legislative scaffolds for salt- reduction programs a new way of regulating business in the ‘nanny...
TRANSCRIPT
Legislative scaffolds for salt-reduction programs
A new way of regulating business in the ‘nanny state’ era
Belinda Reeve, Law Fellow, O’Neill Institute for National and Global Health Law
Bloomberg’s soda rule
The National Salt Reduction Initiative
The links between salt and health
Processed foods: The main source of dietary salt intake
The UK Food Standards Authority
Australian Food and Health Dialogue
• Nine food categories• Twenty targets• Approx. 42 participants
Effective?
Obstacles to public health regulation
• Nanny state rhetoric• Economic productivity arguments• A powerful food industry
Governments remain responsible for public health
A spectrum of regulatory optionsTable 1. Different types of self-regulation
Pure Industry develops initiatives unilaterally
Coerced Self-regulation results from explicit or tacit threat of government action
Sanctioned Industry devises rules that are approved by government
Mandated Government provides legislative framework for self-regulation
Smart regulation
Responsive regulation
Legislative scaffolds
Content Processes Enforcement
ObjectivesTermsConditions
AdministrationMonitoringReview
Incentives for compliance, Penalties for breaches
Improving the Dialogue: Phase 1Content Processes Enforcement
Greater range of targets
Creation of maximum salt caps
Encourage more participants
Monitoring through baseline data on salt intake and food database
Creation of High-Level Steering Committee with equal representation of interests
Targets and caps are voluntary
Warning label for new high-salt products
Improving the Dialogue: Phase 2Content Processes Enforcement
Salt reduction targets apply to specific manufacturers’ portfolios
Creation of an independent regulator with a statutory mandate
Regulator to monitor companies’ performance
Mandatory compliance with average targets
Failure to reformulate requires salt warning label
Regulator can acquire information, ‘name and shame’, seek enforceable undertakings
Improving the Dialogue: Phase 3Content Processes Enforcement
Salt reduction targets apply to specific manufacturers’ portfolios
Independent audit assessing participants’ performance and scheme performance overall
Regulator seeks enforceable undertakings with penalties for non-compliance
Pie in the sky?
