HES 26 - Children in Wales

Children in Wales is the national umbrella organisation in Wales, bringing organisations and individuals together to make the United Nations Convention on the Rights of the Child a reality in Wales. Children in Wales also fights for sustainable quality services for all children and young people and special attention for children in need, as well as ensuring children and young people have a voice in issues that affect them.

Children in Wales has over 180 members, including the major voluntary children’s agencies, professional associations and local authorities, as well as many smaller community groups. Children in Wales works in partnership with the National Children’s Bureau in England, and Children in Scotland and internationally with the European and International Forums for Child Welfare.

Children in Wales is pleased to take this opportunity to respond to Proposed Healthy Eating in Schools (Wales) Measure.  Many of our comments outlined below have emanated from our work through the End Child Poverty Network Cymru, which informed our 2006 briefing paper on the Cost of Education, subsequent campaigning and lobbying activities, in addition to our response submitted to the WAG Appetite for Life consultation.

1. Is there a need for an Assembly Measure to promote healthy eating in schools in view of existing initiatives within this policy area?

We broadly agree that there is a need for an Assembly Measure to promote healthy eating in all LEA maintained schools across Wales.  There is a compelling case for this need, which has been succinctly and comprehensively outlined within the Explanatory Memorandum issued to support the proposed Measure.  There is also a need to strengthen the requirement for compliance amongst key stakeholders in relation to activities previously outlined within existing related policy guidance and action plans.  In addition, we are keen to ensure that there is accountability through strengthening the existing monitoring role of the inspection agency to help ensure that compliance is being met.

2. Do you support the key provisions set out in the proposed Measure, i.e.

- The duty on Welsh Ministers, governing bodies, head teachers and local education authorities to promote healthy eating in schools;

- Healthy eating should be part of the inspection regime and includes reporting requirements on Welsh Ministers, the Chief Inspector of Education and training in Wales and governing bodies;

- Power of Welsh Ministers to specify nutritional standards, including the requirement to specify maximum levels of salt, sugar and artificial additives in food and drink provided for pupils on school premises;

- Encouraging take up of school meals and protection of identity of those who receive them; and

- The duty on local education authorities to ensure availability of drinking water for pupils.

We broadly agree with and welcome the above key provisions as set out in this proposed measure, which support the clear aims and objectives of this Measure.  We would however be keen to pass comment on point 4 - encouraging take up of school meals and protection of identity of those who receive them.

Section 1(3), subsection C(1) – there is a need to clarify the term ‘time to time’.  We would suggest that school councils are at least consulted annually and that pupils have other opportunities to contribute to the dialogue

Section 9(1) – we would be keen to see a duty placed on LEAs to ‘promote the entitlement of pupils to free school meals’.

Section 9(2) –the term ‘reasonable steps’ should be removed and replaced with the term ‘duty’.  This would strengthen the requirement on LEAs to ensure that every pupil who is entitled to receive free school meals receives a lunch free of charge.

Section 10(2) & (3) – the term ‘reasonable steps’ is not sufficiently robust to ensure that LEAs have a duty to protect the identity of pupils entitled to free school meals.  Take up of free school meals in Wales continues to be a cause for concern (around 1 in 4 do not take up entitlement) and all LEAs should make ‘every effort’ to safeguard identity and help reduce incidences of bullying and stigma.  The emphasis on the ‘term’ duty is referred to later in Subsection 6, and we would be keen to see the term embraced throughout Section 10 to ensure consistency and promote accountability.

Section 10(6) – the term ‘have regard’ to any guidance should be strengthened to ‘comply’ with the guidance

3. What are the practical implications of putting these provisions in place?

Whilst recognizing the challenges the lack of current all-Wales and local data on the cost of school meals presents to this discussion, we would have been keen to see some detailed dialogue within the supporting literature to this Measure in relation to the proposed cost of healthy school meals.  We know from research that school meals can currently cost as much as £8.00 per week per child for families.  This is clearly a concern, particularly for the cost implications on families who are not entitled to free school meals under the current means-tested criteria and yet are recognized as being income poor.  Whilst we support the intention behind this Measure, clarity is required in terms of the potential cost for families under these new arrangements.

4. Are there further provisions that you would like to see added to the proposed Assembly Measure?

Whilst there is some recognition of present policy in the other nation states, the recent developments in Scotland by the Scottish Executive to encourage take up of school meals and address child poverty concerns has been overlooked.  Presently, a pilot scheme is underway which is providing universal free school meals provision for primary 1 to primary 3 pupils in 5 disadvantaged local authority areas.  These pilots are subject to on-going independent evaluation, although reports are suggesting that the schemes are delivering well -

http://www.eveningtimes.co.uk/news/display.var.1982652.0.7000_more_kids_going_for_free_school_meals.php.  It is understood that Ministers there are committed to a roll out of universal entitlement to all primary 1–3 pupils in Scotland from 2010.  It is disappointing that this debate is not happening here in Wales, given the links campaigners have made between the potential for universal school meals to help eradicate stigma and bullying, improve take up and to help ensure that all children receive at least one healthy and nutritious meal each school day which this Measure is seeking to ensure.

5. Do you think the proposed Assembly Measure will achieve its overall purpose and aim, i.e. to enable a holistic, comprehensive ‘made in Wales’ policy on nutrition in schools to be developed and implemented?

We broadly agree that this measure will achieve its overall purpose and aims, whilst taking into account our comments above

Sean O’Neill

Policy Director
Children in Wales / Plant Yng Nghymru