Memorandum by Which? (WP 27)
INTRODUCTION
1. Which?, formerly known as Consumers'
Association, is an independent, research-based organisation that
campaigns on behalf of all consumers. Funded through the sale
of our range of magazines and other publications, we are the largest
consumer organisation in Europe and have around 700,000 members.
2. Food and health issues have always been
central to our work because they are central to consumers' lives.
As you will be aware from previous evidence that we have submitted,
much of our work has focused around tackling diet-related disease
and obesity from a food perspective and so our evidence should
be seen in this light. This is the area where we have most experience
and have therefore largely focused our comments.
WHETHER THE
PROPOSALS WILL
ENABLE THE
GOVERNMENT TO
ACHIEVE ITS
PUBLIC HEALTH
GOALS
Overall approach
3. Which? strongly supports the approach
that is set out in the Choosing Health White Paper[64]
and the acknowledgement that the National Health Service (NHS)
needs to improve health and prevent disease, not just treat those
who are ill. It also recognises that if public health is to improve
a multi-sector approach is demanded across central and local government,
but also involving communities, industry, the media and other
non-governmental organisations.
4. Central to the White Paper is recognition
that government has a role in creating an environment that facilitates
healthy choices and that there is a need to focus specifically
on tackling inequalities in health. We believe that the right
balance has been struck between individual responsibility, the
role of government and the need for other relevant stakeholders
and sectors to respond. The challenge is to create an environment
in which healthy choices become the easy option, or as the White
Paper describes it: "to empower people, support people when
they want support and to foster environments in which healthy
choices are easier."
5. With this in mind, we support the three
broad principles that form the basis of the actions proposed:
supporting informed choice, with a special responsibility for
children who are too young to make informed choices themselves;
personalisation of support to make healthy choices, with equal
access to such services; and working in partnership to make health
everyone's business. We also consider that the broad themes identified
in the White Paper ie health in a consumer society, specific issues
for children and young people, local community action, workplace
health, health in the NHS and making health "a way of life"
are the key areas to focus attention.
Ensuring effective delivery
6. We have, however, heard rhetoric about
public health on many previous occasionsthe challenge is
to make the intentions set down in the White Paper real. While
it does provide a firm basis for action, we are concerned about
how it will succeed in motivating and co-ordinating the necessary
actors across the board in order to sustain change and really
make the sentiments set down in the White Paper happen. We are
also concerned that there is too much reliance on voluntary co-operation
by industry and are sceptical about the ability and willingness
of some sectors to deliver the changes that are necessary. Much
therefore will depend on the Delivery Plan and specific action
plans on food and health and physical activity that are promised
for early 2005.
7. The White Paper does set out some specific
mechanisms for delivery including for example, the establishment
of Local Area Agreements between government, councils and local
partners on local delivery of national targets to reflect local
priorities and which will initially be piloted in 21 areas from
April 2005. Primary Care Trusts (PCTs) are also to be required
to develop targets to meet the needs of people living in their
area with local partners in order to meet national targets and
priorities. It is also positive that health is to be included
as a specific component of regulatory impact assessment
something that is long over-due and an essential step towards
ensuring a consistent approach to public health across all government
policies. The establishment of a specific target to halt the rise
in obesity among children is also a useful way of monitoring progress.
Given the importance of European Union (EU) action to help tackle
many of the areas identified in the White Paper, we are pleased
that the Government has also made "empowering people; reducing
inequalities" a theme for the UK Presidency of the EU.
8. However, we believe that in addition
there is a need for mechanisms to engage, co-ordinate and motivate
the stakeholders across all sectors who are needed to deliver
the aims set out in the White Paper. This needs to happen at national
level as well as local level. Specifically, we believe that there
needs to be a strategic body to over-see the delivery of the Food
and Health Action Plan. As we proposed in our policy position
paper "Health Warning to Government"[65]
we consider that a Nutrition Council is necessary to take a strategic
over-view, to co-ordinate, and to ensure that the main stakeholders
make clear commitments and deliver on them. We acknowledge that
the Health Committee also suggested that the Government should
consider expanding the role of an existing body or bodies or creating
a new Council of Nutrition and Physical Activity to improve co-ordination
and inject independent thinking into strategy in its report on
Obesity.
9. The Committee's report also recommended
that a specific Cabinet public health committee be appointed,
chaired by the Secretary of State for Health to ensure that the
problem of obesity is recognised and tackled at the highest levels
across government. While there is now a Ministerial Committee
on Public Health (MISC 27) with a remit to "oversee the development
and implementation of the Government's policies on public health
and reduce inequalities", we are concerned that important
agencies of government that have a key role in delivery, most
notably the Food Standards Agency, are not represented on this
Committee.[66]
While this is clearly a Ministerial Committee, we note that the
Chief Medical Officer is invited to attend.
10. It is essential that all parts of governmentboth
central and localalso become fully engaged and accept their
responsibilities as part of the delivery process and that an impetus
for action is maintained across all sectors. The White Paper is
ambitious and a great deal of commitment will be necessary, backed
up by government incentives including regulation where appropriate,
to achieve the culture change that is needed if we are to see
an improvement in public health. These issues must be addressed
within the Delivery Plan and specific Food and Health and Physical
Activity Action Plans.
WHETHER THE
PROPOSALS ARE
APPROPRIATE, WILL
BE EFFECTIVE
AND WHETHER
THEY REPRESENT
VALUE FOR
MONEY
Marketing health
11. The White Paper highlights the importance
of marketing health, ie. promoting it on the principles that commercial
markets use and therefore making it something that people aspire
to, and the need for information to support healthy choices. We
believe that these are important aspects, but are concerned that
the proposals do not go far enough in some important areas.
12. We are pleased that the Department of
Health (DH) intends to develop a strategy over-seen by an independent
body that extends across all aspects of health and involves a
broad range of different government departments and agencies,
while also recognising the need for specific and targeted approaches.
This needs to draw on the expertise of the marketing and advertising
industries, while avoiding any potential conflict of interest,
and use creative social marketing techniques. However, to be effective,
such a strategy also needs to be closely linked to a broad range
of government, community, industry and other stakeholder activities
to ensure that consistent messages are promoted and that it is
easy and practical for people to put them into effect.
13. As well as promoting positive health
messages, it is therefore also important that misleading or potentially
confusing messages which could undermine efforts to improve healthy
choices are effectively tackled. This includes the way that messages
are promoted through advertising and other marketing and promotional
activities and information such as claims made on food labels.
We welcome the sentiment set down in the White Paper that the
Government now recognises that there is a strong case for action
to restrict the advertising and promotion of foods high in fat,
sugar and salt to childrenand for this action to be comprehensive
and taken in relation to all form of food advertising and promotion.
Our research has shown that this is an issue of great concern
to most parents and that they are supportive of greater restrictions.
For example, a Which? survey in 2003 found that 70% of parents
believe that there should be no advertising of junk foods during
children's viewing times.[67]
However, we are concerned that the White Paper is short on specifics
about what the Government intends to do to address thispassing
the issue back to Ofcom for further consultation.
14. While it is encouraging that the Government
intends to work with industry, advertisers, consumer groups and
other stakeholders to encourage new measures to strengthen existing
voluntary codes in non-broadcast areas, we are concerned that
this is too weak. The Government states that it will monitor the
success of measures in relation to the balance of food and drink
advertising and promotion to children by early 2007, but we would
like to see firm action to tackle the problem sooner, based on
the evidence that has been provided by the FSA commissioned Hastings
review[68]
and the research commissioned by Ofcom.[69]
We would like to see an explicit commitment to tackle this area,
including a commitment to restrict the advertising of such foods
during children's viewing times. We would also like to see the
Government pushing this message in Europe in the context of the
review of the Television without Frontiers Directive.
Information to Support Healthy Choices
15. It is very encouraging that the Government
has recognised the need for consumers to have simple information
that they can trust. We particularly welcome the commitment to
introduce a simple sign-posting or coding system for foods by
2006. This is something that we strongly supported in our written
and oral evidence to the Health Committee's Obesity Inquiry and
we were therefore pleased that this was included among its recommendations.
16. It is important that industry signs
up to such a scheme and that we are not presented with a proliferation
of simplified labelling schemes which only serve to create further
consumer confusion. It is essential that the Government over-sees
and drives this forward. It is disappointing that at the moment
some parts of industry do not appear to support such an approach
or accept that consumers favour a simple sign-post labelling scheme.
Others are developing their own schemes which is encouragingbut
unless these schemes are consistent, they will merely lead to
more consumer confusion. We are therefore very supportive of the
research work with consumers currently being undertaken by the
Food Standards Agency to decide which is the most suitable labelling
format. We are also pleased that the Government will be pushing
for improvements to nutrition labelling as part of the UK Presidency
of the EU.
17. It is also essential that the EU develops
tighter controls over health and nutrition claims and fortified
foods to protect consumers from being misled. Far too many products
are misleadingly promoted as healthy, including some supermarket
healthy eating range products, when they are still high in fat,
sugar or salt, as we highlighted in our recent report "Healthy
rangesthe slim truth?".[70]
Which? briefings on the EU proposals for legislation in these
areas are enclosed.[71]
18. In terms of consumer information, we
also welcome the creation of Health Direct with the aim of achieving
a joined up approach with existing services, as well as new funding
to enable every Primary Care Trust (PCT) to run at least one Skilled
for Health programme each year, by 2007, focusing first on the
most deprived areas. We also support proposals for more tailored
approaches to information and support for healthy choices, including
for example children's health guides as part of the Child Health
Promotion programme, but also proposals for NHS health trainers
and personal health kits.
Industry Responsibility
19. As we have already emphasised, industry
has a key role in tackling the barriers that make it difficult
to make healthy choices. We therefore welcome the White Paper's
acknowledgement of the important role that industry must play
and of the public's expectation for industry to act in a socially
responsible way. Four key areas are identified for the food industry,
which we agree with: product development, labelling information,
promotion and pricing and customer information and advice.
20. We agree that the food industry has
a responsibility to increase the availability of healthy food
and welcome the commitment to establish long-term and interim
government targets for reductions in sugar and fat levels in different
categories of foods, building on the work already under-way on
salt, and to develop guidance on portion sizes. Research that
we have carried out comparing the nutritional content of breakfast
cereals[72]
and of ready meals[73]
has highlighted the huge variations in fat, sugar and salt levels
depending upon which brand consumers choose and therefore the
scope for making reductions. These two reports are enclosed.
21. While we hope that industry can respond
constructively and act collectively to tackle the key issues,
it is important that the Government carefully monitors progress
and ensures that there is an adequate response. If industry does
not respond, the Government must use regulation to drive responsible
behaviour. As highlighted above, we remain concerned about the
proposals regarding the important area of food marketing and promotion.
We are sceptical of the industry's willingness to accept responsibility
in this important area. Government action is therefore essential
to ensure that failure to tackle any contradictory messages and
promotions here, does not undermine the other commitments and
proposals set down in the White Paper and the forthcoming Food
and Health Action Plan.
Children and Young People
22. We welcome the acknowledgement that
children need particular protection. We agree with the intention
behind the Child Health Promotion programme to create a broad-based
programme of support that will "address the wider determinants
of health and reduce health inequalities". This needs to
address the complex interactions that come into play. For example
poor nutrition may affect mental health and in-turn mental health
can lead to people adopting negative health behaviours such as
smoking and alcohol abuse. A co-ordinated and multi-faceted approach
is therefore essential in order to tackle the different elements
and address the particular problems of different groups. It will
be important that local services work in a joined-up way across
health, social services and educationand at local and national
levels. It is essential that support is provided, and provided
appropriately, at all stages of a child's development.
23. We are, however, concerned that the
proposals for schools are not ambitious enough. We do not think
that it is sufficient to aim for half of all schools to be healthy
schools by 2006, with the rest working towards healthy school
status by 2009. We are concerned that this timetable is too long
and would like to see proposals for all schools to become healthy
schools as standard. We support the commitment to role out a "whole
school approach to healthy eating and drinking". However,
we would again like to see this as standard and see a greater
emphasis on the teaching of food skills as part of the national
curriculum.
24. We are, however, pleased that the Government
has more specifically committed to improving nutrition in schools,
including revising both primary and secondary school meal standards
and extending these standards to cover food across the school
dayincluding vending machines and tuck shopsand
supporting school meal service provision. We also welcome a similar
approach to catering in other institutions and public bodies,
building on this work.
WHETHER THE
NECESSARY PUBLIC
HEALTH INFRASTRUCTURE
AND MECHANISMS
EXIST TO
ENSURE THAT
PROPOSALS WILL
BE IMPLEMENTED
AND GOALS
ACHIEVED
25. We do not consider that the necessary
infrastructure and mechanisms currently exist to deliver on the
proposals set out in the White Paper. However, we do believe that
the White Paper is a very useful starting point that now needs
to be built upon through concrete steps including clear commitments
at all levels and adequate resourcing.
26. Some of the measures that are set out
in the White Paper will help to make delivery achievable. Primary
Care Trusts (PCTs), for example, have a key role as a promoter
and facilitator of good health in local areas, but must engage
actively with the local community and community groups on the
basis of an equal partnership. It is also important that local
targets are focused on the issues that make sense and which are
important to local communities, and that they focus on outcomes
not just outputs or what is easily measured. Adequate resourcing
by government for these initiatives will be crucial. It must be
ensured that money given to PCTs for the purposes set out in the
White Paper is actually spent on public health measures. It must
also be ensured that PCTs have the capacity and the competence
to take on this leading role.
27. The White Paper does, however, set out
an ambitious vision that requires a new approach at both central
and local government level as well as within the NHS. Some measures
even require action at European level if they are to be put fully
into effect. New challenges are also raised for communities, companies,
consumer and public health organisations, the media and for individualsactors
at every level. We believe that we will only begin to see change,
and change that can be sustained, if there truly is a multi-stakeholder
and multi-sectoral approach to tackling public health. This requires
a great deal of motivation, enthusiasm, specific commitments and
perhaps most of all, effective and sustained leadership and co-ordination
from central government.
CONCLUSION
28. We consider that the approach set out
in the White Paper is the right one, but we have concerns about
how the proposals will be delivered in practice. We therefore
look forward to seeing how these issues will be tackled within
the Delivery Plan and the specific Food and Health and Physical
Activity Action Plans which must be a priority. As we have already
highlighted we believe that there is a need for strategic, cross-sectoral
and cross-governmental structures to be put in place if the aims
of the White Paper are to be achieved and the momentum and enthusiasm
that is needed to deliver better public health is to be sustained
in the longer-term.
January 2005
64 Choosing Health-making healthy choices easier,
HM Government, November 2004. Back
65
Health Warning to Government, Which?, February 2004. Back
66
Response to Parliamentary Question from Baroness Howe of Idicote
(HL567), 13 January 2005. Back
67
Face to face interviews were conducted with parents with a child
between the ages of three and 12 between 11 to 17 April 2003.
The data was weighted to be representative of Great Britain's
population, giving an overall weighted base of 446. Back
68
Research on the effects of food promotion to children, Hastings
et al, September 2003. Back
69
Childhood obesity-food advertising in context, Children's food
choices, parents' understanding and influence and the role of
food promotion, Ofcom, 22 July 2004. Back
70
Healthy ranges-the slim truth?, Which?, November 2004. Back
71
The Hidden Truth?-health and nutrition claims, Which?, January
2005; Added Value?-fortified foods, Which?, March 2004. Back
72
Cereal offenders, Which?, March 2004. Back
73
Recipe for Disaster, Which?, May 2004. Back
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