HES 33 - Welsh Food Alliance
Consultation – Proposed Healthy Eating in Schools Measure Committee
Response from the Welsh Food Alliance
WFA is an independent, self-financed organisation established in 1999. It brings together expertise, and citizens, in all aspects of food policy. We aim to provide a new perspective based on informed public participation. Volunteers do all our work and we network extensively with other organisations. Key areas of work include: promoting food policy, growing malnutrition in an ageing population and quality public sector catering, all of which we have championed over the years.
1. Is there a need for an Assembly Measure to promote healthy eating in schools in view of existing initiatives within this policy area?
Yes, especially since the ‘One Wales’ manifesto refers to hospital food, but not to school meals or ‘Appetite for Life’. However, given existing initiatives, what is of greater significance will be the political will and the financial resources to make a reality of the intentions behind the proposed Measure as part of a much bigger policy jigsaw. This is more than ever necessary with the rising cost of food commodities, manufacture, distribution and catering, which will affect all aspects of food policy; and when family budgets are coming under increasing pressure.
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;
Yes. We have strongly supported provisions set out in this measure over a long period of time. We think it essential that the future "A Healthy Future" - A Public Health Strategic Framework for Wales to 2020, currently being driven by the Chief Medical Officer should play a powerful role in driving improved nutrient standards.
Current policy places emphasis upon children, but this requires greater recognition of the crucial importance of nutrition for Preconception, Pregnancy/ Gestation, Birth and Infancy, which follows when young people create families. This crucial aspect has been raised in endless Assembly consultations and the evidence offered has been substantial. It is now time for this to be properly factored into public health strategy.
Very rarely do we have such a captive audience in terms of a single public health intervention. With school children and young people we have a once in a lifetime opportunity to directly improve health and reduce intergenerational health inequalities. Both are key aspects of ‘One Wales’. In particular we draw attention to the contribution that school meals make to addressing low birth weight and the key role of Head Teachers in increasing the uptake of school meals.
School meals will be a key test of our new public health strategy. This measure is supportive of evidence we recently submitted as a member of "A Healthy Future" - A Public Health Strategic Framework for Wales to 2020 reference group. (See question 3, financial implications).
In addressing future financial challenges (see Q3) in providing an efficient school meals as a social service do we have sufficiently flexibilities to stream line existing fragmented operations across local government so that we achieve optimum economies of scale and excellence, through, for example, one centrally planned system and one agreed price and menu?
- 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;
Monitoring and Evaluation – food in schools
We understand that in England the new Ofsted inspection framework will require schools to present evidence about their approach to food and healthy eating as well as the standard of school lunches. We would be most concerned if this simply involved a tick box approach to monitoring and evaluation.
Our analysis of a recent Scottish HMI October 2005 report is that overall they reach good conclusions. Some of the good practice identified in Scotland can also be related to good practice in Wales, but in Wales a clear strategy and method of evaluating systems and outcomes needs to be identified and developed.
In contrast to the broad approach in a recent Estyn statement, we wish to highlight the Scottish success with HMI monitoring which has demonstrated the value of independent, external verification of the extent to which government policy has been implemented at a grass roots level. With two food specialist HMIs, their reports allow best practice and creativity activity to be shared across Scottish schools: creating a competitive health drive.
HMI English Food Specialists are well represented within HMI England. When we responded to the ‘Appetite for Life’ consultation, this was not so in Wales. Neither is there a Food Specialist within what was ACCAC. This issue must be addressed if food and related subjects are to be taken seriously.
Contrary to current Government, it is recommended that Wales should follow the Scottish model, with dedicated food specialist HMIs.
- 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;
Yes, because this will drive the appropriate specification of food through local authority procurement. To obtain maximum impact procurement needs to aligned and span all government departments across the UK. This enormous purchasing power in turn should drive the specification of manufactured foods available to the public sector and the wider population. This provides a double dividend for public health.
Our main concern with the public sector is with manager training, across procurement, production, service and monitoring, and the knowledge, understanding and application of nutrition, and which delivers the product required for public health. This is an issue raised with the Welsh Assembly Government in relation to all aspects of public sector catering, CAP reform and non-devolved NVQ National Occupational Standards for catering workers.
- Encouraging take up of school meals and protection of identity of those who receive them;
Protection of the identity of pupils receiving free school lunches is clearly an important aspect of human dignity and we have long supported cashless systems as a method of tackling this issue.
The significant costs arising from an increasing proportion of eligible pupils taking up school meals are a direct charge to the LEA. Whereas, the cost of free primary breakfasts are drawn down directly by the LEA from central government and is not part of the local government settlement. Any measure to directly address this aspect must consider the perceived consequences of funding mechanisms used by LEAs. We suggest that the funding of school meals should be ring fenced, or grant funded by central government.
We also have concerns about any further funds being spent on reviews, literature searches and other non-essential expenditure. These issues have been around for a long time! Certainly from our experience over the past four decades. As we recommended in the ‘Appetite for Life’ consultation (2006), central government funds be targeted at:
(i) Addressing child poverty for children living in families in receipt of Family Credit (Now Working Families Tax Credit) who are currently not eligible for Free School Meals, which is already the position in Scotland (2007); and
(ii) Enabling the appointment of two Food Specialist Inspectors at Estyn, when they currently they employ none (see later ‘Monitoring and Evaluation – food in schools’.
- The duty on local education authorities to ensure availability of drinking water for pupils.
Yes, a basic human right. It needs to be fresh drinking water.
3. What are the practical implications of putting these provisions in place?
Since meeting with Jennie Randerson AM last year to discuss this Measure, one crucial development has been the end of the post war era of cheap oil and food. If this Measure is to achieve its purpose, the impact of food, oil and fuel price inflation requires particular scrutiny and realistic financial provision. This should be seen alongside anticipated aspects of Assembly food policy and a report on food security to be issued by the UK Cabinet Office.
The end of cheap food and fuel
Three key points are that: -
(a) 20th century economy efficiency gains are heavily oil-dependent;
(b) 95% of all food is oil-dependent: on farm; processing; distribution; retail; and consumers;
(c) Oil at $100 barrel could add 10% c. to food prices (Sustainable Development Commission, 2007). The price of oil is currently about $130.
Other factors impact upon both supply (eg, drought, banning of food exports, biofuels) and demand (eg, food wastage, westernisation of diets with increased standards of living in developing countries, population growth).
Internationally, with fuel and food price inflation continuing over the next decade, Wales is commencing this new measure at the worst possible time. We have long advocated and therefore welcome the new emerging Public Health strategy, which seeks to link healthcare, sustainable agriculture, climate change, child poverty, service commissioning and the important functions of local government.
The financial data accompanying the proposed measure are out of date and require realistic assessment. It is unfortunate that the timing of the measure is such that economic circumstances are forcing the school meals system in the opposite direction to those intended.
In our view these external factors impacting upon school meals in Wales, over which government has limited control, means that with current levels of funding, we will be very lucky to retain current nutrient standards, let alone improve them.
In addition to the financial pressures experienced by local authorities, families are facing higher bills for food, mortgages, oil, power, and transport. We therefore envisage growing service user resistance to achieving improved nutrient quality, through increasing the price of school meals.
We note that the current Health and Social Care Bill provides for increased financial assistance to mothers in the 29th week of pregnancy. Without doubt this non-devolved resource would have been more productively invested in improving the nutrient quality of school meals for future parents.
Work based training and NVQ assessment processes
A catering operation preparing and cooking freshly prepared food requires significantly different skills and qualitatively different results from reheating food in a microwave oven. It also has implications for funding equal pay for work of equal value. Work based training and NVQ assessment processes will be expensive and therefore needs to be carefully organised within the existing national framework of NVQ Food Preparation and Cooking Units, modified to include nutrition as a common mandatory unit to all public service caterers in Wales.
CPD for key workers
We note that a high proportion of eligible pupils do not take advantage of free school meals. Where Head teachers have an understanding and commitment to the nutritional health of pupils this can be reflected in an increased uptake of school meals. Does the significance of nutrition for health and brain function feature in CPD for key workers?
Other aspects
Dining room capacity.
The time allowed for school lunch so that pupils can eat in an orderly and satisfactory manner.
Pupils need to eat with teachers, which helps provide the social context and encouragement for reinforcing messages learnt in the classroom.
4. Are there further provisions that you would like to see added to the proposed Assembly Measure?
Packed lunches should be compliant with the recommended standards, with Head Teachers being held responsible for monitoring. Hampshire has developed a policy model packed lunch policy for Head Teachers to circulate to parents / guardians. Could we do likewise in Wales? This already happens to some extent with items being removed and returned at the end of the day. Such policies should be contained within the school prospectus.
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?
It is crucial to understand that this Measure is only one part of a complex jigsaw, with each contributing to the whole, and that higher levels of government, particularly in the context of growing global food insecurity, and food affordability, have an important part to play in achieving our overall aims and objectives.
In our view this Measure will help contribute towards the purpose and the aim of this intervention. It will make other parts of the school community and governors, take responsibility for the nutritional status of pupils, which has historically sat with the school caterer.
Historically the school caterer, driven by Compulsory Competitive Tendering legislation, have excelled at providing pupils with ‘food’ high in salt, sugar and fat and unhealthy, but commercially viable. We now have to reverse the past 25 years when school meals are not fit for purpose.
Budgets may be a perceived difficulty, if some Head Teachers have not fully understood partnership working and that the responsibility for nutritious provision lies beyond the concept of where the budget holder is located.
In respect of school caterers we would ask if they are still feeling the impact of the commercial pressures to deliver meals within a budget and if this is still impacting on the speed at which change can be delivered.
Regarding external factors, such as oil and food prices - outside of governments control - it is unlikely that a holistic, comprehensive ‘made in Wales’ policy on nutrition in schools to be developed and implemented without substantial additional resources to improve the quality of food put on the plate and the necessary resources to address capital costs, dining room refurbishment, equal pay for work of equal value and necessary staff training costs to enable fresh food production on site. Is there any real objection to purchasing good value quality fruit from just over the border, which is famous for fruit growing, if Welsh producers are not up to this challenge?
Abolition of free prescriptions will cost in the order of £30m. Our priorities would have been different with some of this public money being invested in our school meal system, as a social, rather than as a commercial service. We have calculated that universal free school meals – which ideally we support - in one authority would cost £12m. Paying for those eligible but not receiving free meals would be in the order of £2m.
Our immediate priority, in addition to directly funding the cost of free schools meals would be targeted at (i) addressing child poverty for children living in families in receipt of Family Credit (Now Working Families Tax Credit) who are currently not eligible for Free School Meals. Curriculum.
If we believe in preventative measures, we should replicate Scandinavian policies which advocate that good nutritious food daily can help produce a healthy population – physically and mentally – then this is the way forward. The resource invested will be evident in future years and generations.
David Smith
Policy Adviser
Welsh Food Alliance
