. 2020 topics and objectives. Available at:
https://www.healthypeople.gov/2020/topics-objectives. Accessed July 12, 2018.
6. American Heart Association. Creating healthier options in the food supply. Available at:
https://sodiumbreakup.heart.org/lowering_sodium_in_the_food_supply?utm_source=SRI&utm
_medium=HeartOrg&utm_term=Website&utm_content=SodiumAndSalt&utm_campaign=Sodiu
mBreakup. Accessed July 11, 2018.

Appendix 3b. Summary of Public Comments from 60 Day FRN
CDC received two comments related to the previous notice, but neither were substantive.
Comment
ISSUE china and India; Why is Air pollution monitoring only available in one quarter of
the population in China and only a few percent of the population in India, and in both
countries, PM2.5 monitoring networks have only been created very recently, so long-term
trends cannot be assessed. India pollution levels have kept creeping upwards, 2015 was
the worst year on record. Out of India 89 cities only 17 are covered by the continuous air
quality monitoring system, Durgapur, Gorakhpur, Asansol, Shiliguri, Bareilly and
Ludhiana are among the most polluted cities without. Therefore, the 2009 Air rules on the
USA should not apply since the report failed to account for all countries. EPA reliance on
IPCC an international organization, this in not fair to America. China has passed United
States in 2011 as the largest global GHG emitter and China, India, do not ascribe to
international GHG reduction agreements. The emission of the nitrogen dioxide pollutant
has gone up significantly in the South Asia region, Chhattisgarh region of India, largest
increases occurred over Jamnagar (India), Dhaka (Bangladesh) had the largest increase
(79 per cent) of any world city. Example in city of Ludhiana India PM 2.5 108 VERY
BAD PM 10 Pollution Level: 201 VERY BAD Extremely High Pollution Index: 89.65
HIGH Pollution Exp Scale: 162.21 Extremely High Air Pollution 85.42Very High
Drinking Water Pollution 61.05 High , Bad Water Pollution 70.24 High Air quality14.58
Very Low Drinking Water Quality38.95 Low Water Quality 29.76 Low Mexico, Mexico
City Air pollution data from World Health Organization Info Last update: March 2018
The air in Mexico City has an annual average of 20 g/m3 of PM2.5 particles. Thats 100%
Worse than
WHO safe level. (WHO recommends PM2.5 at 10 ) PM10 42 Bad unhealthy PM2.5 20
Red Pollution Index: 85.32Bad unhealthy Pollution Exp Scale: 153.63 high numbers for
very polluted cities RED Air Pollution 83.33 Very High Drinking Water Pollution 61.02
High RED unhealthy Water Pollution71.61 HighRedunhealthy Air quality 16.67 Very
Low Red unhealthy Drinking Water Quality38.98 Low Bad unhealthy Water Quality
28.39 Low Bad unhealthy Compare to the USA TEXAS HOUSTON The air has an
annual average of 10 g/m3 of PM2.5 particles. That’s at the WHO safe level. Healthy,
GREEN ALABAMA, Birmingham The air quality has annual average of 11 g/m3 of

Agency
Anonymous

Response
Action
This comment Out of
is not related to scope
this data
collection

PM2.5 particles. Thats 10% BETTER than WHO safe level. GREEN KENTUCKY ,
Louisville annual average of 11 g/m3 of PM2.5 particles. That’s 10% BETTER than
WHO recommended safe level. GREEN PENNSYLVANIA, Pittsburgh, air quality has an
annual average of 10 g/m3 of PM2.5 particles. Thats at the WHO safe level. GREEN
Agency needs to ensure only scientific studies with data available to the public are used
when creating policy. increase transparency at the EPA and the BLM, boost confidence in
the agencys decision making. improve transparency for the cost of each decision. Tariffs
are needed to protect America and resend and or cancel the 2009 GHG Regulations.
Thank you for the opportunity to comment on the proposed Evaluation of the Sodium
USU
Reduction in Communities Program (SRCP). I have a degree in dietetics from Brigham
Young University and I am a nutrition and dietetic technician, registered (NDTR). I am
currently completing a dietetic internship through Utah State University, which allows me
to gain supervised practice hours in a variety of community and health settings in
preparation to becoming a registered dietitian nutritionist (RDN). I have a strong interest
in helping individuals attain optimum health, and I believe sodium reduction will help
individuals prevent health complications caused by high sodium intake.
In the US, about 90% of the population consumes too much sodium.1 Children and teens
ages 2 to 19 consume an average of over 3,000 mg daily, while adults consume an
average of over 3,500 mg daily.2 The way in which food is prepared greatly influences
sodium intake. Recent research has shown that sodium added to food outside the home,
including processed and restaurant foods, may account for over two-thirds (71%) of
sodium intake in adults.3 Not all products or food dishes are offered in low-sodium
variations, which makes it more difficult for consumers to reduce sodium intake.
A diet lower in sodium can lead to improved cardiovascular health. According to the
American Heart Association (AHA), individuals should eat less than 2,400 mg daily to
lower blood pressure, but even reducing intake by 1,000 mg per day can help.4 If food
service organizations even make small changes in reducing sodium, those changes could
help Americans lower their overall sodium intake. Several Healthy People 2020 goals are
also related to reducing sodium intake, including reducing sodium consumption for ages 2
years and older to 2,300 mg per day (NWS-19) and increasing the proportion of adults
with prehypertension and hypertension who meet sodium intake recommendations (HDS9.3 and HDS-10.3).5 America needs sodium reduction programs to help meet these
important health goals.

This comment Out of
is simply
scope
complementing
the program
associated with
the data
collection

Concern 1: Evaluate whether the proposed collection of information is necessary for the
proper performance of the functions of the agency, including whether the information will
have practical utility.
The work completed by the SRCP is valuable in helping food service organizations
reduce sodium for the health of the population. The collection of information from
grantees and partners will help the CDC evaluate how the programs are progressing, what
strategies have been implemented, and the amount of resources required for the programs,
including cost, time and staff. The information gained from the
evaluation will have practical use in evaluating the success of such programs and giving
new organizations useful information for getting started with their own sodium reduction
programs.
There are many food organizations that can benefit from knowing how to implement
sodium reduction programs. AHA is working to achieve a 20% decrease in sodium intake
among Americans by encouraging consumers to write letters and sign petitions to
convince large food companies to reduce sodium.6 The implementation of a new program
can be an overwhelming task for any organization to undertake. With successful programs
serving as models, other organizations could have access to strategy ideas and estimates
for cost and other resources so they can effectively implement their own programs.
Gathering information from as many programs as possible will allow for more diverse
data, as factors like the size of the organization and region of the US may influence
certain aspects of program implementation. Evaluating the current programs will only
further the nationwide sodium reduction effort.
Thank you for considering my comment on this important matter. I believe the Evaluation
of the SRCP will provide very useful information for current and future sodium reduction
programs.
Sincerely,
Alexi Meredith
USU Dietetic Intern
1. Jackson SL, Coleman King SM, Zhao L, Cogswell ME. Prevalence of sodium intake in
the United States. MMWR Morb Mortal Wkly Rep. 2016;64:1394–1397.
2. U.S. Department of Agriculture, Agricultural Research Service. Nutrient intakes from
food and beverages: Mean amounts consumed per individual, by gender and age, in the
United States, 2013-2014. Available at:

https://www.ars.usda.gov/ARSUserFiles/80400530/pdf/1314/Table_1_NIN_GEN_13.pdf.
Accessed July 10, 2018.
3. Harnak, LI, Cogswell ME, Shikany JM, et al. Sources of sodium in US adults from 3
geographic regions. Circulation. 2017;135:1775-1783.
4. American Heart Association. The American Heart Association's diet and lifestyle
recommendations. Available at:
http://www.heart.org/HEARTORG/HealthyLiving/HealthyEating/Nutrition/TheAmerican-Heart-Associations-Diet-and-LifestyleRecommendations_UCM_305855_Article.jsp#.W0bDzdJKiuU. Accessed July 11, 2018.
5. Office of Disease Prevention and Health Promotion. 2020 topics and objectives.
Available at: https://www.healthypeople.gov/2020/topics-objectives. Accessed July 12,
2018.
6. American Heart Association. Creating healthier options in the food supply. Available
at: https://sodiumbreakup.

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Author	Yarnoff, Benjamin
File Modified	2018-09-26
File Created	2018-09-26