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‘Canada’s Food Guide’ --Promoting Health or Protecting Wealth?

Bill Jeffery, National CoordinatorCentre for Science in the Public Interest

at

Think AgainA conference sponsored by the

Canada Millennium Scholarship Foundation Parliament Hill, OttawaSeptember 16, 2005

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About the Centre for Science in the Public Interest (CSPI)

Is an independent health advocacy organization focussing on nutrition policy issues.

Has offices in Ottawa and Washington, with Canadian staff based mostly in Toronto and Ottawa.

Is funded in Canada by over 100,000 subscribers to the Canadian edition of the Nutrition Action Healthletter.

Does not accept funding from industry or government.

Coordinates a coalition of two dozen non-profit groups collectively representing 2 million Canadian citizens and health professionals.

Founded the International Association of Consumer Food Organizations (IACFO), an officially recognized observer at the WHO/FAO Codex Alimentarius Commission, and two other global consumer protection alliances.

**A summary of our public policy recommendations to improve diet (and increase physical activity) -- such as shifting sales taxes from nutritious to junk foods, prohibiting advertising to children, improving nutrition labelling on restaurant menus and prepackaged food labels, and including preventative nutrition counselling under medicare -- can be found at: http://cspinet.org/canada/pdf/PanCdn_EffectiveStrat.pdf

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My goals, this morning:

1. Underscore that the Food Guide is a key staging ground for conflict between public health and the commercial interests of, primarily, the food industry.

2. Summarize some evidence establishing the importance of nutrition for health and economic well-being.

3. Discuss the implications for CFG of an expert report of the World Health Organisation.

4. Canvass CSPI’s recommendations for reforming Canada’s Food Guide (CFG).

5. Make some observations about the vulnerability of the CFG review process to those vested interests.

6. Consider whether the 1992 Canada’s Food Guide actually helped cause, not prevent, rising obesity rates.

7. Make recommendations for fixing the advisory committee process.

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1. Amending Canada’s Food Guide is extremely contentious.

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Advice in Canada’s Food Guide has implications for most of an agri-food industry with financial interests in $100 billion in annual sales.

In an undated 2004 memo (Memo ref. 04-10-18-26-9) to the Minister, Health Canada officials

stated:

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Recommended reading for biological, social and political scientists as well as citizens and eaters:

Marion Nestle, Food Politics, (Los Angeles: U. of Calif., 2003)

Managing Editor, 1986-88 of the US Surgeon General’s Report on Nutrition and Health Professor of Nutrition at New York University

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As Professor Nestle put it:

“Food companies are not health or social service agencies, and nutrition becomes a factor in corporate thinking only when it can help sell food…My first day on the job [to edit the US Surgeon General’s Report on Nutrition and Health], I was given the rules: No matter what the research indicated, the report could not recommend ‘eat less meat’ as a way to reduce saturated fat, nor could it suggest restrictions on intake of any other category of food…Agency officials had learned to avoid such interference by resorting to euphemisms, focusing on nutrients rather than foods that contain them, and giving a positive spin to any restrictive advice about food.” (Nestle:2-3)

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For a brief account of food industry practices, see the alternate food guide (pyramid) prepared by Dr. Walter Willett, Professor of Epidemiology and

Nutrition, Harvard School of Public Health. http://www.hsph.harvard.edu/nutritionsource/Printer%20Friendly/Food%20Pyramids.pdf

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2. Nutrition is very important for health and economic well-being.

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Canadian annual costs of diet-related disease

An average of nearly 5 years of healthy life expectancy is lost due to six diet-related risk factors. (See: World Health Organization, The World Health Report 2002, (Geneva: WHO, 2002). Esp. see Table 4 in the annex which shows that loss of healthy life expectancy due to all risk factors is 9.4 disability-adjusted-life-years averaged for Canadian men and women at http://www.who.int/whr/2002/en/whr2002_annex4.pdf) and Table 10 which shows that, in developed countries, 50% of all-risk-attributable Disability-Adjusted Life Years (DALYs) were lost due to blood pressure, cholesterol, overweight, low fruit and vegetable intake, and certain rare types of childhood and maternal undernutrition at http://www.who.int/whr/2002/en/whr2002_annex9_10.pdf). So, 50% of 9.4 years is 4.7 years.)

More than 25,000 premature deaths annually are caused by diet-related disease. (See, for example, the extrapolation from published figures in endnote 11 at: http://cspinet.org/canada/pdf/Eng_CSPI_Finance.pdf)

A total of $6.6 billion per year from the Canadian economy as a whole (health care costs plus lost productivity) (See: Diane Gorman, Assistant Deputy Minister of Health, “Speech at the Stakeholder Meeting on the Review of Canada’s Food Guide to Healthy Eating,” (Ottawa: Health Products and Food Branch, Health Canada, January 20, 2004) at 3 estimating the value of health care costs and lost productivity due to diet-related disease to be $6.6 billion annually in Canada. Available on the Internet at: http://www.hc-sc.gc.ca/fn-an/alt_formats/hpfb-dgpsa/pdf/food-guide-aliment/pres_speech_adm-pres_contexte_sma_e.pdf and see Health Canada (2003) Economic Research Analysis Section, Policy Research Division, Strategic Policy Directorate, Population and Public Health Branch. Custom tabulations).

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The de facto nutrition education in Canada

Over $720 million was spent to advertise restaurants, food and alcohol in 1998. (McElgunn J. Canada's top 25 advertising categories. Marketing Magazine September 27, 1999:44.)

The average Canadian child sees 350,000 TV commercials before graduating from high school, spends nearly as much time watching TV as attending classes.

What’s on the menu?: nutritional weaklings like soft drinks, sugary cereals, candy, french fries, fast food, condiments, and activity-limiting products such as video games, movies, and television shows.

In a 1991 survey of programming, less than 9% of food ads were for dairy, fruits and vegetables (excluding french fries) (Østbye T, Pomerleau J, et al. Food and Nutrition in Canadian ‘Prime Time’ Television Commercials. Canadian Journal of Public Health 84(6) 370-74.)

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3. The World Health Organisation published an expert report with important implications for Canada’s Food Guide.

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Report of the Joint World Health Organization/Food and Agriculture Organization Expert Consultation on Diet, Nutrition, and the Prevention of Chronic Diseases, (Tech. Rpt. 916)

(WHO: Geneva, 2003) available at: http://whqlibdoc.who.int/trs/WHO_TRS_916.pdf

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Foods with demonstrated effects on health:

Protective Effects: fruits, vegetables, whole grain cereals, non-starch polysaccharides (from whole grains, fruits and vegetables), legumes, fish, fish oils, unsalted nuts (in moderation); water (as an indicator of energy density); and

Causative Effects: free sugars, preserved and red meat, salt preserved foods; salt (as distinct from sodium), hydrogenated oils, Chinese-style salted fish.

**This is important because: • people eat foods, not nutrients (cf. Dietary Reference Intake reports), and • many of the health benefits of certain types of foods are not yet definitively

attributable to well-known nutrients (e.g., fruits and vegetables). ...But also controversial because singling out foods for reduction or elimination is

effective advice and decidedly bad for the business of affected companies.

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Put yet another way, by the WHO/FAO Technical Report No. 916...

Food and food ingredients (as distinct from nutrients) for which there isconvincing or probable evidence of causative or protective effects on disease risks

Whole foods/ingredients(as distinct from nutrients)

Cancer CardiovascularDisease

Hypertension Diabetes DentalCaries

Obesity

Fruits (96,100) (81,89,90) (86) (75,77)Vegetables (96,100) (81,89,90) (86) (75, 77)Whole grain cereals (88, 90) (75, 77)Non-starch polysaccharides(from whole grains, fruits, vegetables)

(82, 90) (75, 77) (58, 63)

Legumes (89) (89) (77) (56 footnote “c”)Fish (81, 88, 90)Fish Oils (81, 88)Unsalted nuts (in moderation) (82, 87, 88)Water(as an indicator of energy density)

(70)

Free sugars (109, 112,114, 116,118, 119)

(57)

Preserved and red meat (96)Salt preserved foods; salt (as distinctfrom sodium)

(96)

Hydrogenated Oils (89)Chinese-style salted fish (96)

N.B. Numbers in parentheses refer to pages in Technical Report 916 where applicable conclusions are made.

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Contribution of Macronutrients and Alcohol to Apparent per Capita Energy Consumption

(Adapted from a slide on the Health Canada web-site with information from elsewhere on the HC and WHO sites)

Estimatedactualconsumption1992

Estimated actualconsumption2002

HealthCanadaRecom..1992

HealthCanadaRecom.2005

WHORecom.20031

% Energy from carbohydrates 52% 51% 55% 45-65% 55-75%% Energy fr. addedsugars

? ? n/a “limit” (<25%?) <10%

% Energy from fat 33% 35% <30% 20-35% 15-30%SaturatedMono-unsaturatedPoly-unsaturated

10%16%5%

9%11%3%

<10% <10% <10%

6-10%% Energy from protein 12% 11% 13-15% 10-35% 10-15%% Energy from alcohol 3% 3% <5% N/A

Note: Interpret data with caution due to changes in data collection of Oils and Fats introduced in 1995Sources: Health Canada slide 10 at http://www.hc-sc.gc.ca/fn-an/food-guide-aliment/review-examen/meet-reunion/pres_food_supply-pres_approvisionnement_alimentaire_e.html#10, and Statistics Canada, Canada Food StatsNovember 2003. Waste-adjusted data, and Report of the Joint World Health Organization/Food and Agriculture OrganizationExpert Consultation on Diet, Nutrition, and the Prevention of Chronic Diseases, (Tech. Rpt. 916) (WHO: Geneva, 2003), 56 athttp://whqlibdoc.who.int/trs/WHO_TRS_916.pdf

1 See: Report of the Joint World Health Organization/Food and Agriculture OrganizationExpert Consultation on Diet, Nutrition, and the Prevention of Chronic Diseases, (Tech. Rpt.916)(WHO: Geneva, 2003), 56 at http://whqlibdoc.who.int/trs/WHO_TRS_916.pdf

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4. These are CSPI’s three key recommendations for reforming Canada’s Food Guide.

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First, don’t counsel over-eating.

Reconsider the significant 1992 increases in the numbers of servings for all food groups, except “vegetables and fruit.” (see discussion below).

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Second, revise food group titles to reflect and reinforce dietary goals, not industry commercial objectives.

Current Titles Proposed Titles (textproposed by CSPI isunderlined)

Grain Products Whole Grain ProductsVegetables and Fruit (Retain in current form.)Milk Products 1% or less milk products

and fortified low-fat soyalternates. 1

Meat and Alternatives Fish, beans, nuts, andlow- fat meat/poultryalternatives2

Other Foods Non-essential foods tolimit or avoid.3

1 Also specify “whole milk” in current age-specific recommendation for children aged 2-3.2 Also modify directional statement accordingly.3 Add two directional statements: “If you use oils, choose products low in saturated and transfats.” “Avoid foods that are high in salt, sugar, white flour, and partially hydrogenated vegetableoil.”

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Third, make dietary guidance in the “Canadian Guidelines to Healthy Eating” clear and specific.

Current Proposed new or revised statement

Enjoy a VARIETY of foods. (Retain in its current form.)

Emphasize cereals, breads, other grain products,vegetables and fruit.

Eat more vegetables, fruits, whole grain cereals andbreads.

Choose lower-fat dairy products, leaner meats and foodprepared with little or no fat.

Choose non-fat or low-fat milk, and milk products,beans, and oily fish (such as salmon and trout). If youeat meat or poultry, choose low-fat forms and preparethem with little or no fat.

Achieve and maintain a healthy body weight by enjoyingregular physical activity and healthy eating.

Limit calorie intake to manage body weight. And enjoyphysical activity at any weight. Spend less timewatching TV and playing video games.

Limit salt, alcohol and caffeine. Avoid most processed and restaurant foods, which arehigh in salt. Limit caffeine and, if you consume alcohol,do not exceed two drinks per week for men and one forwomen.

New statement: Eat less cheese, beef, pork, cream, whole and 2% milk,egg yolks, pastries, and other foods that are high insaturated fat, trans fat or cholesterol.

New statement to address the health problems associatedwith foods high in added- sugars:

Drink fewer soft drinks, and limit cake, cookies, frozendesserts, and other foods rich in added refined sugars.

New statement to reflect widespread contemporary useof restaurant , drive-through, and take-out foods and thehigh-calorie, nutrient-poor nature of typical menu items:

When dining out, choose low-fat vegetable and fruitdishes instead of high-calorie, nutrient-poor dishes.Drink water, low fat milk, or real juice. Share or takehome the remainder of dishes served in large portionsizes. Avoid desserts.

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5. Protecting the review of Canada’s Food Guide from the influence of vested interests?

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The first step in forming the expert advisory committee was:

Health Canada contracted the former C.E.O of the National Institute of Nutrition, a body whose members consisted of large food companies, and which recently merged with the Canadian Institute for Food Information to form to form the Canadian Council of Food and Nutrition.

NIN patrons and benefactors were: Thomas D. Smyth, Bestfoods Canada, George Weston Limited, Griffith Laboratories, H.J. Heinz Company of Canada Limited, Kellogg Canada Inc., Loblaw Companies Limited, Nestlé Canada Inc., Sobeys Canada Inc., Redpath Industries Limited, J.M. Schneider Inc., Unilever Canada Limited, Suzanne Hendricks, The Canadian Salt Company Limited, Kraft Canada Inc., Manulife Financial, Maple Leaf Foods Inc., Parmalat Canada, Proctor and Gamble Inc., Robinhood Multifoods Inc., Scott’s Restaurants Inc.

CCFN members are: Advertising Standards Canada (an industry association), Beef Information Centre, California Walnut Commission, Canada Pork, Canadian Egg Marketing Agency Canadian Restaurant and Foodservice Association, Canadian Salt Co. Ltd., Canadian Sugar Institute, Canadian Turkey Marketing Agency Cantox Health Sciences International, Chicken Farmers of Canada, Council for Biotechnology Information, Dairy Farmers of Canada, Fleishmann Hillard Public Relations Canada, Freeman Mandel & Associates, GCI Group, General Mills Canada Corp., George Weston Ltd. - home of Loblaw Co. and Weston Foods Inc., Hain Celestial Canada, Heart and Stroke Foundation of Canada, Kellogg Canada Inc., Kraft Canada Inc., Langdon Starr Ketchum, McCain Foods Canada, Nestlé Canada Inc., Nicole Doucet Communications Inc., Ontario Society of Nutritional Professionals in Public Health, Pepsi - QTG Canada, Pioneer Hi-Bred, The Art of Living Well Catering, Wyeth Consumer Healthcare).

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And...

All three nominations by the Ontario Society of Nutrition Professionals in Public Health -- perhaps the only nutrition group independent of the food industry to file a formal nomination

directly with Health Canada -- were rejected.

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Consumer representation?

A Health Canada official solicited input from colleagues on a question asked by the consultant:

The reply from two Health Canada officials was:

and…

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Composition of 12-member Advisory Committee (and indicia of the institutional capacity, relevant expertise, and potential conflicts of interest)

See: http://www.hc-sc.gc.ca/fn-an/food-guide-aliment/revision/fg_advis_com-com_cons_ga_e.html

Private Interest

The Director of Scientific and Regulatory Affairs of the Food and Consumer Product Manufacturers of Canada representing 180 member companies

The President of the Vegetable Oil Industry Council representing 85,000 oilseed growers

The Nutrition Manager of the BC Dairy Federation

Public Interest Reps

Four community dietitians for small towns municipal governments (Dieppe, Vaudreuil-Dorion, Prince Albert and St. John’s; two have populations of less than 15,000, and one less than 35,000)

A professor of nutrition at one of the smallest universities in Canada

A professor of nutrition who is an advisor to the sugar industry

An untenured assistant professor of social psychology (with interests in physical activity and nutrition research)

The (general) Director of Prevention at Alberta Cancer Board

A policy researcher with the Manitoba Government interested in cultural aspects of food with a bachelor’s degree in nutrition

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6. Did 1992 CFG actually contribute to over-eating and rising rates of obesity?

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Canada’s Food Guide (front image)

1982………………………….…...…………1992

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Canada’s Food Guide (back image)

1982………………………….…...………….1992

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From E. Goddard, et al., Dept. of Rural Economy, University of Alberta, 2005 in their speech “Canadian Agricultural Policies and Health: An Example from the Meat Sector”

http://www.coop.re.ualberta.ca/symposium_2005/Presentations/egoddard1.pdf.

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Changes to average number of recommended servings by CFG food group, 1982-1992

(Table prepared by CSPI based on comparison of 1982-92 CFGs.)

Recommendednumber of servings

of Food Groups

% Increase in averagerecommended

number of servingsIn 1982 In 1992 In 1992

Grain Products 3-5 5-12 +113%Milk Products 2 2-4 +50%Vegetables and Fruit 4-5 5-10 +67%Meat and Alternatives 2 2-3 +25%

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“Foundation Diet” vs. “Total Diet”

According to Health Canada:

Predecessors to the current (1992) Food Guide were based on a "foundation diet" approach. This approach was replaced with a "total diet" approach when the current Food Guide was released in 1992. The total diet approach provides guidance to meet nutrient recommendations across a range of energy intakes, in contrast to the foundation diet approach in which minimum food intakes were suggested to provide essential nutrients in amounts recommended.”

But, the 1975 and 1982 CFGs also recommended ranges of servings for most food groups.

Whether one accepts this explanation or not, lets look at indications of possible consequences of this approach; at a minimum, maybe there are better ways to corral the bricklayers and basketball players than with ranges.

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Overall, the distribution of nutrients in the diet

did not change.

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Changing Apparent Per Capita Food Consumption,by commodity group, 1992-2002

(Consumption of nearly all major commodity groups increased during the period.)Note: Interpret data with caution due to changes in data collection introduced between the time points studied

(e.g., data collection of 'Oils and Fats') Source: Statistics Canada, Canada Food Stats November 2003. Waste-adjusted data.

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Changes to actual consumption by CGF food group, 1992-2004

(Table prepared by CSPI based on Statistics Canada Food Disappearance data Food Consumption in Canada, 2005 table Food Consumed by Major Group per Person”)

Actual Consumption Post-1992based on disappearance per capitaadjusted for loss due to waste(rounded to the nearest ½ KG)

FOODGROUP

Rise in averagerecommendedservings in 1992

StatisticsCanada proxycategories

1992 2004 % Change1992-2004

Meat andalternatives

25% Red meat +poultry + fish*+ eggs + pulses+ nuts

65 KG 69 KG +6%

MilkProducts

50% Dairy (milksolid equivalent)

17 KG 17.5 KG +3%

Vegetablesand fruit

67% Vegetables +fruit

187 KG 207 KG +11%

Grainproducts

112.5% Cereals 53.5 KG 67 KG +25%

Other n/a Oils and fats +sugars andsyrups + alcohol+soft drinks

215 KG 226 KG +5%

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Health Canada distributed approximately 24 million copies of the Guide 1992-2004.

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Could Canada’s Food Guide 1992 revisions have actually contributed to rising obesity by promoting higher calorie intake?

Note: Interpret data with caution due to changes in data collection of 'oils and fats' introduced in 1995 Source: Statistics Canada, Canada Food Stats November 2003. Waste-adjusted data.

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7. CSPI has some recommendations for re-thinkingthe advisory committee process.

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Recommendations for reform to the advisory committee process.

1. TRANSPARENCY: Government decisions should be based only on stated evidence which, with rare exceptions, should be made available to the public. One way of assuring transparency is by making available transcripts of committee deliberations as House of Commons committees, courts and numerous administrative tribunals do.

2. CONSUMER INVOLVEMENT: Representatives of independent consumer groups should be included in the consultation process and their input valued.

3. CONFLICTS OF INTEREST: While anyone ought to be entitled to make transparent representations to government about public policy, NOBODY with significant financial conflicts of interest (company stocks, employment, research grants, etc.) should serve on government appointed expert advisory bodies. It is nothing short of bizarre that government policy requires nominees to disclose conflicts of interest but conflicts, no matter how great, are not (yet) barriers to appointment, and disclosure forms are kept confidential despite the obvious public interest in their release.

4. ASPIRE TO ADVANCING THE PUBLIC INTEREST, NOT APPEASING AND COUNTER-BALANCING PRIVATE INTERESTS: Public policy reforms, like revisions to Canada’s Food Guide, should be based on the best available evidence, and designed to further the public interest; they should not be aimed at appeasing vested interests. When it comes to conflicts of interest, we should expect no less of scientific and policy advisors than we do of MPs, Senators, judges (or any government decision-maker), or even hockey referees, namely: demonstrable freedom from

bias.

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Parting thoughts:

1. Encourage (or form) independent health and citizens groups to join CSPI’s coalition of two dozen health and citizens groups collectively representing over 2 million Canadians. See: http://cspinet.org/canada/pdf/PanCdn_EffectiveStrat.pdf for a summary of recommendations and list of members.

2. Subscribe to Nutrition Action Healthletter at https://www.cspinet.org/cgi-bin/join.cgi?country=canada

3. Subscribe to our grassroots action coalition, NAHAlert, by sending an e-mail to nahalert@istar.ca with “join” in the subject line.

4. Always inquire: “Who benefits?”

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Contact info:

Bill Jeffery, L.LB., National CoordinatorCentre for Science in the Public Interest

Suite 4550, CTTC Bldg.1125 Colonel By Drive

Ottawa, Ontario K1S 5R1jefferyb@istar.ca

Tel.: 613-244-7337Fax: 613-244-1559

Website: http://www.cspinet.org/canada/