Let’s start with the positive:

1) It’s much easier to understand that the current American Food Pyramid (2005):

This was so complicated (and seemingly needed to be individually tailored), that many people just carried on using the old American Food Pyramid (below – introduced 1992), which directed Americans to have: 6-11 grain portions a day; 2-4 fruit portions; 3-5 vegetable portions; 2-3 dairy servings and 2-3 meat/egg/fish/bean/nuts/egg servings per day. Hence Americans could have 26 portions of food a day – all having an impact on blood glucose levels. And we wonder why America led the world in getting fat and sick.

MyPlate is served with some advice, as a side dish

Here is the accompanying dietary advice in black; my comments in red alongside:

Balancing Calories
●     Enjoy your food, but eat less. (Less than what? An anorexic? Less than you are eating now? Less than you need for health?)
●     Avoid oversized portions. (Requires too much judgement to be useful advice – what is oversized to you may not be to me or vice versa. Plus – it is very difficult to ‘overeat’ real food – organic meat/fish/eggs/veg – it is very easy to ‘overeat’ processed food. Hence nature sorts out portion sizes for us)

Foods to Increase
●     Make half your plate fruits and vegetables. (i.e. Fructose & glucose & glucose).
●     Make at least half your grains whole grains. (there is debate on this in the informed nutritional world – whole grains have more nutrients than white grains (still far fewer than quality meat/fish/eggs), but white grains are less abrasive than whole grains and therefore less likely to cause irritable bowel syndrome or bowel cancer. It’s all glucose to the body either way).
●     Switch to fat-free or low-fat (1%) milk. (The UK is deficient in vitamins A, D, E and our government doesn’t bother recording vitamin K in the National Food Survey, but no doubt we are deficient in all four fat soluble vitamins. I doubt that the USA is any better, so we would be well advised to consume real fats in real food – like milk from ruminants freely living on grass. Nature sensibly puts real fat with real fat soluble vitamins in real food. Man stupidly takes them out).

Foods to Reduce
●     Compare sodium in foods like soup, bread, and frozen meals ― and choose the foods with lower numbers. (Don’t eat anything processed).
●     Drink water instead of sugary drinks.  (Good advice. Better still “Don’t drink anything processed”).

So the new MyPlate is simpler, but does this make it any better… Here are my key concerns for America’s national (public) health and for the nutritional advice in this new model…

Three national health concerns about MyPlate

1) This will do nothing to solve the obesity epidemic.

I have written 135,000 words on The Obesity Epidemic: What caused it? How can we stop it? In a nutshell we changed our diet advice (America in 1977-1980 and the UK followed suit in 1980-1983) and obesity has increased 10 fold since in the UK; America started from a slightly higher base, so has ‘only’ increased by a few multiples and not 10! We changed our advice away from “Farinaceous and vegetable foods are fattening, and saccharine matters are especially so” (Tanner, The Practice of Medicine, 1869) to “Base your meals on starchy foods.” This has had catastrophic consequences for human weight and health and cataclysmic benefit for the food, drink and drug industries, which profit from us being fat and sick.

MyPlate will do nothing to change this. It is still telling humans to “Base your meals on starchy foods” instead of realising, as we did for the 3.5 million years before the last 30 years of ‘conventional wisdom’, that carbs are uniquely fattening (and unnecessary for human health). Grains are just glucose, fruit is fructose and glucose (a particularly uniquely fattening combination – the same as sucrose – table sugar), vegetable are glucose (potatoes and starchy vegetables especially so) and dairy (processed yoghurts) and protein foods (beans etc) chosen can also have a carbohydrate content.

2) This will do nothing to solve the nutritional crisis.

We seem to have forgotten why we eat. We eat because there are 13 vitamins and c.16 minerals vital for human existence, let alone health and well being. All the plates and pyramids are obsessed with macro nutrients (fat, protein, carbohydrate); they seem to have forgotten mico nutrients (vitamins & minerals) entirely. Remember that slogan “Take care of the pennies/cents and the pounds/dollars look after themselves”? This applies nicely to nutrition. “Take care of the vitamins and minerals and the fats, protein and carbs will look after themselves.”

Our dietary advice should start from – how do we get our vitamins and minerals (notwithstanding that the concepts of “Recommended Dietary Allowance” (RDA), let alone “Adequate Intake” (AI) are a joke – as Sally Fallon Morell says “Why am I only allowed a certain  level of nutrition?”!) I did just this in my book The Obesity Epidemic. I’ve put three examples (for omnivores, vegetarians and vegans) as an Appendix to this post.

MyPlate will do little to nothing to improve the health of the American nation. We should be telling people to base their meals on meat and eggs from animals freely grazing on grass; fish and vegetables/salads. Quality dairy (again – only products from grass living animals are worth consuming), nuts & seeds (in moderation if overweight) and local, seasonal fruits (in moderation if overweight) are useful additions to the meat/fish/egg/veg base. Almost half the plate is taken up by fruits and grains – high glucose/low nutrition relative to meat/fish & eggs. No attention is given to the quality of food (other than the emphasis on whole grains, which is debatable (see red notes above)). The importance of eating animals that have predigested cellulose for us (arguably their role in the circle of life, along with fertilising the soil without needing oil) is not addressed. The epidemic of (type 2) diabetes will continue unabated with this level of carbohydrate intake.

3) The food industry will still love this.

The food industry, in fact, wasted no time in saying how much they loved it. Kellogg’s and General Mills (sponsors of the American Dietetic Association) (ADA) will love that grain segment – that’s cereals for breakfast then. Unilever and CoroWise (more  ADA sponsors) should be happy – dietitians will be telling people to put hydrogentated spreads on their copious amounts of bread – certainly not that natural butter product. The dairy industry (another ADA sponsor) will be very happy – they’ve got their own little segment all to themselves. When chips and potatoes count as veg, the fast food companies will be happy (Aramark – the ‘dining away from home’ ADA sponsor – should be happy anyway). Plus, no one is really going to opt for water instead of phenomenally promoted Coca-cola & Pepsi (not least when these are also ADA sponsors and therefore able to convince dietitians of the marvel of calorie-free, aspartame-laden, fizzy concoctions).

Here’s how it works for the fast food industry: Burger (protein), bun (grains), fries (vegetables), tomato slice (fruit), lettuce leaf & gherkin (more vegetables), strawberry milk shake (more fruit & dairy) – the perfect meal!

Anything that the food industry likes is a fail. The food industry would hate my advice – see below!

Three nutritional/technical concerns about MyPlate

1) The USDA appears not to know the difference between a food group and a macro nutrient!

There are 3 macro nutrients: fat, protein and carbs. There are essential fats (i.e. fats we must eat); there are essential proteins (i.e. amino acids we must eat); there are no essential carbs (i.e. there are no carbs that we must eat). Yes the brain does need glucose, but that doesn’t mean that we need to eat it. Indeed, anyone wanting to lose weight should relish in the fact that the brain needs glucose. Don’t eat it and then the body send out a signal to break down body fat to get glycerol/glucose. Result!

MyPlate has 4 food groups: vegetables, fruits, grains and dairy and one macro nutrient – protein! Protein is actually in everything. Literally everything from lettuce to apples to oats to beef. Hence MyPlate has protein in every segment. This is not necessarily a bad thing, but they still don’t know food groups from macro nutrients!

My food groups would be: meat; fish; eggs; dairy; vegetables & salads; nuts & seeds; fruits; beans & pulses and grains. That would make 9 in total. 5 of my food groups – meat; fish; eggs; nuts & seeds and beans & pulses – would end up in the one macro nutrient group on MyPlate – the protein segment. This should be the major part of the plate, not the minor part and the USDA should know a food group from a macro nutrient.

2) The USDA is as fat phobic as ever.

We changed our dietary advice c. 1980 (and started the obesity epidemic in so doing) because we developed this mad idea that fat is going to kill us. The Dietary Guidelines for Americans 2005 list: ice cream; sherbet; frozen yogurt; cakes; cookies; quick breads; doughnuts; margarine; sausages; potato chips; corn chips; popcorn and yeast bread as saturated fats. These are not saturated fats – not primarily, not even secondarily. They are first processed foods, secondly major sources of carbohydrates and thirdly, almost all then have more unsaturated fat than saturated fat (not that any real fat is better or worse than any other, but these are not real fats, and they are not saturated fats). Don’t eat any of these heaps of junk because they are processed heaps of junk. However, real fats in real food are absolutely vital for human health and we are suffering epidemic levels of deficiencies, in vitamins A and D particularly, in the UK and the USA.

Where is the fat on MyPlate? Where is the quality offal and red meat? the mackerel? the sardines? the quality dairy foods? the real butter? the free range eggs? Where are the vital fats that we need? Emphasizing protein and carbs and not fat is seriously harmful to health. Fats are vital, carbs are not. Protein is vital, but consuming protein in an unnatural balance (without the fat that nature provides naturally alongside) is a rapid route to vitamin A depletion and  liver and other health damage. Ask bodybuilders!

3) MyPlate is a visual guide, which is easy to understand but then falls victim to “The law of unintended consequences”.

MyPlate is clearly intended to be volume guide “Make half your plate fruit and vegetables” is one of the instructions. The UK eatbadly plate may appear to be a visual “this is how your plate should look”, but, when I asked the UK Food Standards Agency where the proportions in their food groups came from (listed below), the answer was based on weight.

33% Starchy foods (bread, potatoes, pasta, cereals etc)
33% Fruit and vegetables
15% Non dairy protein (meat, fish, eggs, beans etc)
12% Milk and Dairy products  
8% Foods high in fat and sugar  (101% due to rounding)

I did another interesting experiment in The Obesity Epidemic: What caused it? How can we stop it? I started with 100 grams of starchy foods and then calculated the weight of the other categories, to maintain the proposed proportions. The weight of fruit and vegetables would also be 100 grams; non dairy protein would be 45 grams; there would be 36 grams of milk and dairy and 24 grams of foods high in fat and sugar.

Using a sample of foods from the USDA food database, I estimated the calorie averages for 100 grams of each of these food groups as 333, 42, 188, 183 and 595 respectively.  This would give the estimated calorie values (for each of these weights) of 333, 42, 85, 67 and 144 respectively. If these are then scaled up in proportion for a 2,000 calorie a day diet, the five groups end up with 992, 125, 255, 198 and 430 calories respectively. The numbers will vary for each person’s interpretation of the plate, but you can see how one third of intake in the form of starchy foods can represent half of calorie intake and another third from fruit and vegetables just 6% of energy. The supposedly smallest segment, being so energy dense, can form a perhaps unanticipated 21% of calorie intake.

The same will happen with MyPlate – potatoes and chips as ‘vegetables’ not withstanding, the energy intake (which is what the body registers) for vegetables will be small relative to, say, nutritionally inferior grains.

MyAdvice

This would be my advice by the way:

1) Eat food – we shouldn’t need to call it real food.

2) Eat that real food three times a day – unless you are a cow, or want to be the size of one, stop grazing!

3) If you need to manage your weight, manage your carb intake. Gaining weight is literally defined by the formation of triglyceride (body fat) and this is beautifully facilitated by eating carbs, which provide glucose for the glycerol part of the triglyceride structure and insulin to enable fat storage. Losing weight is literally defined as breaking down triglyceride (body fat) which can happen when the brain wants the glycerol part for glucose or the body wants the fat part for energy/repair. So, weight gain happens in the presence of carbohydrate/glucose/insulin and weight loss happens in the absence of carbohydrate/glucose/insulin.

MyPlate

MyPlate will encourage you to eat 70% of your food intake in a form that contains carbohydrate and allows you to eat 100% in this way. Nothing like what we have been eating for 3.5 million years and nothing like what we need to eat to end the epidemics of being fat and sick.

This is another tragic missed opportunity to do something about the weight and health of Americans. Follow MyAdvice and not MyPlate and you’ll buck the trend.

Appendix

In The Obesity Epidemic, for Appendix 3, I did an experiment where I tried to get the Recommended Daily Allowance (RDA) for 12 vitamins (information for B7, Biotin, was not available) and 8 minerals (calcium, magnesium, phosphorus, copper, iron, manganese, selenium and zinc). These were the nutrients for which the United States Department of Agriculture database had information and for which there was an RDA. Having said this, there were no RDA’s for vitamins B5, D and K or for the minerals calcium and manganese – an ‘Adequate Intake’ was recommended.

- Omnivores can get the RDA’s/AI’s from the following 5 foods: 100 grams of liver, 200 grams of sardines, 200 grams of whole milk, 100 grams of sunflower seeds and 200 grams of broccoli (1,300 calories). There will be infinite combinations of real foods that can provide the RDA’s/AI’s, but I started from the ones known to be highly nutritious.

- For vegetarians, the RDA’s/AI’s’s could be met with these five foods: 500 grams of whole milk, 450 grams of eggs (10 medium eggs), 300 grams of spinach, 250 grams of raw mushrooms grown in sunshine and 50 grams of sunflower seeds (1,360 calories). Dietary advisors applaud people for choosing a vegetarian diet, but then tell them to avoid eggs and to consume low-fat milk. It then becomes practically impossible for a vegetarian to meet even minimal nutritional requirements.

- Vegans can’t get B12 naturally and they would need to eat 2.25 kilograms of (raw sunshine grown) mushrooms in a fat delivery mechanism (e.g. vegetable oil – unhealthy per se) to get the ‘adequate intake’ for vitamin D and an unusual food like oriental dried radishes to get their calcium – and to repeat this daily. For completeness, the five vegan foods would be 2.25 kilograms of mushrooms, 175 grams of porridge oats, 25 grams of sunflower seeds, 100 grams of oriental dried radishes and 300 grams of spinach (in more vegetable oil) and a vitamin B12 supplement. Without the calories in the vegetable oil, the vegan basket adds up to 1,644 calories – the highest of all three sample ways of getting our nutritional requirement.

1)  I subscribe to the Children’s Food Campaign newsletter and support their campaigns.

The CFC got a great article in The Independent, which can be seen here.

2) This was an extract from the Children’s Food Campaign January newsletter: “Ever thought of avoiding Coco Pops after school?”

“A new advertising campaign from Kelloggs, suggesting to children “ever thought of Coco Pops after school?” has been eliciting outrage from parents on forums such as Netmums and Twitter. We think it’s shocking that Kelloggs, who are partners of the Government’s Change4Life health campaign, are encouraging children to eat more sugary cereals (Coco Pops are 35% sugar) when one of the key messages of the Change4Life campaign is “sugar swaps”, encouraging families to swap snacks with added sugar for low sugar or sugar-free alternatives. If you’d like to complain, you can email Kelloggs at corporateresponsibility@kellogg.com. You might also like to copy the Department of Health into your email to make them aware of your concerns: dhmail@dh.gsi.gov.uk .”

3) So, of course, I emailed Kelloggs Corporate responsibility and the Department of Health as follows:

Dear Department of Health and Kellogg’s (30/1/2010)
I am writing to complain about the advert encouraging children to eat Coca Pops after school. It is bad enough that our young people start the day with a bowl of sugary cereal (coca pops being 34% sugar). It is even worse to think that children are being encouraged to have another bowl after school. We are fighting an obesity epidemic and any sugar (empty calories) either displaces other nutritional food, which adversely impacts health, or it is eaten on top of other nutritional needs, which adversely impacts weight. There is no room for sugar in a healthy diet – let alone this amount being pushed on parents and children alike as a fun thing to do with cartoon animation etc.
That Kellogg’s does this is not a surprise – it’s a private company looking to maximise brand profitability for shareholders. That the Department of Health has Kellogg’s as a Change for Life ‘partner’ is a disgrace. Department of Health – you lose all credibility as an advisor to UK citizens having such blatant affiliations with the food manufacturers.
I look forward to your response
Kind regards – Zoe Harcombe , Obesity researcher

4) You then get an auto reply from the Department of Health saying they will reply within 20 days,  but I did get a letter back from Kellogg’s on 3/2/2010 – fair do’s – pretty speedy. Here is the response (I’ve put in my comments along side each ‘defence’):

Dear Zoe

Re: COMPLAINT TO KELLOGG’s ABOUT COCO POPS ADVERTISING

I wanted to contact you following your recent email to Kellogg’s about us promoting our Coco Pops cereal as an after school snack.

The reason for recommending Kellogg’s Coco Pops with milk as an after-school snack is no different from recommending it for breakfast – it’s a nutritionally sound product that is suitable as part of a healthy balanced diet.

The fact is Kellogg’s Coco Pops is a low fat, low saturated fat food, containing just 175 calories per serving with semi-skimmed milk.  It provides 25% of the RDA (recommended daily allowance) for six B vitamins and 17% of the RDA for iron and calcium, as well as encouraging the consumption of milk which is normally eaten with our products.  In fact, 40% of milk consumed in Britain is with cereals. , and breakfast cereals are the leading source of iron in the diet of UK children . (Zoe comment: Coco Pops are low fat because they are a cereal and cereals are predominantly carbohydrate! Coco Pops have vitamins because they are ‘fortified ‘ because they would be nutritionally lacking if they weren’t and even more vitamins are added when people drink milk  – so give your child a glass of milk when they get home).

When it comes to sugar, one portion of Kellogg’s Coco Pops has just 10.5g – approximately two teaspoons.  To put this into context: a portion of fruit yoghurt contains 20g of sugar and toast and jam has 13g . (Zoe comment: sugary yoghurts and jam are also full of sugar  – this doesn’t make our product good, but we’ll compare it to other bad stuff to try to make it look good).

Breakfast cereals provide only 5% of the adult daily intake of added sugars in the diet – compared to 37% from drinks, 32% from sugar, preserves and confectionary and 14% from other cereal products such as cakes .  Breakfast cereals contribute 6% of the average daily intake of sugar in children yet up to 30% of some micronutrients such a B vitamins and iron. (Zoe comment: so let’s double the intake of sugar from cereals, by getting kids to eat them after school, as well as before school, as cereal manufacturers are missing out on their share of the ‘junk’ market. Check spelling of confectionEry also).

Sugar adds to the enjoyment of food with no detrimental effect to health – there is no scientific evidence showing a link between sugar and obesity, cardiovascular disease, diabetes, hyperactivity or cancer. (Zoe comment: I love this one! I didn’t actually suggest that sugar is behind the major killer diseases of the modern day, but, now you mention it… See Warburg, see Yudkin… what was my quote again? “If we have been eating food as nature intended for 24 hours then agriculture, which gave us large scale access to carbohydrates, started 4 minutes ago and our consumption of sugar has increased 20 fold in the past 5 seconds. I wonder which substance is more likely to be responsible for obesity, diabetes, or indeed any modern disease…”)

What I hope we can agree on is there’s an established link between excess calorie consumption and weight gain.  So – given the obesity challenge we all face – it seems prudent to compare the amount of calories in Kellogg’s Coco Pops and milk to many typical post school snacks. A serving of Kellogg’s Coco Pops with milk contains around 10% of a child’s calorie GDA, a suitable amount for a snack. A typical milk chocolate bar is 255 calories; a 4 finger chocolate and wafer bar is 213 calories and a bag of chewy fruit flavoured sweets is 222 calories. Kellogg’s Coco Pops with milk have noticeably fewer calories and less sugar then most of these options and provide many positive nutrients the other snacks do not. (Zoe comment: No. We can’t agree on this. I actually don’t care about calories – they are just fuel. I care about empty calories – sugar – which deliver fuel with no nutrition. This is what an obese society cannot afford to consume).

As a mum of two I understand the need for kids to have a quick snack when they got home hungry from school.  But, we don’t see any evidence that encouraging Kellogg’s Coco Pops as an after school snack prevents children from snacking on fruit. (Zoe comment: Are they eating both?! Not much room left for a good dinner eh?)

Independent research shows 90% of mums  give their children a snack after school, therefore we are not encouraging an eating occasion that would not normally happen.  The top six foods eaten being crisps, fruit, sweets, yoghurt, chocolate and biscuits.  Those who said that they would choose Kellogg’s Coco Pops with milk as an alternative said it would replace (in descending order) crisps, chocolate, sweets and biscuits – not fruit or yoghurt. (Zoe comment: So parents who give their kids junk now have another option. The parents that give fruit will still do so. This is the argument used by cigarette manufacturers – we don’t increase the size of the market – we just encourage people to swap brands).

Therefore, having Kellogg’s Coco Pops with milk as an after school snack does not discourage the selection of fresh fruit, and also encourages the consumption of milk and provides essential micronutrients – an accepted dietary recommendation.

It’s for these reasons we don’t see promoting Coco Pops as an after school snack as being counter to our involvement with Change4Life. (Zoe comment: see what else Kellogg’s sponsor below…)

I’d like to assure you that at Kellogg’s we ensure all of our marketing and advertising is rigorously reviewed so that it complies with the relevant CAP broadcast and non-broadcast advertising codes.  (Zoe comment: None of this matters much because we comply with the advertising standards code, so we can do what we want!) I’d also like to advise you the current Coco Pops outdoor advertising campaign comes to its natural end this Friday.

I appreciate dialogue via a letter isn’t always the most productive.  So, I or a member of my team of nutritionists would be more than happy to meet with you and discuss your concerns in person.

Yours sincerely

(Zoe: I’ve left out the name and contact numbers for privacy, but after the job title is “State Registered Dietitian”) (Zoe comment: why am I not surprised?! The Kellogg’s Senior Manager for nutrition is a dietitian. The head of the Sugar Bureau is a dietitian. The British Dietetic Association (BDA) is “delighted” (their word) to be ‘in bed with’ the sugar and flour organisations. Kellogg’s are the sponsors of the British Dietetic Association’s annual conference on obesity. The American Dietetic Association is sponsored by Mars, PepsiCo, Kellogg’s, Unilever, General Mills and Coco-Cola. The BDA won’t tell me their sponsors – can’t think why. And then the dietitian primary slogan is “Trust a dietitian to know about nutrition”. Not when every dietitian I have met defends sugar I won’t!)

Finally – check out the Children’s Food Campaign competition for a new Coco Pops slogan - great fun! x