I'll be taking a a few weeks off to spend time with my family and travel. Meantime, I'll be reposting some of the more popular and relevant posts I’ve written over the past years so that new readers have a chance to catch up.
The connection between diet and health was proposed some 24 centuries ago by Hippocrates, and I can imagine he first heard of it from his mom, who heard it from her ancestors.
Today, grandmas, moms and physicians have piles of scientific evidence supporting their observations and advice. It’s true: Diet does play an important role in health. We’re learning more each day and the discovery is fascinating.
Unfortunately, scientific discoveries are being overly-interpreted to promote the sale of foods, and scientific jargon appears all too often as buzzwords on packaged goods.
Every Flu season and especially the recent spread of the new H1N1 virus have given rise to a new barrage of immunity claims shouting at us from every supermarket shelf and commercial. It’s a perfect time to look at the diet/health connection and these claims.
A short introduction to food label claims
There are several types of claims allowed by the FDA on foods.
A health claim describes a relationship between a food or food component and a disease, and it must:
• Be pre-approved by the FDA. There are currently slightly more than a dozen of these approved claims.
• Be phrased in the specific language the FDA requires. The claim must indicate that the disease may be caused by a variety of causes, and must state that the food should be consumed as part of a healthy diet.• Appear on food that meets certain nutritional requirements.
A structure/function claim is quite a different animal.
Structure/function claims describe a role of a nutrient, a substance in food or a food supplement in affecting the normal structure or function in the body. Unlike a health claim, it doesn’t relate to a disease or a health-related condition. The verbs “support”, “improve”, “boost” and “maintain” are often a telltale sign of a structure/function claim.
A Structure/function claim:
• Requires no FDA pre-certification.A few quick examples:• Can be attached to any food, including junk food (there are no overarching nutritional requirements).
• Can be phrased in many ways.
• Is the manufacturer’s responsibility. While the claim “must be truthful and not misleading”, there’s no specification about how much evidence is needed to make the claim.
“Calcium reduces the risk of osteoporosis” is a health claim; “calcium builds strong bones” is a structure/function claim.“Fiber may reduce the risk of some cancers” is a health claim; "fiber maintains bowel regularity," is a structure/function claim.
Confused? You’re in good company. Most consumers can’t tell the difference.
Even the pros in the food industry can’t necessarily make sense of structure/function claims. They consult expert lawyers whose entire practices are devoted to advising companies on the language of the label. Creative marketing devises the claim and legal counsel makes sure it’s defensible and at least somewhat based on reality.
What’s clear is that the structure/function claim has been a boon to food manufacturers. Since there are so few limitations on its use and the trusting public can’t distinguish between a health claim and a structure/function one, why not be creative, develop a claim that meets your goals and slap it on the package? Market research shows these structure/function claims really help with sales.
What's the evidence backing these “immunity” claims?
There are, in fact, no approved health claims related to immunity.
What does that mean? It means that no one has presented to the FDA enough evidence of a relationship between a food, a food ingredient or a dietary supplement and reduced risk of contracting or of treating an immune mediated or infectious disease such as the flu to warrant a health claim.
That means the immunity claims you see everywhere are all structure/function claims.
What are the claims based on? The immune system is very complicated, and its integrity depends, among other things, on good nutrition. States of vitamin, mineral or protein deficiency lead to reduced immunity and correcting the deficiency does improve immunity.
But while it’s true that if you had a vitamin C or zinc deficiency you could improve your health and immunity by eating a vitamin-fortified cereal or a vitamin supplement, it’s clear that shouting “Immunity!” from the cereal box is misleading. Vitamin deficiencies are rare, and therefore the cereal might be yummy, but it’s not doing much for your immune system.
Most food contributes to one’s health, so by that token we can add a structure/function claim to pretty much anything:
• Sleep, for example, is very important to immunity; should we advertise mattresses as immunity boosters? All mattresses or only some brands?• Exercise improves immunity. Maybe “immunity now!” should be painted on sidewalks?
• Stress reduction improves immunity; how about an “immunity massage”?
• Why, even breathing air supports immunity.
These immunity claims are all without much substance I’m afraid, but it’s especially outrageous to see them on junk food. Cocoa Krispies is 40 percent sugar, but hey, don’t you need to maintain normal sugar levels for good immunity? Correcting potential hypoglycemia is critical for good immunity, isn't it?
Thankfully, after receiving a letter from San Francisco’s city attorney last November, Kellogg announced it would phase out the immunity claims on Cocoa Krispies.
Will misleading claims ever end?
Two scenarios I can imagine:
• Consumers will start rejecting these claims, viewing them as a hyped and misleading insult to their intelligence, and move toward products that are marketed in a more sensible and honest way.
The only reason these claims abound is because we’re buying them.
And here comes my question: Do people really believe that they can buy immunity in box? Or are they buying it knowing that an easy fix is a fantasy, but it still feels good to dream?
• The second option is the litigious route: A few really big class action suits, representing misled consumers who saw no health benefits from investing their hard-earned money in products that failed to deliver can change everything. In that respect, the recent FDA warning letters to manufacturers who post misleading or false claims could act as important evidence and actually make a difference.
I prefer the first scenario.
There’s actually a third possibility.
The FDA can overhaul the whole health-claim structure/function scene, crackdown on false and misleading claims and help consumers understand that good health (and building a strong immune system) has nothing to do with buying products that make health claims. People need to just eat well by consuming healthy, real foods over a long period of time.
Sorry, but that’s the truth—eating well is about good habits and good food, not about sprinkling vitamins, anti-oxidants and omega 3 on processed food. The Center for Science and Public Interest (CSPI) is urging the FDA to do just that in a report it recently sent. (It’s 158 pages, but well worth a read, and it includes lots of pictures.)
So, what to make of these medicinalized foods?
I think it’s best to simply leave them on the shelves and opt for good, healthy choices. As Hippocrates said, “To do nothing is sometimes a good remedy.”
Happy healthy new year!
Dr. Ayala