VEGA comments on an FSA consultation
VEGA comments on an FSA consultation
Re: Food Competency framework: food skills and knowledge for young people aged 7-9, 11-12, 14 and 16+
Questions on the Draft Regulatory Impact Assessment
1. What do you think of the themes and statements of skills and knowledge detailed in the food competency framework? For instance are they consistent with what you would expect young people of these ages to achieve - are there any gaps?
General comment: The themes and statements of skills and knowledge appear to be comprehensive and well formulated.
(i) Diet and Heath: “… use / apply current healthy eating advice” should be set in the context of diets that may be restricted, eg for health, cultural, religious or ethical reasons. The need for and benefits of balanced and healthy food choices within restricted diets must be stressed. Home produced/prepared food should be compared to ready prepared ‘microwave meals’, ‘fast food’ and snacks. The benefits of a ‘portfolio’ of healthy food choices could be emphasized.
(ii) Consumer Awareness: in “consider a wider range of factors when making food choices…”, we suggest adding “animal welfare” and “fair trade” as these are not mentioned in the Food Competences and are a significant factor in young people’s food choices (eg the proportion of vegetarians and vegans amongst children and young adults is substantial). The influence of the supply chain (farmers, manufacturers and retailers) could be examined, eg supermarkets vs local shops.
(iii) Food Preparation and Handling Skills: “… modify dishes to promote health through altering or substituting ingredients…” could include “substituting for animal products”. The benefits of raw fruit and vegetables (eg suitably prepared salads) as well as nuts and seeds should be promoted.
2. Do you agree with our assessment that encouraging a voluntary approach to using the food competence framework is most beneficial in terms of impact and cost?
Encouraging a voluntary approach would appear to allow greater flexibility at the outset. A legislative approach might be needed at a later date if there are mixed results and ‘minimum standards’ are not being met.
3. Who (individuals or organisations) do you see as being best placed to make sure that young people have the opportunities to acquire these skills and knowledge?
Schools are obviously best placed to ensure that all children have the opportunity to acquire appropriate skills and knowledge. Many other organisations that work either with young people or in the areas of nutrition/food/agriculture/environment should be involved. Any means possible to encourage better dietary habits and understanding amongst parents, teachers and other mentors should also be considered.
4. How should we promote these to young people – do we need to develop a young people’s version?
There must be appropriate resources available for all concerned, eg teachers, parents and young people themselves. This should include training for teachers and others and a wide range of educational materials.
5. We propose a voluntary approach to adopting the food competences, which may affect small and other food businesses. What resource implications, including administrative costs would you anticipate falling to your business as you respond to possible changes in consumer’s choices?
We are an educational charity working in the areas of food, health, animal welfare and the environment. We welcome the opportunity to engage in initiatives such as the food competences. However, our resources to do this are relatively limited.
6. We asked you about costs incurred due to a voluntary approach. This question may be of particular interest to businesses and enforcement bodies, such as local authorities/HMI’s. What would be the effect on your resource/cost ‘if’ we were to pursue a legislative approach to the food competences?
The common good (ie children’s health and well being) should prevail over any commercial interests.
7. What additional resource and/or support materials/activities would you need to help communicate/promote these competencies, through a voluntary approach, to your audience, for example to teachers or community workers?
Further comments Short Sustainability Assessment
Whilst we recognize that the direct health gains for young people are the most significant benefits, the potential for other benefits, eg for the environment, animal welfare or local economies, should not be underestimated.