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‘Canada’s Food Guide’ -Promoting Health or Protecting Wealth?
Bill Jeffery, National Coordinator
Centre for Science in the Public Interest
at
Think Again
A conference sponsored by the
Canada Millennium Scholarship Foundation
Parliament Hill, Ottawa
September 16, 2005
1
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

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
2
counselling under medicare -- can be found at: http://cspinet.org/canada/pdf/PanCdn_EffectiveStrat.pdf
Healthletter.
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.
4
Advice in Canada’s Food Guide has implications for most of an agrifood 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:
5
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
6
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)
7
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

8
2. Nutrition is very important for health and economic well-being.
9
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-guidealiment/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.)
11
3. The World Health Organisation published an expert report
with important implications for Canada’s Food Guide.
12
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
13
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 is
convincing or probable evidence of causative or protective effects on disease risks
Whole foods/ingredients
(as distinct from nutrients)
Fruits
Vegetables
Whole grain cereals
Non-starch polysaccharides
(from whole grains, fruits, vegetables)
Legumes
Fish
Fish Oils
Unsalted nuts (in moderation)
Water
(as an indicator of energy density)
Cancer
 (96,100)
 (96,100)
Cardiovascular
Disease
 (81,89,90)
 (81,89,90)
 (88, 90)
 (82, 90)
Hypertension
Diabetes
Dental
Caries
 (86)
 (86)
 (75,77)
 (75, 77)
 (75, 77)
 (75, 77)
 (58, 63)
 (89)
 (81, 88, 90)
 (81, 88)
 (82, 87, 88)
 (89)
 (77)
 (56 footnote “c”)
 (70)
 (109, 112,
114, 116,
118, 119)
Free sugars
Preserved and red meat
Salt preserved foods; salt (as distinct
from sodium)
Hydrogenated Oils
Chinese-style salted fish
Obesity
(57)
 (96)
 (96)
 (89)
 (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)
% Energy from carbohydrates
% Energy fr. added
sugars
% Energy from fat
Saturated
Mono-unsaturated
Poly-unsaturated
% Energy from protein
% Energy from alcohol
Estimated
actual
consumption
1992
Estimated actual
consumption
2002
Health
Canada
Recom..
1992
Health
Canada
Recom.
2005
WHO
Recom.
20031
52%
?
51%
?
55%
n/a
45-65%
“limit” (<25%?)
55-75%
<10%
<30%
<10%
20-35%
<10%
15-30%
<10%
13-15%
<5%
10-35%
6-10%
10-15%
N/A
33%
35%
10%
16%
5%
12%
3%
9%
11%
3%
11%
3%
Note: Interpret data with caution due to changes in data collection of Oils and Fats introduced in 1995
Sources: Health Canada slide 10 at http://www.hc-sc.gc.ca/fn-an/food-guide-aliment/review-examen/meetreunion/pres_food_supply-pres_approvisionnement_alimentaire_e.html#10, and Statistics Canada, Canada Food Stats
November 2003. Waste-adjusted data, and 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), 56 at
http://whqlibdoc.who.int/trs/WHO_TRS_916.pdf
16
4. These are CSPI’s three key recommendations
for reforming Canada’s Food Guide.
17
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).
18
Second, revise food group titles to reflect and reinforce
dietary goals, not industry commercial objectives.
Current Titles
Proposed Titles (text
proposed by CSPI is
underlined)
Grain Products
Vegetables and Fruit
Milk Products
Whole Grain Products
(Retain in current form.)
1% or less milk products
and fortified low-fat soy
alternates. 1
Fish, beans, nuts, and
low- fat meat/poultry
alternatives2
Non-essential foods to
limit or avoid.3
Meat and Alternatives
Other Foods
1
Also specify “whole milk” in current age-specific recommendation for children aged 2-3.
2
Also modify directional statement accordingly.
Add two directional statements: “If you use oils, choose products low in saturated and trans
fats.” “Avoid foods that are high in salt, sugar, white flour, and partially hydrogenated vegetable
oil.”
3
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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 and
breads.
Choose lower-fat dairy products, leaner meats and food
prepared 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 you
eat meat or poultry, choose low-fat forms and prepare
them with little or no fat.
Achieve and maintain a healthy body weight by enjoying
regular physical activity and healthy eating.
Limit calorie intake to manage body weight. And enjoy
physical activity at any weight. Spend less time
watching TV and playing video games.
Limit salt, alcohol and caffeine.
Avoid most processed and restaurant foods, which are
high in salt. Limit caffeine and, if you consume alcohol,
do not exceed two drinks per week for men and one for
women.
New statement:
Eat less cheese, beef, pork, cream, whole and 2% milk,
egg yolks, pastries, and other foods that are high in
saturated fat, trans fat or cholesterol.
New statement to address the health problems associated
with foods high in added- sugars:
Drink fewer soft drinks, and limit cake, cookies, frozen
desserts, and other foods rich in added refined sugars.
New statement to reflect widespread contemporary use
of restaurant , drive-through, and take-out foods and the
high-calorie, nutrient-poor nature of typical menu items:
When dining out, choose low-fat vegetable and fruit
dishes instead of high-calorie, nutrient-poor dishes.
Drink water, low fat milk, or real juice. Share or take
home the remainder of dishes served in large portion
sizes. Avoid desserts.
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5. Protecting the review of Canada’s Food Guide
from the influence of vested interests?
21
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).
22
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.
23
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…
24
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
25
6. Did 1992 CFG actually contribute to over-eating
and rising rates of obesity?
26
Canada’s Food Guide
(front image)
1982………………………….…...…………1992
27
Canada’s Food Guide
(back image)
1982………………………….…...………….1992
28
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.
29
Changes to average number of recommended servings
by CFG food group, 1982-1992
(Table prepared by CSPI based on comparison of 1982-92 CFGs.)
Grain Products
Milk Products
Vegetables and Fruit
Meat and Alternatives
Recommended
number of servings
of Food Groups
In 1982
In 1992
3-5
5-12
2
2-4
4-5
5-10
2
2-3
% Increase in average
recommended
number of servings
In 1992
+113%
+50%
+67%
+25%
30
“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.
31
Overall,
the distribution of nutrients in the diet
did not change.
32
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.
33
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”)
Rise in average
recommended
servings in 1992
Statistics
Canada proxy
categories
Meat and
alternatives
25%
Milk
Products
Vegetables
and fruit
Grain
products
Other
50%
Red meat +
poultry + fish*
+ eggs + pulses
+ nuts
Dairy (milk
solid equivalent)
Vegetables +
fruit
Cereals
FOOD
GROUP
67%
112.5%
n/a
Oils and fats +
sugars and
syrups + alcohol
+soft drinks
Actual Consumption Post-1992
based on disappearance per capita
adjusted for loss due to waste
(rounded to the nearest ½ KG)
1992
2004
% Change
1992-2004
65 KG
69 KG
+6%
17 KG
17.5 KG
+3%
187 KG
207 KG
+11%
53.5 KG
67 KG
+25%
215 KG
226 KG
+5%
34
Health Canada distributed approximately
24 million copies of the Guide 1992-2004.
35
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.
36
7. CSPI has some recommendations for re-thinking
the advisory committee process.
37
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 [email protected] with
“join” in the subject line.

4. Always inquire: “Who benefits?”
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Contact info:
Bill Jeffery, L.LB., National Coordinator
Centre for Science in the Public Interest
Suite 4550, CTTC Bldg.
1125 Colonel By Drive
Ottawa, Ontario K1S 5R1
[email protected]
Tel.: 613-244-7337
Fax: 613-244-1559
Website: http://www.cspinet.org/canada/
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