A working definition of an action must be usable before anything is done. Something like "makes you feel intimidated, degraded or humiliated" is worse than useless, it also cannot depend on a posteriori opinion of the object. Or if that is allowed I have the right to judge if her clothing is harassing or not.
Saying one's opinion on the looks of a fellow passanger is stupid but it is not automatically offensive. I would never do it, never done it. I am just against the late largely feminist opinion that the object has the right to be offended by anything. And still think that "tidy babe" is not bad, is it wise, no.