Unless you have been “off the grid”, you are more than aware of the tsunami of consultations, regulations and proposed regulations regarding nutrition and food labelling, food safety and prohibition of ingredients. Let’s recap what happened in the past 200 days. IN SEARCH OF A HEALTHY EATING STRATEGY On October 24, 2016, Health Minister Jane Philpott launched The Healthy Eating Strategy for Canada. The objective of the strategy is to improve the food environment in Canada and the outcome is to make the healthier food choice the easier food choice. By making it easier for Canadians to eat well, Health Canada is attempting to address the burden on Canada’s health care system due to chronic diseases, which Health Canada says is caused by poor diet. Yet like many things with government, Health Canada is proposing a number of initiatives in search of a strategy! BAC has undertaken an extensive review of all documents and participated in a wide variety of government consultations and we are still unable to articulate the Healthy Eating Strategy clearly. At the most fundamental level, a strategy is about creating clarity of purpose. If the purpose of these tactics is to make the healthier food choice the easier food choice the first question that needs to be answered is what is a healthier food choice? Can this definition be supported scientifically? Todate it hasn’t! SWEAT THE EXECUTION Launching the Healthy Eating Strategy is only the beginning. To be successful it needs to be well executed. Most strategic planning experts will say that a well-executed strategy requires: clear priorities, evaluation of the measurable goals specified in the strategy, continuous communication and education and a final SWOT (an acronym for strengths, weaknesses, opportunities and treats analysis. Although Canada has many data sets, its food performance data are not collected strategically on a pan-Canadian scale to measure the goals set out in the Healthy Eating Strategy. Many organizations including BAC recommended that the Canadian Community Health Study (CCHS) to be updated every five years. The previous 2004 CCHS Nutrition Survey is over 13 years old and new results of the 2015 CCHS Nutrition Survey will not be released until the summer of 2017. Will the strategy be updated to reflect the most recent consumption survey? Will a SWOT analysis be done to validate that the strategy is responding to the most recent needs of Canadians? If past experience is any indicator of future behaviour, the answer is no! ONE OUNCE OF PREVENTION IS WORTH A POUND OF CURE One of the weaknesses of the Healthy Eating Strategy is the absence of nutrition education. How can consumers, especially children change their behaviour and make educated food choices if they themselves are not “educated”? Health Canada’s investment in education is vague at best, if not missing entirely. The lack of consumer nutrition education programs actually undermines the labelling tactics that are part of the Health Eating Strategy. In their consultation document “Toward Front-of-Package (FOP) Nutrition Labels for Canadians, Health Canada states that existing nutrition labelling tools are perceived by some consumers to be too complex to understand and use. Instead of helping consumers improve their nutrition literacy with education programs Health Canada is proposing to multiply the number and amount of nutrition based labels – labels that Health Canada admits consumers already find too challenging to use. INDUSTRY MAKING INVESTMENTS – WHERE IS GOVERNMENT? The food industry has calculated it will need to invest over $2 billion to comply with the upcoming Healthy Eating labelling tools. These billions don’t take into account the further billions of dollars in innovation and reformulation that Health Canada is pushing for. Health Canada’s failure to make substantial and ongoing investments in consumer based food/nutrition education is unfortunately not new. One need not look any further than the lack of education programming around previous releases of the Nutrition Facts Table and Sodium Working Group recommendations on sodium reduction as evidence of Health Canada’s singular focus of putting the responsibility (and costs) for mitigation of chronic disease squarely on the shoulders of the food industry. PROGRAMS AND DECISIONS BASED ON SCIENCE??? One of the major commitments of the new federal government was to use evidence/science based decision making. Over the past 200 days BAC is left asking “Where’s the science?” to support many of Health Canada’s initiatives. As an example, BAC has pointed out to Health Canada: i) The new %Daily Value on total sugar, rather than being based on science, is based in part on opinion and consumer consumption data that was collected as much as 15 years ago. ii) the footnote at the bottom of the new Nutrition Facts Table about % daily value to help consumers understand what is a little and what is not science based. Indeed, the U.S. uses a different criteria and so does the U.K. iii) Front of Pack Labelling – Health Canada is proposing warning labels for three essential nutrients – sugar, sodium and saturated fat. Yet the criteria to trigger the warning isn’t based on science - Health Canada itself says it’s a “rule of thumb”. iv) Banning partially hydrogenated oils (trans fats) is solving a problem that simply no longer exists. The food industry has already removed 97% of trans fats and the remainder is soon estimated to disappear. If the last 200 days are any indication of what is to come, we are in for a stormy next 200.
Published by Annex Bakers Journal. View All Articles.