What Makes One Food “Healthy” and Another Less So or Not “Healthy”?
As part of the September 28, 2022 White House Conference on Hunger, Nutrition, and Health, the Food and Drug Administration published in the Federal Register a Proposed Rule that had been fermenting for six years. The rule sets forth a new definition of “healthy” food and lays out a front-of-package labeling system designed to assist consumers pick healthier food products.
The term “healthy” as defined by the FDA in its Proposed Rule means the capacity of a food to promote human health by meeting a person’s daily needs for essential nutrients, health-promoting vitamins and minerals, phytochemicals, antioxidants, and healthy fatty acids.
FDA invited comments from the public, scientists, and the food industry on the nuts and bolts of their newly proposed definition of “healthy” food. HHRA’s comments begin with a paragraph explaining why this Proposed Rule could be the most important one issued by the FDA in the last half century when measured by potential positive impacts on our collective health.
“Data compiled by the Institute of Health Metrics and Evaluation at the University of Washington show that in 2010 dietary choices accounted for the largest share of deaths, and nearly 50% more deaths than smoking (the #2 cause of death). Food and diet quality are important factors driving 6 of the top 10 causes mortality across the US population.”
Food both sustains us and cuts short far too many lives. It impairs the quality of life for about one-third of the US population, impacting people who struggle with overweight and one or more chronic disease with roots in food choices.
The HHRA Public Policy Advisory Committee took the lead in recruiting an international team of scientists with expertise in multiple disciplines. Their collective critique of the provisions in the FDA’s proposed rule is contained in their 45-page set of comments submitted today to the FDA (see some news coverage here). The team writes:
“We conclude that the new definition of healthy food and the food labeling system proposed by the FDA will likely do little good in moving consumers toward healthier dietary patterns. Indeed, the FDA apparently agrees with our assessment, given FDA’s sobering estimate that its proposed new definition of healthy food and labeling system will alter no more than 0.4% of consumer food purchase decisions.”
Given this very modest projected impact, the HHRA team decided to describe the primary provisions of a definition and labelling system with potential to guide consumers hoping to make smarter, more health-promoting food choices. It will also help people sort through the many, sometimes dubious “healthy” food claims on packaging encountered along almost every aisle in supermarkets.
HHRA’s Counter Proposal – The NuCal System
The HHRA comments spell out the core provisions of what we call the NuCal system. NuCal is designed to overcome the inherent weaknesses of the system proposed by the FDA. It incorporates a commonsense metric that captures in a single value the degree to which a serving of a given food meets a person’s essential nutrient needs.
An Appendix in HHRA’s comments provide the detailed data used to calculate NuCal values for 196 common foods. These values are then used to array the foods along a “Nutritional Quality Continuum” divided into green (very healthy), yellow (moderately healthy), and red (not so healthy) zones.
Healthy foods are those that provide 4-times or more of the essential nutrients a person needs in a day compared to the share of the total calories that person can consume in a day while maintaining a healthy bodyweight.
Not so healthy foods take up twice or more of the caloric space in a person’s daily diet relative to the percent of total essential nutrients we all need to stay healthy.
The top five green-zone foods that excel in the NuCal system and each food’s score using the system’s novel metric are:
- Spinach (NuCal score 17)
- Turnip greens (17)
- Kale (15.3)
- Asparagus (15.2)
- Broccoli (8.8)
Red-zone foods take up more caloric space relative to the nutrition they deliver. The five foods with the lowest NuCal scores are:
- Sprite, Coke, Pepsi, 7-Up and most sugar-sweetened soda (0.03),
- Honey (0.04)
- Fruit flavored Gatorade (0.09)
- Butter (0.17)
- Yellow cake with icing (0.31)
The NuCal system makes it easy for consumers to make choices that will promote rather than undermine good health. Here is one of the insights gained from the NuCal system that is featured in the HHRA comments:
“Consuming a serving of orange juice with a NuCal score of 1.45 instead of a coke or 7-Up would enhance the NuCal metric score for a single beverage serving by 48-fold!”
Food choices matter. Check out where some of your favorite foods and meals land along the Nutritional Quality Continuum and find answers to these two questions:
Of the 196 foods included in HHRA’s analysis, which food delivers the most nutrients per serving compared to all other 195 foods?
What portion of a person’s daily caloric intake is “taken up” by a Big Mac with cheese?