Competitive Foods: First Health Impact Assessment on a Federal Rule
A first-of-its-kind health impact assessment (HIA) released today by the Kids’ Safe & Healthful Foods Project and the Health Impact Project looked at updating nutrition standards for snacks and beverages sold in school from a perspective of both student health and school budgets. This is the first HIA completed to inform a new federal rule.
NewPublicHealth spoke with Aaron Wernham, MD, MPH, director of the Health Impact Project, about what this HIA represents for the field.
>>Read more on the HIA findings in a Q&A with Jessica Donze Black, project director of the Kids’ Safe & Healthful Foods Project.
NewPublicHealth: Isthis is the first time an HIA has been done on a federal rule?
Aaron Wernham: This is a somewhat new topic for HIA. There have been a number of HIAs of federal agency decisions. So, for example, developing permits for mines and oil and gas activities, but this is the first time that we’re aware of that an HIA has addressed a federal rule-making process.
NPH: Why was HIA the right tool to use in this circumstance?
Aaron Wernham: We advocate for doing an HIA on a decision where it absolutely adds value. There are some decisions for which the health implications may be obvious and are already being addressed, and other decisions where there really aren’t such important health implications. In this case we felt as if some of the health implications were known, or at least suspected as far as the potential nutritional benefits, but there were a lot of questions, such as just what are those benefits and how strong is the evidence for them? So I think that was one reason why we thought the HIA would be very valuable was really to put all of that evidence together into a clear picture to help USDA think through the nutritional benefits for children in setting these standards.
The second question, which really sealed the deal, was the realization that setting nutritional standards is great, but what about the practical challenges that schools may face implementing them? So, HIA was the right tool for this job because it really is a good way to bring the perspectives of the different stakeholders into the picture as well as the best available evidence. The HIA serves to make sure that you’re considering not just what might appear best for health on the face of it, but really a deeper look at the tradeoffs and how to make sure that that ultimate decision is a win/win.
NPH: What implications does this HIA have for the practice of HIAs as a tool to enforce important policy?
Aaron Wernham: I hope and believe that the information in this HIA is going to be useful to USDA as they make their decisions on this rule. But I also think that it’s a pilot to help us understand how do you do HIA well to inform a high level federal regulatory decision? What are the data needs? How do you put together a solid team to do the analysis? What sorts of information are most useful? How do you make sure that all of the stakeholders are collaborating effectively through the process? So I think we’ve learned a lot about that through the process of doing this HIA, and I think that will strengthen the field going forward into doing more HIA work at this level. As the first HIA on federal rule making, we wanted to make sure that it was adequately resourced and done very rigorously.
As a field, we also recognize that there’s really a downside to not considering health when we make many decisions—both small or local decisions and larger federal decisions. The National Research Council, in its review of HIA, said that HIA is valuable because it seeks to correct the fundamental problem of failing to consider health at all in decision making, and even with a lack of perfect data it’s still a valuable tool because it’s better to identify potential health risks and benefits than to ignore them. HIA can really be fit for different purposes and different levels of resources.