The Food Industry and FSA must do better. Nutrient profiling is the subject of a proposed model that the Food Standards Agency has developed to support work “to further regulate the advertising and promotion to children of foods that are high in fat, saturated fat, salt, and sugar”. It oversimplifies the challenge (ignoring special groups such as veggies and others with particular aversions) and is a poor spatchcocked version of a scheme involving parents, teachers, and the children in the full resources of labelling and easily available information technology. And emphasis on school meals is overshadowing the significance of breakfasts, lunchboxes, and audits of the nutritional waste from well-meant meals that are spurned and possible spared from dumping in land fill by directing into recovery programs or the compost bin. VEGA involved in an FSA consultation.
re: Food Promotions and Children’s Diets – Consultation on Nutrient Profiling
1. We appreciate the effort that has gone into the nutrient profiling and the conflations and scoring entailed, but emphasize the need for much increased education of parents and teachers, as well as doctors, on the principles of nutrition. Increasing availability of non-invasive methods of screening should ease the discharge of these responsibilities. More informative and detailed labelling with comparison with RNIs (or RDAs) and, possibly, colour coding should furnish customers with easily available information at the point of purchase. All these earnests in promoting healthy lifestyles should acknowledge the benefits of physical activity and the harm of smoking.
2. We note the following reservations:
2.1 Nutritional information is subject to a great deal of modification and extension as vigorous research, epidemiology, and medical evidence change factors. Your comments on fibre content and the consequent uncertainties illustrate a problem with radical simplification. Others would include:
2.2 Difficulties for consumers of restricted diets to disentangle factors of individual significance. Worked examples should illustrate interpretations that people with well-known aversions or food-intolerances would need to make. Some years ago we published Dayplans of nutritionally-assessed menus for vegetarians (strict and lacto-ovo), for instance. Even the “indian cuisine” has big differences within the UK according to custom and habit in the sub-continent itself: risks of rickets, for example, differ between populations with Muslim persuasions from those of Hindu custom, and for such consumers – and especially the women – intakes of calcium and its absorption are not much good without appraisal of vitamin D status (and warnings of the possible need of supplements).
2.3 Such populations are likely to resort to alternative foods or specialized products for which comprehensive nutritional information is lacking. These commodities may be manufactured or imported by firms with relatively small turnovers. They may turn to advisors such as us, who can help by reference to internationally published tables of compositions of food, some of them, such as USDA’s, more accessible than the British compilations (especially if enquirers lack an academic affiliation). Accordingly, the consequences of the conflation of measures of calcium, iron, and n-3 PUFAs with a single protein criterion are dangerous: much more consideration is needed, with appraisals with groups in mind following various regimens. As more genetic counselling affects lifestyle practices broad descriptions will be broken down into sharper definitions: fruit is good for you – but not if you eat a lot of grapefruits when you consume a lot of coffee or are on some drugs such as warfarin or statins (things are not quite as bad at the moment that children would be taking many of the latter).
2.4 The profiling needs to anticipate trends and alterations of policy apparent to the public. Plenty of debate seems likely over the “quality” of carbohydrates and proteins. Profiling of glycemic index (or load) is just one factor to consider. It now seems appropriate to include trans-acids with saturated or to rate them separately. Ratios might be usefully included, e.g. sodium/potassium and n-6/n-3 fatty acids, and vitamin-like substances (such as taurine, carnitine, alpha-lipoic acid, and the “essential fatty acids” DHA and EPA – once, presumably, what was meant by vitamin F) should be comprehended in the profiling.
2.5 The diet of the offspring begins before the time of conception. The National Diet and Nutrition Survey has revealed deficiencies in iodine intake in girls. Some groups such as vegetarians may be at particular risk to their thyroid status unless they take supplements. This factor may rank as significant as intakes of essential fatty acids in developments of the brain and cognition. We have at last succeeded in persuading some manufacturers of soya milks to fortify their products to near the levels of cow-milks (which depend on supplements to feeds and residues of iodophor disinfectants – iodine deficiency in British cattle and sheep is quite common). Goitrogenic substances crop up in fruit, vegetables and cereals, so “healthy” changes in profiled choices may entail overlooked consequences. Plant milk alternatives may need appraisal in the further context that they are lower in protein than comparable animal derived products; moreover, they lack other properties in these nutritional sources and fortified versions.
2.6 Some other factors of specialized but significant interest may arise from zealous advocacy of fruit and vegetables (and the definition of vegetables should comprehend marine sources). The non-terrestrial weeds provide the essential fatty acids that fish derive and then pass on to human consumers. The sea-vegetables also concentrate the iodine (and probably selenium) in sea water to the benefit of human consumers by direct consumption or indirectly by eating fish or meat and milk from animals grazing pastures fertilized with seaweed or by consumption of supplements. Some seaweed products are much used in manufactured foods, e.g. for texture (such as agar, carrageen, and alginates). We collaborated with MAFF some years ago and supplied some information for the Composition of Food Tables, and as a result entered into some correspondence in the Lancet and other medical journals and we sponsored research resulting in a PhD on this subject and its corollaries (see our website). We have had no cooperation from the food industry in declarations over the iodine content of foods attributable to the plant sources of the element, nor from synthetic colourings such as erythrosine. These are factors for further consideration and monitoring in treatments with iodine-containing drugs (such as amiodarone) and in dealing with thyroid cancers and nodules and with victims of radioactive exposure. Although some of these eventualities are unlikely for children, adventitious intakes of iodine may cause harm; but the risks and benefits in often overlooked contexts must be entertained in attempts at profiling.
2.7 Fluoride is another of the halide family requiring special attention for children. The FSA has brushed off our comments on this factor, explaining that it is not responsible for water-supplies. This argument does not wash: the customer reads labels on foods citing water as an ingredient and buys bottled waters declaring fluoride content. As a parent the child’s carer is likely to receive a homily from the dentist on the benefits of fluoridation for the health and development of teeth and bones (along with intakes of calcium and fat-soluble vitamins and certain cereals, as sources of silicon). The FSA must not duck the significance of fluoride, if only because some recommended fruit juices are made up of imported concentrates diluted with water, of undisclosed fluoride status, from sources much nearer to the point of sale. (Some nice teasers on food miles there!). Further, as with iodine, dietary excesses of fluoride can occur, with harm to thyroid function. The precautionary principle needs constant scrutiny and application in the ratings of foodstuffs in communities with different habits and needs.
2.8 Similarly with salicylates, which are rated as plant components offering benefits associated with the consumption of vegetables. They are part of the plant’s specific acquired resistance – their immune system – of which aspirin is a simple derivative. However, aspirin is a drug contra – indicated for use in children (owing to Reye’s disease). Does the profiling take account of this possible confusion for parents, teachers, and health professionals?
2.9 The system projected for nutrient profiling must clarify the purposes and circumstances for which the foods are intended. Snack or Sunday lunch? Lenten collation or mardi gras celebration compensating for a bout of frugality and mortification? (carnival, by the way, means good-bye to meat carne, vale!). After much effort we have persuaded major retailers into year-round sales of tree-nuts. The British custom of eating nuts as adjuncts to high-calorie celebratory meals is misguided: they are almost meals themselves and suitable for compact meals taken in breaks from physical activity. They are still undervalued in the fashion of confectionery: enrobing them in chocolate or mixing them with dried fruits are additions acceptable in certain circumstances but likely to attract undue scoring debits for fat and sugar.