Thursday, November 16, 2006

Consultation? What Consultation?

Health Canada is very proud of their consultative process. They will happily talk about their coast-to-coast consultations and how they spent more time doing outreach with this Food Guide revision than any other.

With regards to their coast-to-coast consultations, it's true, they did travel coast-to-coast and they did indeed have an online consultation process open to all Canadians.

Unfortunately, those consultations were about form, not substance.

Don't believe me? Check them out yourself online where you can see that indeed Health Canada wanted input, it's just that the input that they wanted was pretty much relegated to what font you liked, what pictures you wanted, how many pages it should be, which vegetables should be pictured and so on.

Still don't believe me? Here's a quote from Health Canada on the matter,

"One of the criticisms is that there was little focus on the actual pattern and more focus on the packaging of the pattern. That was indeed a constraint that emerged out of the online approach to the consultation."
Ok, so you might argue that maybe the online consultation should have been about form and not substance, after all they were reaching out to the average Canadian, not to folks with specialized knowledge in nutrition.

Ok, well that leaves us with the in-person group consultations.

Our registered dietitian Shawna Hunt attended the in person group consultation that took place in Ottawa on November 24th, 2005.

She was excited to be given the opportunity to have discussions on what she saw were major shortcomings in the nutritional recommendations of the proposed Guide as well as the incredible number of calories it would lead Canadians to consume.

Wanna know what she got instead?

Pretty much the same forms involved in the online consultation.

As far as discussions go, one of the more heated "discussions" that took place that day involved an industry representative from the Dairy Board who angrily argued that because the milk carton depicted in the proposed Guide's pictorial representation of food choices was slightly askew compared with the soy beverage, that those depictions might therefore lead Canadians to consume less milk and more soy. Important discussion for the Dairy board? Maybe. Important for the health and welfare of Canadians? Not so much.

Ok, so the online consultation wasn't too impressive and neither was the group about the personal outreach?

I experienced that outreach.

Shortly after my views on the Food Guide were published in the Canadian Medical Association Journal, I received a phone call from Health Canada asking if we could set up a meeting. We of course obliged and within a week we met face-to-face with Health Canada officials.

On the one hand, it was quite nice for them to have come to chat with us. Unfortunately, there was another hand. If the purpose of the meeting was for Health Canada to say that indeed I'd been "heard", then I suppose the meeting was a great success. The problem is, there is a very big difference between someone being heard and someone actually listening.

Shawna, our dietitian, had prepared a number of test diets based off of the draft Food Guide's recommendations. She prepared a best case diet, a typical diet and a worst case diet to illustrate the incredible number of calories following the Food Guide would lead Canadians to consume.

Among other objections, Health Canada objected to Shawna's choice of quinoa, a whole grain in one of her test diets, that her use of nuts was not an appropriate source of protein, and that avocados were not an appropriate fruit choice.

We were both told that Health Canada had done their own modeling for calories and that their models were much lower than ours.

I firmly and wholeheartedly believe that to be true.

Frankly at the time, we couldn't understand (none of us, not I, not Shawna and not Health Canada) where the discrepancy in calories came from as it's not an especially difficult procedure to calculate calories and we and Health Canada were quite confident that we had done so correctly.

In fact, we both had.

The problem is, the reason their models are lower than ours is because, for a lack of a better term, the calorie-counting book they used is woefully outdated and it supplied them with non-real world data in the calculation of their calories (stay tuned for the post on this subject specifically).

In the end I believe they left our offices, really not having heard much of what we had said, but concerned enough to apparently have told CTV that they refused to appear together with me in any type of debate style format (this is what CTV told me when I specifically asked them if they could arrange a frank and open discussion on air between me and Health Canada officials).

Bottom line of course is the simple act of having consultations does not necessarily mean that the appropriate questions were asked during the consultative process, that the appropriate people were involved in the consultative process, and that if the appropriate people were involved that their input was included. Perhaps this is why on Halloween, included in their motion to have the draft Food Guide tabled before the House of Commons, the Standing Committee on Health members also asked that Health Canada table,
"a list of people brought forward who were actually consulted, the types of questions that were asked, and also to ensure and take a look at where those suggestions ended up and whether or not they were incorporated into the food guide."
At the end of the day, if Health Canada is so confident in their draft's revisions, why don't they simply release them for all to see?

Nothing would please me more than to see that our concerns have been addressed and that in fact the Food Guide has undergone a dramatic overhaul and rejuvenation.

Of course even if that were true, I would still be scratching my head about the process. The draft of the Guide that I've seen, that Dr. Willett has seen, that the Centre for Science in the Public Interest has seen, was released in April 2006, not in November 2005 as Health Canada purports. For those keeping track, April 2006 is 27 months after the revisions began. However even if we do talk about the November draft where as Health Canada officials themselves state,
"What we did in November was come out with a platform. It was the best we could do at the time. What we heard back was, "Sorry, it's not good enough"
I have to ask, why the heck wasn't it good enough? Was 27 months not long enough to come out with a Food Guide? Didn't they undertake an incredible number of consultations and conduct more outreach than any other Food Guide? What exactly did they do for 27 months? Were their experts lacking in expertise? Were there undue and irresponsible pressures being put to bear on those experts? Were their experts simply not listened to?

After 27 months of research and work, I would expect something significantly better than, "Sorry, it's not good enough", after all, these aren't medical secrets we're discussing.

Monday: Please Eat White Bread - Why Wonder Bread's more in touch with the evidence on whole wheat than Health Canada.

Yesterday: At Least You'll Get Enough Zinc - Health Canada cares a lot about nutrients...not so much about foods. Last time I checked, I eat foods, not nutrients.