Health assessments urged for federal laws and regulations

Doctors are urging the federal government to adopt health impact assessments as a policy tool to analyze the effects of its legislation and regulations.

Quebec, New Zealand and several European countries — including the United Kingdom, the Netherlands, Sweden and Denmark — already use health impact assessments to ensure they do not overlook the consequences of their laws and policies on health care and the determinants of health.

“We believe one way in which the federal government could fulfill its leadership role in health care is by applying an evidence-based health impact assessment to all cabinet decision making,” Dr. John Haggie, president of the Canadian Medical Association, told the Senate Finance Committee in June. “All decisions would have to be viewed through the lens of possible impacts on health, health care and Canada's overall health objectives.”

Canada’s doctors are concerned that the Conservative government is making critical decisions without fully considering their health consequences, Haggie says. For example, raising the age at which Old Age Security and Guaranteed Income Supplement programs begin to 67 from 65 could detrimentally affect the health of the elderly poor. “Without the rigour of actually forcing [these changes] through a health impact assessment, then they are never challenged over the health or health care-related issues.”

Changes to the Employment Insurance program that limit the ability of seasonal workers to rely on it as an income supplement may also have health impacts that will go undetermined without a health impact analysis, Haggie says.

Like environment impact assessments, a health impact assessment is intended to “remove the subjectivity” and result in transparent, evidence-based policies, he says. “At least on a process issue the politicians can be held to account if the evidence was there and they chose to ignore it, or if they chose to go a different direction.”

Government decisions, such as changes to policies that affect the income of seniors on fixed budgets, can have profound health consequences.

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Under its Public Health Act, Quebec requires legislators to consult the Minister of Health and Social Services regarding measures in any act or regulation that could have significant impact on the health of the population. The minister is also empowered to advise cabinet colleagues on any matter regarding health.

Those provisions, which have been in place since 2002, allow “the health sector to have a voice during the policy-making process,” says Louise St-Pierre, head of projects at the National Collaborating Centre for Healthy Public Policy in Montréal, Quebec, one of six centres funded by the Public Health Agency of Canada to study the impact of policy decisions on health.

Within the Quebec government, the legal framework requiring health impact assessments has been used to encourage collaboration among departments to maximize the positive health benefits of laws and regulations, St-Pierre says. Article 54 of the Public Health Act “has developed a new sensitivity, a new knowledge, a new culture within the government regarding how the sectors should share their responsibility for the health of the population.”

Between 2003 and 2010, Quebec’s Ministry of Health received 327 requests for health impact advice from other government departments or agencies, says St-Pierre. About 54% of those concerned proposed bills and regulations, while 46% involved policies, strategies or action plans.

It’s difficult to analyze the impact of health impact assessments on cabinet deliberations because those discussions are secret, says St-Pierre. But she believes the consultations on policies, strategies and action plans — which are not required under the legislation — are an indicator of the increasing acceptance of health assessments as a vital part of the policy-making process.

In 2011, for instance, the province’s agricultural ministry asked for advice on the health impact questions to be included during the consultations phase of a strategic plan being crafted to promote agricultural development, she notes.

Quebec’s regional public health authorities also work with municipalities to conduct health impact assessments. Earlier this year, for example, the mayor of Acton Vale, a small town about 100 kilometres east of Montréal, sought and received a health impact assessment from public health officials about a residential development project located between a snowmobile trail, a provincial highway and a school. The assessment provided concrete advice about how to reduce noise pollution and maintain green space to encourage healthy activity.

“The final decision is still the mayor and council’s, but the mayor told us that it was very important to have this information before [undertaking the project],” says St-Pierre. “Because after, it’s too late.”

Other municipal entities, including Toronto Public Health, have developed health impact checklists to assess policies and programs. The city’s medical officer of health in 2011 assessed the health impact of different options for managing biosolid waste at the Highland Creek Wastewater Treatment Plan. Initially, the city planned to incinerate the waste. But after a health assessment found that a “beneficial use” option that would turn the waste into pellets and cakes for fertilizers would produce less air pollution and fewer negative health impacts, city council voted for that option.

The health impact assessment “was quite influential,” says Monica Campbell, director of Healthy Public Policy at Toronto Public Health. “You can see from the decision and we know from the Council debates that this report was important.”