The definition of health

by Ari LeVaux

The FDA wrote a rather unkind letter to the makers of Kind Bar brand granola bars in March, accusing the company of mislabeling its product. When the letter was posted to the FDA website on April 13, it caused quite a stir. The agency took pointed issue with the use of the word “Healthy” on the labels of four flavors of Kind Bar, and a natural takeaway was that the nut and grain-dense treats might not be as healthy as the company claims.

“Healthy,” according to the FDA, is not a squishy, ambiguous word like “Natural.” It has a specific legal meaning, including a requirement that a product have less than one gram of saturated fat per serving. Kind Bars have up to five grams.

The definition of “healthy,” according to 2013 guidance, also specifies a maximum of three grams total fat and 90 milligrams cholesterol per serving, and requires a serving provide 10 percent of one’s daily requirement of at least one of the following: vitamin A, vitamin C, calcium, iron, protein or fiber.

Whether something is truly healthy depends greatly on the context, including the personal health issues of the eater. If one is dying of thirst, or about to collapse from low blood sugar, a big bottle of Coke might be a life-saver, very healthy indeed.

In fact, the FDA’s definition of “healthy” doesn’t make a single mention of a food’s sugar levels. Incredibly, that bottle of Coke would qualify as “healthy” if a juicy-enough lime were squeezed into it. It would contain no fat, no cholesterol, and lots of vitamin C.

I can sympathize with the agency’s need to regulate how the word is used, or it would be on everything from Twinkies to bubble gum. Unfortunately, FDAs definition of healthy is built, in part, on outdated science, and is on track to soon be contradicted by some very important policy being drafted by USDA and Health and Human Services. These agencies update America’s dietary guidelines every five years, and a draft proposal for the latest guidelines was released in February – with comments being taken until May 8. If these proposed changes are adopted, many will be in stark contrast to FDA’s definition of “healthy.”

The new dietary guidelines would significantly soften or remove earlier cautions against dietary fat and cholesterol, and include much stronger warnings against sugar. These changes are a result of increasing evidence that sugar, rather than fat, is behind the national rise in obesity and the associated cluster of disorders called metabolic syndrome. Fat, in moderation, is not the demon we once thought it was, increasing research is suggesting. Dietary fat has negligible impact on blood cholesterol levels, it has been repeatedly shown. And some types of fat, including many saturated fats, can have nutritional benefit. Healthy, as it were.

The FDA’s letter also took issue with Kind Bar’s claims of having no trans-fats and warned it “...would likely consider exercising enforcement discretion” regarding the no trans-fat claim. Interestingly, the agency offered no evidence of trans-fat in Kind Bars and acknowledged that hydrogenated vegetable oils, the primary source of dietary trans fat, are absent from the ingredient list. The FDA argues that claiming a product is low in trans-fat is misleading, even if true, because it gives the impression that the product is low in fat.

“Scientific evidence suggests that trans-fat acts in a similar manner to saturated fat with respect to raising LDL cholesterol,” the letter states. “Higher total and LDL cholesterol levels are associated with increased risk of developing coronary heart disease.” The implication is that since trans-fats are basically the same as saturated fats, it’s misleading to claim no-trans fats in a product that’s full of saturated fat.

Indeed, saturated and trans fats do have similar impact on blood LDL cholesterol levels – that impact being almost none. In other words, while LDL in the blood is a problem, LDL levels are not raised by dietary fat, as was once widely believed. There are, however, reasons to avoid trans fats that have nothing to do with cholesterol levels, such as increased risk of diabetes.

Meanwhile, the word “sugar,” which many health experts would agree is probably the product’s most dangerous ingredient, is not mentioned a single time in the letter. There are no limits on sugar in the FDA’s definition of “healthy.”

Kind Bars are made primarily of nuts, grains and fruit dressed with coatings like chocolate and held together by various sugary syrups. A Kind Bar has nearly as many calories as a Snickers bar, and is, arguably, a glorified candy bar. But in many ways they are indeed healthier, if you’ll pardon the expression, than a typical candy bar.

One of the reasons a Kind Bar is so much better than a Snickers bar is all of the fiber in the nuts and oats. Indeed, the label boasts of its fiber content. But the FDA’s letter states that if Kind Bar wants to claim its product as a “Good Source of Fiber,” it must include “...the required statement disclosing that the food is not low in total fat in immediate proximity to the claim.”

This demand is based on the notion that from a weight gain perspective, dietary fiber will tend to cancel out the calories one consumes, as fiber takes energy to break down. But sugar and carbohydrates, not fat, are turning out to be more responsible for weight gain, and fiber is good for reasons beyond weight control. Demanding that the company remind us of its fat content while boasting of its fiber levels is curiously, and excessively, micromanagerial.

Like the Kind Bar itself, the FDA’s letter amounts to a cluster of sorts. If nothing else, it raises some important issues and serves as an invitation to food fight over the word “healthy.” But the letter does little to improve the Kind Bar label’s relationship with the truth.

Instead of regulating and enforcing the meanings of an ambiguous term like “healthy,” FDA would do better to ban it altogether, because of how difficult it is to define and the ease with which it can be misused. And while they’re at it, ban “natural,” too.

And rather than micromanage how terms like “high-fiber” and “trans fat” can be used, FDA should keep the editorializing and bureaucratic confusion to a minimum. Labels should focus on the actual ingredients and nutrient levels themselves, and trust consumers to interpret them appropriately.