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EBSCOhost: Health claims: The need to match public health policy to theory

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Title: Health claims: The need to match public health policy to theory. By: Lawrence, Mark, Australian Journal of Nutrition & Dietetics, 10321322, 19980601, Vol. 55, Issue 2 Database: SPORTDiscus with Full Text

HEALTH CLAIMS: THE NEED TO MATCH PUBLIC HEALTH POLICY TO THEORY

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Section: Leading articles (See article by Williams, page 87) Health claims are generally prohibited on food labels and in advertising in most countries. According to the Codex Alimentarius Commission, 'Health claims means any representation that states, suggests or implies that a relationship exists between a food or a nutrient or other substances contained in a food and a disease or health-related condition' ( 1). For example, 'Product X may help prevent cancer'. Among their reasons for the general prohibition, food regulators refer to conventional wisdom that there is no such thing as a good or bad food, rather it is the overall diet that is important for health. However, in the early 1990s the United States Food and Drug Administration (FDA) issued legislation which permitted the use of 'model' health claims on the labels of those food products that met specified compositional criteria. This policy change came about after powerful lobbying by US food manufacturers. Following the lead of their colleagues in the. US, food manufacturers around the world are now lobbying national governments to repeal their prohibition on health claims. The article by Williams in this issue succinctly presents many of the arguments being used by food manufacturers in this process. It refers to health claims as a form of nutrition education that may help to promote public health nutrition. Conversely, public health practitioners and consumer organisations express concern that health claims are motivated by marketing objectives and have the potential to mislead consumers about food and health by promoting food as 'magic bullets'.

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EBSCOhost: Health claims: The need to match public health policy to theory

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The Australia New Zealand Food Authority (ANZFA) is now reviewing its prohibition on health claims with Proposal P153. The DAA has made a detailed submission ( 2) to the first of ANZFA's two planned consultation rounds. This submission did not share the same degree of positive assessment for health claims as that in the article by Williams. Nevertheless, the DAA did countenance a review of health claims. Specifically, the submission stated: DAA supports a cautious approach by initially allowing limited exemptions to the current general prohibition, provided adequate resources are made available to evaluate the impact of these under Australian conditions, and sufficient resources are allocated to support nutrition education. As the first of its guiding principles in conducting its review, ANZFA has stated that if a health claims framework was to be permitted it would be on the promise that it shall 'enhance public health' ( 3). The challenge for ANZFA is that there is no evidence, either locally or internationally, on which to make such an assessment. In this 'evidence-free' environment, policy development is vulnerable to the posturing of both the opponents and proponents of the debate. Extravagant statements abound. These range from implying that health claims will solve diet-related disease expenditure to dismissing them as only pandering to the 'worried well'. Policy makers need to defer to theoretical principles to assess the plausibility of such statements and thus their value to inform decisionmaking. As Williams' argues, scientific substantiation will be fundamental to the approval of potential health claims. This process is broadly supported and a substantiation framework that has been synthesised from the literature has recently been proposed ( 4). Consistent with the nature of the scientific evidence that is being proposed, health claims (and the so-called 'functional foods' on which they might appear) may conceivably offer benefits to certain individuals. An example where this has been applied is the association between folate intake and reduced risk of neural tube defects. The precise mechanism of folate's protective influence remains uncertain, it may be that additional folate is compensating for a genetic disorder affecting its metabolism in susceptible women. As such, it would be acting more as a therapeutic than as a conventional nutrient. This illustrates where health claims may inform relevant consumers of the functional properties of those products in the grey area between food and drugs. As such, drug companies may become increasingly involved in the health claims process given their experience and expertise in conducting epidemiological trials and health economic evaluations. Health claims are less likely to be user-friendly to basic foods such as the humble fruit or vegetable. Apart from the difficulty of displaying a health claim on a product that does not come in a wrapper or a packet, the research and development that will generate the scientific data to justify a potential health claim will require substantial investment. It is highly processed, value-added products that would more likely be the beneficiaries of this investment. From a public health context there is a need to keep expectations regarding potential health claims in perspective. Scientific substantiation is being positioned as the harbinger of 'truth' in

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EBSCOhost: Health claims: The need to match public health policy to theory

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the decision-making process for health claims. Yet, truth about food and health depends upon context. It cannot be assumed that the findings of a clinical trial on individuals can necessarily be generalised to predict population-wide outcomes. No matter how strong the quality and quantity of their scientific substantiation, health claims will not be able to tackle the socioeconomic circumstances where health (and disease) in society are created. A challenge for decision makers will be to avoid fostering a policy framework that promotes a peculiarly clinical, reductionist form of science to dominate the way the relationship between food and health is defined, investigated and applied. Despite the requirement for further consultation, the Minister for Health and Family Services announced during his launching of Kellogg Australia's Facts for Life program that ANZFA 'will develop a scientifically-based framework for health claims' ( 5). The rationale for this announcement was apparently an assessment that heath claims will be the solution to, rather than the cause of, public confusion about nutrition, diet and food messages. The results of the limited number of studies that have evaluated this particular aspect of health claims are inconclusive. For example, among the findings of the FDA study ( 6) to which Williams refers, it was also found that consumers felt 'bombarded' with diet and health information. A more constructive approach to address consumer confusion regarding food and health might be to promote nutrition education. Rather than relying on the availability of more information, nutrition education provides consumers with the principles and skills to interpret food and health information and thereby improve their capacity to make food selection choices. Public health practitioners are asking whether the Minister's comments suggest the government is abrogating responsibility for complex public health nutrition issues by placing its faith in quick fix initiatives offered by the private sector; that is, are health claims a form of 'privatisation' of nutrition education? In the absence of evidence, the policy approach appears to be to proceed with the reassurance that sufficient nutrition education, monitoring and evaluation and enforcement frameworks will be put in place to complement policy change. The question becomes, who is going to pay for these services? In its submission DAA stated it: . . . is keen to ensure that the limited and shrinking public health dollar is not diverted into funding the establishment of a complex and costly system to regulate health claims, at the expense of positive health promotion and education activities. DAA does not support the introduction of health claims without this guarantee ( 2). Clearly there are many complex policy issues to resolve. The health claims 'agenda' will exert substantial influence over food and nutrition research and the information environment within which food is marketed in the future. As informed professionals experienced in assisting consumers with their food selection choices, dietitians have a key role to play in actively contributing to the decision-making process for health claims rather than passively responding to its outcome. References

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EBSCOhost: Health claims: The need to match public health policy to theory

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1. Codex Alimentarius Commission. Appendix 1: Draft guidelines for use of health and nutrition claims. Rome: Food and Agriculture Organization of the United Nations, World Health Organization CL 1995/26-FL, 1995. 2. Dietitians Association of Australia. DAA submission in response to Australia New Zealand Food Authority Proposal P153 Health and Related Claims. DAA: Canberra. November 1997. 3. Australia New Zealand Food Authority. Information summary, proposal P153, health and related claims. Canberra: ANZFA, 1997. 4. Lawrence M, Rayner M. Functional foods and health claims: A public health policy perspective. J Public Health Nutr 1998:1:75-82. 5. Wooldridge M. Confusion about nutrition, diet and food messages: government and industry to explore new approach. Media release 18 March 1998. http://www.health.gov.au/ mediarel/mw47i98. 6. Levy AS, Derby BM, Roe BE. Briefing session on health claims quantitative study. Washington. DC: Food and Drug Administration, Division of Marketing Studies, 1996. ~~~~~~~~ Mark Lawrence, NHMRC Scholar, Deakin University, Victoria

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