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Health Impact Assessment of the Proposed Trans-Pacific Partnership Agreement

An HIA of the Trans-Pacific Partnership Agreement (TPP) has just been released, authored by Katie Hirono, Fiona Haigh, Deborah Gleeson, Patrick Harris and Anne Marie Thow.

From the media release:

Report finds medicine affordability, public health policies at risk in Trans Pacific Partnership
A report released today by a large team of academics and non-government health organisations reveals that the Trans-Pacific Partnership Agreement (TPP) poses risks to the health of Australians in areas such as provision of affordable medicines, tobacco and alcohol policies and nutrition labelling. Many public health organisations have been tracking the progress of the TPP negotiations over the past several years and have expressed concerns about the potential impacts and lack of transparency. 
“The TPP includes provisions that don’t just affect trade. They affect the way the Government regulates public health,” said Michael Moore, Chief Executive Officer (CEO) of the Public Health Association of Australia (PHAA). “In many areas – such as nutrition labelling - it’s already a struggle to implement effective policies that promote health. If certain provisions are adopted in the TPP, this will be another hurdle for organisations seeking positive public health outcomes.”
The report also argues that: “The TPP risks increasing the cost of the Pharmaceutical Benefits Scheme (PBS), which is likely to flow on to the Australian public in terms of increased co-payments (out-of-pocket expenses) for medicines”. An increase in co-payments risks declining public health and increasing hospitalisations, particularly for people who are already disadvantaged.
A team of researchers from UNSW Australia, Sydney University and La Trobe University conducted the health impact assessment based on leaked documents from the trade negotiations.
“In the absence of publicly available current drafts of the trade agreement, it is difficult to predict what the impacts of the TPP will be,” said Dr Deborah Gleeson, one of the report’s authors. “In the study, we traced the potential impacts based on proposals that have been - or are being - discussed in the negotiations. But the only way to properly assess the risks is to allow a comprehensive health impact assessment to be conducted on the final agreement before it gets signed by Cabinet.”
The report offers a set of recommendations to the Department of Foreign Affairs and Trade to reduce the likelihood that the TPP will negatively impact health in Australia. Such recommendations include excluding an investor-state dispute settlement (ISDS) mechanism, and including strong wording to ensure that public health takes priority where there is a conflict with trade concerns. The report also recommends that Government change its approach to conducting trade agreements, for example by publishing draft texts and negotiating positions on issues of public interest.
Trade negotiators are meeting next week in Hawaii. The Minister for Trade and Investment, Andrew Robb, has said he anticipates the negotiations will wrap up within the next few months.
“It’s vitally important that health is given high priority in the final stages of the negotiations,” said Lynn Kemp, Director, Centre for Health Equity Training, Research and Evaluation. “We urge the Australian Government to consider these issues seriously.”
The HIA report can be accessed here.

The effectiveness of HIAs conducted in Australia and New Zealand



It occurred to me that I haven't posted a link to the final report on the Australian Research Council-funded study on the effectiveness of HIAs conducted in Australia and New Zealand between 2005 and 2009. The report has lots of information in it. Download it here.


Launch: Effectiveness of Health Impact Assessment in New Zealand and Australia Report

The Centre for Health Equity Training, Research, and Evaluation invites you to attend the launch of The Effectiveness of Health Impact Assessment in New Zealand and Australia: 2005-2009 Report

Friday, 13 December, 2013
2 – 4 pm
Lavender Bay rooms 1&2,
North Sydney Harbourview Hotel
17 Blue Street, North Sydney


Webinar facilities will be available for our interstate and international attendees. RSVP to Heike Schutze: h.schutze@unsw.edu.au

Health Impact Assessments in Australia and New Zealand 2005-2009

Overview of HIAs in Australia and New Zealand during the study period
I'm excited that several colleagues and I have published a paper on HIAs conducted in Australia and New Zealand between 2005 and 2009:


This paper is essentially a census of practice. It's the first paper from an Australian Research Council-funded study of the impact and effectiveness of HIAs conducted in Australia and New Zealand. The best thing is it's an open access publication, so anyone can access the entire article for free.

The flow chart below gives an overview of how HIAs were selected for inclusion in the study. We don't think we included every HIA done - a number were not possible to find or were never publicly released - but the study represents one of the more systematic and comprehensive attempts to describe HIA practice internationally.


A total of 115 potentially eligible HIAs were identified; 55 met the study's inclusion criteria
Please let us know what you think in the comments.

The application of Equator Principles in high-income OECD countries

Map of the Ichthys LNG Project Area
in North West Australia
There's a very interesting post by Mehrdad Nazari about the use of the Equator Principles and related performance standards in an Australian setting:

The Equator Principles website highlights that “Designated Countries [such as Australia and other high income OECD countries] are those countries deemed to have robust environmental and social governance, legislation systems and institutional capacity designed to protect their people and the natural environment”. The EPIII also notes that for “Projects located in Designated Countries, the Assessment process evaluates compliance with relevant host country laws, regulations and permits that pertain to environmental and social issues”. In the preceding paragraph, the EPIII highlights that for “Projects located in Non-Designated Countries, the Assessment process evaluates compliance with the then applicable IFC Performance Standards on Environmental and Social Sustainability (Performance Standards) and the World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines) (Exhibit III).”
Despite the proponents in the Ichthys LNG Project reportedly used the EPIII performance standards in an Australian context. Read the post in full here.

Speaking in a purely personal capacity I'd like to see more use of the Equator Principles in developed countries. They're rigorous and well-understood internationally, and can help to allay international investor concerns and facilitate due diligence on a project. An excellent point is made in the comments for Mehrdad's piece:
Although Australia is a developed country, projects like this are usually situated in remote areas which have many of the same characteristics as developing nations: delicate & untouched environment, indigenous traditional landowners, etc. Local laws regulate these issues but, by hedging its bets, the bank does not have to due diligence local law to the same extent – and the syndicate’s lawyers don’t have to convince 41 credit committees.
Thanks to Martin Birley for alerting me to the piece.



There's some very low-resolution images of the article from Project Finance International on the case below.




"There are already mechanisms in place": same old arguments against health impact assessment?

The Australian Senate
The Australian Senate Standing Committees on Community Affairs released a report on Australia's domestic response to the World Health Organization's (WHO) Commission on Social Determinants of Health report "Closing the gap within a generation" last night. The response to the report seems lukewarm to me, though that may be coloured by my personal sense that this represents another missed opportunities for intersectoral action for health in Australia. The Social Determinants of Health Alliance released a fairly upbeat press release.

From an HIA and Health in All Policies perspective there are a few interesting sections. I'll post two reasonable lengthy excerpts below so you can make up your own mind. This is from the Government response section:

Adopting a Health in All Policies approach
4.46      The pre-eminent idea put to the committee to address the social determinants of health in Australia was for the Commonwealth government to adopt a similar mechanism as the South Australian 'Health in All Policies' (HiAP) approach to government action. HiAP is a horizontal health policy strategy that incorporates health as a shared goal across all parts of Government and addresses complex health challenges through an integrated policy response across portfolio boundaries.[54] As explained by representatives from the South Australian Government:
Health in All Policies is essentially an approach to working collaboratively on policy issues across government to enable joined up policy responses to complex, so-called wicked, policy goblins. The problems faced by the health department results from these wicked problems, such as obesity, chronic disease and health inequities. All of these have serious impact on health services and health financing and budgets, but health departments do not actually have the policy levers to address them. Other sectors and departments do have the policy levers—such as transport, agriculture, employment and education—however many of these agencies that are able to take action on these determinants of health and wellbeing do not see health as their business...Our version of Health in All Policies looks at how we can assist other agencies in meeting their goals, in a way that supports health and wellbeing...In South Australia the Health in All Policies approach is applied in the internal government policy process, focusing strongly on Health being a partner rather than a director in the public policy process.[55]
4.47      Under the South Australian model, in order to ensure that policies have considered potential health impacts, health impact assessments are used. Health impact assessments consider the potential health consequences of a policy.
4.48      A large number of stakeholders called for the Commonwealth to adopt HiAP approach similar to the one used by the South Australian government.[56]
Later in the chapter:
 4.54      One argument put forward for the adoption of a health impact or equity assessment framework was that it would 'create a little bit more awareness and consciousness around how decisions we make in every government department impact on people's health and equity issues.'[62] The actions already taken by a number of state governments point towards some jurisdictions being well ahead of the Commonwealth when it comes to ensuring that there is a sufficient understanding of the social determinants of health within government programs. Improving the awareness of health in areas outside the traditional health field is to be encouraged.
4.55      Although the Department conceded that health impact assessments might be useful, it was argued that this needs to be considered alongside their time- and cost-heavy nature:
Health impact assessments have been promoted as a means of assessing the health impacts of policies, plans and projects using quantitative, quantitative and participatory techniques. While we think that they may be a useful tool, we believe that they have the potential to be expensive and time-consuming, and we believe that this needs to be taken into account in any further consideration of these.[63]
4.56      This point was expounded upon in the Department's supplementary submission:
In the case of both the South Australian Government and Tasmanian Health in All Policies Collaboration, key drivers have been established through legislation; in particular Public Health Acts, as well as state based strategic plans and/or targets. Duplication of such approaches at a national level could add further complexity to an already complicated environment without a clear mandate for action.[64]
4.57      The Australian Social Inclusion Board made a similar case against the use of a South Australian style approach:
The development of a more formally structured framework, such as the South Australian approach, could introduce ambiguity into existing Commonwealth mechanisms and therefore detract from the social inclusion narrative. It could also result in current measurement and reporting framework and social inclusion principles holding less currency.[65]
4.58      However, representatives from the Department argued that there was already adequate consideration given to health in public policy making:
An approach is taken, certainly by our department, that recognises the interconnectedness and complexity of the social determinants of health through integrated approaches to the development and implementation of social policy and programs, both at the Commonwealth level but also across all levels of government. Key aspects of the approach include a number of things: firstly, strong governance arrangements. Some examples of those are the Australian Social Inclusion Board, the Social Policy and Social Inclusion Committee of Cabinet and also COAG's standing committees that look into these issues...[W]e believe that other approaches can and are also being used to achieve coordination across sectors and levels of government.[66]
4.59      The committee did not receive any evidence in the form of improved health outcomes that the South Australian model is more effective than comparative systems. The diversity of international and domestic responses to rising awareness of the social determinants of health points to a field of practice undergoing rapid evolution of thought. As noted by the Chief Executive Officer of ANPHA:
We are not sure which approaches will work best. We have almost got a set of natural experiments going on in Australia, which we think ought to be evaluated before we come to a conclusion on that. The South Australian method is one way of doing it...We are not quite sure what will do the trick here. It is one of the reasons we looked at Canada so closely. They do a bundle of different things, and other countries have done different things as well.[67] 
Committee view
4.60      The committee notes that the Department believes that it effectively takes a social determinants approach within its own policy making. However, the key point is that such an approach needs to be taken across government, and in particular in social, economic and employment policy decisions that affect social determinants (such as employment status, levels of welfare benefit, and access to education). The need for a social determinants approach lies not only within, but beyond, the health portfolio.
4.61      There are already mechanisms in place to ensure that important issues are considered across government when necessary, such as the requirements for inter-departmental consultation in the preparation of cabinet submissions, the requirement for Regulatory Impact Statements in conjunction with the introduction of legislation, and statements of compatibility with human rights.
4.62      Introducing a health in all policies approach of some sort would not therefore represent a completely new dimension to policy development. While the committee does not have a fixed view about how it should be done, the government's adoption of a social determinants approach should influence the policy development process, particularly in relevant areas such as education, employment, housing, family and social security.

There are a few familiar themes in this response that I've heard from government representatives over the years, from local health services to the World Health Organization:
  • HIA is expensive and time-consuming;
  • we're already doing addressing health in all our policy; and
  • HIA or HiAP would create duplication between levels of government and existing cross-sectoral policy initiatives.
All these assertions seem almost entirely without evidence to me. They may in fact be true but I haven't seen any empirical research that demonstrates them compellingly. Any discussions about expense and time investment should be in comparison to other interventions, rather than continuing to do nothing. HIA practitioners in many Federalist countries (e.g. Canada, U.S.A, Austria, Switzerland) have faced similar rationales to not develop an HIA or HiAP agenda at a federal level.

We need to be more assertive in calling out these kind of untested attitudes if we want to see further intersectoral action for health.

Does health impact assessment protect health? Is that the right question?

There's a thought-provoking piece at ABC Environment on Does environmental impact assessment protect the environment? The piece quotes several well-known Australian EIA academics about how well EIA in Australia is performing in terms of environmental protection.

There's no consensus in the piece about whether EIA is successfully protecting the environment or not, though some different ways of thinking about it are discussed. I think that's because the article dances around the core issue: what is the purpose of EIA? This may seem axiomatic and uncontested but I wonder if it's an under-examined difference between the goals and purpose of impact assessments.


In a sense we're lucky in the HIA field. The yoke of regulatory requirement and government mandate hasn't weighed us down too much... yet. Practice is still evolving and hasn't been circumscribed by regulations and legal challenge to the same extent as EIA. Because of this, my impression is that there's more acceptance that an HIA will probably have a limited impacts on health outcomes in itself. The stated goals of HIA are to protect health, promote health and to reduce health inequalities (and possibly to improve governance and public decision-making, as well as learning). HIA seeks to influence decision-making and implementation in order to influence a range of determinants of health, which in turn will impact on health outcomes, as shown below:


This is an idealised representation of an HIA's influence. Other assessment processes, organisational considerations and even broader social conditions will play much larger roles. In fact the process depicted is never linear either. Health outcomes and determinants are constantly changing, and decisions are constantly revisited. The delay between an activity and eventual health outcomes can sometimes stretch to decades. At each step there are a multitude of other factors that exert influence, apart from the HIA.

Though HIA's goal is to protect health, like EIA's is to protect the environment, the practical purpose of an HIA is to change decisions and implementation - the first step in the process depicted above. We should think about the purpose of EIA the same way. It's not an environmental intervention, it's a decision-making intervention. Burdening it with expectations of environmental protection isn't realistic.

If we do acknowledge that it will be difficult if not impossible for an HIA to demonstrate its role in changing health outcomes, we should redouble our efforts to prove its effectiveness in influencing decisions and implementation. I made a related argument in a recent article:

In some ways the issue of effectiveness may have less currency in relation to other forms of IA [than HIA]. Impact assessment, in particular environmental impact assessment, is used in some form in almost every country. Its use is common, accepted, well understood and not usually actively compared to other interventions or activities. This is not necessarily true for health impact assessment though because of the resource constraints and associated health disciplinary and epistemological concerns... if HIA's use is to continue to be supported in increasingly resource-constrained health systems that demand evidence of the comparative effectiveness of interventions.

The right question is not whether HIA changes health outcomes. Instead it's does HIA change decisions, implementation and ways of working?

The health impacts of diesel exhaust: Australian radio documentary



Dangerous Diesel is an interesting radio documentary on the health impacts of diesel exhaust. The program is Western Australia-focused and some nuance about the evidence on health impacts is lost, nonetheless the program is worth listening to.

Program Link

Michiko Hoshiko: Researching the use of health impact assessment in Japan and Australia

I have been conducting research related to health impact assessment in Japan since 2008 at the Kurume University School of Medicine. As part of this I have been involved in several HIAs, for example our health impact assessment of the transition to a “core city” (core cities are cities of more than 300,000 people that take on greater governmental autonomy and some of the responsibilities of prefectural governments) and a HIA of the redevelopment of a major hospital site. I have also been involved in the development of a HIA screening checklist for use in government.

Following the completion of my PhD I have been able to pursue further research into HIA, through a fellowship based at the University of New South Wales in Sydney, Australia. My aims during the fellowship are:

1) Investigate the use of HIA screening checklistsI will investigate the use made of the NSW Healthy Urban Development Checklist as a tool for engaging with local government officials around population health issues, comparing it with the checklist I developed at Kurume University in Japan.

2) Investigate the use of health impact assessment in local governmentI will investigate the use of health impact assessment and related tools to improve the population health impacts of decisions made by local government. In particular I will investigate process and procedural aspects of HIA that are associated with impacts on local government decision-making and implementation.

3) Investigate the use of health impact assessment in urban regeneration projects and major projectsI will investigate the role of HIA in influencing the health impacts of urban regeneration projects, and its role in addressing health within major project assessment.

4) Investigate and compare the different barriers and facilitators for HIA’s use in Japan and AustraliaDuring my staying in Australia, I will conduct research on the different barriers and facilitators for HIA’s use, particularly on issues such as health service planning, urban sprawl, energy, and disaster response.

I hope to develop at least two academic journal articles on this program of research. If you’d like to find out more about my research or get in touch please email me at hmichi AT med.kurume-u.ac.jp

The Role of HIA in Promoting Healthy Urban Development

I'll be live blogging a workshop on HIA and healthy planning, which is being held in Sydney and organised by the Public Health Association of Australia, the Australian Health Promotion Association and the UNSW Research Centre for a primary Health Care and Equity. I'll update this post as we go along.
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HIA In the USA
Dr Andrew Dannenberg, formerly of the US CDC, gave an overview of the inks between the built environment and public health. He then moved on to detailing the history of HIA in the US. The first HIA in the US was conducted in 1999 - around 160 have been completed in the USA as of 2012.

In the US, as elsewhere, most HIAs have been voluntary. The regulatory ones are less common and tend to be more contested, though they are still being done. Quantification and modelling ends to be more speculative but is important for reasonable cost-benefit models, which have been important to get traction in major decision-making processes in the US.

Community involvement in HIAs remains a thorny issue, as it does virtually everywhere. Vulnerabilities are important differential impacts to consider but practically challenging (as elsewhere).

There's an interesting distribution in the use of HIAs in the US. Most states have done one or are doing one, but most of the experience is on the west and east coast states. The majority have been conducted on built environment and transport proposals. San Francisco has been a leader in HIA and that work has largely been done using existing resources, i.e. not using special funds. Interesting examples room San Francisco and Boston were discussed. He gave some good examples of where good HIAs were conducted but they didn't change decisions - timing and other factors matter. "Getting the health information into the discussion is the primary purpose of HIAs" - I wonder if many would agree. That seems to be *a* purpose but is it the *only* purpose? And is it enough to justify HIA's use?

Andy mentioned a number of high-level govt documents that mention and support HIA's use. He also mentioned Health in All Policies and the work done to explore this in California. Massachusetts has introduced a requirement that HIA screening has to be done on all transport proposals, but the practicalities of this has still got to be figured out.

Andy mentioned the National Environmental Policy Act and how HIA might be integrated into that requirement (500 national NEPA-mandated EIAs are conducted every year, many more under state "mini-NEPAs"). Alaska has done a lot of work on health in EIA under their regulatory impact assessment procedures.

There's a lot of discussion on the legislative mechanisms that exist in the US, eg laws that are compatible with HIA's use. I wonder if this is a necessary but not sufficient condition for HIA's use, or maybe even not even necessary. Australia has had a lot of policy support for HIA that hasn't converted to activity. An imponderable.

Questions
Evaluation in HIA? Andy says that evaluation of HIA is useful but focusing on the predictive efficacy of HIA can be misguided/difficult. A lot of the evaluations that have been done have been conducted that the case level - there aren't many cross-sites studies of effectiveness (he mentioned the major Australian Research Council-funded study of HIA effectiveness that UNSW is currently completing, which I'm involved in and this is why Andy is here). Also most decisions have many factors that influence them, so it's hard to attribute change solely to HIAs.

Qualitative evidence for HIAs - can they ever give insights into the magnitude of potential impacts? Andy sort of flipped it around, there are lots of limitations to what we can quantitatively model. His point is essentially that we should quantify what we can. "My feeling is that the recommendations from an HIA would be the same without quantitative predictions, though the decision might not be." Well said.

What factors help enhance the uptake of recommendations? Relationships with decision-makers, that you're a known, credible group. Also that recommendations be actionable - where they lead to clear activities and not be motherhood statements.

We're many of the HIAs required by regulation? No, the vast majority are voluntary.

Have you seen many HIAs that are just done to tick a box? No, because most are done voluntarily that means that someone usually wants them done. (my view is that this is a major strength of HIA rather than a limitation - Ben)

Can you comment on the state of the art in qualitative research in HIA? Yes, it's difficult. Is air quality more important than physical activity? Difficulties in trying to prioritise between behaviours/environments/risks. It's hard.

Commentary from Australia: A planning perspective - Susan Thompson and a public health perspective - Peter Sainsbury.

They echoed many of Andy's points. Both identified the need for dedicated resources.
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My iPad ran out of charge so I wasn't able to do justice to Susan and Peter's presentations. I'll add their presentations and the recording to this post in the next few days.
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