Start Making Sense

  By Michael Applebaum, MD, JD, FCLM

In its public statements of 10 July 2003, the FDA declared, “To confront the growing epidemic of obesity and obesity related diseases in America, FDA will implement a review process for qualified health claims to help consumers obtain accurate, up-to-date, and science-based information about the health consequences of the foods they consume.”


Hooray!  Not really.  The FDA plan, as stated will do little to curb “obesity.”


“Obesity” is the result of consuming more calories than are burned.  That is the only known nutritional cause.  Too much in, too little out.  No mystery here.  So what is the FDA’s solution to national “obesity?”


The FDA “believes that helpful, scientifically accurate, carefully and expertly reviewed qualified health claims on food packages would influence shopping choices, and thereby encourage food firms to compete on the health effects of their products, rather than merely their taste, price or ease of use.”


Okay.  So how is this health claim information supposed to reverse the “obesity” epidemic?


"Protecting consumers by helping them get better nutrition information is among FDA's top priorities, because the choices that Americans make about their diet have a great impact on the health of the public. This new initiative will better protect consumers from making uninformed or misinformed choices about their diet and nutrition, by giving consumers better information about the health consequences of those choices," said FDA Commissioner Mark B. McClellan, M.D., Ph.D. "The FDA review process for making qualified claims, when combined with our strong enforcement work, will reward companies that make healthier products while more aggressively enforcing the law against companies that appeal to consumers through false and misleading health claims."


There is no direct relationship between “health claims” and caloric intake.  “Obesity” is necessarily a calorie management problem,  but not necessarily a knowledge problem.


Interestingly, the FDA acknowledges that the public possesses a lot of knowledge about food and health.  It is just ignored.


“There is growing evidence of a public health gap in knowledge and behavior with respect to substance/disease relationships. According to the recent Sloan State-of-the-Industry Report published in Food Technology (Top 10 Trends to Watch and Work On, April 2003), consumers have no problems holding dichotomous attitudes about the pleasures of food and its power to influence their health. As more shoppers acknowledge indulging their cravings, more of them also admit that what they eat can have a major effect on how healthy they feel.


The most recent Food Marketing Institute (FMI, 2002) Trends in the United States Survey indicated that the percentage of consumers who recognize the importance of eating healthfully and who are interested in trying foods that may improve their health is increasing. 86% agree or strongly agree that "in most cases, eating healthfully is a better way to manage illness than medications," up from 76% in 2001. 54% said they are very interested in trying health-promoting foods. 51% want products designed to help them with high blood pressure and diabetes; 50% with allergies; 49% with weight control; 41% with osteoporosis; 40% with arthritis, and 40% (women only) with problems with women's hormones.


Despite these encouraging findings, other results from the same survey indicate that the percentage of consumers who acknowledge unhealthy eating behaviors is also increasing. 72% of shoppers agree or strongly agree with the statement, "I eat foods I enjoy, even if they're not good for me," up from 64% in 2001. 34% agree or strongly agree with the statement, "I eat whatever I want and don't think much about how it affects my health," up from 25% in 2001.”


It should be apparent that the new health claim grading system, although potentially useful if “combined with [the FDA’s] strong enforcement work,” is not aimed at the real problems causing “obesity” – overeating, under-exercising.


We, as a society, have chosen, in addition to labels, other means to prevent the abuse of ingestible substances that negatively affect the collective, such as alcohol (ethanol).  These include: the prevention of some persons from overindulging (Dram Shop Acts), civil penalties and criminal punishment.


In other words, in some cases our culture demands responsible behavior and punishes those who fail to act accordingly.


Control of the “obesity” epidemic should be no exception.  With yearly societal costs estimated by the Center for Science in the Public Interest at 617 billion dollars, lives lost prematurely between 310,00 and 580,000 and the number of Americans living with unhealthy diet- and inactivity- related disorders at 215,160,000, it seems as if this should be a “no holds barred” campaign.


Possibly well-intentioned, but definitely poorly aimed, the new labeling efforts by the FDA are not sensible given the stated problem of “obesity” and will not provide a solution.