John Graham, administrator of OMB’s Office of Information and Regulatory Affairs, is urging the departments of Agriculture and Health and Human Services to revise dietary guidelines and the food pyramid to reflect the dangers of trans fatty acids (found in margarine, salad dressings and baked goods) and the benefits of omega-3 fatty acids (found in fish, flaxseed and canola oil). In a “prompt letter” sent on May 27, Graham wrote, “Given the wide reach of the federal nutrition guidelines, we believe that good nutrition habits fostered by improved information on the links between diet and health will have a significant health impact, especially in reducing heart disease. Coronary heart disease (CHD) is our nation’s largest cause of premature death for both men and women, killing over 500,000 Americans each year. Even a modest improvement in dietary habits may lead to significant reductions in the number of premature deaths from CHD.” The letter is specifically directed at the Dietary Guidelines for Americans, which are used by the school lunch program, and the Food Guide Pyramid, which recommends daily food choices. Agriculture and HHS are currently in the process of revising the guidelines, which is scheduled for completion in 2005. The food pyramid, which is based on the guidelines, has not been updated since 1992. Graham previously sent another prompt letter on Sept. 18, 2001, asking that the Food and Drug Administration (FDA) give priority to a new rule that would require labeling for trans fats in food products. FDA expects to issue a final rule by September. In year’s past, OIRA has performed mainly a review function, acting as a clearinghouse for agency regulatory proposals and collections of information (such as tax forms or industrial emissions reports). Graham began sending “prompt” letters as part of his overall effort to exercise more upfront influence. By themselves, none of these letters is truly harmful, and in fact, some may be helpful. However, it raises the question of the proper role for OIRA. OIRA has -- for good reason -- never before attempted to prioritize for agencies, which unlike OIRA, are statutorily charged with protecting health, safety, and the environment. OIRA has little scientific expertise on staff (and as explained here, had none until recently) and lacks the resources and procedural mechanisms to guarantee public involvement in such important decisions.