HES 34 - Food Standards Agency

Consultation - Proposed Healthy Eating in Schools Measure Committee

The Food Standards Agency (FSA) is grateful to the Measure Committee for extending the invitation to comment on the proposed Measure.

The FSA is a non-Ministerial Government Department established under the Food Standards Act 1999 with the responsibility to protect public health from risks which may arise in relation to consumption of food and otherwise to protect the interests of consumers in relation to food.  This remit extends across the whole of the UK.  A key function of the Agency is to develop policies, or assist in the development by any public authorities of policies, relating to matters connected with food safety or other interests of consumers in relation to food.  As such FSA has a role as a statutory advisor to the Assembly in relation to a range of food policy matters.  In fulfilling its remit the Agency is committed to developing policy that is underpinned by the best available scientific evidence.

In answer to the first consultation question, the FSA notes that the proposed measure would give a statutory basis to aspects of the Appetite for Life Action Plan issued by the Welsh Assembly Government in February 2008, following collaborative development with a range of organisations including the FSA.  In particular, this Action Plan seeks to introduce new nutrient, food and drink based standards across the whole school day that go beyond the provisions of the Education (Nutritional Standards for School Lunches) (Wales) Regulation 2001, with supporting whole school measures that range from training for school catering staff to curriculum development, and a comprehensive programme of research and evaluation.  We understand this Action Plan is to be piloted in four local authority areas in Wales for a period of two years from September 2008, and that this pilot is likely to generate evidence to inform future decisions by the National Assembly on the development and implementation of Measures.

The FSA nevertheless welcomes the scrutiny that the committee will give to the proposed Measure and is willing, in addition to offering these preliminary written comments, to assist in the development of more detailed proposals that provide both a framework for current activities and a fresh focus on the importance of addressing dietary health in schools. I confirm the FSA is available to provide oral evidence if the Committee would think this useful.

In relation to the key provisions (the second consultation question):

In order to reflect the potential of the school setting to provide messages to children on food safety, the first might be expanded to provide a duty of “promoting healthy and safe eating in schools”.

As far as the provision to be able to specify nutritional standards is concerned it is recommended the requirement should cover maximum levels of salt, sugar and fat (including saturated fat).  We note that the use of “artificial additives” in food is a matter of EU competence and suggest that the National Assembly should have regard to the provisions of EU law before legislating to control levels of additives in foods or the diet.  The committee will nevertheless wish to note that the FSA has advised UK Ministers, following research on the possible effects of certain food colours on children’s behaviour, that there should be voluntary action by manufacturers in the UK to remove these colours from food and drink by 2009, with action to phase out their use in food and drink across the EU.

In addition to encouraging the uptake of free school meals it may be a helpful precursor to undertake some investigation to understand the barriers to improved uptake.

In answer to the third consultation question, the FSA notes the strong evidence that poor diet is associated with higher levels of heart disease, cancer and diabetes amongst other chronic illnesses.  Achieving the objectives of this proposal will contribute to school-aged children enjoying healthier and more balanced diets, with corresponding improvements over time in terms of a healthier population.  The emphasis is largely on promotion of better diets and the success or otherwise of the Measure may be in part dependant on ensuring awareness of healthier eating is reinforced by improved practical skills and the facilitation of behavioural change.  Increased uptake of free meals, and improvements in the quality of food provided, may have financial consequences and these need to be anticipated.  Full compliance with the proposed requirements will also potentially mean additional administrative burdens on school and LEA staff.

In answer to the fourth consultation question, the FSA suggests that an appropriate additional provision (linked to any duty to promote food safety) would be to impose a duty on LEAs to ensure adequate hand washing facilities are available and to promote good hygiene practice, such as hand washing by children before school mealtimes, both in respect of food handlers and pupils.

I would respectfully observe that the consultation papers do not indicate how it is intended to monitor and quantify any effect the proposed Measure may have, in order to inform policy evaluation.

I hope these comments are useful to the Committee in its consideration of the proposals. As stated above FSA is able to provide further and more detailed contributions, and to provide practical support in relation to the underpinning scientific evidence, as required.

The above comments take into account the views of the statutory Welsh Food Advisory Committee.

Yours sincerely,

Steve Wearne

Director, Food Standards Agency Wales