Critical Analysis of Health Star Rating System Policy-making Process in Australia and New Zealand

This report analyzes the policy-making process for the Health Star Rating system in Australia and New Zealand, and provides evidence for future policy options. It discusses the scientific evidence for the policy problems of obesity and non-communicable diseases, the Health Star Rating system as a policy intervention, and competing values and interests among stakeholders. The report supports the revision of technical details and mandatory implementation of the system on all industries.

TITLE:
CRITICAL ANALYSIS OF THE POLICY-MAKING PROCESS FOR A TOPICAL
FOOD POLICY INTERVENTION.
Case study:
The current policy-making process towards future policy options for the Health Star
Rating system in Australia and New Zealand.
Student name
Professor’s name
Affiliation
Date

Introduction
Dietary risk factors are among the leading contributions to the world wide plague of diseases,
(Ericksen 2008). The front-of-pack package labelling (FOPL) policy interventions is currently a
debate in many countries across the world. Some countries have already began to implement the
FOPL interventions that are geared to promoting a healthy food selection and to help in
preventing obesity and non-communicable diseases and complications, (Mintrom&Norman
2009). Whether the technical details are mandatory or voluntary varies from country to country
across the world. This report about the health star rating system involves a case study of the
current policy-making process towards future policy options for the Health Star Rating system in
Australia and New Zealand. The report seeks to capture the scientific uncertainties around food-
packaging policies and the effect that it has on dietary risk factors. This report further seeks to
investigate and analyses worldviews towards the pathogenesis and effect of these policy
interventions to dietary risk factors.
Health Star Rating
The Health Star Rating is a front-of-pack labeling system that is used for the overall profiling of
the nutritional value of packaged food items, (Maubach, Hoek& Mather 2014). It assigns its
rating from half of a star up to five stars. The more the stars, the healthier and safer the packaged
food item is considered to be. This profiling provides a quick and easier way of comparing
similar packaged foods.
Calculation of the Health Star Rating
The number of stars that is included in the informational package is gotten by assessing the
positive and risky nutrients in the food content then doing calculations through a special
calculator (Health Star Rating Calculator) that is designed for the task of determining the star
rating, (Collinson et al 2009). The algorithm behind the calculation was developed by a
conglomerate of the Food Standards Australia New Zealand and other food nutrition experts.
Food manufacturers are required to comply with all the appropriate and relevant legislations and
regulations of the Health Star Rating System, (White & Signal 2012).

Who designed the Health Star Rating system?
This system was developed by the Australian state government in collaboration with the public
health sector and the consumer groups. In 2014, Australia and New Zealand Ministerial Forum
on Food Regulation (Forum) made an agreement that the Health Star Rating System should be
implemented on a voluntary basis over a timeline period of five years, including a review of the
progress of the process of the implementation over a period of two years, (Smee 2016). In the
year 2015 the members of the review team would later agree that the system of the review should
be rolled out after the five years of implementation.
Description of the scientific evidence for the policy problems of obesity and non-
communicable diseases associated with this case study
Obesity has become one of the issues that are rocked this world into a total mess that has been
considered a global epidemic, (Gortmaker et al 2011). The condition results from a positive
energy imbalance whereby the energy intake from a food item exceeds the energy expenditure.
Scientific research presents that obesity could be reduced by implementing the health star
systems, whereby consumers will be enabled to make health choices.
Its prevalence of obesity and non-communicable diseases is currently on the rise, according to
the World Health organization (WHO). It has been established that obesity augments the risk of
contracting a number of chronic and non-communicable diseases, (World Health Organization,
2017).
Across the world, Australia has one of the highest rates of obesity. This includes 63% adults,
with one in four children being extremely overweight or obese, (Lluch 2011). Most of the
packaged products usually carry an information panel with the nutrition value of the contents of
the food that they carry. But since shoppers in the 21st century are busy due to the dynamic
societal nature of the day, the Health Star Rating provides a cheaper way to compare similarly
packaged foods and hence helps people to make healthier choices, (Michaels 2009). To allow for
the informed consent of consumers is the major objective of the Health Star Rating System. It
will help consumers to choose foods that are high in positive nutrients ad opposed to health
destroying and risky nutrients that are often associated with dietary related chronic diseases and

obesity, (Bowen 2009). This will contribute to a balanced diet and lead to even better health
amongst the consumers.
Most of the packaged products usually carry an information panel with the nutrition value of the
contents of the food that they carry, in order to allow for the right to informed consent of
consumers. Health Star Ratinghelps consumers to choose foods that are high in positive nutrients
ad opposed to health destroying and risky nutrients that are often associated with dietary related
chronic diseases and complications, (Jones,Rådholm&Neal 2008).
Description of the Health Star Rating system as a policy intervention to promote healthy
food selection, its background, purpose, technical details and how it is governed,
implemented, monitored and evaluated
The Health Star Rating (HSR) system is an initiative of the Australian and New Zealand
governments that was endorsed in the year 2014, set for a five-year implementation plan,
whereby a review is set for the year 2019, (Lawrence,Dickie,& Woods 2018). The purpose of the
Health Star Rating System is to assess the general nutritional value of the pre-packaged foods in
order to provide a product rating that normally ranges from a half a star to five stars at most.
The Health Star Rating (HSR) system is composed of three major components, (Ni Mhurchu et
al 2016).
i. The HSR algorithm
ii. HSR graphic
iii. Education campaign
The HSR algorithm uses a special calculator to generate star ratings. Ratings are determined by a
general assessment of ‘risk’ components that includes total energy, saturated fat, sodium and
total sugars that are required to align with the recommended positive nutrients. The rating is
presented in form of HSR Graphic.
The Health Star Rating Advisory Committee (HSRAC) is responsible for monitoring and
evaluation of the Health Star Rating (HSR) system.
Identification of evidence for the following future options for the Health Star Rating
system: Discontinue; Continue with current approach; Continue current approach but

with revisions to technical details; Mandate and retain existing technical details; Mandate
and revise technical details.
While consumers have a right for information, yet the information should be presented in such a
manner as to meet the required quality standards. (Wagenaar 2014). Evidence shows that the
current nutritional information panel of the HSR system of New Zealand does not meet the goal
of facilitating choice of healthy models. There are a number of shortcomings to having the HRR
system apply only to packaged foods. It is worrying to note that some of the packaged products
are given high ratings of up to 4.5 to 5, while fresh produce that is of an indisputable health
quality is not labelled under the current approach. This approach needs to be revised also to
include non-packaged products.
There should be more detailed information for consumers on the labels of packaged food items
that are based on the HSR system. This should be made compulsory to all manufacturers.
Presently, information is displayed on the packaging on a voluntary basis and on a very limited
scope, (Ni Mhurchu C et al 2016). This has a high possibility of misleading consumers into
making wrong assumptions on the health valueof a particular food item. This current approach
shouldtherefore be continuedonly with revisions on this part. For example, Sultan Bran, a
popular biscuit brand, has a high sugar content but Kellogg, the manufacturer of the food item,
have not indicated the information on the label of the packaging, (Ni Mhurchu C et al 2016). It
would be misleading to customers when they would buy the food product with a notion that it is
healthy when actually it is not. It should be made policy that every manufacturer indicates a
detailed informative display about the elements in a food item.
Some manufacturers are unwilling to include the HSR implications on their packaging, and this
is one of the limitation of HSR, (Commonwealth department of Health and Ageing, 2016). The
current approach towards industries and manufacturing plants should be discontinued, and a new
model pact be sought for. Perhaps, making the interventions of this policy law, so as to do away
with unscrupulous manufacturers who would not be willing to abide by the system.
The current algorithm gives messages that are conflicting to consumers. The algorithm needs to
be revised so as to prevent manufacturers from tampering with it in their malicious desires of
obtaining higher star ratings. For example, Milo got 4.5 stars when prepared with skimmed milk
as was displayed on the product, while the product on its own only got 1.5 stars.

Analysis of the competing values, beliefs and interests (if any) among stakeholders towards
future options for the Health Star Rating system, that influenced the policy-making
response to the epidemiological evidence
Stakeholder engagement with HSR system through industry workshops has been beneficial in
bringing up positive issues towards the HSR system, (Gauld 2009). This has led to HSR system
meeting its objectives. However, some partners have worked in collaboration with the HSR
system only for selfish gains, as in to influence the policy making process for their benefit,
(Dizdaroglu, 2017). However, there are many other stakeholders who are positively working
with HSR system, as in to make it more effective, such as Dietitians Association of Australia
(DAA). Dietitians Association of Australia (DAA) supports HSR to make it easy for consumers
to compare products. DAA further recommends that the non-packaged foods which may not be
able to carry a HSR to be still promoted as a pact of the HSR system. DAA is one of the
stakeholders that are collaborating with the HSR system for positive ends.
Analysis of how the issue is being framed, and the relevance and strength of the rational-
linear model and the advocacy coalition framework as policy-making theories to explain
what is happening with policy-making.
Both international and global entities influence research and policy making process for the HSR
system in Australia (Gauld 2009). Furthermore, evidence is an important factor in the HSR
policy making process. It has been established that the current policies governing the HSR
system are based more on politics as opposed to evidence (Ashton &Tenbensel 2010): For
example, notwithstanding the obvious effect of free sugar to consumers, which is increasing
chances of diabetes and obesity, the HSR system policies have not captured this important factor.
Evidence has shown that the major cause of obesity is high saturated fats and free sugar ( Craik
2013). With the knowledge the best way to limit obesity in the population would be to
implement a 5-star rating on all unprocessed or minimally processed fresh produce of fruits,
vegetables and nuts as opposed to labeling only packaged food items.
It has been established that advocacy coalitions and implementation of policy subsystems will
work more effectively in enhance the implementation of established polices. The Obesity Policy
Coalition (OPC) which is made up of health organizations in Australia, in collaboration with

World Health Organization, play a major role in advocating for evidence based changes in
policies and regulations so as to manage the obesity issue in Australia (White & Signal 2012).
Discussion of which of the future policy options you support, why, and whether there are
any additional considerations you believe policy-makers need to take into consideration
and act upon.
Future policy options I support:
The future policy review of the HSR system includes a number of recommendations for
reviewing the existing policies. The Health Star Rating Advisory Committee (HSRAC) has in
its five – year review a plan of future policies which it plans to implement. Some
recommendations of these policies which I am in support of include the following:
i. To remove the existing inconsistencies within the HSR system package by the elapse
of five years,
ii. Definition of free sugars as per the requirements of the World Health Organization.
These free sugars are composed of the ‘added sugars’, which are deemed to be less
healthy. Defining these sugars will help the consumers to make an informed choice
when buying these foods.
Additional Recommendations
i. The policies should include the implementation of the HSR system on other food
items such as fresh produce of fruits and vegetables, for the current policy of the HSR
system only includes packaged food items only.
ii. There should be ongoing and consistent monitoring and evaluation of the
effectiveness of the system.
iii. A policy that should enforce the implementation of the HSR system on all industries
should be formulated. The current HSR system is being implemented on a voluntary
basis.

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