Dick Groves
Editor, Cheese Reporter


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FDA Should Stop Trying To Define ‘Healthy’

The US Food and Drug Administration recently started a public process to redefine the “healthy” nutrient content claim for food labeling. To save time, energy and resources, FDA should just stop this process now, because trying to define “healthy” is simply an unhealthy idea.

As reported on our front page two weeks ago, FDA is requesting comments (the deadline for submitting these is January 26, 2017) on several questions or issues, including when, if ever, the use of the term “healthy” may be false or misleading, and what types of food, if any, should be allowed to bear the term “healthy.”

So why should FDA stop trying to redefine the term “healthy?” It’s pretty simple, really.
FDA published the final rule defining the term “healthy” back in January of 1993, meaning we’ve had more than two decades to live with the consequences of that definition. And how has that worked out?

Well, by most measures (including obesity and type 2 diabetes, to mention just two measures), people have gotten less healthy over the last 23 years. That alone should provide sufficient evidence that trying to define a term such as “healthy” does more harm than good.

But there are plenty of additional reasons why FDA should stop trying to define “healthy.” Just speaking generally, there’s that old saying: “There are no good foods or bad foods, only good diets or bad diets.”
Trying to define “healthy” so that it can be placed on food labels contradicts that notion. It basically suggests, or at least implies, that if you eat a food labeled “healthy,” or, better yet, eat several foods labeled “healthy,” you will, in fact, be “healthy.” That’s ridiculous.

This point was raised more than 20 years ago, in comments submitted to FDA in response to the agency’s proposal on “healthy” claims. As FDA explained in its final rule, some comments opposed the agency’s proposal to define “healthy” on the grounds that the term is more appropriately applied to overall diets. These comments further urged FDA to prohibit the use of the term on food labels “because it describes the total diet, is misleading to consumers, reinforces the ‘good food-bad food’ concept, and could easily lead a consumer to overconsume those products labeled as ‘healthy’ rather than consuming a variety of foods.”

FDA rejected those comments, and said (again, this is more than 20 years ago) it believes that foods labeled with the term “healthy,” whether they are individual foods, main dishes, or meals, “can be used with a variety of foods to assist consumers in maintaining healthy dietary practices.” FDA went on to say that the comments “have not provided convincing information to the contrary.”

No, but more than 20 years later, the evidence seems to point pretty clearly to the fact that allowing the use of the term “healthy” on food labels has, in fact (and among other factors) made people less healthy.

Also just looking at this issue from a broad perspective, it’s worth remembering that science keeps changing what exactly a “healthy” food is, or more specifically what nutrients should or should not be included in a “healthy” food.

This point is raised in a December 2015 petition submitted to FDA by KIND LLC, a producer and marketer of snack bars and related products. As KIND points out in its petition, under FDA’s current regulations, whether or not a food can be labeled “healthy” is based on specific nutrient levels in the food rather than its overall nutrition quality.

“FDA formulated those regulations more than 20 years ago, when available science and federal dietary recommendations focused on limiting total fat intake,” KIND noted. “Today, these regulations will require that the majority of foods featuring a ‘healthy’ nutrient content claim meet ‘low fat’ and ‘low saturated fat’ standards regardless of their nutrient density. This is despite the fact that current science no longer supports those standards.”

Related to that point, the prevailing wisdom for more than half a century was that margarine could be part of a “healthy” diet, but butter could not. Today, margarine (at least the traditional type of margarine) is close to extinct, and FDA has decided that the main ingredient in traditional margarine, namely partially hydrogenated vegetable oil, is no longer generally recognized as safe (GRAS).

FDA wants to know what types of food, if any, should be allowed to bear the term “healthy.” Here’s an idea: allow butter to bear that term. In fact, FDA should allow, if not mandate, the following statement on butter labels: “Healthy. Because it’s not margarine.”

There is at least one other area where the science is slowly changing but FDA’s “healthy” definition is not (at least not yet): sodium. Back in 2005, FDA published a final rule concerning the maximum sodium levels permitted for foods that bear a “healthy” claim.

In that final rule, FDA noted that it had received a comment maintaining that there was no evidence that restricting sodium consumption will result in improved cardiovascular health outcomes, and responded, in part, as follows: “The effects of sodium on blood pressure are well documented.” And FDA noted that the 2005 Dietary Guidelines for Americans recommended that individuals consume less than 2,300 milligrams of sodium per day.

But at least a couple of recent, major studies have concluded that sodium intake above that level is actually healthier than sodium intake at or below that level.

Here’s a healthy idea for FDA: Stop trying to define “healthy.” The more often that claim shows up on food labels, the less healthy people have become. DG

Cheese Reporter welcomes letters to the editor. Comments should be sent to: Dick Groves by Fax at (608) 246-8431; or e-mail your comments to dgroves @cheesereporter.com.


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