Memorandum by Royal College of Physicians
of Edinburgh (WP 70)
The College is pleased to respond to the request
of the Health Committee for evidence on the Government's Public
Health White Paper. The College also welcomes the White Paper
"Choosing Health: Making healthy choices easier" as
an important start to a Governmental commitment to "promote
physical and mental wellbeing and prevent illness".
SUMMARY OF
KEY POINTS
— Critical to the success of this strategy
will be a combination of individual commitment to lifestyle change
and governmental policy to support individual choices.
— Failure to support challenging choices
for individuals will add to the inequalities of health in deprived
communities.
— A European dimension is essential
in the planned Food and Health Action Plan.
— Legislation on banning smoking in
all public places is essential.
— The public health infrastructure
and evidence-base require support to target limited resources
in a cost-effective manner.
1. Whether the proposals will enable the
Government to achieve its public health goals?
The College considers that there are serious
limitations in the proposals that will constrain the success of
the strategy. The following comments are pertinent to food and
nutrition, and tobacco.
(a) Food and Nutrition
This encompasses risk factors for many of the
most prevalent diseases presenting public health challenges in
the UK; improving nutrition in the UK should be seen as the most
important of all our public health challenges. There is no real
dispute regarding what needs to be done—the population should
consume:
— less saturated fat (and therefore
less fat in the diet overall);
— unsaturated fats rather than saturated
fats;
— less beef (and other mammalian meat);
— more fish and vegetable protein;
— more fruit and vegetables;
Detailed proposals for how to achieve these
objectives have been published in local strategies and the College
cites as an example of good practice the Food and Health Strategy
for Greater Merseyside as published by "Heart of Mersey".
This is available at: http://www.heartofmersey.org.uk/uploads/documents/hm_412r_HoM_foodstrategy_Jan05.pdf).
Proposals such as these demonstrate how such
regional and sub-regional projects can become involved in "upstream"
interventions such as in food procurement, in work with the food
industry including caterers, and in contract specifications. In
addition, they can work with local communities through promotional
campaigns etc.
However, the foundations of food policy are
to be found within the Common Agricultural Policy (CAP), within
the context of which so many key decisions are made in food subsidies
and support for farmers. These subsidy arrangements determine
the relative quantities of different foods produced, and what
they cost to the consumer. Massive over-production of saturated
fat-rich dairy products and of beef results from the continuing
subsidies for production of these, resulting in the over-availability
of cheap burgers, and in the Commission disposing of dairy fat
into cakes, biscuits, pies etc, almost by subterfuge (in that
the consumer cannot know of this when these products are purchased).
Meanwhile, there is no subsidy on fruit and vegetable production,
these being the foods for which we need to increase consumption.
The population will always wish to purchase
food which is both cheap and easily available. Because of the
need to address this, public health experts believe that a major
reform of the CAP is required in which food production is clearly
related to the health needs of the consumer. Without such reform,
the College fears that all the well-intended projects to improve
nutrition at a more local level may be doomed to failure. Unreformed,
the CAP is a major hazard to public health, and a major contributor
to the high death rates from CHD suffered by the UK population.
The Faculty of Public Health of the Royal Colleges of Physicians
(FPH) has published a booklet "Health at the Heart of CAP".
This is available at: http://www.fphm.org.uk/publications/publications_general/Health_at_the_Heart_of_CAP.
There is a huge contrast between allocations
in the CAP budget and the dietary targets of the World Health
Organisation (WHO) and the Food and Agricultural Organisation
(FAO) and which illustrate the urgent need for reform. In particular,
there should be a switch from animal-based to plant-based production
and towards more sustainable production.
The College therefore considers that, while
a major omission in the White Paper, it is essential that this
"European" dimension is considered in the planned Food
and Health Action Plan.
However, the College supports the moves already
made towards clearer food labelling and controlling the marketing
on "junk" food to young people. Nevertheless, we believe
that more regulation is required if there is to be more success
in controlling some of the advertising excesses of the food industry.
The College supports fully the Children's Food Bill and its commitment
towards better food and a healthier future.
The College also believes that national legislation
is required to support a reduction in salt, fat and sugar in all
processed food products manufactured and sold in the UK.
Finally, in supporting the public sector to
carry out its role as a corporate citizen, the College urges the
Government to develop nutrient-based guidelines for public sector
procurement.
(b) Tobacco
Prevention of tobacco-related ill-health should
be seen as the second public health priority throughout the UK.
The College is therefore pleased that tobacco has received a high
profile in the White Paper and supports the Government's continuing
action to further curtail the advertising and production of tobacco
products. The College believes this has helped to reduce the prevalence
of smoking and supports those smokers who have given up. However,
the College is concerned that the proposed legislation on smoke-free
legislation is inadequate and potentially ineffective. The College
applauds and supports the proposed legislation in Scotland as
a more appropriate response to this public health challenge.
It has been shown clearly that across the UK
there is a clear mandate for public places to be smoke free. The
College believes that by permitting those public houses not serving
food to allow smoking, there is a danger that this will have a
disproportionate effect in some of the poorest areas, and that
this may result in increased health inequalities. The College
urges a reconsideration of the wording of the new legislation
to give a clear and unambiguous message to the pub and hospitality
trade.
2. Whether the proposals are appropriate,
will be effective and whether they represent value for money?
Public health and other NHS agencies and others
will continue to develop social marketing campaigns to engage
with local communities to create more informed choices. However,
to increase their effectiveness such activity needs to be supported
by Government campaigns promoting healthier food choices and a
smoke-free environment.
As previously noted, national legislation is
necessary in certain situations. Tobacco is a good example. Voluntary
agreements simply do not work. In many cases, people are very
clear on the healthiest choice. For example, most people feel
strongly about food in schools but legislation will be necessary
to require food companies to produce healthier processed foods
(with less hidden fats, sugar and salt) and at the same time advertising
targeting children must be restricted.
If individual and informed choices are not supported
we run the real risk of increasing inequalities as it is always
those from the most disadvantaged areas who find it hardest to
make the changes towards a healthier lifestyle.
It is difficult to say if the proposals represent
value for money and the research base is limited. However, for
example, studies have shown that investment in reducing risk factors
(such as promoting a healthier diet to reduce serum cholesterol)
for coronary heart disease is a much cheaper and more effective
method of reducing the burden of this disease in our UK communities
than cardiological treatments can ever be (see, for example, Kelly
and Capewell, HDA, 2004: http://www.hda.nhs.uk/Documents/CHD_Briefing_
nov_04.pdf).
3. Whether the necessary public health infrastructure
and mechanisms exist to ensure that proposals will be implemented
and goals achieved?
The College believes that it is essential that
adequate funding is provided to support the work described in
the White Paper. This should include national social marketing
campaigns linked to local and regional programmes and support
for research to strengthen the evidence base for public health
interventions.
February 2005
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