Jayne Woodside PhD / Bonnie Liebman's October 31, 2015 email petition to retract an investigation by journalist Nina Teicholz

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      Appendix 1

    From: Jayne WoodsideSent: 23 November 2015 08:35To: '[email protected]'Subject: FW: COIs needed for BMJ retraction letter

    Dear Angela,

    Please fine attached.

    Best wishes,

    Jayne

    Professor Jayne WoodsideNutrition and Metabolism GroupCentre for Public Health First Floor  

    Institute of Clinical Science B Grosvenor RoadBelfastBT12 6BJUKTel: 0044 2890 632585Fax: 0044 2890 235900

    From: Bonnie Liebman [mailto:[email protected]] Sent: 19 November 2015 16:08To: Bonnie LiebmanSubject: COIs needed for BMJ retraction letter

    Dear Colleague:

    In response to our letter asking the BMJ to retract the “investigation” by Nina Teicholz, the

     journal has told us that “the BMJ is continuing to review this article and plan to respond more

    fully when our further enquiries are complete.” 

    In the meantime, the BMJ has invited us to post the letter as a rapid response to the online

    article. In order to post the letter, we have to send the journal a conflict-of-interest form for

    each co-signer.

    Please fill out page 4 of the form (attached) and email it back to my colleague, Angela Amico

    ([email protected]). Once we hear from everyone, she will submit the forms to the BMJ.

    More information about competing interests for a rapid response is available here:

    http://www.bmj.com/about-bmj/resources-authors/forms-policies-and-checklists/declaration-

    competing-interests 

    Best wishes,

    Bonnie Liebman

    mailto:[email protected]:[email protected]:[email protected]://www.bmj.com/about-bmj/resources-authors/forms-policies-and-checklists/declaration-competing-interestshttp://www.bmj.com/about-bmj/resources-authors/forms-policies-and-checklists/declaration-competing-interestshttp://www.bmj.com/about-bmj/resources-authors/forms-policies-and-checklists/declaration-competing-interestshttp://www.bmj.com/about-bmj/resources-authors/forms-policies-and-checklists/declaration-competing-interestshttp://www.bmj.com/about-bmj/resources-authors/forms-policies-and-checklists/declaration-competing-interestsmailto:[email protected]:[email protected]

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     _______________________________

    Bonnie F. Liebman, MSDirector of Nutrition

    Center for Science in the Public Interest1220 L St., NW Suite 300

    Washington, DC 20005

    Ph: (202) 777-8335

    Fax: (202) 265-4954

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    From: Bonnie Liebman [mailto:[email protected]] Sent: 05 November 2015 17:27To: Bonnie LiebmanSubject: request for retraction of Dietary Guidelines Advisory Committee report investigation

    Dear Colleague: Thank you for agreeing to sign the letter urging the BMJ to retract its

    “investigation” of the Dietary Guidelines Advisory Committee’s report. The letter was signed

     by more than 180 scientists in 19 countries.

    We sent the final version of the letter (attached) to the BMJ editors this morning. You can

    also find a version of the letter with live links to the footnotes on our website (see URL

     below). The letter notes (at the end of the last page) that affiliations were listed for purposes

    of identification only.

    http://cspinet.org/bmj-retraction-letter.html 

    Best wishes,

    Bonnie Liebman

     _______________________________

    Bonnie F. Liebman, MSDirector of Nutrition

    Center for Science in the Public Interest

    1220 L St., NW Suite 300

    Washington, DC 20005

    Ph: (202) 777-8335Fax: (202) 265-4954

    From: Jeff CroninSent: Thursday, November 05, 2015 10:17 AMTo: [email protected][email protected]: request for retraction of Dietary Guidelines Advisory Committee reportinvestigation

    Dear Editors,

    Please accept this letter asking the BMJ to retract the investigation by Nina Teicholz into the

    report of the Dietary Guidelines Advisory Committee.

    Sincerely,

    Jeff CroninDirector of Communications

    Center for Science in the Public Interest

    1220 L Street, NW, Suite 300

    Washington, DC 20005

    Ph: 202.777.8370

    Cell: 202-421-8911

    mailto:[email protected]://cspinet.org/bmj-retraction-letter.htmlhttp://cspinet.org/bmj-retraction-letter.htmlmailto:[email protected]:[email protected]:[email protected]://qub-staff-cfs1/staff/StaffShared2/InfoMgmt/INFORMATION%20MANAGEMENT/Freedom%20Of%20Information%20Act/Requests%20for%20Information/2015/FOI-15-269%20-%20Mr%20Jones%20(BMJ%20Conflict%20of%20Interest%20form)/cspinet.orghttp://qub-staff-cfs1/staff/StaffShared2/InfoMgmt/INFORMATION%20MANAGEMENT/Freedom%20Of%20Information%20Act/Requests%20for%20Information/2015/FOI-15-269%20-%20Mr%20Jones%20(BMJ%20Conflict%20of%20Interest%20form)/cspinet.orgmailto:[email protected]:[email protected]://cspinet.org/bmj-retraction-letter.htmlmailto:[email protected]

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    From: Angela Amico [mailto:[email protected]] Sent: 04 November 2015 15:23To: Jayne WoodsideSubject: RE: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Great, thank you for your support.

    Best,

    Angela

    Angela Amico, MPH

    Project Coordinator

    Health Promotion Policy & Biotechnology

    Center for Science in the Public Interest

    1220 L Street NW, Suite 300

    Washington, D.C. 20005

    Direct: [email protected]

    From: Jayne Woodside [mailto:[email protected]] Sent: Tuesday, November 03, 2015 2:50 AMTo: Angela Amico Subject: RE: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Dear Angela,

    I am PhD.

    Best wishes,

    Jayne

    Professor Jayne WoodsideNutrition and Metabolism GroupCentre for Public Health First Floor  Institute of Clinical Science B Grosvenor Road

    BelfastBT12 6BJUKTel: 0044 2890 632585Fax: 0044 2890 235900

    mailto:[email protected]://cspinet.org/mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://cspinet.org/mailto:[email protected]

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    From: Jayne WoodsideSent: 02 November 2015 07:52To: Michelle McKinley ([email protected]); Marie CantwellSubject: FW: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Professor Jayne Woodside

    Nutrition and Metabolism GroupCentre for Public Health First Floor  Institute of Clinical Science B Grosvenor RoadBelfastBT12 6BJUKTel: 0044 2890 632585Fax: 0044 2890 235900

    From: Angeliki Papadaki [mailto:[email protected]

    Sent: 01 November 2015 12:48To: Arne Astrup; Saris, Wim; Inge Huybrechts; [email protected]; Inga Þórsdóttir; Andy Ness;[email protected]; Agneta Yngve; Sibylle Kranz; [email protected][email protected]; Antonis Kafatos; Jayne Woodside; Janet Cade; Dianne WardSubject: Fwd: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Dear colleagues,

    Please see attached a suggestion for a BMJ retraction letter, instigated by Frank Hu at

    Harvard. We were asked to circulate the letter for signatures.

    If you agree, please send an email to Bonnie Liebman ([email protected]) with a similar

    content to the below, in blue font, and circulate to your colleagues.

    I have read the full version of the attached letter and Iagree to include my sign on it.I endorse its full content and the request to the BMJ toretract the journalist's article. 

    Kind regards,

    Angeliki

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]

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    From: Angela Amico [mailto:[email protected]] Sent: 02 November 2015 22:22To: Jayne WoodsideSubject: RE: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Thank you for your support of the retraction letter to the BMJ. Can you please respond with

    any post-graduate degrees you may have? We would like to ensure that we correctly credit all

    the signatories.

    Best,

    Angela

    Angela Amico, MPH

    Project Coordinator

    Health Promotion Policy & Biotechnology

    Center for Science in the Public Interest

    1220 L Street NW, Suite 300Washington, D.C. 20005

    Direct: 202-777-8307

    [email protected]

    From: Jayne Woodside [mailto:[email protected]] Sent: Monday, November 02, 2015 2:52 AMTo: Bonnie Liebman Subject: Fwd: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Dear Bonnie,

    I have read the full version of the attached letter and I agree to include my sign on it.

    I endorse its full content and the request to the BMJ to retract the journalist's article.

    Best wishes,

    Jayne

    Professor Jayne Woodside

    Nutrition and Metabolism GroupCentre for Public Health First Floor  Institute of Clinical Science B Grosvenor RoadBelfastBT12 6BJUKTel: 0044 2890 632585Fax: 0044 2890 235900

    mailto:[email protected]://cspinet.org/mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://cspinet.org/mailto:[email protected]

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    From: Angeliki Papadaki [mailto:[email protected]] Sent: 01 November 2015 12:48To: Arne Astrup; Saris, Wim; Inge Huybrechts; [email protected]; Inga Þórsdóttir; Andy Ness;[email protected]; Agneta Yngve; Sibylle Kranz; [email protected][email protected]; Antonis Kafatos; Jayne Woodside; Janet Cade; Dianne WardSubject: Fwd: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    Dear colleagues,

    Please see attached a suggestion for a BMJ retraction letter, instigated by Frank Hu at

    Harvard. We were asked to circulate the letter for signatures.

    If you agree, please send an email to Bonnie Liebman ([email protected]) with a similar

    content to the below, in blue font, and circulate to your colleagues.

    I have read the full version of the attached letter and I

    agree to include my sign on it.I endorse its full content and the request to the BMJ toretract the journalist's article. 

    Kind regards,

    Angeliki

    ---------- Forwarded message ----------From: Miguel Ángel Martínez González Date: 1 November 2015 at 11:36

    Subject: Fwd: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    To: Antonia Trichopoulou , [email protected], Katia

    Esposito , [email protected], Federico Jose

    Armando Perez Cueto Eulert , "ligia.dominguez"

    , Matthias Schulze , Iris Shai

    [email protected][email protected], Angeliki Papadaki

    , Arne Astrup ,

    [email protected], jose luchsinger , Nikolaos Scarmeas

    , Christian Carpéné , Olle

    Melander , [email protected], Marc Molendijk

    , Adriano Marçal Pimenta

    , Helfimed Study UniSA

    Cc: Frank Hu

    Yes, of course, Frank.

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]

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    I have read the full version of the attached letter and Iagree to include my sign on it.I endorse its full content and the request to the BMJ to

    retract the journalist's article. 

    I'm forwarding to my friends and colleagues this invitation to sign the attached

    letter:

     Dear colleagues,

    if you agree, you can send an email to Bonnie Liebman with a similar content to what I have written above in blue font . 

     I would thank you all very much if you are so kind as to askalso to your friends from different European countries to sign

    the attached letter for the sake of science and public health. 

    Best regards,

    miguel--

    Miguel A. Martinez-Gonzalez

    University of Navarra-CIBEROBNwww.unav.es/preventiva

    www.proyectosun.es

    www.predimed.es

    www.predimedplus.com

    www.ciberobn.es

    Research Gate

    On Sun, Nov 1, 2015 at 1:28 AM, Frank Hu wrote:

    Hi Miguel,

    Would you like to sign the attached letter to retract the BMJ article? if so, please email

    Bonnie Liebman .

    I would greatly appreciate if you can ask your colleagues in Spain and other European

    countries to sign the letter. I think it is extremely important to retract the terrible BMJ article

    for the sake of science and public health.

    Many thanks

    frank

    mailto:[email protected]://www.unav.es/preventivahttp://www.proyectosun.es/http://www.predimed.es/http://www.predimedplus.com/http://www.ciberobn.es/https://www.researchgate.net/profile/Miguel_Martinez-Gonzalez/mailto:[email protected]:[email protected]:[email protected]:[email protected]://www.researchgate.net/profile/Miguel_Martinez-Gonzalez/http://www.ciberobn.es/http://www.predimedplus.com/http://www.predimed.es/http://www.proyectosun.es/http://www.unav.es/preventivamailto:[email protected]

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    ---------- Forwarded message ----------

    From: Bonnie Liebman Date: Sat, Oct 31, 2015 at 2:36 PM

    Subject: Letter to BMJ re Dietary Guidelines--Please respond by Nov. 3

    To: Bonnie Liebman

    Dear Colleague: 

    On Sept. 24, the BMJ (formerly the British Medical Journal) published an “investigation” entitled,

    “The Scientific Report Guiding the US Dietary Guidelines: Is it Scientific?” The article (attached) was

    written by Nina Teicholz, a journalist and author of The Big Fat Surprise” Why Butter, Meat, &

    Cheese Belong in a Healthy Diet .

    The article is riddled with errors. For example, Teicholz claims that the report of the 2015 Dietary

    Guidelines Advisory Committee used “weak scientific standards” because it relied on fewer reviews

    by USDA’s Nutrition Evidence Library (NEL) than the 2010 DGAC committee and instead conducted

    “ad hoc examinations of the scientific literature.” 

    In fact, there were no ad hoc examinations. The appendices to the 2015 DGAC report specify the

    search strategy, inclusion criteria, search results, and AMSTAR ratings for the systematic reviews,

    meta-analyses, and other studies used by the DGAC. The attached letter documents ten additional

    factual errors in the article. 

    (Note: The BMJ article was timed to coincide with an October 7 hearing of the House Agriculture

    Committee, where it was used to criticize the 2015 DGAC’s scientific integrity.)

    The attached letter urges the BMJ to retract the investigation. Please let us know by Tuesday,

    November 3, if you would like to co-sign the letter. (Please also feel free to pass it on to yourcolleagues.) 

    Thanks, 

    Bonnie Liebman 

     _______________________________

    Bonnie F. Liebman, MS 

    Director of NutritionCenter for Science in the Public Interest

    1220 L St., NW Suite 300

    Washington, DC 20005

    Ph: (202) 777-8335

    Fax: (202) 265-4954

    --

    *******************************************************

    Frank B. Hu, MD, PhD

    mailto:[email protected]:[email protected]:[email protected]:[email protected]

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    Professor of Nutrition and Epidemiology

    Harvard T.H. Chan School of Public Health

    Professor of Medicine

    Harvard Medical School

    665 Huntington ave, Boston, MA 02115

    tel: 617 432 0113 fax: 617 432 2435

    http://www.hsph.harvard.edu/faculty/frank-hu/

    ******************************************************

    --

    Miguel A. Martinez-Gonzalez

    University of Navarra

    www.unav.es/preventiva

    www.proyectosun.es

    www.predimed.eswww.predimedplus.com

    www.ciberobn.es

    Research Gate

    --

    Angeliki Papadaki, PhD, MSc (Med Sci), FHEALecturer in Public Health Nutrition

    Programme Director, MSc Nutrition, Physical Activity and Public Health

    Centre for Exercise, Nutrition and Health SciencesSchool for Policy Studies

    University of Bristol

    8 Priory Rd

    Bristol BS8 1TZ

    UK

    Tel: +44 (0) 117 3310453

    Fax: +44 (0) 117 3310418

    Office: Room 2G1, 12 Woodland Rd, BS8 1UQ

    Personal webpage: http://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.html Twitter: @AngelikPapadaki 

    Our unique MSc in Nutrition, Physical Activity and Public Health is recruiting now forSeptember 2016 intake. 

    http://www.hsph.harvard.edu/faculty/frank-hu/http://www.hsph.harvard.edu/faculty/frank-hu/http://www.unav.es/preventivahttp://www.proyectosun.es/http://www.predimed.es/http://www.predimedplus.com/http://www.ciberobn.es/https://www.researchgate.net/profile/Miguel_Martinez-Gonzalez/http://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.htmlhttp://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.htmlhttp://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.htmlhttp://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.htmlhttps://twitter.com/AngelikPapadakihttps://twitter.com/AngelikPapadakihttps://twitter.com/AngelikPapadakihttp://www.bristol.ac.uk/sps/studying/postgraduateprogrammes/postgraduatetaught/nutritionpublichealth/index.htmlhttp://www.bristol.ac.uk/sps/studying/postgraduateprogrammes/postgraduatetaught/nutritionpublichealth/index.htmlhttps://twitter.com/AngelikPapadakihttp://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.htmlhttp://www.bristol.ac.uk/sps/people/angeliki-papadaki/overview.htmlhttps://www.researchgate.net/profile/Miguel_Martinez-Gonzalez/http://www.ciberobn.es/http://www.predimedplus.com/http://www.predimed.es/http://www.proyectosun.es/http://www.unav.es/preventivahttp://www.hsph.harvard.edu/faculty/frank-hu/http://www.hsph.harvard.edu/faculty/frank-hu/

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    Suggested BMJ retraction letter (see Page 7, Appendix 1) Appendix 2 

    Dear Editor:

    A recent article by journalist Nina Teicholz,1 which was published as a “BMJ Investigation” 

    of the Scientific Report of the 2015 Dietary Guidelines Advisory Committee (DGAC),2 

    included numerous errors and misrepresentations. Below we have summarized only

    factual errors, excluding incorrect or biased interpretations of research. The mistakes arebolded.

    Because the “investigation” as a whole is so riddled with errors, we urge the BMJ to retract

    it, not only to inform your readers, but also to protect the BMJ’s credibility.

    1. 

    Teicholz states that “in its 2015 report the committee stated that it did not use

    NEL reviews for more than 70% of the topics, including some of the most

    controversial issues in nutrition. Instead, it relied on systematic reviews by

    external professional associations, almost exclusively the American Heart

    Association (AHA) and the American College of Cardiology (ACC), or conductedan [sic] hoc examination of the scientific literature without well defined

    systematic criteria for how studies or outside review papers were

    identified, selected, or evaluated.” 

    Correction: In Appendix E-2, the Evidence Portfolios for the key topics addressed by

    Teicholz specify the search strategy, inclusion criteria, search results, and AMSTAR ratings

    for methodological quality for the existing systematic reviews (SR) and meta-analyses

    (MA).3 Note that it was the NEL, not the DGAC, that “identified any existing high-quality SRs

    and/or MAs that addressed the topic or SR questions posed.”4 

    2. 

    Teicholz states that “instead of requesting a new NEL review for the recent

    literature on this crucial topic, however, the 2015 committee recommended

    extending the current cap on saturated fats, at 10% of calories, based on a review

    by the AHA and ACC, a 2010 NEL review, and the committee’s ad hoc selection of

    seven review papers (see table A on thebmj.com).” Table A states that “nomethodology for this section of the report : no reason given for why certain

    studies were selected for review and others were not, nor how they were

    evaluated relative to each other.” 

    Correction: Appendix E-2.43 gives the search strategy, inclusion criteria, search results,

    and AMSTAR ratings for methodological quality for the seven review papers, along with alist of excluded articles and the reasons for exclusion.5 (Note: In Table A, Teicholz states

    1 http://www.bmj.com/content/351/bmj.h49622 http://health.gov/dietaryguidelines/2015-scientific-report/3 http://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/4 http://health.gov/dietaryguidelines/2015-scientific-report/05-methodology.asp5 http://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-43.asp 

    http://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-43.asphttp://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-43.asphttp://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-43.asphttp://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-43.asp

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    that “the overall conclusion [of the 2012 Cochrane review by Hooper, et al.] is therefore

    that while saturated-fat restriction appears to reduce heart attack risk, it does not reduce

    overall or cardiovascular mortality (death), which is arguably the more important

    endpoint.”6 This statement contradicts Teicholz’s article, which said that Hooper, et al.“failed to confirm an association between saturated fats and heart disease.” The BMJ

    corrected this error a month after it was published.)

    3.  Teicholz states that “use of external reviews by professional associations isproblematic because these groups conduct literature reviews according to

    different standards and are supported by food and drug companies.” 

    Correction: The “problematic” external review cited by Teicholz was not conducted solely

    by professional associations. The review was actually a “clinical practice guideline”developed by the American Heart Association and the American College of Cardiology in

    partnership with the National Heart, Lung, and Blood Institute.7 The NHLBI’s website

    clearly describes its rigorous standards for assessing the quality of studies and its policy for

    managing potential conflicts of interest and relationships with industry. The NHLBI’s 

    standards for identifying, grading, and assessing the quality of studies are as rigorous, if not

    more rigorous, than those used by the NEL.

    4.  Teicholz states that “in t he NEL systematic review on saturated fats from2010…f ewer than 12 small trials are cited, and none supports the hypothesis

    that saturated fats cause heart disease (see table B on thebmj.com).” 

    Correction: It is incorrect to state that none of the trials cited in the 2010 NEL reviewsupports the hypothesis that saturated fats cause heart disease. The 2010 NEL review

    found “strong evidence” that saturated fat intake increases the risk of cardiovascular

    disease. In Table B, Teicholz over-rules the 2010 NEL review by assigning each trial to one

    of four categories (a) “trials that should not have been included because they did not meet

    inclusion criteria,” (b) “trials that should not have been included because they did not test

    normally occuring [sic] saturated fats or saturated fats at all,” (c) “trials concluding thatsaturated fats had a neutrial [sic] or beneficial effect on health,” and (d) “trials with mixed

    results on blood lipid measures.”8 (Note: Table B has additional errors too numerous to listhere.) Thus, Teicholz concludes that the 2010 NEL review is substandard, but she also

    argues that the 2015 “committee’s report used weak scientific standards,” because it did

    not rely sufficiently on NEL reviews.

    6 http://www.bmj.com/content/bmj/suppl/2015/09/23/bmj.h4962.DC1/teicholzmaster2609.wt1_default.pdf7 http://www.nhlbi.nih.gov/health-pro/guidelines/in-develop/cardiovascular-risk-reduction/lifestyle8 http://www.bmj.com/content/bmj/suppl/2015/09/23/bmj.h4962.DC1/teicholzmaster2609.wt2_default.pdf

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    5. 

    Teicholz states that “perhaps more important are the studies that have never

    been systematically reviewed by any of the dietary guideline committees.

    These include the large, government funded randomized controlled trials on

    saturated fats and heart disease from the 1960s and ’70s. Taken together, these

    trials followed more than 25 000 people, some for up to 12 years. They are some

    of the most ambitious, well controlled nutrition studies ever undertaken.” 

    Correction: It is incorrect to state that these trials were not reviewed by the DGAC. The

    DGAC considered a 2012 Cochrane review that included 4 of the 6 trials cited by Teicholz

    and a 2010 meta-analysis that included 5 of the 6 trials cited by Teicholz.910 (The review

    and meta-analysis both concluded that replacing saturated fats with unsaturated fats

    reduce the risk of heart disease.) One trial cited by Teicholz is excluded from most meta-

    analyses because it tested a multifactorial intervention including drug treatment for

    hypertension, counseling for cigarette smoking, and dietary advice for lowering blood

    cholesterol levels.11 

    6.  Teicholz states that “there have been at a minimum, three National Institutes

    of Health funded trials on some 50 000 people showing that a diet low in fat

    and saturated fat is ineffective for fighting heart disease, obesity, diabetes,

    or cancer. Two of these trials are omitted from the NEL review….When the

    omitted findings from these three clinical trials are factored into the review, the

    overwhelming preponderance of rigorous evidence does not support any of the

    dietary committee’s health claims for its recommended diets.” 

    Correction: The two trials that were “omitted from the NEL review” did not assess the

    impact of diet “for fighting heart disease, obesity, diabetes, or cancer.” They assessed the

    9 Hooper L, Summerbell CD, Thompson R, Sills D, Roberts FG, Moore HJ, Davey Smith G. Reduced or modified

    dietary fat for preventing cardiovascular disease. Cochrane Database Syst Rev. 2012 May 16;5:CD002137. doi:

    10.1002/14651858.CD002137.pub310 Mozaffarian D, Micha R, Wallace S. Effects on coronary heart disease of increasing polyunsaturated fat in place

    of saturated fat: a systematic review and meta-analysis of randomized controlled trials. PLoS Med

    2010;7:e1000252.11 Multiple Risk Factor Intervention Trial Research Group. Multiple risk factor intervention trial. Risk factor changes

    and mortality results. JAMA 1982;248:1465-77.

    http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684

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    impact of diet on serum cholesterol levels.12,13 Furthermore, all three trials were included

    in the Cochrane review that was considered by the DGAC.14)

    7. 

    Teicholz states that “The report also gave a strong rating to the evidence that its

    recommended diets can fight heart disease.…The committee reviewed other,more recent studies but not using any systematic or predefined methods.” 

    Correction:  Appendix E-2.26 gives the search strategy, inclusion criteria, search results,

    and AMSTAR ratings for methodological quality for the six “more recent studies,” along

    with a list of excluded articles and the reasons for exclusion.15 

    8. 

    In Table D, Teicholz includes sections (under “dietary patterns and heart disease”

    and “dietary patterns and obesity”) entitled “DGAC ad hoc review of the

    scientific literature” where she states that “no systematic methodology is givenfor the selection of these studies. It is therefore impossible to know if they

    fairly represent the literature.” 

    Correction: These were not ad hoc reviews. The DGAC details the systematic methodology

    for selecting these studies in Appendices E-2.26 and E2.27.16 Note: Teicholz’s Table D17 

    consists largely of Teicholz’s criticism of the NEL’s Systematic Reviews on the Relationship

    between Dietary Patterns and Health Outcomes, published in 2014.18 Note that Teicholz

    argues that NEL reviews are substandard, but she also argues that the 2015 “committee’s

    report used weak scientific standards,” because it did not rely sufficiently on NEL reviews.

    9. 

    Teicholz states that “Consulting the NEL for a review on this topic turns up a

    surprising fact: a systematic review on health and red meat has not been done. 

    Although several analyses look at ‘animal protein products,’ these reviews

    12 Walden CE, Retzlaff BM, Buck BL, Wallick S, McCann BS, Knopp RH. Differential effect of National Cholesterol

    Education Program (NCEP) Step II diet on HDL cholesterol, its subfractions, and apoprotein A-I levels in

    hypercholesterolemic women and men after 1 year: The beFIT Study. Arterioscler Thromb Vasc Biol 2000;20:1580-

    7.13 Knopp RH, Walden CE, Retzlaff BM, et al. Long-term cholesterol-lowering effects of 4 fat-restricted diets in

    hypercholesterolemic and combined hyperlipidemic men. The Dietary Alternatives Study. JAMA 1997;278:1509-15.14Hooper L, Summerbell CD, Thompson R, Sills D, Roberts FG, Moore HJ, Davey Smith G. Reduced or modified

    dietary fat for preventing cardiovascular disease. Cochrane Database Syst Rev. 2012 May 16;5:CD002137. doi:

    10.1002/14651858.CD002137.pub315 http://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-26.asp16 http://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-26.asp

    http://health.gov/dietaryguidelines/2015-scientific-report/14-appendix-E2/e2-27.asp17 http://www.bmj.com/content/bmj/suppl/2015/09/23/bmj.h4962.DC1/teicholzmaster2609.wt4_default.pdf18 http://www.nel.gov/vault/2440/web/files/DietaryPatterns/DPRptFullFinal.pdf

    http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Davey%20Smith%20G%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Moore%20HJ%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Roberts%20FG%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Sills%20D%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Thompson%20R%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Summerbell%20CD%5BAuthor%5D&cauthor=true&cauthor_uid=22592684http://www.ncbi.nlm.nih.gov/pubmed/?term=Hooper%20L%5BAuthor%5D&cauthor=true&cauthor_uid=22592684

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    include eggs, fish, and dairy and therefore do not isolate the health effects of

    red meat , or meat of any kind. 

    Correction: The NEL reviews cited by Teicholz do examine the results on red meat and

    processed meats separately from the results on other animal proteins.19 

    10. Teicholz states that “The committee’s approach to the evidence on saturated fats

    and low carbohydrate diets reflects an apparent failure to address any evidence

    that contradicts what has been official nutritional advice for the past 35 years.

    The foundation of that advice has been to recommend eating less fat and

    fewer animal products (meat, dairy, eggs) while shifting calorie intake

    towards more plant foods (fruits, vegetables, grains, and vegetable oils) for good

    health. And in the past decades, this advice has remained virtually unchanged.”

    Correction: The 2015 DGAC did not recommend “eating less fat”  or reducing the

    consumption of eggs or dairy products. (In fact, Teicholz wrote in a February New YorkTimes op-ed that “experts on the committee that develops the country’s dietary guidelines

    acknowledged that they had ditched the low-fat diet.”20) The Dietary Guidelines for

     Americans has never recommended eating less meat or dairy products. (In some editions,

    the DGA has included advice such as “moderate your use of eggs” or “use egg yolks and

    whole eggs in moderation. Use egg whites and egg substitutes freely…”).

    11. 

    Teicholz states that “studies showed mixed health outcomes for saturated fats,

    but early critical reviews, including one by the National Academy of Sciences,

    which cautioned against the inconclusive state of the evidence on saturated fatsand heart disease, were dismissed by the USDA when it launched the first

    dietary guidelines in 1980.” 

    Correction: The USDA (and DHHS) published the 1980 Dietary Guidelines for Americans in

    February 1980. Toward Healthful Diets, the National Academy of Sciences report cited by

    Teicholz, was published in May 1980.21 USDA could not have dismissed Toward Healthful

    Diets, because the report was published after the Dietary Guidelines were released.

    In summary, the Teicholz/BMJ “investigation” is based on non-facts. Such a paper has no

    place in the pages of a prominent scientific journal and should be retracted.

    19 http://www.nel.gov/template.cfm?template=sort_list_template&key=83520 Teicholz N. The government’s bad diet advice. The New York Times, 2015 Feb 20.

    http://www.nytimes.com/2015/02/21/opinion/when-the-government-tells-you-what-to-eat.html 21 National Research Council, Food and Nutrition Board, National Academy of Sciences. Toward Healthful Diets.

    National Academy Press, 1980.

    http://www.nytimes.com/2015/02/21/opinion/when-the-government-tells-you-what-to-eat.htmlhttp://www.nytimes.com/2015/02/21/opinion/when-the-government-tells-you-what-to-eat.htmlhttp://www.nytimes.com/2015/02/21/opinion/when-the-government-tells-you-what-to-eat.html

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    Competing Interests Form (see Page 1, Appendix 1) Appendix 3

    BMJ policy on declaration of interests 

    BMJ is committed to ensuring the independence and integrity of our content, products, and services.We strive, therefore, to be transparent about any interests that our users, customers, and partnersmight want to know about. This policy on declaration of interests applies to everyone involved in theconception, creation, and delivery of our content, products, and services.

    1. What interests should I declare? 

    We want to hear about interests that might conflict with the work you are doing or have been asked todo for BMJ. A conflict of interest arises when a person has a personal or organisational interest thatmay influence or appear to influence the work they are doing. Usually this is a financial interest, but itmay also be non-financial.

     Above all we want transparency about any personal or organisational interests that might be seen asa conflict of interest in relation to the task a person is being asked to do for BMJ.

    Conflicts of interest are often unavoidable, and should be managed as far as possible rather thanprohibited. But some interests may be so conflicting that the individuals involved should not do thetask the BMJ needs doing.

    The examples given in this document are not an exhaustive list. Individuals should ask themselves ifthere is anything that may strongly bias their judgement and potentially preclude them fromperforming the task requested of them, as well as anything that someone using BMJ products andservices might want to know, or that might cause embarrassment or reputational damage ifdiscovered after the event.

    We ask people to be as clear and specific as possible about the activities, relationships, and viewsthey are declaring. We may ask for more details about any declaration. We would want to know, forexample, what honorariums were for and how much they were for. In declaring travel expenses, wewould want to know the task that was carried out during that travel.

    To make things manageable we would like to know about interests in the 36 months before the

    declaration and those known to be going to occur during the next 12 months.

    2. How we categorise declaration of interests 

    We categorise declaration of interests into four main areas:

    2.1 Personal financial interests 

     A personal financial interest is considered present when payments are made directly to an individual,whether as a salary or as fees or honorariums; or where an individual receives benefits from a thirdparty who is not their main employer, such as a fellowship, equipment, writing or administrativeassistance, or travel and accommodation expenses; or where an individual owns stocks and shares,patents, or other assets.

    Examples include: Employment Paid consultancy or directorshipOwnership of stocks and sharesPatent ownership or applications Paid membership of speakers panels/bureaus and advisory board 

     Acting as an expert witness Being in receipt of a fellowship, equipment, writing, or administrative support Travel and accommodation expenses Writing or consulting for a medical education promotional or communicationscompany.

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    We do not consider personal financial interests to be present in the case of assets over whichindividuals have no control, such as unit trusts, occupational pension funds, and accrued pensionrights.

    2.2 Organisational financial interests 

     An organisational financial interest is said to exist where the interest belongs at arm ’s length to theindividual—for example, where payments are made to the individual's organisation rather than to theirown bank account.

    Examples include: Research grantsFunds for staff or department

    2.3 Non-financial interests 

    Non-financial interests can take many different forms, including personal or professional relations withorganisations and individuals. Those that we want people to declare are unpaid positions that mighthave a bearing on the product or service being delivered by BMJ. We would also want to know aboutstrongly held beliefs where they are relevant to the task in hand.

    In addition, we encourage people to declare other personal interests that they consider may be aconflict of interest in the context of the task they are being asked to perform for BMJ.

    Examples include: Unpaid officership of advocacy, charity, non-governmental organisation, orrelevant professional groupUnpaid membership of a guidelines panelUnpaid advisory positions in commercial organisationsPersonal relationships with authors or editors of material, including havingheld grants, co-authored articles or papers, or worked together.

    2.4 Interests of related parties 

    Conflicts of interest may also arise where a related party (spouse, partner, or other close familymember) has a financial or non-financial interest as described above that could be seen to conflictwith the task a person is being asked to do for BMJ.

    Examples include: A spouse holding stocks or shares or being on the board of an organisationthat might be affected by the task the person is doing for BMJ.

    3. When will you be asked to make declarations of interest?  

    We expect people to declare their interests before taking up any work for BMJ or entering into acontract with us for your services.

    Where we are recruiting new staff, a declaration of interests will be part of the job application.

    If we invite you to join an advisory board, or commission an article, lecture, or peer review report fromyou, we will ask you to declare your interests at the first approach in case there are conflicts ofinterest that preclude you from accepting the invitation.

     Articles submitted for consideration must be accompanied by a completed declaration.

    BMJ staff and members of advisory boards will be asked to review their declarations of interestsannually (for staff this will be at the time of appraisal).

    4. Dealing with declarations of interest 

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    BMJ Group declaration of interests statement 

    Please complete the declaration below. You may complete and return this form electronically in Wordformat —a physical signature/hard copy is not required. 

    I have read and understood the BMJ Group policy on declaration of interests and declare thefollowing interests: [list them or state “none”  ] .

    None

    Name: Jayne Woodside Date: 23/11/15

    Manager sign off (for internal use) 

    Comments:

    Review date

    Name: Date:

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    [For internal use] 

    Guidance on how to apply the BMJ Group declaration of interestspolicy 

    This policy applies to people involved in the conception and creation of content and services ormaking major business decisions on that content or services

    Who is responsible for getting the declaration of interests?  

    1) Products and services (boards and advisors): the editorial director of the product of service, or hisor her delegate

    2) Content or events (authors, speakers and reviewers): the commissioning/handling editor

    3) Advice: the person getting the advice (e.g. an editor)

    4) Staff: HR is responsible for getting declaration of interests when a new staff member arrives andthe line manager is responsible for existing staff. Staff will be told to read the policy and (in line withthe Business ethics policy) to inform their manager at any time if they have any personal interestwhich might affect, could be seen to affect or leave them open to allegations that this could affect their

    impartiality about the work they are doing.

    How/when will the declaration be obtained? 

    1) Product or service—at the time of convening of boards and advisory groups, and when newmembers are recruited2) Content or event—at commissioning or (for research and other unsolicited content) at submission3) Advice—on requesting the advice4) Staff —as part of their application for the job.

    What should be done with the information? 

    The person responsible for getting/receiving/using the information provided in the declaration should

    ask themselves: does anything in this declaration compromise the person’s ability to do the task thatneeds doing—or could be perceived as compromising this. If the answer is yes or possibly, theresponsible person should discuss it with their line manager or other appropriate person. Practicesmay differ between products and department – the point is that there should be some discussionabout this before a decision is made and there should be some documentation of the decision, thedecision making process, and the reasons for the decision.

    What constitutes “a conflict of interest too f ar” will differ according to the task the person is beingasked to do. As far as possible the types of interest that we have agreed constitute a “conflict ofinterest too f ar” will be listed within the quality indicators for individual products and services. At aGroup level they would be anything that interferes with the unbiased output of the BMJ Group. This islikely to occur if the person declares a current financial relationships or contractual arrangements thatappear to prevent him or her from providing an unbiased expert judgement, e.g. where a person has

    signed a contract in which he or she agrees to be paid for advocating the opinion of that organisationor company, or where he or she is in receipt of significant personal financial benefits.

    Where will the declaration be published? 

    1) Product or service—on the relevant website2) Content or event—alongside each article/module or at the beginning of each talk3) Advice—to those receiving the advice (e.g. to authors and editors in the case of reviews)4) Staff —to line managers and department heads, and on the relevant website for staff makingeditorial or business decisions (generally staff in grade 4 or above).

    How often should declarations be reviewed? 

    1) Product or service—annually2) Content or event—for content that is formally updated: at every updating

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    6

    3) Advice—at least annually for on-going advisors. (For advisors who sit on boards or committeesupdating declarations should be an agenda item at committee meetings at appropriate intervals, butshould be considered formally at least annually)

    4) Staff —at every annual appraisal. Staff have an obligation to tell their manager at any time if theinformation changes.

    What happens if a person fails to make a full declaration of interests?  

    If we are alerted to the fact that someone may have an undeclared and potentially conflicting interest,this will almost always require careful handling. The first step is almost always to raise the concernwith the person involved and ask if the conflict does exist and for their reasons for not declaring it.Based on their response various actions may follow. Their declaration of interests may simply need tobe updated or a clarification notice or response published. Where a conflict is substantial and risks theintegrity of the content, product, or service, the person is likely to have to be removed fromundertaking the relevant task and articles or other content they have been working on may need to beretracted. Such cases must be discussed with senior staff (the line manager in the first instance) andrecords kept of all decision making.

    When documenting the decision making process care should be taken to only record the facts of thecase under review and to avoid any speculation or making any personal comments about a person’sdeclaration of interests.

    FG, LD, RM December 2012