Response to Make America Healthy Again (MAHA) Assessment

While I completely agree with the purpose of the Make America Healthy Again (MAHA) report, to make Americans, especially American kids, healthy again, there are several conclusions and recommended approaches this report proposes that I believe need to be corrected.

This report, while it mentions obesity rates and physical inactivity, seems to spend far more time and focus on ultra-processed foods (UPF), food dyes, “unhealthy” fats, and other things that, clinically anyway, are either NOT a health problem or are not nearly as important as the former! Does this MAHA assessment miss the forest for the trees? I believe in many ways, it does.

Of all the food-related topics this report discusses, by a wide margin, the highest correlation to chronic disease remains obesity. Period. I am not defending ultra-processed foods here, but it appears the biggest negative health aspect UPFs have on us is that they are readily available, relatively inexpensive, calorie-dense AND, to make matters worse, they taste really, really good. The real question is, is it the processing that makes UPFs bad for us, OR is it that calorie density is the last thing we need while we sit on the couch watching TV or playing video games? I’d love to see the research on that topic. As I said above, obesity correlates much higher with chronic disease than any specific food item mentioned in this report.

The report’s definition of ultra-processed foods (UPF) is also quite unscientific.  The report says, “For the purposes of this assessment, UPFs refer broadly to packaged and ready-to-consume products that are formulated for shelf life and/or palatability but are typically high in added sugars, refined grains, unhealthy fats, and sodium and low in fiber and essential nutrients”.  “Typically, high in added sugars” is pretty easy to understand (though it does not define what “high” is). But what is “refined grain” and why is it bad for us? Human beings have been growing wheat and grinding it into flour to produce bread for thousands of years. How is that now “unhealthy”?  And what are “unhealthy fats”? The report takes on “seed oils” later in the report (more on that later), but are “natural fats” somehow better? Butter? Tallow? Lard? All of these contain large amounts of saturated fats and cholesterol. The report refers to saturated fats in a negative light but seems to point the reader back to those fats as a healthy alternative to seed oils.

On page 22 of the report, it refers to “ultra-processed fats” as “industrial fats from refined seed oils, such as soybean, corn, safflower, sunflower, cottonseed & canola”. It references that “Over the course of the 20^thcentury, U.S. dietary fats shifted from minimally processed, animal-based sources like butter and lard – rich in fat-soluble vitamins A, D & E, supporting brain & immune health” as a healthier alternative to seed oils. Is the report suggesting that switching to fats high in saturated fat and cholesterol is actually healthier, presumably because it simply has fewer processing steps? With all due respect, is there research available that actually says that?

On the topic of seed oils, on page 22, the report says, “these oils (seed oils) contribute to an imbalanced omega-6/omega-3 ratio, a topic of ongoing research for its potential role in inflammation”. It then cites what appears to be a single piece of research by a Dr. Artemis P. Simopoulos to back this statement. While I believe I understand her findings, there are dozens of research studies and meta-analyses on the topic, and while some of them indicate a possible link between excess consumption of omega-6 fats and inflammation, most of them simply do not. I have included a video on the topic here, which provides a thorough analysis of all the available research, including meta-analysis on the topic. While additional study is always good, it is not as if this topic has not been looked at in a significant way. The meta-analysis discussed on the video covers dozens of studies that have been conducted on tens of thousands of participants over the last 50 years. There has been an enormous amount of research on the topic, and the results simply do not point to excess omega-6 consumption causing poor health outcomes. I would encourage you to look into the studies discussed in the video.

Worse, there is a mountain of research regarding the poor health outcomes of fats high in saturated fats, especially those containing cholesterol (animal-derived fats). Suggesting that tallow, lard, and butter are somehow healthier alternatives is not supported scientifically.

In conclusion, while I applaud the overall objective and applaud Health and Human Services on the belief that more study is needed on all of these topics, we should not take the approach of frequently banning food items that have been used safely for generations, and THEN conducting the research. We must stick to a rigid process of testing and research when determining the safety of a food product.

Dave Reeble, President and Founder