In August BAC provided comments to Health Canada as part of its second consultation on Canada’s Food Guide’s revision. TOO NARROW AN APPROACH ON WHAT MAKES HEALTHY EATING BAC disagrees with Health Canada’s narrow approach to healthy eating which simplifies the cause of obesity to higher intakes of sugars, sodium and saturated fat. According to the McKinsey Global Institute report on obesity: “Obesity is a complex, systemic, multicausal problem, rooted in the sedentary nature of modern post-industrial life, more widely available and more affordable food, a change in the nature and mix of diets, psychological stimuli such as stress and epigenetic triggers, and potentially even physiological disruption to the gut microbiome.” Among the main findings of the report “education and personal responsibility are critical elements of any program aiming to reduce obesity, but they are not sufficient on their own. Other required interventions rely less on conscious choices by individuals and more on changes to the environment and societal norms. They include reducing default portion sizes, changing marketing practices, and restructuring urban and education environments to facilitate physical activities.” WHOLE GRAINS AND REFINED GRAINS BAC is supportive of the guidance of increasing the consumption of whole grains as documented by research in the “Evidence Review for Dietary Guidance”. BAC however does not believe the evidence warrants lowering of the consumption of “refined grains”. Specifically regarding the recommendation of regular intake of whole grains, Health Canada implies that the regular intake of whole grains means a reduction in the intake of refined grains. Health Canada cites dietary patterns such as the Dietary Approaches to Stop Hypertension (DASH) diet to support their guidance to increase fruits and vegetables, whole grains and plant based protein food. BAC reminded Health Canada that the DASH diet supports the consumption of “refined grains” in identical amounts or higher than whole grains allowance. Health Canada’s recommendation to reduce consumption of refined foods may result in more birth defects and increased health care costs. On November 11, 1998, fortification with folic acid of all types of white flour, enriched pasta and cornmeal became mandatory in Canada. BAC was and is a supporter of the voluntary and then mandatory fortification of white flour etc. and is delighted with the resulting public health impact of this initiative which has resulted in a reduction in the rate of neural tube defects (NTDs) by some 48%. BAC has researched the positive health outcomes of folic acid fortification and estimates that since its commencement more than 5,000 children and families have been saved from the nightmares of NTDs with a corresponding estimated savings to the Canadian healthcare system between $3.5 and $4.5 billion in direct cost, not including billions more in indirect and opportunity costs. BAC recommended that Health Canada incorporate guidance on portion size, calorie intakes and nutrition education in school and at home. Health Canada recently published new regulations for nutrition labelling where serving sizes have been updated to a larger serving size to reflect the portion Canadians are currently eating vs. what is recommended as a reasonable portion size. Based on Health Canada’s and the food industry’s investment in new information about portion size, BAC finds it surprising that this proposed Guiding Principles does not address portion size and calories. BAC is disappointed by the lack of proposals for improving consumer nutrition literacy. Planning and preparing healthy meals and snacks requires more than knowing which foods are healthy and which foods are unhealthy. BAC is disappointed by the lack of commitment towards education and food skills development such as parental education, introducing healthy meals in schools and workplaces, changes in the school curriculum to include nutrition education and more physical exercise which are cost-effective in reducing obesity. The stated primary focus of Health Canada’s proposed healthy eating recommendations is to support health. BAC offered that it is not sufficient to tell people the ideal of healthy eating, or to encourage industry to reformulate their products to meet Health Canada criteria. It is necessary to implement policies that will promote education and knowledge transfer that will help Canadians be better equipped to make educated food choices and to prepare their food at home.
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