CARMEN Pilot Canadian Case Study Final Report

Table of Contents

• Acknowledgements
• Executive Summary
• Background and Rationale
  • Background
  • Rationale for the Study
• Methodology
  • Justification of a Case Study Approach
  • Conceptual Framework
  • Data Collection
  • Data Analysis
  • Limitations
  • Ethical Approval
• Findings
  • Contextual Factors and Ideas
    • The Institutional Setting for Canada’s Nutrition Policy
    • Nutrition as an Emerging Priority
    • Advancing Compatibility with the United States
    • Citizen Engagement
    • Intersectoral Collaboration in Policy Making
  • An Interactive Model of Building Consensus on Policy Making
    • Process Innovation
    • Barriers to Building Consensus
    • Champions
    • Stakeholder Convergence
• Conclusions
  • Policy-making Capacity at the Individual Level
  • Policy-making Capacity at the Organizational Level
  • Policy-making Capacity at the System Level
• Lessons Learned and Recommendations
  • Confirmation of Earlier Policy Study Findings
  • New Lessons Learned
  • Recommendations for Future Research
• Appendix 1
  Analytic Framework – Policy Formulation Stage
• Appendix 2
  CARMEN Pilot Canadian Case Study – Key Informant Interview Guide
• Appendix 3
  Mandatory Nutrition Labelling – A Guide For Food And Beverage Packaging In Canada
• Appendix 4
  Nutrition Labelling Policy Community 1996; 2002

Acknowledgements

The authors thank all the people involved in this study including research participants, federal government representatives, and officials from the Pan American Health Organization, whose knowledge and expertise contributed to the content of the Pilot Canadian Case Study report. Special thanks are extended to the members of the Technical Working Group who provided direction, thoughtful feedback and comments from beginning to end.

The efforts of research teams in both Brazil and Costa Rica helped to ensure the success of this innovative and participatory research process that will increase understandings of how health policies are formulated and approved. The authors gratefully acknowledge the outstanding contribution of the international research team members.

Dr. John Church (Centre for Health Promotion Studies, University of Alberta) assumed a lead role in the development of The Conceptual Framework for the Pilot Canadian Case Study. The researchers thank Dr. Church for his important contribution to the study, particularly in the early stages, and for his expert review of the draft case study report.

Finally, the authors extend their appreciation to Dr. Sylvie Stachenko, Deputy Chief Public Health Officer, Public Health Agency of Canada for her visionary leadership and ongoing support in the implementation of this international research project.

Executive Summary

On December 12, 2002, mandatory nutrition labelling was introduced in Canada. The scope of the regulations place Canada at the forefront of nutrition labelling, and the initiative is widely regarded as ground-breaking from a health policy perspective. Over the next 20 years, the accrued benefits to Canadians will be in the range of $5 billion, an estimate based on reductions in direct and indirect costs associated with cancer, diabetes, coronary heart disease and strokes.¹

Under the new system, the labels of most pre-packaged foods sold in Canada must carry a Nutrition Facts table. Consumer interests and health needs, combined with recent advances in nutritional science, contributed to the innovative design and content of the Nutrition Facts table. The mandatory regulations include updated criteria for nutrient content claims to better address consumer health issues. For the first time in Canada, diet-related health claims are allowed that highlight the relationship of certain nutrients and foods with the reduction of heart disease, cancer, high blood pressure and osteoporosis.

To date, the systematic analysis and evaluation of policy making in the prevention and control of chronic diseases is a neglected area of research efforts.² In the Pilot Canadian Case Study, policy processes leading to the approval of mandatory nutrition labelling regulations are explored. Specifically, we examine the formulation and decision-making stages of the policy cycle, and assess the key success factors in the development of nutrition labelling policies. In carrying out the study, we focus on the interactions among the various stakeholders in this policy arena, including representatives of federal government departments and/or agencies, non-governmental organizations, industry, scientists and consumers to explicate the intersectoral nature of policy making.

The 2002 regulations address three inter-related topics (i.e., nutrition labelling, nutrient content claims, and health claims). Importantly, the policy development process for these initiatives “followed separate collaborative routes of documentation, expert and stakeholder consultations and feedback.”³ However, an unexpected result was the regulations pertaining to nutrition labelling, nutrient content claims, and health claims being merged into one comprehensive “policy package” in the publication of the Canada Gazette, Part II (January 1, 2003).

In conducting the research we carried out extensive document review and synthesis of the nutrition labelling policy formulation process, followed by semi-structured interviews with 24 key informants from government, industry, academia, health professional associations, non-governmental organizations and consumer-advocacy groups. Data collection began in July 2005 and was completed by early January 2006.

Case study findings provide strong evidence that the nutrition labelling policy-making process was complex, often chaotic and unpredictable, hampered by a shortage of human and financial resources, and negatively affected by policy silos. In spite of formidable barriers and very tight timelines, a high degree of stakeholder convergence developed and this convergence facilitated the process of ground-breaking policy development. Stakeholder convergence on nutrition labelling was largely due to three main factors: (1) a common population health policy frame adopted by all participants in the consultative process; (2) the emergence of strong “champions” within the federal government’s health policy sector; and (3) the implementation of an innovative policy development process overseen by an intersectoral Nutrition Labelling Advisory Committee.

The study conclusions position findings within a framework depicting policy-making capacity (PMC) at three levels: individual, organization and system. Evidence indicates that high PMC at both the individual and system levels, combined with medium PMC at the organizational level, resulted in stakeholder convergence on issue frames, and ultimately, in policy adoption. Gaps in PMC, particularly at the organizational level, included barriers in securing resources necessary to enforce the new mandatory regulations. The dichotomy between policy formulation and implementation suggests that, while there was convergence at the policy development stage, there may be challenges at the implementation stage (e.g., enforcement of the nutrition labelling regulations).

In presenting lessons learned, we confirm the findings of earlier policy studies namely that timing is key to successful policy making and that decision-makers must have the capacity to act quickly when a policy window opens. New lessons learned through the Pilot Canadian Case Study suggest that when organizational policy-making capacity is weak, partially as a result of resource shortages and/or restructuring, policy makers must implement strategic change management practices to overcome organizational barriers. Our recommendations include a follow-up study to examine the nutrition labelling implementation process, as well as short- and medium-term outcomes.

In summary, strong evidence depicting the nutrition labelling process as a highly successful policy innovation is reflected in the title of the Pilot Canadian Case Study: “Stakeholder Convergence On Nutrition Labelling: Building Consensus On A Complex Issue.”

References

¹Health Canada. Canada Gazette, Part II. Regulations Amending the Food and Drug Regulations (Nutrition Labelling, Nutrient Content Claims and Health Claims). 2003, January 1. Available from: http://canadagazette.gc.ca/partII/2003/20030101/pdf/g2-13701.pdf Accessed 16 Oct 2006.

²World Health Organization. (2004). Policy development and noncommunicable disease prevention: The road from Kaunas. Copenhagen, Denmark: WHO Regional Office for Europe.

³Memorandum To The Minister, Amendment to Food and Drug Regulations, Schedule No. 1172, Nutrition Labelling, (undated). Health Canada, p. 1.