Challenging Dogma - Fall 2009

Wednesday, December 16, 2009

Why the Smart Choices Food Program Failed To Present Healthy Foods – Monica Baytos

The Smart Choices Food Program has been a recent topic of discussion among health professionals and the media. The premise of the program was to give single front-of-pack (FOP) labeling “that U.S. food manufacturers and retailers could voluntarily adopt to promote informed food choices and help consumers construct better diets” (17). The packaging had both a symbol to identify qualifying products, which was a green checkmark and the label “Smart Choices Program: Guiding Food Choices.” Then, the caloric content was placed below it describing the calories per serving as well as how many servings per package. It is important to note that these nutritional guidelines are already posted on all food packages, usually either on the back or side of the package. The criteria for the program were based on both Dietary Guidelines and “FDA [Food and Drug Administration] standards, reports from the Institute of Medicine, and other sources of authoritative dietary guidance” (17).
This program took over two years to develop and its primary goal was to make it easier for Americans to make good decisions about the meals, snacks, and beverages they were choosing (13). The foods that were included in this program had some of the following nutritional standards according to the Smart Choices website: 1) Total Fat: ≤ 35 % of calories, 2) Saturated Fat: < 10% of calories, 3) Trans Fat: 0 g (labeled), 4) Cholesterol: ≤ 60 mg per serving, 5) Added Sugars: ≤ 25 % of total calories, and 6) Sodium: ≤ 480 mg per serving. In addition to these general benchmarks, as recommended in the Dietary Guidelines for Americans, there also had to be at least one nutrient that is encouraged(Calcium, Potassium, Fiber, Magnesium, Vitamin A, Vitamin C and Vitamin E) or a food group that is encouraged (Fruits, Vegetables, Whole Grains, Fat-Free/Low-Fat Milk Products). While this is an admirable program on the surface, it had at least three flaws that are now being addressed by the FDA. These flaws explain why the Smart Choices Program was unsuccessful and thus currently being phased out of packaging.
The Smart Choices Program has been put on hiatus while the FDA looks further into the program and its criteria. In a press release by Smart Choice, it states, “The Smart Choices Program announced today [October 20, 2009] that it will voluntarily postpone active operations and not encourage wider use of the logo at this time by either new or currently enrolled companies” (16). Halting the program allows time for further investigation and, so far, the FDA has taken a keen interest, beginning in August of this year, in how to make Smart Choices better. William Neuman in his article “For Your Health, Froot Loops,” says “The Food and Drug Administration and the Department of Agriculture have also weighed in, sending the program’s managers a letter on Aug. 19 saying they intended to monitor its effect on the food choices of consumers” (13). Also, on the Smart Choices website there were three tabs that can be viewed by all who visit the site. The tabs were “For Consumers,” “For Health Professionals,” and “For Media.” As of December 1, 2009 (and to this date), the website has taken off the “For Consumers” tab (17). This link enabled those who visited the site to search for foods that had the green check mark and were endorsed by the program.
This paper will explore three specific reasons why the Smart Choices program failed as well as define a specific intervention to make the program better and the food that it endorses actual ‘smart choices.’
Critique Argument 1 – Based on the Theory of Reasoned Action
The first reason that the Smart Choice Food Program failed was because it was based on the Theory of Reasoned Action. This theory is only useful on an individual level, rather than a group level, and it also assumes that we plan our decisions, even though humans are naturally more spontaneous. In their book Belief, Attitude, Intention and Behavior: An Introduction to Theory and Research, Martin Fishbein and Icek Ajzen state that the theory has “two major factors that determine behavioral intentions: a person or ‘attitudinal’ factor and a social or ‘normative’ factor. These two components in the theory are given empirical weights” (7). A quantitative model is used to describe people’s actions toward performing behaviors, which includes the intention of performing the behavior, the attitude of performing that same behavior, as well as the subjective norm. The subjective norm is “beliefs that certain referents think the person should or should not perform the behavior in question” (7). Under the Smart Choices Program, it was assumed that people would believe that because of the green checkmark on packages, the food was good and healthy for them to eat or give to their families. They would want to buy the product (intention) and then they would actually purchase the product (behavior) because of social norms and the perceived value of others’ opinions.
It is possible that when grocery shopping, people would intend to buy one product, but see the green checkmark with the Smart Choice logo and buy that product instead. This would account for spontaneous action. The program used an incorrect model because it was based on the individual, and therefore distorted the weighed outcomes and expectations. The value, or the “empirical weight,” of each product was skewed. The Smart Choices Program included foods and beverages that are not considered healthy by professional standards. For instance, the breakfast cereal Froot Loops was given the green checkmark. Froot Loops’ first ingredient is sugar (13). In essence, if this program were to spread across the United States and people chose unhealthy foods like Lucky Charms (11) and Bagel-fuls (10), our society could become even more obese. The individual results (bad food choices) could then have a group-level effect, and an unhealthy one. In the article from the New York Times, “For Your Health, Froot Loops,” Celeste A. Clark, senior vice president of global nutrition for Kellogg’s, says “Froot Loops is an excellent source of many essential vitamins and minerals and it is also a good source of fiber with only 12 grams of sugar… You cannot judge the nutritional merits of a food product based on one ingredient” (13). It is important to note that Froot Loops has 12 grams of sugar per serving (the maximum allowed by the program) which is “more sugar than in many popular brands of cookies” (13). In trying to spur better food choices by the American people, the Smart Choices program has actually made it worse by endorsing the wrong types of foods.
Critique Argument 2 – Based on the Labeling Theory
The second critique of the Smart Choices program is based on the Labeling Theory, a group-level model. The theory was developed by Howard S. Becker and termed in his book Outsiders: Studies in the Sociology of Deviance. He states, “Social rules are the creation of specific social groups. Modern societies are not simple organizations in which everyone agrees on what the rules are and how they are to be applied in specific situations” (5). The Labeling Theory was used in the Smart Choice program to promote products. The green check mark tells consumers that the standards were put in place by an outside group, in this case “a diverse coalition of scientists, nutritionists, consumer organizations and food industry leaders” (16). The foods are labeled as a smart choice and therefore people have the sense that these foods are the right selection when they purchase various breakfast, lunch, and dinner foods. According to Eileen T. Kennedy, dean of the Friedman School of Nutrition Science and Policy at Tufts University and the president of the Smart Choices board, by “providing a single, simple communication on the front of the package, the Smart Choices Program can help alleviate confusion in the supermarket and help today’s busy shoppers make smarter choices for their families in store and at home” (2).
Unfortunately, the program was only based on Dietary Guidelines and was a mixture of different standards, essentially making the ‘smart choice’ food a bad choice for consumers. The Keystone Center, a nonprofit organization in Colorado, coordinated the American Society for Nutrition and NSF International to jointly control as well as assess the foods and beverages to be included in the program before they were given the green checkmark (1). There are currently no guidelines, restrictions, or rules that are used for FOP labeling so the program formed their own rules and restrictions on how to be included as a ‘smart choice’ food. However, in choosing the lax rules that they did, it actually spurred even further critique from consumers and health professionals. The FDA had to become involved and is now virtually shutting down the program until it re-evaluates its standards in order to include actual healthy choices. Michael Jacobson, director of the Center for Science in the Public Interest, further explains this. The article, “Food Label Program to Suspend Operations” in the New York Times, states, “Mr. Jacobson said he believed that the companies involved in Smart Choices had hoped to head off federal regulation of package-front labeling by showing they could develop an acceptable system on their own. ‘It clearly blew up in their faces…And the ironic thing is, their device for pre-empting government involvement actually seems to have stimulated government involvement’” (13). Jacobson was originally on the committee that helped to develop the criteria for food to receive the Smart Choice label, but quit last year stating that the “standards were too loose” (13). The Labeling Theory did not work for this program because the Smart Choices label, the green checkmark, was based on arbitrary guidelines. Americans are constantly being told to choose a healthy lifestyle, but when foods like Froot Loops are included as a ‘smart choice’ for health, something has gone wrong. The Labeling Theory did work for the Smart Choices Program and people wanted to know what the green checkmark meant and buy the packages labeled with it. However, the theory failed once the public, the media, and health professionals realized that the products included were not healthy and prompted further investigation by the government.
Critique Argument 3 – Based on Ethics
The third and largest critique of the Smart Choices program concerns ethics. The moral and ethical aspects of this program are highly questionable, which is the sole reason that the FDA has now decided to evaluate the program. Bernard Bass, in his article “Ethics, character, and authentic transformational leader behavior,” says ethics involves “three pillars: (1) the moral character of the leader; (2) the ethical legitimacy of the values embedded in the leaders vision, articulation, and program which followers either embrace or reject; and (3) the morality of the processes of social ethical choice and action that leaders and followers engage in and collectively pursue” (4).
The creators of Smart Choices have broken the two latter pillars. The second pillar is violated because the values of the program are not ethical. The ‘followers’ are the consumers and, if one were to follow the green checkmark food choice, the prevalence of obesity would only increase. Walter C. Willett, the chairman of the nutrition department of the Harvard School of Public Health said, “These are horrible choices… It’s a blatant failure of this system and it makes it, I’m afraid, not credible” (14). Unless the program has credibility, there is no point in Americans following it. The choices and actions of the leaders of Smart Choices violate the third pillar. Eileen Kennedy is quoted again supporting the program’s absurd rationalities, she says “You’re rushing around, you’re trying to think about healthy eating for your kids and you have a choice between a doughnut and a cereal…So Froot Loops is a better choice” (14). Kennedy is taking the ‘lesser than two evils’ stance, but there are more cereal options out there that do not include Froot Loops. Bass states, “Ethical content focuses upon values, which highlight the issue of standards and criteria of ethical behavior” (4). The standards and values of the program are skewed and therefore ethics are violated. The green checkmark is too broad and the criteria are too lenient. Even if a food has a Smart Choices logo, it does not necessarily make it a ‘smart choice.’ To the credit of Smart Choices, the first pillar, of ‘moral character of the leaders,’ is no longer being violated. The program is allowing the FDA and the Department of Agriculture to investigate the criterion used to validate the checkmark. They are fully cooperating with the FDA and are waiting for the government to give new guidelines for FOP labeling. After the FDA wrote to the program concerning their lax criteria, Dr. Kennedy said, "The reason why we're not encouraging wider use of the logo at the moment is because we want to be guided by the science and the information that comes out of the FDA…If that guidance indicates that our criteria needs to be tweaked, we will do that" (8).
Ten companies participate in the Smart Choices Program, including Kraft Foods, Conagra Foods, Kellogg Co., and PepsiCo. If the program had continued, more were expected to join. However, in an article entitled “Healthy eating or rotten labeling?; Smart Choices says its logo helps people pick better food. Not if Froot Loops can make the cut, critics argue,” it states, “There is a sliding scale for participation: Companies that sell $75 million a year or less in Smart Choices products, for example, pay a $2,500 annual fee. The fee per product is negligible, a Smart Choices official said” (11). However, having an annual fee keeps smaller companies from joining. It goes further, noting that many health professionals are upset because the professional group, the American Society for Nutrition is involved in the decision making process about what foods or beverages get the green checkmark. Dietician Leslie Mikkelsen, managing director of the Prevention Institute in Oakland, California, says “The public deserves sound nutrition advice, and this needs to be independent of industry” (11). Mikkelsen brings up a valid argument concerning business ethics and the mixing of industries for personal gain, instead of for the good of the public.
Proposed Intervention – To Fix the Smart Choices Program
Considering the failure of the Smart Choices Program, certain actions need to be taken in order for people to begin to adopt it. Setting federal regulations for FOP labeling will help, however it will not be enough for consumers to choose the foods and beverages that are labeled a “Smart Choice.” First, there is a trust issue at stake because the program has already failed once. The intervention needs to fix the unethical points of the program. Second, the program needs to be based on group models that encourage irrational thinking and spontaneity. And third, the Smart Choices Program needs to consider advertising and marketing techniques that are powerful and will help brand their products.
The Smart Choices Program needed to be based on actual health and nutritional factors, not just the ‘lesser of two evils.’ The foods and beverages included in this program should be healthy in all aspects, not only in comparison to another fatty, sugary, or high caloric content food. The commissioner for the FDA, Margaret Hamburg, says, “As a mother of two who frequently finds herself racing down the grocery aisle hoping to grab foods that are healthy for my family, I would welcome the day that I can look on the front of packages and see nutrition information I can trust and use… As the commissioner of FDA, I see it as my responsibility, and the responsibility of this administration, to help make that happen” (9). People do want to have FOP labeling, but the green checkmark should indicate a higher level of nutrition. A similar program to Smart Choices called ‘Guiding Stars’ even saw an increase in sales because it “evaluates the nutritional content of nearly every product in the store (20). Phil Lempert, the writer for Supermarket Guru, said “as long as Smart Choices commits to educational advertising, it should be successful” (9). The Smart Choice label misled consumers, even though their officials stand behind it and say “the criteria are based on federal dietary guidelines” (3). Unfortunately, the guidelines that were followed were not enough and “Discussion of package-front nutrition labeling heated up over the summer when the F.D.A sent a warning letter to the Smart Choices program saying it would be concerned if the program led consumers to choose highly processed foods over fruits, vegetables and whole grains” (12). If the program was more thought out with educational labeling that encouraged healthy foods, instead of processed ones, it could be successful across the country.
The Diffusion of Innovations Theory is defined by Everett M. Rogers in his book Diffusion of Innovations as “the process by which (1) an innovation (2) is communicated through certain channels (3) over time (4) among the members of a social system” (15). Most importantly, the Smart Choice Program needs to work on the second process, of communication through channels. The definition of this step is “the process by which participants create and share information with one another in order to reach a mutual understanding” (15). There is not a mutual understanding between the program’s officials and the American public, which is detrimental to the program’s success. Once the green checkmark represents widely-understood nutritional standards, and the packages are labeled accordingly, the third phase will be able to take effect. To get people to adopt this innovative program, there have to be early adopters, and the rate of adoption defines how many people will adopt this program. Having a strong spokesperson, such as a well-known celebrity, would be a valuable way to get the message of the Smart Choice Program heard. Rogers says, “At first, only a few individuals adopt the innovation in each time period… these are the innovators. But soon the diffusion curve begins to climb, as more and more individuals adopt” (15). The tipping point is where the curve begins to climb. An example of a tipping point for the Smart Choice Program is having an effective message. Having strong credentials and reasoning for why a food or beverage gets stamped with a green checkmark would be effective. This would then lead more people to pick those products if they were unsure or in a rush. After the tipping point there is a drastic increase in people using and adopting the program. This is the herd mentality or conformity of individuals. The Diffusion of Innovations theory is a group-based model, and if the nutritional background is legitimate, then the program will be nationally known for the right reasons.
The Labeling Theory did work for the Smart Choice program. Once the green checkmark that shoppers see on packaging has more weight, the theory will continue to work. However, the Advertising Theory should also be used, specifically, Media Advocacy. In the book Media Advocacy and Public Health, Lawrence Wallack et al. says that “Advocacy is a catch-all word for the set of skills used to create a shift in public opinion and mobilize the necessary resources and forces to support an issue, policy, or constituency” (18). The goal of advocacy is to empower people and groups to “make institutions more responsive to human needs” (18). The intervention needs to include more than commercials and billboards. The Smart Choices Program needs to create a whole package for their products that appeals to more basic and core human values. Fortunately, the Smart Choices Program already has a strong symbol that people recognize, the green checkmark. In addition, the program’s name also empowers people to make their own decisions when shopping for food and beverage items just by having the name “Smart Choice.” The public is still able to choose what they want to eat or drink, but now a healthy option will be provided for them and clearly labeled as such. The Smart Choice brand needs to give “evidence that supports the claims made and provides consumers with a reason to believe that the promise will be delivered” (6). The promise will be empowerment and control over their own lives, or freedom to make healthy choices between foods. The difference after the FDA sets guidelines for FOP labeling, will be that this time the ‘smart choice’ will be backed with actual health guidelines, instead of false healthy choices.
This paper explored the failure of the Smart Choices Program. By using an individual model, the Theory of Reasoned Action, and having untrue labeling techniques, the program was susceptible to not only a public objection, but also a need for government intervention. Using a food items like Froot Loops or Lucky Charms made customers question the validity of the green checkmark. People were unable to trust any green checkmark when walking down grocery store aisles because it was obvious that certain foods were truly unhealthy for individuals. Although the Smart Choice officials tried to follow standards that were put in place by American Dietary Guidelines, it was a failure in all aspects. The proposed interventions, using governmental guidelines and strictly adhering to them, using the Diffusion of Innovations Theory, and the Labeling and Marketing Theories, are intended for success of the program. FOP labeling is an excellent idea and will be used by American society. This can be seen because of the previous public outcry. If no one had cared what the green checkmark was used for, government intervention would have not been necessary. Strengthening the purpose and meaning of the program, as well as standardizing labels across all food and beverages will empower people to make the “Smart Choice” when shopping for groceries.

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