‘Nothing can be done until everything is done’: the use of complexity arguments by food, beverage, alcohol and gambling industries

Background Corporations use a range of strategies to dispute their role in causing public health harms and to limit the scope of effective public health interventions. This is well documented in relation to the activities of the tobacco industry, but research on other industries is less well developed. We therefore analysed public statements and documents from four unhealthy commodity industries to investigate whether and how they used arguments about complexity in this way. Methods We analysed alcohol, food, soda and gambling industry documents and websites and minutes of reports of relevant health select committees, using standard document analysis methods. Results Two main framings were identified: (i) these industries argue that aetiology is complex, so individual products cannot be blamed; and (ii) they argue that population health measures are ‘too simple’ to address complex public health problems. However, in this second framing, there are inherent contradictions in how industry used ‘complexity’, as their alternative solutions are generally not, in themselves, complex. Conclusion The concept of complexity, as commonly used in public health, is also widely employed by unhealthy commodity industries to influence how the public and policymakers understand health issues. It is frequently used in response to policy announcements and in response to new scientific evidence (particularly evidence on obesity and alcohol harms). The arguments and language may reflect the existence of a cross-industry ‘playbook’, whose use results in the undermining of effective public health policies – in particular the undermining of effective regulation of profitable industry activities that are harmful to the public’s health.

The American Beverage Association asks "Does the consumption of soft drinks cause obesity problems?", and in reply states: "Obesity is a complex problem that is influenced by many factors, most importantly diet, exercise and genetics. … The key to living a healthy lifestyle is to incorporate a balanced, healthy diet that balances calories consumed and calories burned through activity and exercise." [13] (ii) Alcohol Documents form the alcohol industry bodies ICAP (International Center for Alcohol Policies see: http://www.ias.org.uk/What-we-do/Publication-archive/The-Globe/Issue-1-2002/The-International-Center-for-Alcohol-Policies.aspx) and IARD (International Alliance for Responsible Drinking: see: http://www.iard.org/) use similar arguments to reject a clear role for alcohol in increasing the risk of NCDs. The IARD document "Drinking and NCDs" states that: "The relationship between alcohol consumption and NCDs is complex; while harmful drinking patterns are a risk factor for several NCDs, drinking in moderation has been identified as a protective factor for others. In addition to harmful drinking patterns, a mix of individual, societal, and environmental factors are associated with, and can further contribute to, an individual's risk for developing NCDs…social determinants of health (e.g. poverty, nutritional status, access to health care, and physical and social environments) remain the most important structural drivers of NCD deaths". [14] Similar arguments have also been used by drinks producer Diageo in respect to young people's drinking,[15] and in the following example, by the Scotch Whisky Association (SWA) to explicitly reject population-level alcohol policies. The policy in question is probably the proposal to introduce Minimum Unit Pricing in Scotland, which the SWA challenged in the European Court of Justice: "… societal issues are more complex than simply having a few drinks too many or in inappropriate circumstances. Indeed, to simply blame alcohol misses the target, perhaps because to find the true cause and solution is seen as too difficult and complex." (Scotch Whisky Association, 2012). [16] The following example comes from Alcohol Beverages Australia: (See: http://www.alcoholbeveragesaustralia.org.au/information/health/) "Multiple risk factors are involved in the development of health problems and the mix is different for each person, but they include genetic, environmental and behavioural variables…Alcohol, like diesel engine exhaust, air pollution, processed meat, soot, solar radiation, salted fish and wood dust, has been linked to cancers and it is generally accepted the risk increases as consumption increases".

Other examples include:
The issue of alcohol abuse is a complex issue, and requires a partnership approach between government, retailers and drinks makers…it's up to individuals to take responsibility for what they consume".. Tennents/InBev spokesperson, (October 2005).

[17]
Here ICAP in 2007 specifically disputes the possibility of effective policy solutions, alluding to a characteristic aspect of complexity, non-linearity: "A linear relationship with an intervention leading to a specific outcome is not possible. As a result, interventions that purport to offer a simple solution are only avoiding the complexity of the problem…it should be noted that the vast majority of policy measures and prevention measures are not evaluated, and that many approaches are designed or implemented in such a way to make evaluation difficult or meaningless... In reality, given the complexity of a behaviour such as drinking and the involvement of a broad range of confounding factors, establishing such a cause-and-effect relationship is rarely possible…complexity and variation in drinking should forewarn against 'off-thepeg' solutions." [18] In the following example, by the Chief Executive of the Scotch Whisky Association (SWA) says: Other alcohol industry examples frequently argue that the problem is too complex for simple solutions (or "magic bullets"). [21]

(iii) Food
The UK Food and Drink federation reveals some inconsistencies in a letter to the Head of the NHS, where it argues against simple solutions which focus on one ingredient (sugar), while elsewhere in the same letter arguing for similarly simple solutions (such as nutrition labelling), and focussing on the importance of removing other single ingredients (e.g. trans fats: "we have virtually eliminated artificial trans fats in products" [22]):

"Obesity is a complex problem which cannot be reduced to the demonisation of one ingredient [sugar]…. …as you acknowledge, a world-leading salt reduction programme is at the forefront of these [industry] achievements … in providing nutrition information on pack".[22]
The food industry also uses the argument to reject public health attempts to address specific dietary factors. Public health interventions, such as soda taxes, tend to target foods containing one or more of ingredients associated with poor dietsparticularly high levels of fat, saturated fat, sugar, and salt (HFSS products). For example, the Director General of the Food and Drink Federation, the representative body for the UK food and drink manufacturing industry, in a 2015 letter to the head of the National Health Service (NHS) in England, makes the case why sugar should not be blamed for obesity: It is not feasible to blame any one food product or beverage as being a sole contributor to obesity problems considering people consume calories from many different sources American Beverage Association." [13] This argument is also used by a McDonalds Vice-President: "Demonising or taxing specific nutrients is not the right tool to address obesity and offers a simplistic solution to a complex problem" Julian Hilton-Johnson, corporate vice-president, corporate relations for Europe, March 10th 2016). [23] (iv) Gambling The Association of British Bookmakers states that, 'It is not possible to clearly single out some types of gambling activities as being specifically associated with problem gambling.' [24] Other industries also argue that complexity in causation makes it difficult to blame specific products. For example, in a 2014 report the betting company Gala Coral state that: "Problem gambling is complex and is about the person not the specific product. Gala Coral, and the bookmaking sector as a whole, is determined to play a leadership role in identifying appropriate measures that improve player protection for those who need it whilst, as far as possible, protecting the freedom of the millions who enjoy betting responsibly". [25] References for web material Diageo Australia's submission to the standing committee on social issues inquiry into strategies to reduce alcohol abuse among young people in New South Wales, 2013. Available at: