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RE: Canada’s Food Guide Consultation – Phase 1

December 8, 2016

Dr. Hasan Hutchinson
Director General of the Office of Nutrition Policy and Promotion
Health Products and Food Branch
Health Canada

Dear Dr. Hutchinson,
 I am writing on behalf of the members of the Ontario Public Health Association (OPHA) in response to your consultations on Canada’s Food Guide. Our not-for-profit organization provides a strong, unified, independent voice for all citizens, public-health professionals and volunteers committed to improving the health of Ontarians. We are pleased to host the Nutrition Resource Centre (NRC) which plays a key role in strengthening the capacity of dietitians and other health professionals and intermediaries involved in healthy eating, nutrition programming and policy development across Ontario. To achieve this work, we rely on Health Canada to take the lead in providing guidance, evidence and tools to support healthy eating in Canada.
 OPHA commends you, your department and the Government of Canada for taking action to make healthy eating the easy choice for all Canadians through the initiatives mentioned in your recently released “Healthy Eating Strategy”. This strategy recognizes the important role that the food environment plays in influencing the food choices and eating behaviour of Canadians. It also recognizes the need to increase access to healthy eating information that will enable Canadians to make healthy food choices. This includes making revisions to tools such as Canada’s Food Guide (CFG) and nutrition labels.
 Health Canada’s evidence review1 demonstrates that while the CFG is a sound tool, its credibility has been challenged and it has been subject to much criticism. While 80% of consumers use the food label to make healthy choices1, only 31% of Canadians use the food guide when grocery shopping.1 Additionally, the use of CFG by Canadians to learn about healthy eating is very low (9%)3 illustrating the need for more positive and effective communication about dietary guidance from Health Canada to encourage greater confidence in and use of the CFG and related tools and resources. The evidence review reinforces this point noting that “dietary guidance can make an important contribution to nutritional health, but must be used and implemented by Canadians in order to do so.”1
 OPHA affirms the needs for an evidence-based food guide that defines a healthy eating pattern to promote health and reduce risk of obesity and nutrition-related chronic diseases. However, the revised food guide must resonate with consumers and be mindful of the changing population and food environment in Canada. 2
We offer the following recommendations for revising Canada’s Food Guide and implementing yourdepartment’s Healthy Eating Strategy. More details about each recommendation can be found in theattached Appendix.
 1. Overarching dietary guidelines are needed to provide the basis for the food guide and related supports and interventions including programs and policies. 2. It is imperative for the dietary guidelines and the food guide to be evidence-based so that health professionals, health intermediaries and educators understand the rationale for them and can communicate these effectively to their audiences. 3. The revised food guide needs to be culturally relevant and should provide examples of culturally familiar foods that meet the dietary guidelines. 4. It is crucial for dietary advice to be reflective of and address health inequities. Targeted universalism should be the framework for dietary guidance. This needs to be accessible, practical, and relevant along the many social determinants of health, including income, education, employment conditions, housing, culture/race, disabilities and gender.
5. Consumers should be engaged in the various stages of development of the revised CFG to help determine the most appropriate tools and resources and to test the resources and or supports developed for them.
6. Engaging experts (academics, health professional groups, and NGOs) is inherent for supporting positive and effective communications about the dietary guidelines, the food guide and supporting resources, as well as support for the interventions and policies, included in the healthy eating strategy.
 7. It is imperative to establish monitoring and surveillance to measure the impact of the dietary guidelines, food guide and food environment interventions on the nutrient intakes and eating behaviours of Canadians.
 8. A comprehensive approach as outlined in the Healthy Eating Strategy is required to make the significant changes needed to improve the eating habits and the health of Canadians.
 We appreciate this opportunity to provide comments on the revision of CFG and Health Canada’s Healthy Eating Strategy. We look forward to continuing to be involved in consultations that shape the development of dietary guidance in Canada and initiatives that promote healthier food choices and a healthy food environment for all Canadians.
Thank you for your consideration.
 Pegeen WalshExecutive DirectorOntario Public Health Association

Read the full letter here.