Part 2: The WHO’s War on Stakeholder Dialogue

How Censoring all Industry Engagement Will Affect Policy and Human Health

The World Health Organization (WHO) Europe has declared the stakeholder dialogue process dead. In a recent report, entitled “Commercial determinants of noncommunicable diseases in the WHO European Region”, contains a large number of case studies with advice and best practices on how to control and isolate health-harming industries (HHIs) from the policy process. The first part of this Firebreak series demonstrated how almost all industries, of any size, are HHIs.

This second section of a five-part analysis will assess what such a blanket banning of all industry from societal discourse and the policy arena would mean in practice. It will look at past examples of the WHO’s implementing of their zero tolerance ban on the tobacco industry and draw scenarios how such a wider cancelling of almost all industry engagement would affect human health. We need to ask if the WHO, in imposing such a ban, is acting to protect public health or merely running a political campaign that will have detrimental effects on human well-being.

Fighting Big Tobacco

The tobacco industry fought against anti-smoking campaigners for more than five decades and the lobbying tactics did get dirty on all sides. Health authorities and activist groups learned to play hardball in attempting to ban smoking, bankrupt tobacco companies and restrict access to cigarettes. The blacklisting of tobacco companies, their products and marketing techniques was largely instigated by the WHO via their Framework Convention on Tobacco Control (WHO FCTC), established in 2003. The decisions of this Framework Convention, that meets regularly to update policies and strategies (including the recent policy to denormalize vaping and e-cigarettes along the same lines as tobacco products), are legally binding in the 182 ratifying countries.

In order for the WHO to succeed in banning any engagement with other industry groups, in order for their decisions to have teeth and not look like they were just blowing off some political steam with this report, they would need to pass through a series of similar framework conventions per sector. There would have to be hundreds of organizations with a significant number of ratifying members giving them credibility and implementation force. So we would need a WHO Framework Convention on the Control of Processed Foods, or a Framework Convention on Meat Control. And let’s not forget Framework Conventions restricting the pharmaceutical industry, or controlling sugar, sodas or cosmetics…

How many WHO member states would ratify a WHO Framework Convention on Alcohol Control when so many countries are promoting their drinks industries and export revenues? Which European nations would vote to prohibit or restrict international trade in alcohol products? The idea has been proposed within temperance movements but the most the WHO could do, in 2010, is provide a non-binding strategy to try to reduce harmful alcohol consumption.

There is a Framework Convention on Climate Change (UNFCCC) which has hosted the annual COP climate summits for almost three decades now but even after intensive campaigns and government pressure, their declarations cannot even single out the fossil fuel industry for its contributions to climate change. The WHO would have a hard time achieving restrictions on the fossil fuel industry on the basis of health effects from climate change.

The WHO leadership knows this, so how could they take their own proposals and this report seriously?

Follow the Money

If the WHO is aware of their limitations and that they would not be able to create hundreds of framework conventions ratified by a significant number of member states to give institutional force to any exclusion of industry representatives, why did they spend so much time and energy to produce this document and put forward demands they would never be able to see come to fruition?

The first step is to follow the funding. In the 1970s, 20% of WHO funding came from foundations or earmarked programs but this amount ballooned to over 80% by 2022. Groups that make large donations to a global health organization like the WHO are most often driven to reform public health policy and public practices. Foundations funding the WHO like Bloomberg Philanthropies are driven to use the WHO to impose their long list of health and lifestyle interventions, from restricting sugary drinks to banning e-cigarettes.

Source

Furthermore, the WHO are under pressure from health activist scientists and academics. Much of the vocabulary in the WHO’s “ban industry” report echo articles published last year in a special Lancet series on controlling the commercial determinants of health. To a certain degree the WHO is following the academic activism more than leading it. In an article in the Lancet series, WHO Director-General, Tedros Adhanom Ghebreyesus, stated:

Transformative change is needed to combat the commercial determinants of health. This Lancet Series helps to strengthen the evidence base and inform this agenda.

This WHO report proposing to ban almost all industries from the stakeholder dialogue process is merely a reaction to demands made by groups funding the WHO, even though the WHO are fully aware that implementing their strategy is completely unworkable. In any case, like other activist groups, this global health organization has to bow to its paymasters.

So even if the WHO does not take their report, proposal and agenda seriously, many will be demanding to implement its politically driven objectives to exclude all industry representatives from the public dialogue and policy process. We need to consider the risks of certain scenarios by benchmarking what has been achieved in the WHO’s blacklisting of the tobacco industry.

Lessons from the WHO’s Denormalization of the Tobacco Industry

Case 1: Poor Policies

Member states who have signed onto a WHO Framework Convention, are obligated to implement any policies entered into official documents at the national level. That was the European Commission’s justification when they threatened to break relations with an independent Brussels-based think-tank, The European Policy Centre (EPC), unless they expelled the trade association, Tobacco Europe, from its membership. Some would argue that it was a little too zealous to deter private organizations from having contacts with representatives of legal and widely accepted industries, but as the WHO has been so successful in destroying the reputation of Big Tobacco, no one objected to the European Commission’s attack. As the EPC was dependent on the involvement with European decision-makers for their credibility, they bowed, last year, to the external pressure and denied the tobacco trade association the right to be involved in their policy discussions.

This story was broken by The Firebreak last autumn (four months after the fact given the media did not find it newsworthy). At that time, I questioned who in industry would be next to be silenced as the European Policy Centre also has members from the fossil fuel industry and from the chemical industry. No one from industry spoke up when the European Commission interfered with how a think-tank could gather information and engage with (legal) stakeholders. Will any voices be heard when all industries will be expelled from private policy organizations like the EPC?

Let us assume, after the WHO anti-industry strategy is implemented, that a future European Commission would demand that the EPC expel representatives from the natural gas industry from participating in EU policy discussions. EU civil servants themselves would not be allowed to speak to these actors. As strong, stable policies depend on access to the best information and stakeholder engagement, if there were another energy supply crisis (similar to that following the Russian invasion of Ukraine in 2022), would EU policy be sound and effective if the decision-makers were unable to gather important information from key energy providers?

While the WHO does not think very much about good governance in its own institutions, such a situation and the devastating outcomes from poor policy decisions would create serious threats to consumer and social well-being.

Case 2: Left for Dead

At the height of the COVID-19 pandemic, the Canadian government funded research into Covifenz, a plant-based vaccine it approved for use in preventing the spread of the coronavirus. Covifenz could be easily and cheaply produced and distributed without the need for cold-chain storage technologies, making it perfect for use in developing countries and rural regions. The WHO could have approved the vaccine for emergency use in 2022, when there was a desperate need for vaccines in developing countries. But Covifenz was a nicotine-derived vaccine and the tobacco company, Philip Morris, was an initial funder involved marginally in the research and development. Because of the WHO rule demanding exclusion of any interaction with tobacco companies (or those working with them), the WHO refused to grant the vaccine emergency use approval. At the time of a major global pandemic, the WHO proved to be more committed to restricting an industry it despised rather than compromise for the sake of saving lives.

If the WHO succeed and apply the same tobacco engagement restrictions on the pharmaceutical industry, how would the WHO possibly be able to work with industry representatives to produce vaccines or procure necessary healthcare products if no one in the organization or its ratifying member states were allowed to have any contact with the main researchers and producers of the necessary pharmaceutical products, vaccines and medical equipment? They wouldn’t and the blacklisted pharmaceutical industry would simply have to work around those government institutions and the WHO in order to save lives.

The insanity of the WHO even thinking that their strategy of forbidding interaction with all industries is a potentially good idea makes it a relief that the last WHO General Assembly failed to create a new, global pandemic agency. Too many people would die if decisions at a time of crisis were left to a group of unyielding, anti-industry zealots with no concern for the consequences of their actions.

Similar examples like a food contamination outbreak or an antimicrobial-resistant bacterial epidemic would need the best minds with the best resources to address the problem, find solutions and save lives. Governments and international organizations do not have the resources, capacity or, in many cases, knowledge to address such crises. Industry does, so it beggars belief that the WHO would even consider restricting any contact, engagement or involvement with the only stakeholder group that can protect and promote public health in such global emergencies.

Am I the only one who thinks the world has gone insane?

Part 5 of The Firebreak series will try to understand how so many well-paid WHO representatives with PhDs could produce and publish such an incredibly stupid strategy document. The fourth part of this series will consider whether the WHO’s proposed alternative (more funding for activists and civil society organizations) could provide better services than what industry-led initiatives have been able to achieve. But first, the next section will consider how the WHO’s poor understanding of how industry works, their Corporate Social Responsibility (CSR) motives and government means to conduct stakeholder dialogue is at the source of this poorly written document and misguided strategy.