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What arguments and from whom are most influential in shaping public health policy: thematic content analysis of responses to a public consultation on the regulation of television food advertising to children in the UK
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  • Published on:
    Did industry unduly influence Ofcom’s decision on restricting TV advertising of unhealthy kids’ foods?: A response
    • Ahmed Razavi, Academic Clinical Fellow University of Cambridge

    Dear Editor,

    We were interested to read the response to our recently published paper from the Principal Economist of OfCom during the time of the consultation, which is also available on the Institute of Economic Affairs website - https://iea.org.uk/does-ofcom-prioritise-commercial-interests-over-publi.... The additional context Mr. Gibson provides is welcome. On close reading we find that our original paper agrees with many of the points that Mr Gibson raises. We describe these, and provide more explanation on a number of other points below.

    Mr Gibson points out that OfCom used much more than just the stakeholder responses analysed in our article to come to a decision on their final policy on TV food advertising to children. We recognise this in Figure 1 and in the discussion section of our paper where we describe the other ways in which interested parties could influence OfCom. A number of OfCom reports, in which much of the evidence noted by Mr Gibson was published, are also cited in our paper.

    Mr Gibson appears concerned with our claim that the only independent evaluation of the regulations on TV food advertising to children found no change in the proportion of HFSS adverts seen by children between before and after implementation. As far as we are aware, the paper we cite (Adams et al, 2012) remains the only independent, peer-reviewed evaluatio...

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    Conflict of Interest:
    None declared.
  • Published on:
    Did industry unduly influence Ofcom’s decision on restricting TV advertising of unhealthy kids’ foods?

    In December 2003 the Secretary of State for Health asked Ofcom to look into the regulation of television advertising of High Fat, Salt and Sugar (HFSS) food to children in order to address concerns about the rising levels of childhood obesity. How did Ofcom decide on an appropriate set of advertising regulations to address those concerns?
    According to the authors of a paper in the BMJ Open , Ofcom consulted on the issue, considered the arguments advanced by the different stakeholder groups (advertising companies, food manufacturers, food retailers and broadcasters on one side, lobbying for more relaxed regulations, and civil society groups, politicians and public health stakeholders on the other, arguing for stricter rules to protect children), decided which arguments they liked and determined their final recommendations accordingly. They argue that because Ofcom moved towards the industry arguments between their original proposals and final recommendations on more issues than they moved towards the public health direction, that they favoured commercial interests over protecting children’s health. They even suggest that Ofcom might have been Machiavellian enough to cynically set some of their initial proposals in such a way that that they could concede ground to public health stakeholders on those issues and distract from more contentious issues.
    In fact, the truth is somewhat different. Ofcom when moving forward with a complicated public policy question such...

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    Conflict of Interest:
    I undertook the original Impact Assessment of Television Advertising Restrictions of Food and Drink Products to Children while working as Principal Economist at Ofcom from 2004 to 2007