plate with shrimp and vegetables

After a bit of "KIND" nudging (via a citizens' petition filed a year ago by KIND snacks), the FDA is redefining the criteria foods must meet to use "healthy" on a label, and is seeking suggestions. Here are mine.

Featured recipe: Shrimp Pad Thai Salad

1. Healthy food promotes health.

"Health" is notoriously challenging to define because being healthy manifests itself in different ways-from how one feels to mood and mental health to disease risk factors detectable only with a blood test. But here's my assertion: health is a state of general vitality combined with a good probability of longevity. This includes a low risk for chronic diseases (e.g., heart disease, diabetes, cancer) and low likelihood of risk factors (e.g., high blood pressure, obesity) for disease. Healthy foods should increase our vitality and longevity and decrease our chance of chronic diseases. Foods that do the converse are necessarily "unhealthy."

2. Healthy is contextual.

To promote health, food has to deliver nutrients we need and avoid or minimize those we don't, either because they are intrinsically bad for us (e.g., trans fat) or we get too much already (e.g., sodium). Nutrient needs, however, vary with circumstance. In the U.S. we generally get too many calories and plenty of protein, but fall short on many nutrients we'd get if we ate enough vegetables and fruits. In South Sudan, however, there's famine and children are prone to protein malnutrition (called kwashiorkor), therefore, any concentrated source of calories and protein is healthy. In the U.S., it is rather the contrary.

3. Healthy isn't lipstick on a pig.

If ever there was an example of failing to learn from history, it is nutrition practice in America for the past 50 years. When we were advised to cut fat, we mostly added low-fat, sugary junk foods to our diets. Then we shifted our focus to avoiding carbohydrates and added junk like low-carb brownies made with trans fat. These days, there is a booming cottage industry in gluten-free junk food. And all the while, adding nutrients to foods has been used, like that proverbial lipstick on a pig, to mask a food's basic character. A breakfast cereal loaded with added sugar and salt does not become a healthy food, no matter what concentration of vitamins and minerals is tossed in. Nutrient fortification can make a good food better (e.g., vitamin D added to plain yogurt), but it cannot make a bad food good.

4. Healthy is holistic.

The definition should consider all of a food's nutrient attributes; a "healthy" food must have a decisive preponderance of beneficial nutrients relative to nutritional liabilities. Many unprocessed foods qualify readily: vegetables, fruits, legumes, whole grains, nuts and seeds, as does plain water. And while some whole foods like nuts and avocados have lots of calories-not all that helpful in this age of epidemic obesity-the calories are justified both by the concentration of beneficial nutrients and the fact that these foods are satisfying. For processed foods, an actual ratio of beneficial to detrimental nutrients might be necessary. Such tools exist. I helped build one: NuVal (found at some leading grocery chains) scores the nutritional quality of foods from 1 to 100. Research shows that when people eat more foods that score higher, they lower their risk of heart disease, diabetes and mortality.

5. Even healthy needs a home.

There can be no healthy people and no healthy food on a ravaged planet. Sustainability simply must figure in the definition. Minimally processed foods and foods emphasizing simple, plant-based ingredients tend to have lower carbon footprints and use much less water. For example, even if beef is healthy for our bodies, it's not for the planet: more water is used to produce beef than for almost any other food. The world can no longer afford to ignore such considerations in a modern definition of "healthy."

In conclusion:

Unprocessed and minimally processed vegetables, fruits, legumes, nuts, seeds-and foods made just from these-and pure water automatically qualify. Unprocessed seafood, eggs, dairy, poultry and meat can qualify, but with ­caveats about dose. Processed foods should only qualify as "healthy" when their ingredients and nutrients offer net benefit. Healthy is holistic, sustainable and contextual!

VOICE YOUR OPINION! Tell the FDA what you think "healthy" should mean. The comment period is open until April 26, 2017.