The commercial determinants of health (part one)

Someone has let the Coco Pops guy edit a journal

Step away from the sandwich

Chris “Coco Pops'“ van Tulleken has been given the privilege of guest editing something called the Future Healthcare Journal and has invited some of Britain’s most prominent nanny state cranks public health experts to contribute. The theme is the ‘commercial determinants of health’. These are the things that nasty businesses do to make the proletariat act against their own interests. As we all know, nobody really wants to smoke, drink, vape, gamble or eat high-calorie food. What people really want is to cook from scratch, drink tap water and go to bed early with a copy of Doughnut Economics. Alas, corporate interests have found ways to manipulate our fragile little minds. And they do it all FOR PROFIT!

Fortunately, a children’s entertainer with an undiagnosed eating disorder has seen through this scam and there is much to learn from the magazine he has guest edited. According to the editor-in-chief, van Tulleken is “recognised as a global expert in the area of commercial determinants of health”. Let’s dive in…

Chris kicks us off with an article titled ‘If commercial incentives are the engine, then conflicts of interest are the lubricant’. He begins by telling a little story. After his godawful book, Ultra-Processed People, was published, he says that someone from McDonalds e-mailed him to ask if he would like to meet up.

It turned out to be an invitation from a ‘senior director of menu innovation’. They wanted to fly me to Chicago to meet the senior leadership team.

‘I am keen for an inspirational, thought provoking yet realistic ambassador on food and nutrition. Could you let me know if this would be of interest and if so, what the potential fee rates might be.’

I knew that I couldn’t take the money, but I was keen to speak to them and understand their work, so I offered to fly myself to Chicago. They wouldn’t even have to buy me a burger.

The offer evaporated. This made sense. McDonald’s have nothing to learn from speaking with me. In my view, they simply wanted to pay me and create a conflict of interest. To get the money, I would likely have had to sign a contract that would prevent me from criticising McDonald’s, their products or their customers. But even if the contract didn’t gag me, taking the money would. How could I credibly criticise a company I had decided to be an ambassador for?

We don’t actually know why the meeting never happened and nor does van Tulleken. In the absence of any facts, he is allowing his imagination to run riot.

This was the first of many similar offers from the food industry. If you are involved in influencing food policy, or public opinion around food, whether you are a scientist, an influencer, a charity or a policymaker, the food industry will try to pay you.

No, they will try to speak to you. In his case, they might want to point out some of the many inaccuracies in his book in the hope that he doesn’t repeat them. They might reasonably assume that they will have to compensate you for your time, especially if you are a wealthy doctor/TV presenter. But they would rather you didn’t have a conflict of interest because if you then said something vaguely nice about their company, people like van Tulleken would say “Ooh! He’s got a conflict of interest.”

Of course, industry and those they pay have a well-rehearsed set of arguments to undermine the proposals laid out by the authors in this issue.

They say that the interests of industry and the public are aligned. They are not. Corporations’ primary motivation is to maximise profits.

And how do corporations maximise profits in a free market? By providing goods and services that people want. If they don’t align themselves with the interests of their consumers, they won’t be around for long. It is true that they can also try to rig the market with regulation that keeps out the competition and raises prices, but that is not want people like van Tulleken are concerned about. It is the products being sold that they object to and they would be happy to see prices rise and choice restricted.

The interests of the alcohol industry, for example, are to sell as much alcohol as possible

Not really. It is, as he just said, to make as much profit as possible. That does not necessarily mean selling more alcohol. Have you heard of premiumisation? It is a very real thing, especially in the booze industry.

From the outset, therefore, we have a basic inability to understand the economics of the industries van Tulleken is a supposedly a ‘global expert’ on. His failure to distinguish between revenue, volume and profit is only the start of his ignorance.

The purpose of Coke is to sell as much Coke as possible.

He’s on firmer ground there, although they’re equally happy selling Diet Coke or Dansani. But…

Once more, for those at the back, this primary interest of the Coca-Cola corporation is in direct opposition to public interest in terms of health, plastic pollution and many other factors.

The ‘public interest’ is here defined as whatever van Tulleken thinks it should be. It is not related to what the public is actually interested in, as shown through revealed preferences, i.e. drinking Coke.

there is not a single instance where voluntary self-regulation by any industry to improve public health has proven effective.

Does van Tulleken think that it would be better if alcohol companies could make health claims in their adverts or say that drinking beer makes you strong and attractive to the opposite sex? Does he think nicotine pouches should be sold to children? None of this is illegal, but it doesn’t happen thanks to self-regulation. Challenge 25 in pubs? Fortifying bread with folic acid? Not legal requirements. In Britain, warning labels on cigarettes were not mandatory until the 1990s, but have been around since the 1960s. Traffic light labelling on food is not mandatory. These are all products of voluntary action by industry.

These industries will insist that they are necessary for the economy. This is more true for some than others. Food and drink is one of the UK’s largest industrial sectors, but tax revenues are dwarfed by the cost to our economy of diet-related disease in terms of public health costs, reduced productivity and lost human capital.

The benefits of the food industry cannot be quantified by the tax revenues it produces. The economic contribution of the food industry is unimportant when compared to the real benefit of having a food industry, which is that it produces food to keep us alive. No industry needs to prove that it is ‘necessary for the economy’, whatever that means. The only justification we need for the existence of an industry is that it produces something that people want to buy.

There are so many solutions to the problems caused by these industries. But as long as industry are [sic] in the room when policies that affect them [sic] are being written, rates of commerciogenic disease will continue to grow unchecked.

This is van Tulleken’s main bugbear. He wants anyone who has ever worked with industry in any capacity to be excluded from the policy-making process. He doesn’t think that conflicts of interests should be merely reported, but that the existence of a conflict of interest should get you blacklisted.

The problem with this is that whether he likes it or not, the industry is an important stakeholder. The other important stakeholder is the consumer. Van Tulleken doesn’t want to hear from either of them. He wants policy-making to be dominated by people who hate the products in question, who know nothing about the market and who don’t understand economics. Hating something doesn’t make you a stakeholder, nor does claiming to be acting in the public interest. Every busybody claims to act in the public interest. A teetotal temperance activist is not a stakeholder in alcohol regulation. He is an interested bystander at best and a bloody nuisance at worst.

Van Tulleken expands on his thesis in another article - ‘Ultra-processed foods and public health: Evidence of harm and of conflicts of interest in the food industry to evade regulation’ - which begins with the usual parade of lies (10% of 5 year olds are obese, obesity costs the economy £58 billion, etc.) before summarising all the junk science about ultra-processed food (UPF) that has been published in recent years. The whole category of UPF has been widely criticised for being excessively broad. It includes foods that are objectively healthy alongside foods that are very bad for you if eaten in excess. It also excludes some foods which are not particularly healthy on the arbitrary basis that they are produced in factories. Because of this, epidemiological studies looking at UPFs are poor even by the dismal standards of nutritional epidemiology. Although they find associations with various health conditions, it is very unclear what the mechanism is, if any.

Van Tulleken has no intention of engaging with such criticisms.

Despite widespread acceptance of the risks of UPF globally, in the UK you could be forgiven for thinking that the subject was a matter of legitimate scientific controversy.

This is because of the extensive conflicts of interest between the UPF industry and many of the individuals and institutions who might regulate it.

Yes, it’s those conflicts of interests again which he now portrays as being almost physical entities. He has a pop at the Science Media Centre, UK Research and Innovation, the Scientific Advisory Committee on Nutrition, the Food Strategy Advisory Board, the Food Standards Agency and the Department for the Environment, Food & Rural Affairs for having supposedly conflicted members.

What he wants to say is that numerous eminent scientists have spent their careers lying to the public because they have been bought off by Big Food. He can’t say that because he’d get sued so he just heavily implies it by continually repeating the phrase ‘conflicts of interest’.

As a result of these conflicts we have incredibly light-touch regulation of food when it comes to health.

Ignoring the fact that it is not “incredibly light-touch”, what is the evidence that the COIs are responsible? It is, at best, post hoc ergo propter hoc logic: the government hasn’t clamped down on the food supply as much as I, a fanatic, would like, therefore the government must be in the pocket of the food industry. This is just childish rubbish and despite the subtitle of his article, he produces no evidence for it whatsoever.

UK policymakers have partnered with industry for more than two decades. Industry consulted on the nutrient profile thresholds that have been used to describe ‘less healthy’ food in the UK and have been involved in every major policy decision since then.

The nutrient profile thresholds are ridiculously stringent! They were designed by the Reverend Mike Rayner, a dyed in the wool ‘public health’ zealot who thinks God told him to campaign for the sugar tax, and the thresholds were lowered even further by Public Health England a few years ago.

Children are steeped in marketing and we have no mandatory warning labels on even the most harmful products.

Advertising ‘junk food’ during programmes aimed at children has been banned for well over a decade. A watershed TV ad ban will commence next year. We have no mandatory health warnings on food because we were in the EU until recently and food labelling was an EU competence to ease free trade. There is little demand for them now we have left the EU because we still want to ease trade and we have a voluntary system which does the same job.

The voluntary traffic lights are applied using thresholds which are entirely divorced from internationally agreed norms including our own government Eatwell guidance.

Absolute nonsense.

We apply a sugar levy to sugary soft drinks, but not to any other sugary products (including milkshakes and confectionery!).

If the ‘conflicts of interest’ were so powerful, there wouldn’t be sugar tax at all, would there?

Milkshakes were exempt because milk is a good source of calcium and flavouring it encourages kids to drink it. Drinks were targeted because they were said to have no nutritional value and sugary drinks were ‘empty calories’. That’s not what the industry was saying. It’s what ‘public health’ campaigners were saying back in the day when Chris was still gurning on Operation Ouch!

Of course, the real reason the sugar tax hasn’t been extended to sugary food (yet) is because it would be politically unpopular. It is political feasibility, not food industry lobbying, that dictates whether policies happen. As various politicians explained to Chris’s sister-in-law recently, they are itching to introduce nanny state legislation but they have to wait until the public have been softened up for it.

All van Tulleken is doing in this article is fantasising about what he would do if he were dictator for a day and concluding, without even a side-eye to evidence, that these things haven’t happened because government agencies speak to people from the industry they are regulating. It is fatuous beyond belief.

We urgently need to make healthy food affordable and to start to regulate food more effectively, but this will not happen as long as industry are [sic] in the room.

We have a sugar tax that is being extended to milkshakes. We have a ‘world-leading’ food advertising ban starting in January. We have a ban on BOGOFs starting in October. We already have restrictions on where supermarkets can display the tastiest food. This week, it was announced that supermarkets are going to be fined if they don’t selling people fewer calories. If that’s what happens when the industry is ‘in the room’ I’d hate to see what happens when the only people politicians consult with are nanny state nutters.

Coming up in part two, Lord Bethell on Hovis bread and Mark Petticrew on the booze industry