This week US Health and Human Services rolled
out their new inverted food pyramid that has created a buzz in the
health freedom community. Analysis of my response was summarized by
AlterAI.
Summary: Dr. Peter McCullough’s Response to the New HHS Inverted Food Pyramid
In his Focal Points presentation, Dr. Peter McCullough, an internist, cardiologist, and epidemiologist, critiques and evaluates the new inverted food pyramid introduced by Robert F. Kennedy Jr. and the Make America Healthy Again (MAHA)
coalition under the Department of Health and Human Services (HHS). The
new model flips the traditional pyramid structure—placing previously
limited foods at the base and moving carbohydrate-heavy items to the to
the bottom tip meaning low or no intake.
Core Principles from McCullough’s Analysis
Humans as Omnivores but Poor Starch Tolerance McCullough emphasizes that humans are omnivorous by design but historically suffered rising chronic disease rates after adopting agrarian, starch-based diets (wheat, rice, potatoes). He calls starch the primary driver of obesity and insulin resistance, noting that up to 60% of modern caloric intake comes from starch, which he likens to “sugar molecules linked together.”
Three Primary Dietary Villains — “The Three S’s” He identifies three major contributors to chronic disease:
Sugar
– Addictive, nonessential, and dangerous in both processed and natural
concentrated forms. This group is associated with obesity and diabetes.
Starch – Excessive carbohydrates converted to sugar, fueling obesity and diabetes.
Saturated Fat
– Found in animal products like meat, butter, cheese, and pork;
stimulates hepatic cholesterol synthesis and promotes atherosclerosis.
Saturated animal fat is calorie dense, provides nonessential fatty
acids, and directly contributes to obesity. They also are associated
with increased risk of some cancers. So this group is associated with
atherosclerotic cardiovascular disease, cancer, and obesity.
He critiques the new HHS pyramid for defending the third “S.” According to him, saturated fat intake should remain below 10 grams daily to prevent cardiovascular disease and obesity. Robert F. Kennedy has said there has been an '‘unjust war against saturated fat.” McCullough disagrees.
Americans
consume around 50 billion hamburgers annually. This figure comes from
USDA estimates and industry reports, which note that the average
American eats about three burgers per week, adding up to roughly 150
burgers per person per year across the population. That is hardly a
“war” on animal fat. Rather there will plenty of work for interventional
cardiologists, cardiac surgeons, and heart centers eager for more cases
as the new pyramid advances more animal fat from pork, beef, chicken,
and full-fat dairy products.
Evidence Linking Saturated Fat to Disease McCullough references extensive clinical evidence—over 1,500 studies—linking
saturated fat to elevated LDL cholesterol and coronary artery disease.
He rejects recent “pro-saturated-fat” or keto/carnivore
reinterpretations as methodologically weak, calling them “sloppy dietary epidemiology” done to justify the keto-carnivore craze.
Recommended Diet Composition McCullough proposes a diet emphasizing:
High-quality proteins: fish, beans, nuts, egg whites, and nonfat dairy.
Fruits and vegetables: unrestricted consumption.
Avoidance: pork (due to “genetic vaccines” in livestock), processed oils, refined starches, sugars, and saturated fats. He approves limited, infrequent consumption of lean chicken or beef.
Praise and Critique of the Inverted Pyramid
Grade: B
— McCullough praises the pyramid’s reduced emphasis on starch and sugar
but criticizes inclusion of red meat, butter, cheese, and pork.
Suggestions for “A+” rating: remove those saturated fat sources entirely or relegate them to the bottom with refined starch.
Lifestyle Validation: The Seventh-Day Adventist Example He cites Seventh-Day Adventists—noted
vegans and vegetarians—as having the lowest rates of coronary disease,
diabetes, and metabolic syndrome, highlighting National Nutrition
Advisor Dr. Ben Carson as an exemplar. McCullough notes their dietary purity and longevity as benchmark outcomes.
Takeaway Dr. McCullough concludes that minimizing all three S’s (sugar, starch, and saturated fat)
is the key to optimizing cardiovascular and metabolic health, reducing
cancer risk, and promoting longevity. He underscores that health is not
achieved by favoring one macronutrient but by simultaneously de-emphasizing all harmful dietary groups.
References
HHS / MAHA Announcement: “Department of Health and Human Services, Make America Healthy Again Coalition Announces Inverted Food Pyramid” (U.S. Department of Health and Human Services, 2025).
American Heart Association (AHA) Dietary Guidelines: “Dietary Fats and Cardiovascular Disease: A Presidential Advisory from the AHA,” Circulation, 2017 — reaffirmed updates 2024.
Recommends <10% of daily calories from saturated fat and substitution with unsaturated plant oils.
McCullough, P. (2025).Focal Points: Response to New Food Pyramid.