In the context of a wider study on behaviour change strategies, the House of Lords Science & Technology Select committee has published advice on voluntary agreements.
FINAL REPORT RECOMMENDATIONS ON VOLUNTARY AGREEMENTS (July 2011)
5.13. In general, the evidence supports the conclusion that non-regulatory or regulatory measures used in isolation are often not likely to be effective and that usually the most effective means of changing behaviour at a population level is to use a range of policy tools, both regulatory and non-regulatory. Given that many factors may influence behaviour, this conclusion is perhaps unsurprising.
5.14. We welcome efforts by the Government to raise awareness within departments of the importance of understanding behaviour, and the potential this has for the development of more effective and efficient policies. We are concerned, however, that emphasising non-regulatory interventions will lead to policy decisions where the evidence for the effectiveness of other interventions in changing behaviour has not been considered. This would jeopardise the development of evidence-based, effective and cost-effective policies.
5.15. We therefore urge ministers to ensure that policy makers are made aware of the evidence that non-regulatory measures are often not likely to be effective if used in isolation and that evidence regarding the whole range of policy interventions should be considered before they commit to using non-regulatory measures alone.
5.25. The involvement of other organisations to support the Government’s behaviour change initiatives may provide valuable opportunities to improve the effectiveness of behaviour change interventions, in particular by allowing a range of messengers to be used to deliver them. We welcome the Government’s intention to use such collaborations.
5.26. However, we have major doubts about the effectiveness of voluntary agreements with commercial organisations, in particular where there are potential conflicts of interest. Where voluntary agreements are made, we recommend that the following principles should be applied in order to ensure that they achieve their purpose:
- The Government should specify clearly what they want businesses to do based on the evidence about how to change behaviour, and what steps they will take to achieve the same result if voluntary agreements are not forthcoming, or prove ineffective.
- Voluntary agreements should be rigorously and independently evaluated against measurable and time-limited outcomes.
5.27. Given that these principles do not appear to have been applied consistently to the Public Health Responsibility Deal Network, we urge DH, in particular, to ensure that these principles are followed when negotiating further voluntary agreements. In relation to the current agreements, we recommend that DH should state for each pledge what outcomes are expected and when, and provide details of what steps they will take if the agreements are not effective at the end of the stated period.
SIGNIFICANT EXTRACTS FROM EVIDENCE TO THE SELECT COMMITTEE
Pg 398 - “Professor Theresa Marteau: I’m not intimate with the Government’s policy on obesity, but my understanding is that, after the publication of the public health White Paper, there will be a separate report coming out in the spring. Part of it will be the responsibility deal that the Government are engaged in at the moment. Perhaps I could make a few comments about that. This is about government partnering with relevant industries for self-regulation. An interesting paper, which I will pass on to the Committee, is an analysis by Kelly Brownell in Yale of the history of self-regulation of the alcohol and tobacco industries. The paper compares that with marine fishing and forestry to try to see what we can learn about self-regulation for the food industry. In the analysis, the suggestion is that self-regulation has worked well for marine fishing and forestry because the threat is internal. In effect, if those industries don’t regulate themselves, they’ll have no industry. Where the threat is external, which is what the paper believes has been the case with alcohol and tobacco, and probably with food as well, self-regulation hasn’t necessarily worked so well. The report makes recommendations for how self-regulation by the food industry can be made to be most effective. It will come as no surprise to you that the emphasis is on the importance of transparency, objective evaluation and realistic goals.”
Also see pages 454-7 f0r evidence from ASDA.