LETTERS DISTINGUISHING ACCOUNTABILITY FROM RESPONSIBILITY: AN ACCOUNTABILITY FRAMEWORK In their retrospective study, Dorfman et al.1 examined media, legislative, and industry documents reflecting tobacco control responsibility rhetoric (1952---1965). The investigators used a responsibility framework to analyze causality, culpability, and accountability. The causality frame found tobacco harm attributed to the product rather than the industry that produced it. The culpability frame found blame without identifying responsible actors or remedial actions. The accountability frame found government was perceived as most accountable to address smoking hazards. The investigators discussed the implications for unhealthy food environments by emphasizing the need to shift the discourse from unhealthy products to the food industry’s harmful corporate behavior. They recognized several challenges, including divisive party politics and public distrust of government, but did not mention how a prevailing neoliberal ideology drives governance gaps, a deregulatory agenda, and the “corporate capture of public health.”2

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FIGURE 1—Accountability framework for healthy food environments.

Public health challenges have been viewed through a collective responsibility lens3---5 to prevent an overemphasis on personal responsibility rooted in victim-blaming ideology. Yet responsibility framing is unlikely to challenge government inaction or create optimal healthy default choices in food environments.3 We believe that responsibility and accountability are distinct concepts. Both were important core values for the global tobacco control epistemic community to confront a powerful tobacco industry.6 Responsibility involves using moral judgment to act in an ethically appropriate way.7 By contrast, accountability demands a relationship between an actor and a forum, the actor is required to explain and justify one’s performance or conduct, the forum has power to pass judgment, and the actor may face consequences.8 Viewing corporate performance through an accountability lens is essential to guide government and food industry engagement as part of a broader obesity prevention strategy.9 An empowered body has not yet been appointed in the United States or other countries to

develop clear objectives, a transparent governance process, and performance standards for diverse food industry actors to address unhealthy food environments.10 We suggest that governments, researchers, and independent bodies use an institutional accountability framework to assess and benchmark progress and communicate evidence of progress; that government agencies hold actors to account by acknowledging and incentivizing achievements, disincentivizing noncompliance, and enforcing regulations; and that all stakeholders respond to the account through system-wide structural improvements (Figure 1).10 The systematic process of taking account (assessment), sharing the account (communication), holding to account (enforcement), and responding to the account (improvements) can bypass a narrow conception of responsibility and minimize neoliberal pseudoaccountability that appears to promote healthy food environments.10 j Vivica I. Kraak Boyd Swinburn Mark Lawrence

American Journal of Public Health | June 2014, Vol 104, No. 6

LETTERS

About the Authors Vivica I. Kraak is with the World Health Organization Collaborating Centre for Obesity Prevention, Deakin Population Health Strategic Research Centre, School of Health and Social Development, Faculty of Health, Deakin University, Melbourne, Australia. Boyd Swinburn is with the Department of Population Nutrition and Global Health, University of Auckland, Auckland, New Zealand. Mark Lawrence is with the School of Exercise and Nutrition Sciences, Faculty of Health, Deakin University. Correspondence should be sent to Vivica I. Kraak, PhD, RD, World Health Organization Collaborating Centre for Obesity Prevention, Deakin Population Health Strategic Research Centre, School of Health and Social Development, Faculty of Health, Deakin University, 221 Burwood Highway, Melbourne, Victoria 3125 Australia (e-mail: vkraak@gmail. com). Reprints can be ordered at http://www.ajph.org by clicking the “Reprints” link. This letter was accepted January 19, 2014. doi:10.2105/AJPH.2014.301899

Contributors V.I. Kraak drafted the initial letter, coordinated feedback of co-authors for subsequent revisions, and led the submission process. B. Swinburn and M. Lawrence further developed the concepts and provided feedback on earlier drafts of the letter. All authors read and approved the final submission.

Acknowledgments Vivica Kraak received research support from Deakin University’s World Health Collaborating Centre for Obesity Prevention and the Population Health Strategic Research Centre to complete this letter.

10. Kraak VI, Swinburn B, Lawrence M, Harrison P. An accountability framework to promote healthy food environments. Public Health Nutr. 2014;25:1---17.

DORFMAN ET AL. RESPOND Kraak et al. offer a model of corporate accountability that, if adopted by agencies such as the Federal Trade Commission and others, would be of great service to public health. Their framework takes our conceptualizations of responsibility to the next level. The object of historical investigation is to apply an understanding of the past to look forward. Looking back to the pre-1964 Surgeon General’s report era, we were reminded of a time when Americans were not timid about the need for government intervention in the face of health harms. The irony is that in those circumstances it would have been easier to advance the type of robust corporate accountability rubric that Kraak et al. propose, yet the need for such actions would have been less apparent. By contrast, the need is evident now, but given the vilification of government and ascendancy of corporate power that the authors acknowledge, that need will be difficult to answer. j

References 1. Dorfman L, Cheyne A, Gottlieb MA, et al. Cigarettes become a dangerous product: tobacco in the rearview mirror, 1952-- 1965. Am J Public Health. 2014;104(1):37-- 46.

Lori Dorfman, DrPH, MPH Andrew Cheyne, CPhil Mark A. Gottlieb, JD Pamela Mejia, MS, MPH Laura Nixon, MPH Lissy C. Friedman, JD Richard A. Daynard, JD, PhD

2. Mindell JS, Reynolds L, Cohen DL, McKee M. All in this together: the corporate capture of public health. BMJ. 2012;345:e8082. 3. Brownell KD, Kersh R, Ludwig DS, et al. Personal responsibility and obesity: a constructive approach to a controversial issue. Health Aff (Millwood). 2010;29(3): 379---387. 4. Minkler M. Personal responsibility for health? A review of the arguments and the evidence at century’s end. Health Educ Behav. 1999;26(1):121---140. 5. Brown RC. Moral responsibility for (un)healthy behaviour. J Med Ethics. 2013;39(11):695---698. 6. Mamudu HM, Gonzalez ME, Glantz S. The nature, scope, and development of the global tobacco control epistemic community. Am J Public Health. 2011;101(11): 2044---2054. 7. Turoldo F. Responsibility as an ethical framework for public health interventions. Am J Public Health. 2009;99(7):1197---1202. 8. Bovens M. Analysing and assessing accountability: a conceptual framework. Eur Law J. 2007;13(4):447-- 468. 9. Swinburn B, Vandevijvere S, Kraak V, et al. Monitoring and benchmarking government policies and actions to improve the healthiness of food environments: a proposed Government Healthy Food Environment Policy Index. Obes Rev. 2013;14(suppl 1):24---37.

About the Authors Lori Dorfman, Andrew Cheyne, Pamela Mejia, and Laura Nixon are with Berkeley Media Studies Group, a project of the Public Health Institute, Berkeley, CA. Mark A. Gottlieb and Lissy C. Friedman are with the Public Health Advocacy Institute, Boston, MA. Richard A. Daynard is with Northeastern University School of Law, Boston, MA. Correspondence should be sent to Lori Dorfman, Berkeley Media Studies Group, 2130 Center St #302, Berkeley, CA 94704 (e-mail: [email protected]). Reprints can be ordered at http://www.ajph.org by clicking the “Reprints” link. This letter was accepted January 30, 2014. doi:10.2105/AJPH.2014.301915

Contributors All authors contributed equally to the letter.

June 2014, Vol 104, No. 6 | American Journal of Public Health

Letters | e3

Distinguishing accountability from responsibility: an accountability framework.

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