HES 32 - Snack Nut and Crisp Manufacturers Association (SNACMA)

Re : Consultation - Proposed Healthy Eating in Schools Measure Committee

I am writing to you on behalf of the Snack Nut & Crisp Manufactures Association (SNACMA) in response to your letter of the 16^th May 2008.

SNACMA represents the interests of the savoury snack food industry in the UK. Our Members are manufacturers of potato crisps, extruded snacks, pretzels, savoury biscuits, popcorn and nut products employing about 12,000 people directly and approximately 50,000 indirectly in the UK. The SNACMA membership is made up of both national and regional companies responsible for producing over 90% of all the savoury snacks sold in the UK.  

The savoury snack sector has long been involved in the health and wellness debate and, to that end, has been ahead of the rest of the food industry on issues such as product reformulation, clearer labelling and responsible marketing and promotion of our products to children. We would offer the following comments to the questions posed in the consultation letter :

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

We are on the whole supportive of the proposed measures for schools in Wales and acknowledge the need for an Assembly Measure to promote healthy eating in schools.

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

(i) the duty on Welsh Ministers, governing bodies, head teachers and local educationauthorities to promote healthy eating in schools;

We agree that there is a duty for Welsh Ministers, governing bodies, head teachers and local education authorities to promote healthy eating in schools

(ii) 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;

We agree that incorporating healthy eating into the inspection regime is an effective way of raising standards

(iii) 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;

SNACMA fully supports the Assembly’s initiative to improve the diets of children as part of a wider programme of improving their health through increased physical activity and better health education. The food industry and indeed the savoury snacks sector should be an integral part of this and we welcome the opportunity to work with other relevant stakeholders in order to find appropriate practical solutions. Schools should encourage a balanced approach to diet and lifestyle, taking into account the fact that a balanced diet is a varied diet within which it should be possible to include all foods in appropriate amounts; this should not mean that certain foods are demonised and banned. Our children’s health is so important that any interventions must be evidence based and likely to have a positive effect. The aim must be to encourage children to eat a diet with improved nutritional balance and this cannot be achieved overnight, by restricting choice, or in isolation of a wider healthy balanced lifestyle initiative within schools.

We believe that in trying to influence pupil’s choices it is essential that a positive approach is taken, i.e. promoting increased consumption of a variety of foods in moderation and balance rather than attempting to demonise certain foods because they do not have an 'ideal' nutritional profile. The likelihood of radical changes to the foods being offered in schools including vending and tuck-shop’s etc., being embraced quickly, if at all, by children is remote as evidenced by the problems experienced in schools in England. It is important in this context to understand that changes in behaviours and habits are achieved only slowly and when the change is easy to accept and adopt.

The approach taken by the Scottish Executive regarding standards for school meals is an outstanding example of how working with industry on possible solutions can deliver maximum benefits. The approach they have taken sets tough but achievable nutrition standards for food products in schools with no exclusion of any foodstuff. As a result the nutrition standards of products in Scottish schools has improved significantly with those products meeting the criteria set mostly being better-for-you versions of products within a sector. With ambitious but achievable targets in place, the food industry is incentivised to invest in the development of products with improved nutritional profiles, rather than would be the case if restrictions or bans were to be put into place.   

Savoury snack manufacturers have already invested heavily in providing a very wide choice for consumers. They have made significant improvements to the nutrition profile of their standard products and also offer an extensive range of lower fat, lower saturated fat, and lower salt products. Furthermore they provide extensive on-pack nutrition information to help consumers make an informed choice. As a sector we therefore already have a whole range of ‘better-for-you’ products that could be made available to schools now.

(iv) encouraging take up of school meals and protection of identity of those who receive them;

Whilst we acknowledge the desire to encourage the uptake of school meals, it is important to allow parents choice in how they feed their children. Furthermore as already recognised in these proposals it is important to involve and engage pupils in the choice of foods that are made available to them. It is entirely possible for parents to provide packed lunches that are of better nutritional quality than school meals. Therefore, the increased uptake of school meals should not be seen as the only way to achieve a healthier diet.

(v) the duty on local education authorities to ensure availability of drinking water for pupils.

We fully support the provision to impose a duty on LEAs to ensure the availability of drinking water to all pupils.

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

We believe that the provisions can have a positive impact on healthy eating in schools. However, we also believe it is important to allow parents and children a degree of independence in deciding what their children eat. To that end, we welcome the exclusion of packed lunches from the measure, but, as above, urge caution in your desire to encourage greater uptake of school meals, as parents and children may reject the idea.

We are in the process of conducting research into parental attitudes towards guidance on the contents of packed lunches. We would be happy to meet to discuss the results later in the year.

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

We feel the Assembly Measure goes far enough.

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

We agree that the Assembly Measure will go some way to achieving its purpose of a enabling a holistic, comprehensive ‘made in Wales’ policy on nutrition in schools. However, we would argue that to be truly holistic, the policy must include a focus on increasing the levels of physical activity for children and young people, which is vital to the fight against childhood obesity.

As previously stated, we generally welcome Assembly Measure and are supportive of the fact that it does not include food and drinks brought into school by a pupil for their own consumption. We only urge caution over the definitions and limits used for nutritional standards, and the innate dangers of prohibition.

We would be happy to provide oral evidence, if required. We would also welcome the opportunity to meet with members of the Committee to discuss the findings of our survey into parental attitudes towards guidance on packed lunches and the overall nutrition debate. We believe that we have an impressive record on product reformulation, labelling and marketing, and always aim to engage with Government organisations on the best ways of working together.

If you would like to meet us, please do not hesitate to get in touch.

Kind regards,

Steve Chandler

Director-General, SNACMA