Rule Three: Vegetables & Fruits are Heart of Controlled-Carb

We hear much of a healthy diet is from eating fruits and vegetables. Research suggests there is a strong correlation between "good" health and "bad" health over the long-term when comparing the dietary habits of those eating a diet rich with fruits and vegetables to those consuming less than recommended levels.

Diets that strategically restrict carbohydrate are often criticized for lack of fruits and vegetables in the dietary approach. Much like the second rule getting lost in translation, from an allowance of a large variety of meats, poultry, fish, shellfish and game to a requirement to eat "fatty steaks, bacon, brie and cheeseburgers," by those unconvinced a low-carb diet is scientifically supported, rule three is often either ignored in the media and/or used to show how unsustainable carbohydrate restriction is in the long-term for someone to do forever.

How about we take a look, and see what the third rule actually says, and what it "pearls" it contains in both the short and long-term, and where vagueness may lead to misinterpretation:

Rule 3:

• Eat no more than 20 grams a day of carbohydrate, most of which must come in the form of salad greens and other vegetables. You can eat approximately three loosely packed cups of salad, or two cups of salad plus one cup of other vegetables.

First, we know from the published books, that the Induction period is a minimum of two weeks; while one can, and many do, stay within the 20g of carbohydrate beyond two weeks, the above rule is in place for at least the first two weeks.

During this time, the person starting the low-carb diet is tasked with two things in this rule:

1. limiting carbohydrate to just 20g a day and
2. ensuring that most of those 20g carbs are from salad greens and other (allowed) vegetables.

As an example, the rule says this is "approximately" three loosely packed cups of "salad" (note not simply salad greens), or two cups of "salad" (again not simply salad greens) plus one cup of other (allowed) vegetables (without mention of raw or cooked state).

We also know that the plan includes a deduction of fiber, so the amount of non-starchy vegetables (and fruits which I'll get to in an upcoming post) - in cups - that one is expected to consume depends highly on which allowed vegetables are selected in a day. Regardless of which are included, a minimum 10g net (deducting fiber) must come from non-starchy vegetables!

We also plainly see that it is not *mandatory* to deduct fiber per the rule above; however, I strongly suggest folks do deduct fiber as it allows a greater intake of non-starchy vegetables, which are not only low in calories, but nutrient powerhouses. When you deduct the fiber, you're able to consume more essential nutrients than if you don't.

I've previously offered examples of how different selections of non-starchy vegetables may look in a day of eating on a plan allowing 20g net in a day. Once again, I am providing examples to emphasize, even at 20g net carbohydrate, where 10g net is the minimum, a low-carb plan - done properly - meets or exceeds intake recommendation of at least five servings per day in the Dietary Recommendations for Americans for fruits and vegetables.

Example 1

• 1-cup green beans (cooked measure)
• 2-cups Shredded Cos/Romaine Lettuce (raw)
• 4-pieces Crimini Mushrooms (raw)
• 1/4-cup Shredded Red Cabbage (raw)
• 4 Cherry Tomatoes (raw)
• 1-cup Spinach (raw)
• Total Carbohydrate = 18g
• Fiber = 8g
• Net Carbohydrate = 10g
• USDA Servings of fruits/vegetables = 5

Example 2

• 1/2 Avocado (raw)
• 3-cups Cos/Romaine Lettuce (raw)
• 4 Cherry Tomatoes (raw)
• 1/4 cup Shredded Red Cabbage (raw)
• 1-cup Spinach (cooked measure)
• 1/2-cup Broccoli Florets (raw)
• 1/2-cup Sliced Cucumber (raw)
• Total Carbohydrate = 24g
• Fiber = 14g
• Net Carbs = 10g
• USDA Servings of fruits/vegetables = 6

Example 3

• 2-cups Shredded Cos/Romaine Lettuce (raw)
• 1/2-cup Cherry Tomatoes (raw)
• 1-cup Spinach (cooked measure)
• 1/2-cup Asparagus (cooked measure)
• 1/2 cup Sweet Green Peppers (cooked measure)
• Total Carbohydrate = 21g
• Fiber = 9g
• Net Carbs = 12g
• USDA Servings of fruits/vegetables = 6

One can see from the examples above, depending on selections made from those fruits and vegetables allowed in the first two weeks, it is not difficult to meet the recommended intake of 5-or-more servings of fruits and vegatables.

The aim to include a minimum of 10g (of the 20g allowed) from non-starchy vegetables is a "must" in the rule above.

It is also clearly stated as a "minimum," and therefore understood that if you would like to include 12g, 15g or more from non-starchy vegetables in lieu of other foods that have carbohydrate, that is also allowed.

So, if one is cognizant of and desiring more than the minimum intake of fruits and vegetables, they are completely allowed to consume more - with the only restriction being not to exceed 20g net (deducting fiber) during the first two weeks.

Must you aim to consume half your allowed carbohydrate from fruits/vegetables? YES

Can you eat more fruits/vegetables (allowed ones), say 12g, 15g, 18g? YES

Can you deduct fiber? YES

Do you have to? NO (but doing so allows a greater intake of fruits/vegetables and associated essential nutrients)

With all that said, and focus on what all the rules mean for the long-term, I contend that one is expected to continue eating this level (as minimum each day) as they progress toward the long-term eating. I believe that this is one more "foundational" part of carbohydrate restricted diets in the long-term and something intended to be continued as one increases carbohydrate and includes a wider selection of foods, including more vegetables, fruits, nuts, seeds, legumes, and if desired, even whole grains.

Many folks say a low/controlled-carb diet is a way of life, yet find it difficult to take what they start with - 20g net (deducting fiber), of which most must be provided by non-starchy vegetables, a 10g minimum each day - and maintain that aspect as one solid foundation to build upon as they continue to lose weight and then maintain their weight.

Old eating habits start to creep back with more carbs; habits such as preferrentially selecting sweeter foods or grains (even if whole grain) with consumption of non-starchy vegetables waning as one re-introduces more carbohydrate.

If one takes this rule, and continues to extend it --- fully --- until they reach 40g net carbohydrate each day (deducting fiber), they will be consuming incredibly healthful levels of fruits and vegetables, and will be able to eat a very wide variety of them too. That is, until 40g carbohydrate is achieved in the diet during weight loss, one must always include half those carbohydrates from fruits and vegetables with each incremental increase in carbohydrate. (Beyond that, it is increasingly difficult to continue adding more non-starchy vegetables and fruits due to their bulk; you can, of course - it's just not as easy to do).

Now that isn't exactly stated explicitly in the rule, but it is from my experience and those I've given assistance, one significant contributor to maintenance of weight in the long-term. That's because if you're aware of and including a lot of fruits and vegetables (specifically non-starchy vegetables and low-glycemic load fruits) it is difficult to consume excess calories each day over the long-term.

It becomes much easier to consume excess calories when you "play" the carb game (like many play the "points" game with Weight Watchers) and make choices to stay within a number, rather than focus on quality of choice.

But if you're committed to making sure that, no matter what intake of carbohydrate you reach (60g, 90, 120g or more), that you always are sure you include at least 10g net minimum at the start and then 20g minimum (net) from non-starchy vegetables/low glycemic-load fruits as you continue along, you'll have a favorable calorie intake that helps maintaining weight easier.

As you add back carbs, this rule must remain in your eating habits, even if you only stick with 10g net as minimum (which I don't suggest you do) as you're learning in the beginning - you cannot add back carbs and eliminate or reduce how many vegetables and salads you eat each day and expect to maintain your weight using grains, nuts, fruits, etc. as your primary source of carbohydrate later....you must always maintain a level of carbs from your vegetables and salad greens - even in maintenace.

This rule, like rule two, is taking you "back to basics" - helping you learn, step-by-step, how to nourish your body with high quality nutrients from real foods; over time you're encouraged to include a wider variety of non-starchy vegetables, low glycemic-load fruits, nuts, seeds, legumes and more, and the starting basics for the diet should be extended out for the long-term; that is, establish now, at the start, that as part of your long-term habitual diet, non-starchy vegetables and low-GL fruits will be a large part of your overall diet - your body will thank you!

Thirteen Days Remain for Comments

A quick reminder - the FDA is awaiting comments on their proposed guidance document concerning Complementary and Alternative Medicine. It is Docket No. 2006D-0480 and the full-text is here: Draft Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration.

I previously urged readers to submit comments here, or send comments via snail mail to:

Dockets Management Branch (HFA-305)
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852

Be sure when you do to include Docket Number 2006D-0480 in your submission.

Please carefully read the document and pay attention to the terminology used.

The document, if approved, specifically medicalizes complementary and alternative therapies, along with the products, supplements, devices and even foods often part of those therapies. By using "treatment" rather than "therapy;" - "medical" rather than "modality;" the document terminology sets traditional and alternative approaches to well-being and health inside allopathic or conventional medicine in the United States and will regulate products currently protected by congressional legislation, in DSHEA (Dietary Supplement Health and Education Act of 1994).

The document, if approved, effectively renders the DSHEA null-and-void, not by congressional mandate, but by a cunning use of terminology to eliminate the limitations the law imposes on the FDA in its current oversight of dietary supplements.

Please take a few moments to add your comments that an end-run around congress is unacceptable - DSHEA was enacted into law after extensive public debate and only public debate, in the House and Senate - in our legislature - should preceed any change made to its mandates.

If the FDA wants greater authority to regulate supplements they need to go to congress and make their case to amend DSHEA, not make an end-run around the existing legislation!

BE HEARD: FDA Commentary Open for Complimentary & Alternative Medicine

A Guidance Document open for public comments over at the FDA came to my attention this morning. The comment period ends April 30, 2007 and I strongly encourage my readers to take a few moments today to submit comments along with some additional follow-up.

Why?

Draft Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by the Food and Drug Administration, Docket No. 2006D-0480 is as detailed and vague as it gets. It seeks to "tie up loose ends" many feel exist in current regulation around approaches used in Complementary and Alternative Medicine (CAM) by establishing guidance for industry about communicating benefits of a "wide array of healthcare practices, products and therapies that are distinct from practices, products, and therapies used in 'conventional' or 'allopathic' medicine."

The critical issues to think about:

1. The guidance document, if finalized as written, will regulate virtually all herbs and supplements as drugs if they actually benefit a medical condition unless it is "generally recognized, among experts qualified by scientific training and experience to evaluate the safety and effectiveness of drugs, as safe and effective for use under the conditions prescribed, recommended, or suggested in the labeling."

Not only that, but also...

2. The document, if finalized as written, is extremely vague as to the extent of regulatory reach. For example, the document states, as an example, that vegetable juice (yes, vegetable juice) "absent any claims that would make the juice subject to the drug definition, the juice would be a 'food' under section 201 (f) of the Act because it is used for food or drink for man."

Now earlier in the document, in an attempt to define how vegetable juice might be defined as a drug, it is stated, "This means, for example, if a person decides to produce and sell raw vegetable juice for use in juice therapy to promote optimal health, that product is a food subject to the requirements for food in the Act and FDA regulations...If the juice therapy is intended for use as part of a disease treatment regimen instead of for the general wellness, the vegetable juice would be subject to regulation as a drug under the Act."

The FDA defines a drug as "...(B) articles intended for the use in the diagnosis, cure, mitigation, treatment or prevention of disease in man or other animals; and (C) articles (other than food) intended to affect the structure or any function of the body of man or other animals..."

So, with that, any person (or product) that states "drink some vegetable juice to prevent [insert disease]" is making a drug claim; and if vegetable juice is not recognized by the FDA as a legally available drug in the United States, the person (or company) making the claim is now subject to prosecution if they are not a medical professional licensed to practice medicine.

Vegetable juice, a drug?

Not only that, but also...

While it may seem unthinkable, consider this, as another blog highlighted, "[i]ts very specificity makes manifest fundamental inconsistencies and absurdities in the DSHEA law. If you substitute "water" for "cranberry tablets" and "severe dehydration" for "urinary tract infection," as found on Page 12, then you've turned water into a drug according to these guidelines. Obviously, the FDA would never turn water into a drug, but the guidelines allow them the option to do so. That "flexibility" alone makes the guidelines dangerous. In reality, what the guidelines do is extend the FDAs authority to arbitrarily decide when to enforce their will."

Not only that, but also...

The most alarming thing to me is the use of language throughout the document - the FDA sets the stage that anyone who is not a licensed healthcare professional (physician, nurse, DO, etc.) will be subject to prosecution for practicing medicine without a license because the terms used, "medicine" rather than modality, "treatment" rather than therapy. This is because of already established regulations and laws in all 50 states as to whom may "treat" medical conditions; these new regulations will specifically limit whom is able to communicate options to consumers to those holding a professional license. Any practitioner - homeopathic, naturopathic, reflexologist, Chinese or Ayruvedc practitioners, nutritionists, etc. - will all be at risk for practicing medicine without a license if they even suggest something like vegetable juice may prevent, treat or mitigate the symptoms of a disease.

Which brings us back to the vague nature of the document...the specific language - everything termed as medicine and treatment - leaves the very real potential that any and all substances - vitamins, minerals, herbs, co-factors, probiotics, etc - could be classed drugs, new drugs, or medical devices if they are being recommended to prevent, treat, mitigate or cure disease states (remember water cures dehydration).

While the media is silent on this, the FDA quietly awaits comments that few know are open.

Well, now you know and now you can let the FDA know what you think - because if we do not comment we'll have no one to blame when we lose access to the vast options available to us right now.

Here is what you can do to let your voice be heard:

1. Submit comments online. Be sure you include the Docket No 2006D-0480 with your comments.

2. You can also send comments via snail mail to:

Dockets Management Branch (HFA-305)
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852

3. You can call and chat up the following people and let them know what you think:

Sheryl Lard-Whiteford at 301-827-0379
Daniel Nguyen at 301-827-8971
Ted Stevens at 301-594-1184
Wayne Amchin at 301-827-6739

4. In addition to the above comment submissions, write or call your representatives and senators! You can find the contact information for your representatives in the House and Senate here.