HES 31 - Merthyr Tydfil County Borough Council

Healthy Eating in Schools (Wales) Measure 2008

On behalf of Integrated Children’s Services, school meal catering service I am writing in response to the consultation document and your letter dated 16th May 2008.

In response to the questions posed I ask that you note our comments:

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

It is my view there is no need for a measure, as a school meal provider and as all school meal providers in Wales we are currently working within existing legislation. The statutory nutritional standards required for school lunches are laid down in the Education (Nutritional Standards for School Lunches (Wales)) Regulations 2001.

The Welsh Assembly Government guidance documents already provide advice for school governors, head teachers and caterers on the statutory standards required for school lunches.

This authority is totally committed to the healthy eating principles and are already providing healthy and nutritious meals within the financial constraints and budgets. We work closely with partners such as healthy schools, community dietician the local health board etc, this works well within therefore I believe that regulation and enforcement would be an unnecessary burden and cost.

The Appetite for Life Action Plan, launched in November 2007, is supported by caterers in Wales. This sets out the strategic direction and actions required to improve the nutritional standards of food and drink provided in schools in Wales. Its development was formed as a result of a consultation exercise with various stakeholders that included children and young people’s views, together with lessons learnt from other parts of the UK.

The pilot research project will commence in September 2008 for two years and four Welsh authorities will partake in the implementation of the seven actions as laid out in the plan, Merthyr Tydfil County Borough Council is one of these four authorities chosen to pilot the actions in this plan. This will enable the testing of the actions to ensure they are workable and will raise any practical implications prior to implementation as regulation.

As a member of LACA “local authority caterers association” the authority is aware that the school meal caterers in Wales will be supporting the four authorities involved in the project and will be able to discuss issues and problems together with sharing ideas and “show casing” best practice. The whole school approach is the underlying “thread” throughout the plan and encourages co operation and partnership working with key stakeholders together with cross border working.

As with any initiative, we would continue to work closely and engage with the children and young people in schools, their views need to be reflected in any outcomes or decisions and changes that affect the school meal service.

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

i.e.
The duty of Welsh Ministers, governing bodies, head teachers and local education authorities to promote healthy eating in schools

Healthy eating should be part of an 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 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

There is support for the key provisions in principle as they are broadly similar to those outlined in the Appetite for Life Action Plan. The key difference is that the time frame for the Appetite for Life Action Plan provides a period to “try and test “the actions to ensure that they are workable prior to regulation.

There will be a requirement as part of this process to engage with school colleagues so that they are aware of the duty and the impact this may have during the school working day.

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

The main concerns of putting these provisions in place are the financial aspects and implications on existing budgets together with the time frame of bringing in the regulation.

It is considered that the current position in which the service finds itself in with regard to being ”singled out” as the way forward in improving children’s diets. The school meal represents less than a third of a child or young person’s food intake per day and the services only operate for five days per week, 39 weeks per year.

The legacy of policy, legislation and bureaucracy over the past few years has left the school meal service in its current under funded state and has undermined caterers’ ability to provide higher levels of food provision now being called for. Additional funding will be required and time will be needed to engage with pupils in respect of the importance of a balanced diet and healthy eating particularly in secondary schools.

The cost estimate outlined in the measure of “an anticipated maximum investment £17million - £38 million for Wales over a three year period (Annex A) falls short of the amount that is believed is actually required to provide healthier school meals. More funding is needed to increase the actual working hours of kitchen employees to enable them to produce meals from raw ingredients; they would be required to start to prepare meals earlier in each morning.

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

Packed Lunches should be included in any regulation or legislation                                    
Any regulation or legislation made should include food that pupils bring from home – i.e. the packed lunches and food for breaks etc. that are currently not controlled.
If pupils are allowed to bring in crisps, sweets, chocolate, sugary food and fizzy drinks into schools then this will undermine the healthy eating work going on in schools.

Legislation to ensure the lunch period should be a minimum of one hour

Nutritional education and cookery lessons as part of the curriculum activity recently introduced is welcomed as it is vital that what is learnt in the class room is put into practice and taken from the classroom to practice in the dining hall. However, with some schools shortening lunch breaks nutritional education is not going to be much benefit if schools do not allow pupils sufficient time to make educated healthy choices and sit and eat in a social environment.

Free School Meals for all pupils in Wales

If the Welsh Assembly Government is serious about improving the long term health of children and young people in Wales then should we not be considering or calling for school meals to be available to every pupil free of charge? School meals should be regarded as an integral part of the school day for all pupils. Just as lessons are free for all, free school meals for all would ensure that every pupil is treated equally with the same chance for a healthier diet and future life style.

There would be a significant amount of cost savings if free meals for all were provided. Current school administration costs would reduce as there would be no requirement to separately record free meal and paid meal pupils. Both the school and caterers’ would save money in the labour costs attributed to cash taking, recording and cash collection areas. Till costs and maintenance costs would also be another area of cost saving together with the external contracts with security companies that collect cash from schools and bank on their behalf. Although there will be a need for investment – long term benefits will include the reduction of the health bill and cost to our NHS in Wales.

Policy of keeping Years 7 8 & 9 in at lunch time in secondary schools

Currently there is no clear guidelines or policy relating to the requirement of keeping pupils on school premises during the lunch time period, this is undermining the work currently going on in schools when providing healthier options through the service when pupils are going to nearby food outlets, purchasing non healthy food items and bringing them back to consume on the school premises; this has a detrimental impact on the motivation and moral of the kitchen staff who are actively encouraging the children and young people to make healthier choices whilst members of their peer group are sitting with them eating the products they have bought in. The aims of improving the health of the young generation in Wales will not significantly improve to meet the targets set if this area is not addressed.

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?

Councils cannot be expected to enforce a radical change of eating schools when we as a nation have yet to embrace this healthier eating philosophy, although clearly we will play our part. We need to nurture a social environment that renders healthier food more attractive and accessible. This together with a policy of positive price discrimination in favour of healthier food options will encourage greater family purchase and thereby greater recognition and acceptance by children and young people of these foods in their every day lives.

It therefore has to be recognised that this change in eating culture will take a long time, to make the marked improvements in healthy choices. It is for this reason that it is unclear how an enforcement route will speed the process up.

I would like to thank the National Assembly for Wales for the opportunity to be involved in this consultation process.

Yours sincerely

Marjorie Hope

Team Leader – School Meal Catering Service
Integrated Childrens Services
Merthyr Tydfil County Borough council