Friday, 30 October 2015
Jamie Oliver wants Justin Trudeau to focus on child nutrition | Toronto Star
Jamie Oliver wants Justin Trudeau to focus on child nutrition | Toronto Star
We can do better . The model based on Physical Activity Only is in need of an overhaul and I think we need to be more inclusive whith regard to the obesity issue. Paul Murphy
Copied Below:
We can do better . The model based on Physical Activity Only is in need of an overhaul and I think we need to be more inclusive whith regard to the obesity issue. Paul Murphy
Copied Below:
"Celebrity Chef and Sobeys pitch-man, Jamie Oliver, is nudging the new
Liberal Government to do better on child nutrition and food labelling:
http://www.thestar.com/entertainment/2015/10/29/jamie-oliver-wants-justin-trudeau-to-focus-on-child-nutrition.html
It is timely advice to Prime Minister Designate Trudeau as he prepares
to give his new ministers of health and finance their marching orders.
The previous Conservative government, by the end, acknowledged the
huge human and economic toll of diet-related disease but never
mustered the political will to implement foreseeably effective new
regulations and programs to help make Canadians, especially children,
be healthier. The former government seemed too unwilling to speak
truth to the powerful food industry.
It is not clear if the mandate letters for the soon-to-be-be named 25
cabinet Ministers will be published (as Ontario, BC, and NB liberal
counterparts have done recently) or remain cabinet secrets in the long
tradition of opaque federal governance.
There is much to commend in the Liberal Government election platform.
See our synopsis issued after the polls closed:
http://cspinet.org/canada/pdf/federal-election.2015.public-health-nutrition.pdf
I look forward to working with new government to ensure that the broad
ideas set out in its Platform are converted into effective public
health laws, policies and programs.
-Bill Jeffery
-----------------------------------------
Bill Jeffery, LLB, National Coordinator
Centre for Science in the Public Interest (CSPI)"
Thursday, 29 October 2015
Rudd Center Recent Publications October 2015
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Britain: 'the fat man of Europe' - Live Well - NHS Choices
Britain: 'the fat man of Europe' - Live Well - NHS Choices
“The UK is the ‘fat man’ of Europe,” writes Professor Terence Stephenson in Measuring Up, a 2013 report on the nation’s obesity crisis by the Academy of Medical Royal Colleges (AoMRC).
“It is no exaggeration to say that it is the biggest public health crisis facing the UK today,” he says.
From the article .
“The UK is the ‘fat man’ of Europe,” writes Professor Terence Stephenson in Measuring Up, a 2013 report on the nation’s obesity crisis by the Academy of Medical Royal Colleges (AoMRC).
“It is no exaggeration to say that it is the biggest public health crisis facing the UK today,” he says.
From the article .
Mum’s fury as overweight daughter cast as Augustus Gloop in school play | The Sun
http://www.newslocker.com/en-uk/news/uk_news/lexi-shaw-given-part-of-augustus-gloop-in-school-play-of-charlie-and-the-chocolate-factory/view/
Mum’s fury as overweight daughter cast as Augustus Gloop in school play | The Sun
Overweight and Obese children continue to be targeted and stigmatized. The full story may not be out and we may have other articles that may help to sort out the issue. Paul
Mum’s fury as overweight daughter cast as Augustus Gloop in school play | The Sun
Overweight and Obese children continue to be targeted and stigmatized. The full story may not be out and we may have other articles that may help to sort out the issue. Paul
Wednesday, 28 October 2015
Food For Tomorrow 2015 - Taxing Soda: A Sweet Solution or Not?
Food For Tomorrow 2015 - Taxing Soda: A Sweet Solution or Not?
Centre for Science in the Public Interest (CSPI) Draft Document
The Honourable Dipika Damerla, MLA October 26, 2015
Associate Minister of Health Responsible for Wellness
Ministry of Health and Long-term Care
777 Bay Street, Suite 1903
Toronto, ON M7A 1S5
By email
to: Martha.Greenberg@ontario.ca ; Andrew.Robertson@ontario.ca
Dear Minister Damerla:
I am pleased to offer the
following comments of the Centre for Science in the Public Interest Canada
(CSPI)[1] in regards to the
consultation on restaurant menu labelling.
Nutrition Regulation-Making Context
Poor nutrition is the leading cause of preventable death and disability in Canada,
causing an estimated 48,000 to 66,000 deaths each year as a result of
nutrition-related heart disease, stroke, cancer, and diabetes caused by excess
sodium intake, excess abdominal body fat, risky blood cholesterol and glucose
levels, and inadequate fruit and vegetable intake.[2] In high-sodium-consumption countries like
Canada, there is a 90% lifetime risk of developing hypertension—the world’s
leading single risk factor for death, due mainly to heart attacks and strokes.[3]
Improving nutrition could be a major
driver of increased workforce productivity, and a major source of enhanced
human liberty, quality of life, and childhood life chances in peaceful
countries with modern health care systems, like Canada.
This year, Heath Canada estimated that people
consuming an unhealthy diet are 11% less productive than those who have a
healthy diet,[4] a
huge sum in a $2 trillion economy. Annual
nutrition-related financial losses—even at a paltry $25,000 per lost life-year—totaled
more than $21 billion in Canada in 2010 based on the estimated 864,034
life-years lost.[5]
Good nutrition can also provide important
relief for provincial
and federal Medicare as well as public and private employer disability pension
budgets and shorten wait times for publicly funded health care. Ways to effectively
prevent nutrition-related illness also take on heightened importance as Ontario
and other governments consider implementing a national pharmacare program,[6]
potentially with the collaboration of the new federal government.[7]
Clause-by-Clause Recommendations
Our
recommendations are set-out below, using tracked changes to describe proposed deletions
(struck-out text) and additions (underscored text) to the Government’s proposed
regulatory text.
I.
PRIORITY RECOMMENDATION: Mandating sodium disclosures on restaurant menus
is crucial.
a.
CSPI-proposed revisions to the draft regulation
Add the following after section 6 of the proposed regulations:
Sodium information is to be displayed on menus, etc.
6.1
Effective July 1, 2017, the amount of sodium in milligrams per
serving must also be reported for every menu item except alcoholic beverages
containing less than 50 milligrams of sodium and all other food and beverages
that are otherwise exempted from the calorie information disclosure requirement.
6.2
The information disclosed pursuant to section 6.1 must be displayed
in the same manner as the calorie information and using a context statement that
is worded in accord with the following chart based on information that may be
amended from time to time by Health Canada:
|
Age Ranges
|
Target Sodium (mg/day per person)
|
|
Children
aged 4-8
|
1,200
|
|
Children and adults aged 9-50
|
1,500
|
|
Adults
51-70 years
|
1,300
|
|
Adults 71+
years
|
1,200
|
b.
Rationale
Section 2 of the Healthy Menu
Choices Act, 2015 clearly empowers the Government of Ontario to require the
disclosure of the amount of sodium on menus, in addition to calories.[8] The
Ministry of Health and Long-term Care, through the Lieutenant Governor in
Council Government of Ontario should set a clear timetable for mandating sodium
disclosures on chain restaurant menus that specifies the format for such
disclosures and mandates a phase-in
date even if it allow a delay beyond the January 1, 2017 deadline for calorie disclosures
laid-out in the Healthy Menu Choices Act,
2015. Two
dozen of MPPs from all three political parties recognized the value
of sodium labelling on restaurant menus on the record of the Legislative
Assembly, some MPPs stressing this on several occasions.
And, while the Ontario government
maintains that requiring sodium labelling on menus could be considered in the
future, Health Canada says that the average
Canadian now consumes more than double the target amount of sodium
(3, 400 mg instead of 1,500 mg), causing upwards of 10,000 premature deaths
annually in Canada and heavy use of often government-insured anti-hypertensive
drugs.[9] More
than 40 Canadian community leaders and experts, including
internationally recognized experts in nutrition and health policy, the Canadian
Diabetes Association, Canadian Nurses Association, Canadian Public Health
Association, Canadian Women’s Health Network, College of Family Physicians of
Canada, Dietitians of Canada, and the Fitness Industry Council of Canada, and
the federal Minister of Health’s Sodium Working Group[10]
recommended sodium labelling (along with calories) at restaurants to prevent
thousands of heart attack and stroke deaths.
Health
Canada, the World Health Organization, the Ministry of Health and Long-term
Care, and Public Health Ontario urge people to reduce sodium to reduce blood
pressure and the risk of heart disease and stroke. More than 82% of
Canadians support requiring chains to disclose amounts of sodium on menus.[11] University of Toronto researchers found that
sodium levels in main entrees at 65 fast food and sit-down chains were
“alarmingly high” (1,011 mg and 1,455 mg, respectively)[12]
and that posting sodium numbers on menus could reduce intake by 681-1,360 mg
per meal.[13] A recent Public Health Ontario study indicates
that calories-only labelling at fast food restaurants (i.e., without sodium
information) may even nudge customers to choose higher calories options possibly because, unlike sodium levels,
fast food calorie numbers are often lower than what respondents expect.[14]
Large amounts of salt can be added to food by restaurants without
consumers’ knowledge. By the same token, it is much harder to estimate sodium
levels than calories from menu names, pictures, and even by taste. Without seeing so on menus, Ontarians won’t
know that, for example:
·
McDonald’s Angus
Classic Bacon and Cheese Sandwich (1,690 mg) has two-and-half times
the amount of sodium as the Quarter Pounder Without Cheese (670 mg); and
·
Tim Hortons’ Biscuit, Sausage, Egg,
Cheese Breakfast Sandwich has two-and-half times the sodium (1,130 mg)
of the English Muffin with Egg and Cheese (610 mg).
Currently, food
labels on prepackaged foods systematically and dramatically understate the
saltiness of foods and are partly responsible for the current high sodium
intake in the population. Federal
labelling regulations currently and, in our view, without justification, mandate
that the amounts of sodium in Nutrition Facts tables be expressed as a
percentage of a Daily Value based on 2,400 mg per day—a figure based on the maximum recommended intake instead of
the target intake. In 2010, the federal
Minister of Health’s own Sodium Working Group unanimously recommended changing
the Daily Value from 2,400 mg per day to 1,500 mg per day to better guide
sodium intake by individuals and provide more effective incentives to food
manufacturers to reduce the amount of salt added to processed foods.[15]
|
|
Target Intake
|
Daily Value on Labels =
Upper Limit Intake
|
Current Estimated Actual
Intake
|
|
Sodium
|
Recommended
daily intake = 1,500 mg (and only 1,000-1,300 mg/day for young children and
adults over 50)
|
Current DV =
2,400 mg
|
3,400 mg
|
According
to a national public opinion poll commissioned by the Public Health Agency of
Canada in 2009, 76% of Canadians believe that the amount of sodium should be
based on the 1,500 mg adequate intake, and only 15% believed it should be based
on the upper limit (9% did not know) a five-fold difference.[16] The survey did not ask whether the current DV
was based on a target or a maximum, but one can reasonably conclude that many
Canadians are now misinterpreting this label information and eating saltier
food than they intend.
According to the U.S. Institute of
Medicine, the vast majority of elevated blood pressure is due to excess sodium
intake (chiefly from added salt), overweight (largely caused by excess caloric
intake), and insufficient potassium intake.[17] As noted above, in high sodium-consumption
countries like
A study by Canadian researchers published this year in a journal of
the American Heart Association, Hypertension,
estimated that hypertension—up to
one-third of which is estimated to be attributable to excess sodium intake[18]—cost
the Canadian healthcare system nearly $14 billion in 2010.[19] Accordingly, excess sodium could cost the Ontario healthcare
system more than $1 billion annually.
In 2010, Premiers and
territorial leaders agreed that:
Supporting healthy living is also important
to reducing burdens on the health care system.
For example, reducing sodium intake could prevent up to 23,500
cardiovascular events annually, and generate close to $3 billion in health care
savings. Premiers encouraged Canadians to reduce their personal sodium intake
level to 1500 mg per day and urged the food industry to immediately implement
voluntary measures recommended by the recent [federal health minister’s expert]
Sodium Working Group report.[20]
Then Provincial and Territorial Health Ministers later called for
federal regulations to be developed in case timely voluntary sodium reductions
were not demonstrated. The health
ministers issued a joint statement that stated, in part:
Provinces and territories commit to sodium reduction
initiatives within their own jurisdictions. Ministers support the immediate
implementation and monitoring of the Federal Government’s voluntary targets
while developing mandatory regulations to follow should the voluntary approach
not prove effective.
II.
Remove the exemption for on-line menus that do not
provide prices.
a.
CSPI-proposed revisions to the draft regulation
Amend subsection 3(2) of the
proposed regulation as follows:
(2)
Online menus and menu applications, advertisements and promotional flyers are
exempt from the requirements of subsection 2 (2) of the Act as long as they do not list
standard food items that are available for delivery or takeaway ordering.
b.
Rationale
Since the costs of providing nutrition information in more than one
location on websites is very low (little more than the price of copying and
pasting text), providing this information wherever the product is named will
simply ensure that the information is more likely to be seen by the purchaser
and used to inform product choices.
III.
Narrow the exemption for seasonal/infrequent menu
items from 90 days to 30.
a.
CSPI-proposed revisions to the draft regulation
2. (2) The following food or
drink items are exempt from the definition of “standard food item” in
subsection 1 (1) of the Act:
1. Food or drink items that are offered for sale by the regulated food
service premise for less than 30 days per calendar year, whether consecutively
or non-consecutively.
b.
Rationale
The exemption for seasonal and other irregular menu items that are sold
fewer than 90 days per year is over-broad. For instance, as currently drafted, this
clause entirely exempts products that are available for all three summer months
even if they are highly standardized and sold year after year. Likewise, this subsection would indirectly
expand the scope of subsection 5.1 (exemption for seasonal foodservice
operations from 60 days to 90 days, rendering that section meaningless.[*] A limit of the requirement to foods sold only
for 30 days per year or more is a sufficient threshold to exempt true culinary
experiments.
IV.
PRIORITY RECOMMENDATION: Specify minimum colour contrast and formatting
specifications for calorie disclosures to ensure their prominence and use.
a.
CSPI-proposed revisions to the draft regulation
6. The information that, under section 2 of the Act, is required to be
displayed on menus, labels and tags shall be displayed in accordance with the
following rules:
1. The information must be adjacent to the name or price of the standard
food item to which it refers.
2. The information must be in the same font and format as, and must be
at least the same size and prominence as, the name or price of the standard
food item to which it refers.
3. The information must be displayed in black or red print against a
white or neutral background.
4. The information must avoid the display of redundant and disorganized information
unless doing so would impede consumers’ ability to make menu choices.
b.
Rationale
Achieving high colour contrast between the text and
the background, sorting menu items from highest to lowest within comparable
product categories, and reducing the display of redundant information are approaches
that can increase the salience and highten the usefulness of calorie and sodium
information displayed on menus. If more
consumers notice nutrition information, more will use it to make healthier
choices and manufacturers will, in turn, have greater incentives to reformulate
products to reduce sodium and calories which will benefit all of their
customers, not just the ones that read labels.
V.
Clarify requirement to ensure that the calorie-range
approach is not abused to conceal product-specific calorie information for products
that very widely, nutritionally, and that an average calorie approach must be
used to describe the calorie counts of numerous flavours that differ only
trivially, nutritionally.
a.
CSPI-proposed revisions to the draft regulation
7. Where a standard food item that is available in a number of flavours,
varieties or sizes is listed on a menu, label or tag,
i. if the menu, label or tag does not list the flavours, or varieties of
the standard food item that are available, and only includes a general
description of the standard food item, the calorie range for the available
flavours, varieties or sizes of the item must be displayed provided that the
actual number of calories is displayed on the label or tag where the flavour is
displayed.
ii. if the menu, label or tag lists specific flavours, varieties or
sizes of the standard food item, the number of calories for each flavour,
variety or size must be displayed.
iii if the menu lists more than two flavours or varieties of a standard
food item that are available and those flavours vary by less than 5% in calories
from lowest to highest, the number of calories for the range of flavours must
be indicated by the average calories for all of the flavours.
b. Rationale
When average calories counts are provided to consumers for
nutritionally similar foods (e.g., for flavours of non-diet pop), it can
simplify the amount of quantitative information that customers need to process
to make menu choices. By the same token,
in the case of all food and beverages (except calorie-free drinks), the amounts
of calories for various size options will always be important information
unique to that choice and unlikely to be usefully displayed elsewhere than on
the menu itself. That information should
never be reduced to a range because doing so would undermine customers’ ability
to make nutritionally informed choices.
VI.
Ensure that regulations applicable to customizable
foods mandate the disclosure of calories in the standard menu items, not undressed
menu items, and meal-component calorie-counts are also provided.
a.
CSPI-proposed revision to the draft regulation
8. For standard food items that are offered for sale with the option of
adding standard supplementary items such as toppings, sauces, dressings or
condiments that are listed on the menu, label or tag,
i. the number of calories must be displayed for the standard preparation of the food item,
ii. the number of calories must be separately declared for each standard
supplementary item that is listed, and a statement must be included that
indicates that the calories are additional to the calories displayed for the standard
preparation of the standard food item or deleted from that standard preparation
if the respective items are omitted, and
iii. the number of calories for each standard supplementary item that is
listed on the menu, label or tag must be declared for each size of the standard
food item it complements.
b.
Rationale
The current draft of the regulation appears to allow restaurant to,
for instance, to furnish the calorie count for a menu item without condiments
or sauces (e.g., a plain burger and bun, or a turkey sandwich without cheese
and mayonnaise) and is therefore misleading under-estimates calories and
needlessly obliges customers to tally calorie numbers in nearly every case,
even if they do not customize the standard option. Also, allowing restaurants with menus that
promote customization the ability to name sauces and toppings without
specifying the calorie counts associated with those choices needlessly deprives
consumers of the information they need to select healthier options.
VII. The alcohol labelling requirement should inform consumers about the
caloric diversity of alcoholic beverages available at chain restaurants and
should observe the proposal’s own general rounding rules for calorie
disclosures.
a.
CSPI-proposed revision to the draft regulation
Signs, premises that serve alcohol
7. A person who owns or operates a regulated food service premise is exempt
from paragraph 1 of subsection 2 (1) of the Act with respect to standard food
items that are alcoholic beverages, as long as the information in the
following Table, in substantially the same format as in the Table but modified
to reflect the serving sizes used in the restaurant, is displayed in close
proximity to the place where the alcoholic beverage is listed on the menu,
label or tag, and in the same font, size and prominence:
|
Standard Alcoholic
Beverages
|
Standard
Serving Size
|
Average Calories per Standard Serving Size
|
Calories per 100 mL
|
|
Red Wine (11.5%)
|
1 glass (150 mL/5 oz)
|
130
|
90
|
|
White Wine (11.5%)
|
1 glass (150 mL/5 oz)
|
120
|
80
|
|
Regular Beer (5%)
|
1 large glass (20 oz/600
mL)
|
260
|
40
|
|
Regular Beer (5%)
|
1 bottle (341 mL)
|
150
|
40
|
|
Light Beer (4%)
|
1 bottle (341 mL)
|
100
|
30
|
|
Spirits (40%)
|
1 shot (45 mL/1½ oz)
|
100
|
220
|
|
Note: Actual calories
of alcoholic
beverages may vary and calories for
additional ingredients
are not included. Standard serving sizes
are based on one drink as outlined in Canada’s Low-Risk Alcohol Drinking
Guidelines.
based on one drink as outlined
in Canada’s Low-Risk Alcohol Drinking Guidelines.
based on one drink as outlined in
Canada’s Low-Risk Alcohol Drinking Guidelines.
|
|||
7.1 Mixed drinks that
include both alcohol and non-alcoholic beverages must disclose calorie
information in the same manner as for other foods and non-alcoholic beverages
as prescribed by these regulations.
b.
Rationale
The proposed regulations recommend average reference calorie numbers
for standardized drinks rounded to the nearest calorie (i.e., needlessly
precise detail), but proposes that calories for all other foods and drinks be
rounded to the nearest 10 calories (i.e., wisely avoiding needless precision). Proposed section 6.4 states:
The information with respect
to the number of calories of the standard food item must be rounded to the
nearest 10 for items with over 50 calories and to the nearest five for items
with 50 calories or less.
Also, 20 ounce “pints” are commonly served sizes
for draft beer so should be included in the chart where such drinks are on the
menu, but the calorie numbers in this chart should always be adapted to reflect
the serving sizes for beverages used in the particular restaurant where the
chart is posted.
Lastly, many restaurants and drinking
establishments serve cocktails with non-standard amounts of alcohol and copious
amounts of non-alcoholic drink mixes which can raise calories to levels that exceed
those of full course meals. We were
unable to find any chain restaurants that disclose calorie information online for
all of their alcoholic beverages.
However, one small survey by the Globe
and Mail’s nutrition columnist, Leslie Beck, revealed that the calorie
counts for home-made cocktails can be
upwards of eight-fold higher than the approximately 100 calories for a shot of
an unsweetened spirit, for example:
·
Long Island Iced Tea: 780
calories
·
Margarita (made with premix):
740 calories
·
White Russian: 425 calories
·
Mai Tai: 350 calories
·
Smirnoff Ice: 310 calories[21]
VIII.
PRIORITY RECOMMENDATION: Draft benchmark statements for daily calorie
guidance are up to 20% higher for adults and 30% higher for children, a glaring
miscalculation for a policy that the government has publicly and repeatedly portrayed
as a measure to reduce childhood obesity.
a.
CSPI-proposed Amendments to Proposed regulation:
9. (1) For the purposes of subsections 2 (6)
and (7) of the Act, one or more signs that comply with the following rules are
required to be publicly posted at every regulated food service premise:…
2. Each sign must contain the following information: “The average adult
requires approximately 2,000 calories per day” and, where the regulated food
service premise sells or offers for sale standard food items that are targeted
at children, must contain the following information: “The average child aged four
to 9 years old requires approximately 1,300 calories per day, and the average
child aged 10 to 13 years old requires approximately 1,800 calories per day.”…
(3) Where a menu or part of a menu is only targeted at children, the
following alternative information may appear in place of the information listed
in paragraph 2 of subsection (1): “The average child aged 4 to 9 years old
requires approximately 1,300 calories per day, and the average child aged 10 to
13 years old requires approximately 1,800 calories per day..
b.
Justification and rationale
Ontario’s proposal
would require chain restaurants to counsel Ontario adults to consume 2,000-2,400
calories per day, much more than the 2,000-calorie benchmark long-required
for Canadian pre-packaged food labels and for the new U.S.
Food and Drug Administration menu labelling system.
Worse, the Ontario government
proposes to let companies recommend that 4-9-year
olds consume 1,200-2,000 calories per day, which is much more than
the 1,250-1,750
calories Health Canada advises for that age and way more than the
1,200-1,400 calories the U.S. FDA menu label rule allows for children that age.
It is hard to
imagine how this approach could help Ontarians, especially parents of children,
meet sensible healthy eating goals, but easy to see how this could be a bonanza
for chain restaurants. The infamous
obesity epidemic followed a rise in average caloric intake of approximately 240
calories during the 1990s.[22]
The fact that
individual needs vary is implicit in the use of the word “average.” Briefer statements are more likely to be read
and understood.
IX. The
regulations should impose the duty on the vendor to ensure the nutrition
information is accurate, not just a duty to select a reputable service or
approach to making the calculations.
a.
CSPI-proposed Amendments to Proposed regulation:
Determination of number of calories
10. For the purposes of subsection 2 (8) of the Act, the number of calories
in a standard food item may be determined by either,
(a) testing by a laboratory that the person who owns or operates the
regulated food service premise reasonably believes will provide accurate
results; or
(b) a nutrient analysis method that the person who owns or operates the
regulated food service premise reasonably believes will accurately estimate the
number of calories in a standard food item,
however, the responsibility for the accuracy of the information and for
compliance with these regulations rests with the operator of the regulated food
premises.
b.
Rationale
The restaurant operator must be
responsible for the food it sells and the information about that food that it
provides to consumers. Its
responsibility must not stop at the decision to hire a reputable party to calculate
that information, especially because those parties are not obliged to shoulder
any responsibilities under these proposed regulations or the statute.
Summary and Conclusion
The Province of Ontario is leading
the way in Canada by mandating the disclosure of nutrition information on
restaurant menus, however, it is especially incumbent on the Ministry of Health
and Long-term Care to ensure that the regulations best protect Ontario children
and adults, especially so that consumers:
·
also have sodium information as soon as possible;
·
benefit from sufficient formatting and colour-contrast specifications to
ensure that the calorie and other nutrition labelling information is
prominently displayed enough to fully promote its use; and
·
are not nudged to consume even more calories than before by context
statements that advise consuming up to 30% more calories than what Health
Canada and countless public health authorities have been advising for more than
a decade.
The surprising failures of the
regulations in these three respects raises concern that the government may have
yielded so much to industry pressure as to undermine the public health benefit
of these regulations to the point that the health and public finance interests
of Ontarians may actual suffer rather than improve when these regulations are
implemented in 2017. The Government of
Ontario repeatedly gave prominence to food industry views when the proposal to
mandate calorie labelling was first announced with a VP of McDonald’s Canada, during the consultation process in the fall of 2013, during the 2015 clause-by-clause review in the Standing
Committee on Government Operations, and immediately following the passage of the legislation. It
is not too late to rectify these shortcomings by refining the menu labelling
regulations in the manner that we described in this comment.
Respectfully
submitted,
Bill Jeffery, LLB, National Coordinator
Centre for Science in the Public Interest
References
5. Persons who own or operate the following regulated food service premises
are exempt from section 2 of the Act with respect to those food service
premises:
1. Food service premises that operate
for less than 60 days in a calendar year.
[1] The
Centre for Science in the Public Interest (CSPI) is a non-profit health
advocacy organization specializing in nutrition and food safety with offices in
Ottawa, Washington, and staff in Toronto.
CSPI's Ottawa advocacy efforts are supported by nearly one subscriber the
Canadian edition of Nutrition Action Healthletter within a block of
every Canadian street corner. CSPI does not accept
industry or government funding.
[2] World Health
Organization. Global Health Risks: Mortality and burden of disease
attributable to selected major risks. 2009. W.H.O. Geneva. See, esp. p.
17. Available at: http://www.who.int/healthinfo/global_burden_disease/GlobalHealthRisks_report_full.pdf
Statistics Canada. Mortality, Summary List of Causes. 2008. Ottawa. Catalogue no. 84F0209X
which indicates the total number of deaths in 2008 was 238,617, 20% of which is: 47,723.
Available at: http://www.statcan.gc.ca/pub/84f0209x/84f0209x2008000-eng.pdf
See
also: The Washington-based Institute
for Health Metrics and Evaluation’s disease risk factor calculator which uses
country data compiled by the World Health Organization, to estimate, e.g., that
65,722 deaths in Canada are due to dietary risks: http://www.healthmetricsandevaluation.org/gbd/visualizations/gbd-arrow-diagram
[3] Vasan RS, Beiser A, et al. Residual lifetime risk for developing
hypertension in middle aged women and men: The Framingham Heart Study. Journal of the American Medical Association.
2002; 287:1003-1010 cited in Appel L (Panel Chair). Dietary Reference Intakes for Water, Potassium, Sodium, Chloride, and
Sulfate. U.S. Institute of Medicine. Washington, D.C. 2005 at 354.
[4] Governor in Council proposal to make Regulations Amending the Food and Drug
Regulations — Nutrition Labelling, Other Labelling Provisions and Food Colours.
Canada Gazette, Part I. Vol. 149, No. 24 pages 1192-1265 at 1203. Available at: http://www.canadagazette.gc.ca/rp-pr/p1/2015/2015-06-13/pdf/g1-14924.pdf
[5] The Washington-based Institute for Health
Metrics and Evaluation’s disease risk factor calculator also uses country data
compiled by the World Health Organization, to estimate, e.g., that 65,722
deaths in Canada are due to dietary risks: http://vizhub.healthdata.org/irank/arrow.php
World Health Organization. Global Health Risks:
Mortality and burden of disease attributable to selected major risks. 2009.
W.H.O. Geneva. See, esp. p. 17. Available at: http://www.who.int/healthinfo/global_burden_disease/GlobalHealthRisks_report_full.pdf –
Statistics Canada. Mortality, Summary List of Causes. 2008. Ottawa. Catalogue
no. 84F0209X which indicates the total number of deaths in 2008 was 238,617,
20% of which is: 47,723. Available at: http://www.statcan.gc.ca/pub/84f0209x/84f0209x2008000-eng.pdf
[6] Health minister says
it's time to fix drug plan. The Daily
Gleaner (New Brunswick). June 26, 2015 Friday. Pg. A1.
[7] The 2015 election platform of the
Liberal Party of Canada at page 9 states: “We will negotiate a new Health
Accord with provinces and territories, including a long-term agreement on
funding…We will join with provincial and territorial governments to buy drugs
in bulk, reducing the cost Canadian governments pay for these drugs, and making
them more affordable for Canadians.”
See: https://www.liberal.ca/files/2015/10/New-plan-for-a-strong-middle-class.pdf
[8] Paragraph 2(1)1, 2(1)2, and 2(1)6 of the Healthy Menu Choices Act, 2015, S.O. 2015, c. 7, Sched. 1,
available online at http://www.ontario.ca/laws/statute/15h07
state:
Information
to be displayed
2. (1) Every person who owns or operates a
regulated food service premise shall ensure that there is displayed, in
accordance with the requirements of this section, the following information:
1. The number of calories of every
standard food item that is sold or offered for sale at the regulated food
service premise.
2. Any other information required by the regulations with respect to every standard food item that is sold
or offered for sale at the regulated food service premise…
Signs
(6) Every person who owns or operates a
regulated food service premise shall ensure that there are publicly posted at
the regulated food service premise, in a manner that is in accordance with the
regulations, one or more signs that contain any caloric or nutritional information that may
be required by the regulations.
[bold red emphasis added]
[9] See,
e.g., Kirsten Bibbins-Domingo. Projected Effect of Dietary Salt Reductions on
Future Cardiovascular Disease. New England Journal of Medicine. 2010;362:590-9; and Havas S, Roccella
EJ, et al. Reducing the public health burden from elevated blood pressure
levels in the United States by lowering intake of dietary sodium. American
Journal of Public Health. 2004; 94(1):19-22. U.S.-based Institute
for Health Metrics and Evaluation’s Global
Burden of Disease project estimated that approx. 5,000 to 24,000 deaths are
attributable to sodium in Canada. See: 2013
details published by the New England Jl
of Med: http://www.nejm.org/doi/full/10.1056/NEJMoa1304127
[10] Sodium Working Group. Sodium
Reduction Strategy for Canada. Ottawa. Health Canada. July 2010. Available at: http://www.hc-sc.gc.ca/fn-an/alt_formats/pdf/nutrition/sodium/strateg/reduct-strat-eng.pdf
[11] Canadians’ Perceptions of, and Support for,
Potential Measures to Prevent and Reduce Childhood Obesity Final Report. for Health Canada by Ipsos Reid. Nov. 2011 which found that 92% of
Canadians favour requiring “fast food restaurants to list nutrition
information, such as caloric, fat, and sugar content, on their menus.” See: http://www.sportmatters.ca/files/Reports/Ipsos%20Obesity%202011.pdf
Final Report: Canadians’
and Health Care Professionals’ Views on Sodium. Health Canada
POR-08-21. Dec. 16, 2009. which found
that 90% of Canadians support “Require foods that are high in sodium to display
symbols or words on the front of the label that highlight that fact.” at 46,
Available at: http://epe.lac-bac.gc.ca/100/200/301/pwgsc-tpsgc/por-ef/public_health_agency_canada/2009/117-08/report.pdf Arcand, J, Mendoza,
J, et al. Results of a National Survey Examining Canadians’ Concern, Actions,
Barriers, and Support for Dietary Sodium Reduction Interventions. 2013. Cdn
Journal of Cardiology at S2.
[12] Scourboutakos M, Corey PN,
Mendoza J, Henson S, and L’Abbe M.
Restaurant Menu Labelling: Is it worth adding sodium to the label? 104(1) Canadian
Journal of Public Health e1-e7.
Accessible via: http://journal.cpha.ca/index.php/cjph/article/view/4492
[13] Scourboutakos M and L’Abbe
M. Sodium Levels in Canadian Fast Food
and Sit-Down Restaurants. 104(1) Canadian Journal of Public Health e2-e8. Accessible via: http://journal.cpha.ca/index.php/cjph/article/view/3683
[14] Erin Hobin, Heather Lillico, Fei Zuo, Laura Rosella, David Hammond.
Effect of Menu Labelling on Parents’
Willingness-To-Pay for Fast-Food Kids’ Meals: Experimental Auction Analysis.
2015. Public Health Ontario. Under
review.
[15] Sodium Working Group. Sodium
Reduction Strategy for Canada. Ottawa. Health Canada. July 2010. Available at: http://www.hc-sc.gc.ca/fn-an/alt_formats/pdf/nutrition/sodium/strateg/reduct-strat-eng.pdf
[16] Final Report: Canadians’ and Health Care Professionals’ Views on
Sodium. Health Canada POR-08-21. Dec. 16, 2009. Prepared for: Public Health
Agency of Canada which found that 90% of Canadians support “Require foods that
are high in sodium to display symbols or words on the front of the label that
highlight that fact.” at 46, Available at: http://epe.lac-bac.gc.ca/100/200/301/pwgsc-tpsgc/por-ef/public_health_agency_canada/2009/117-08/report.pdf
[17] Committee on Public Health Priorities to Reduce and used Control
Hypertension in the U.S. Population, Institute of Medicine of the National
Academies. A Population-Based Policy and
Systems Change Approach to Prevent and Control Hypertension. Report, v-173.
2010. Washington, DC, USA, National Academies Press.
[18] U.S. Institute of Medicine 2010. A Population-Based Policy and Systems Change Approach to Prevent and
Control Hypertension. Washington, DC at pp. 74, 83. Available at: http://www.nap.edu/catalog/12819/a-population-based-policy-and-systems-change-approach-to-prevent-and-control-hypertension
[19] Colin G. Weaver, Fiona M. Clement, Norm R.C. Campbell, Matthew T. James, Scott W. Klarenbach, Brenda R. Hemmelgarn, Marcello Tonelli, Kerry A. McBrien Healthcare Costs
Attributable to Hypertension Canadian Population-Based Cohort Study. Hypertension.
2015; 66: 502-508
Available at: http://hyper.ahajournals.org/content/66/3/502
[20]
Council of the Federation.
Communiqué. Premiers Protecting Canada’s Health Care
Systems. Winnipeg. August 6, 2010. Available at: http://www.councilofthefederation.ca/pdfs/PremiersProtectingCanadasHealthCareSystem.pdf
[21] Leslie Beck has calorie counts for your favourite drinks. CTV News. July 28, 2010. Available at: http://www.ctvnews.ca/leslie-beck-has-calorie-counts-for-your-favourite-drinks-1.536854
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