MEMORANDUM 30
Submitted by the National Heart Forum
INTRODUCTION
1. The National Heart Forum (NHF) is a alliance
of over 35 national organisations—from the medical, health
and public interest sectors—and individual expert members,
all involved in preventing coronary heart disease—the leading
single, yet preventable, cause of death and disability in the
UK.
2. It is the NHF's hope that the Food Standards
Agency will play a significant role in the formulation of the
nutrition policies which would assist with the prevention of chronic
diseases such as coronary heart disease. Diet and nutrition are
key factors in the development of coronary heart disease,
as well as in stroke and in other chronic diseases such as cancer.
As our 1997 Looking to the Future conference report states:
"there is considerable evidence that the composition and
the quantity of our dietary constituents are critical, possibly
fundamental factors, in the development of atherosclerosis and
coronary heart disease.1" Current figures
set premature deaths from food poisoning at around 74 per year.
In contrast, nutrition is believed to underlie the majority of
the 150,000 deaths from coronary heart disease annually2.
3. The rate of decline of coronary heart disease
has been slower in the UK than in other similar developed nations,
such as Australia, Sweden and the US. Medical and health professionals
believe that the failure to implement a successful nutrition policy
is a significant factor in the UK's lower rate of decline. There
are two clear instances where nutrition policies are not working:
intakes of fat and saturated fat in the UK are still substantially
above the Government's recommended levels; and intakes of vegetable
and fruit are still too low at only three of the five portions
(400g) recommended daily, and even less in Scotland, northern
England and among children and low income groups3.
4. We are very concerned that, as the draft
Bill stands, the opportunity to make a real impact on food standards,
including nutrition, will be missed.
5. Our main concerns are that:
— the FSA should be given an appropriate
remit to promote as well as to protect the public's health;
— the FSA should have the power to
address nutrition, and formulate nutrition policy, as well as
food safety issues;
— public health professionals should
be appropriately represented in overseeing the work of the Agency;
— funding arrangements for the FSA
should not have a negative impact on the diets of low income consumers.
FSA'S ROLE
IN PROMOTION
AND PROTECTION
OF PUBLIC
HEALTH
6. The NHF welcomes the draft Food Standards
Bill, to establish the Food Standards Agency ". . . to
protect public health from risks which may arise in connection
with the consumption of food . . ." (Clause 1(2). However,
we are concerned that the protection it offers will be interpreted
in a narrow, safety-only context, and not with the longer term
prevention of food—and nutrition—related disease.
For the Agency to play a genuine role in improving public health,
it must be concerned with both promotion and protection
of public health.
FSA POWER TO
ADDRESS NUTRITION
7. We have always argued that nutrition should
have a high status within the Agency, and to some extent this
was reflected in the White Paper, but we are concerned that this
has not been translated to the draft legislation. Whereas the
White Paper specifically mentions "nutrition" within
its proposals (5.6 to 5.15) and, the primary guiding principle
states that the essential aim of the Agency is the protection
of public health in relation to food and nutrition; nutrition
is still not explicitly mentioned in the draft Bill.
8. We are concerned that, if nutrition is not
specifically mentioned in primary legislation then the interpretation
of the Bill concerning nutritional aspects will be ambiguous and
its implementation weak, because those clauses which are meant
to encompass nutrition are not sufficiently inclusive. We believe
that if this draft Bill is given assent, then the Agency runs
the risk of being left without sufficient power to deal with those
issues and aspects of nutrition which were proposed in the White
Paper.
9. The NHF therefore strongly recommends that
the draft Bill be amended to include the word nutrition in the
main objectives of the Agency, so that "The main objective
of the Agency in carrying out its functions is to protect and
promote public health from risks which may arise in connection
with the consumption of food . . . and other wise to protect the
interests of consumers in relation to food and nutrition".[Clause
1(2)]
NUTRITION POLICY
10. The Agency should be established as the
much-needed, co-ordinating hub for food and nutrition policy in
the UK. In order to do this we believe that the draft Bill must,
again, explicitly mention nutrition—and that this should
also be extended to be included in its information provision and
research and policy development remit.
11. The Agency should therefore also have responsibility
for:
— the surveillance of the nutritional
status of the population;
— the definition of the health education
message on nutritional issues;
— and policy formulation and advice
to Ministers.
12. The latter is of particular importance when
considering the development of nutrient standards, especially
in the light of increased processed and prepared foods.
13. The NHF also recommends that, in order for
the Agency to fulfil its nutrition responsibilities effectively
as a main function, these must be more clearly defined than those
currently set out in the draft Bill. This could be done by including
"nutrition" in Clause 9(1)(a) on the function of the
Agency: will develop policies ". . . relating to food
safety or other interests of consumers in relation to food and
nutrition."
14. On the basis of the nutrition role set out
for the Agency in the White Paper, and implicit in the Bill, we
recommended that the Government reconsider its proposal to the
Committee on Medical Aspects of Food Policy (COMA) to be jointly
controlled by the Agency and the Department of Health, and that
COMA should report directly to the Agency. This will also ensure
that COMA's advice is free from political pressure which could
arise by having a secretariat spanning both bodies.
15. This shift of responsibilities would mean
that the Agency had the primary responsibility for the formulation
of nutrition policy.
LINKS WITH
OTHER GOVERNMENT
DEPARTMENTS
16. The NHF welcomes the draft Bill's stipulation
that links between different government departments will be promoted.
However, we hope that the Agency will work in consultation, not
competition, with other government departments.
FSA APPOINTMENT OF
PUBLIC HEALTH
PROFESSIONALS
17. The NHF is pleased to note that the Agency's
membership will represent a reasonable balance of relevant skills
and experience [Clause 2 subsection (2)], and that certain members
will have a particular knowledge and experience of food safety
or other interests of consumers in relation to food. In recognition
of the Agency's public health remit, we recommend that this should
be extended to include experience in public health and/or nutrition
and that public health professionals are involved in numbers and
positions sufficient to inspire confidence in the decision-making
and priority setting processes.
FUNDING IMPACTS
18. We are aware that a separate consultation
document has been published on the Government's proposed schemes,
to raise funds for the Agency, and we will be responding to this
in due course. However, the NHF would like to stress our concern
that any levy or fee-scheme on the industry will not result in
the costs being passed on to consumers through an increase in
the price of food. For low income consumers in particular, who
spend a greater proportion of their income on food, this will
be detrimental, and act in direct contradiction to the Government's
overall aim of reducing health inequalities in society.
CONCLUSION
19. The creation of a Food Standards Agency
presents the best opportunity of recent years to formulate a national
food and nutritional strategy, developed by an independent body
where nutrition and safety are regarded as co-equal in terms of
function and staff expertise. But for nutrition and safety to
be so regarded, the nutrition functions of the Agency should be
strengthened beyond those inferred by the draft Bill.
March 1999
REFERENCE
1 National Heart Forum (1997): Coronary
Heart Disease Prevention; Looking to the Future.
2 British Heart Foundation Health
Promotion Research Group/Statistic Database (1997).
3 National Heart Forum: At Least
Five a Day; Strategies to Increase Vegetable and Fruit Consumption.
The Stationery Office. 1997.
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