VEGA's comments on the Food Standards Agency's Action Plan on the promotion of food to children
1. We accept the need to have an Action Plan at last, but emphasize our reservations over its selectivity. The following particular issues concern us.
1.1 The tactics under consideration must integrate into a comprehensive strategy for health in which nutrition is an important part requiring consideration for individual needs and strengths and for the range of ages in a society embracing a variety of cultures and responsibilities. Mobilization of effort on the nutrition and health of the young must engage the nation that premature degeneration in the elderly may owe its beginnings in the nutrition of the mother even before her baby has been conceived. It is noteworthy that farmers condition-score and control the nutrition of livestock used for reproduction more closely than the nutrition and health of girls and young women are cared for by parents and the government.
1.2 The proposed Action plan may pay special attention to its effects on different - and particularly minority – ethnic and cultural groups, some at added risk of exaggerated reaction or isolation. From our experience we would cite the precautions needed in caring for people of Asian, particularly Indian, origin who are at enhanced risk of diet-induced obesity and all the corollaries of early progression into the corollaries of metabolic syndrome and type 2 diabetes. This challenge adds to the constant threat of osteopenia (e.g. rickets), in which diet, culture, and adaptation are involved. In this example there have been faults due to neglect and inadequacy in the medical services, aggravated by language difficulties. Useful booklets of advice in various languages familiar to these communities have been provided by the pharmaceutical industry; the Action Plan should ensure that its messages are similarly translated, without commercial endorsements.
1.3 The Action Plan material contains scant attention to the effect on sensitive communities with metabolic disorders, many of which have familial and genetic associations. Some of these are well-recognised, such as diabetes, celiac disease, phenylketonuria and, increasingly, hemochromatosis (iron overload) and polymorphisms in the actions of certain B-vitamins (among which are folate and vitamins B2, B6, and B12). These conditions are being recognized more successfully and testing, diagnosis, and treatment are being brought to bear as genetically-based surveys and facilities are developed (e.g. in the MRC’s Bio Bank project). It is regrettable that a parliamentary committee was recently misled in an otherwise worthy analysis into misinterpreting an infantile example of obesity that turned out to be primarily due to a chromosomal deletion (Prader-Willi phenotype- the commonest genetic cause of obesity, according to the textbooks). In our experience inconsiderate but well-meaning dietary messages can prompt unwonted harm in reactions categorized by psychologists and nutritionists as anorexia and bulimia, and manifested by extremes of refusals and bingeing and with behavioural and other threats to health and development. The Action Plan needs rapid and hard-thinking multi-disciplinary teams of specialized experts in an area of nutrition with many uncertainties and risks of doing harm.
2. Well-man and well-woman services are being increasingly provided by the NHS and private health-services, so this is a time to look at and overhaul well-child monitoring to provide parents and guardians, as well as the children themselves and their doctors and their teachers, individual and anonymized professional advice and treatment. Improvements in the NHS’s IT systems will greatly augment the monitoring of trends and the availability- with the subjects approval- of comprehensive records. The child’s doctor can also be furnished with relevant comments from teachers. The NHS would have to ensure, for these and other reasons, that s/he can call on the services of dieticians and appropriate counsellors, with constant involvement of the parents and the children (such attention begins to attain the equivalent veterinary care devoted to the horses at Newmarket!).
2.1 Advances in diagnostics and bedside and portable versions of the equipment once needing major installations suggests that a well-child bus could visit schools to run the appropriate tests and examinations on-board and expeditiously and thus greatly extend the range of benefit formerly at the limits of the school nurse or doctor (if any). They would also detect the onset of obesity and its corollaries, as well as other conditions that need skilled advice and treatment.
3. The campaign on children’s health should be accompanied by school syllabuses on citizenship that would prepare children for their national and individual responsibilities and for the development of their own talents. Such syllabuses, which should run on an organized and examined basis, would comprehend the elements of home economics, commerce, business accounting, governance, health, first aid etc. These courses would complement the measures intended for the Action Plan and provide practical experience in buying and selling, reading and interpreting labels, claims, advertisements etc. As far as possible, they should also involve growing food. City livestock farms seldom teach the realities of commercial production; perhaps realistic videos and commentaries should be shown with cylinders of “atmosphere” to complete the picture.
4. Overhaul of labelling requirements is overdue. Consultation on the Action Plan needs more worked examples of the proposals suggested in your documents. Definitions such as high in fat (sugar, salt etc…) have to be made and composites comprised in the traffic light system require adjustments and scoring for priorities (is fat more important than sugar, for instance, and how do the components of, say, a fat count –saturated, MUFA, PUFA, LCPUFA, omega 6, omega 3, for example); and what is the food required for- breakfast, evening meal, a snack, or a beverage, or at what cost and to satisfy what tastes? An instant red for the oil added to a salad would seem unnecessary, unless the signalling (double yellow, perhaps) can distinguish the different nutritional properties of the various components and their sources. A chippie might use beef tallow for the potatoes, which would justify a red, or vegetable oil (a possible amber, with some queries of the type of potato and fish). Public perceptions and prejudices persist: for instance, the general public regard nuts, which as eaten are highly concentrated in nutrients, as seasonal adjuncts to already hi-calorie festive and seasonal meals; vegetarians, on the other hand, are year-round nutters, though not always understanding the potency and nutritional balance of their “meat”. The high content of fruit (intrinsic) sugars is also noticeable. The FSA must warn the public of the dangers of un-buffered sugars on children’s teeth and the consequent debate on fluoridation.
4.1 Nutrition information of five vegetarian foods
fruit baked nut bean veggie
& nuts beans cutlet burger banger
Energy (kcal) 512 85 308 241 223
Protein 16.1 4.6 17.7 5.9 8
Carbohydrate 31 15.9 22 23.2 11.7
sugars 29.1 5.2 5.4 2.6 - Fat 36 0.3 21 13.9 16
saturates 6.7 0.1 4.8 1.8 -
monsaturates 16.3 - 10.6 - -
polyunsaturates 13 - 5.4 - -
Fibre 4.8 3.5 3.5 3.5 -
Sodium 0.1 0.5 0.6 0.6 -
Salt - - - 1.5 -
4.2 With these reservations in mind we have set forth the declared nutritional data on items selected from a household fridge/freezer/pantry, as an example for consideration for warnings or signals. We have no information at hand on cost, which might be used as a datum line, e.g. Xcals per 7p; or Zg protein per 1p. We regard this example as proof enough that labelling requirements must be extended, as the brute force of a 3-mode traffic-light system obscures a good deal of confusion and ignorance. We think the public and special groups need nutrition information prominent enough (e.g. occupying at least half of the printed space on the label) to attract attention. Colour-coding or formatting could then be used for individual warnings (so fat on a product might be reported in red, but salt- or sodium- content in green). The information should be accompanied with some general description.
5. School meals should cater for lack of parental responsibility for breakfast. An adequate early meal reduces the need for mid-morning snacking, which need be
mainly a source of some basic nutrients in a source of water. Lactose-free (plant) milk drinks, some containing fruit juices, are convenient for this purpose and avoid the need for cow milk. Brought-in lunches and snacks avoid systems of monitoring proposed in the Action Plan, unless the emphasis and assistance from general education are transmitted to the providers. It seems likely that children will gain access to “forbidden” advertising (e.g. on TV)
through parents and peers: forbidden fruits taste the sweetest and the proscriptions may be circumvented by recourse to artificial sweeteners. We suggest that children have access to vending machines at their school that purvey snacks and meals with a minimum of reds and that accept payment only by credit cards debited to the respective parents or guardians. With modern bar-coding and IT it should not be difficult to render accounts listing the corresponding contents of nutrients. Exclusion zones of van sales and unsuitable sources of food should be established: access to them should require expenditure of much energy.
6. Sales of symbols and lease of logos are misinterpreted or given undue trust, e.g. by over-interpretation of perceived values (e.g. organic, free range, GM free). Our table (4.1) illustrates an example where the Vegetarian Society is receiving fees on a product bought in a health-food store that is inadequately labelled for present purposes and by the standards, still inadequate, for products suitable for vegetarians but not bearing the symbol/emblem and “approval”. We describe on our website the full story of our protracted complaint, as a consequence of the responsibilities of the Campaign For Real Bread and of our Assalt course on various foods, over Marmite flaunting the emblem/symbol and approval in its product: a slice of bread prepared for Marmite soldiers contains the equivalent of about 1g of salt, roughly half-half from the bread and yeast-extract, with a negligible amount from the fatty spread (a daily maximum of salt intake for a toddler would be 3g). Some salt contents in bakery products have been reducing over the years more than your account describes- but retailers of branded and own-brand yeast extracts have resisted change, except for one or two in the health-food trade in which the load has been reduced by about 90% (from 11% content to about 1%). There are several instances in which charities and NGO’s have sold their name on products that are objectionable in ways beyond their competence to assess and monitor.
7. Sociological reviews of food and feeding practices need regard to the status of “wicked” foods as rewards, especially the “Granny effect” in offering “sweeties”. Ready availability of convenience foods and unrestricted consumption of beverages and greasy take-aways in public places violates prudent dietary practice and hygiene. Restrictions applying to smoking could be extended to food consumption but with a more positive approach to alternatives. Licensing of pubs and restaurants could require suitable space for consumption of brought-in-catering: vandalizing and closure of many municipal lavatories and toilets now mean recourse to brief visits to catering establishments’ facilities in the High Street. It does not seem unfair to load the food industry with some of the effects of the over-consumption its products have stimulated. Reduction in the size of packets of condiments, sweeteners etc provided free in restaurants and hotels could be another incentive to curb undesirable intakes (or increase them by doubling the number of packets used!).
8. Possible confusion may be caused by advocacy of reduced salt/sodium consumption. Some authorities still believe that the UK’s population is safe from iodide deficiency because the salt used in manufacturing and in the household is iodised, and that high intakes of salt can therefore be justified. The belief is false: iodide intakes in the UK are subjects of concern needing other solutions, which would use potassium, rather than sodium, substances.
9. Use of celebrities for a cause may backfire for reasons not directly connected with the association. The publicity many actually benefit the personality more than the cause, and the person may fall undignified from grace. The serious topics of nutrition and health should treat children in a respectful way and not be presented by the very facile means errant manufacturers have adopted.
10. We regard the Action Plan as too soft on the food-industry, even if naming and shaming is practised vigorously. Selective taxes on fats, sugars, and salt could be applied and levies mulcted as penalties for an industry guilty of serious malpractice, irresponsible research, and an inability to police itself. The Advertising Standards Authority has proved ineffectual and our experience with it confirms that it should be replaced by an independent national body that should examine all claims and advertisements for foodstuffs (except for warnings of hazards) before publication. All such material should be available in a collection open to public inspection.
Hon Research Advisor