Evidence for presentation to The Economic, Trade and Rural Affairs Committee 17^th February 2023

British Dietetic Association represented by Dr Amanda Squire

The general principles of the Food (Wales) Bill and the need for legislation to deliver the stated policy intention.

The British Dietetic Association* (BDA), representing Dietitians in Wales, welcomes and fully supports the introduction of the Food (Wales) Bill to secure a healthy, resilient, and sustainable food system and protect the health and wellbeing of our future generations in Wales.

Dietitians are Health and Care Professions Council (HCPC) registered professionals who translate the science of nutrition into understandable and practical food and dietary information. They support individuals, communities and the population in Wales to have the skills, opportunity and confidence to access healthy, affordable and sustainable food.

We welcome the Bill which we feel is imperative if we are to meet the scale of the economic, health and social challenges ahead. We believe food is a basic human need.  It is essential for healthy growth and development of children and young people and important in enhancing wellbeing and quality of life.

This Bill will support a more joined-up approach to food and provide a much needed, integrated framework upon which to develop a safe and sustainable food system in Wales. To have a long-term impact on inequalities and to improve health outcomes in Wales, requires multi-sector involvement.  We need clear goals related to food, to be achieved collectively.

We agree that a radical, long-term approach is needed to overhaul the Welsh and UK food system with a focus towards sustainable, home grown, produced and distributed food. The Bill should encompass the key aim to balance the population’s food supply to reduce food industry production and supply of high fat, sugar and salt (HFSS) foods. The impact of Wales’s obesogenic environment is currently compounded by a complex and largely unregulated food system, targeted advertising and easy access to HFSS foods. These can only be addressed through a cohesive and supported food environment, coupled with easy access to the right, evidence-based advice.

Action is paramount to reduce the burden that diet-related ill health has on people’s lives, economic stability and life expectancy. Through these actions we can reduce the impact of  illness on the NHS and health and social care services.

Wales faces a health crisis compounded by the current financial environment. Almost 60% of adults and 27% of children in Wales are overweight or obese. Wales has the highest proportion of overweight and obese 4–5-year-olds in Great Britain. Obesity is the leading cause of major health conditions including Type 2 diabetes, stroke, cardiovascular disease and a number of cancers.

Figures produced by the Audit Office suggest that it may be our youngest members of society who face the biggest impact on their long-term health and wellbeing. The Auditor General released a report (November 2022) which calls for a review of Welsh Government policy to tackle the cost-of-living crisis and that 34% of children in Wales are living in severe poverty in Wales. This is further compounded by food prices rising steeply by 15% over the last year. The Food Bill is a key measure to address and support Wales’ recovery from food poverty and support the Wellbeing of Future Generations Act.

This perfect storm of rising rates of obesity and related comorbidities, compounded by potential food poverty for many of our population will result in increased poor health, morbidity and mortality with a huge increase in burden on our already overstretched health service.

Food goals and targets

The British Dietetic Association (BDA), support the inclusion of food goals as a means to underpin objectives.  If goal terminology is to be used as part of the bill and associated secondary legislation/ regulations, we suggest it would be best practice to adopt the same terminology, structure and purpose across all food goals. The goals must align with other relevant legislation and policy and have a SMART goal principles in order to be actionable.

As the Bill goes onto explain that there will be ‘targets’ flowing from the secondary food goals and we are concerned that there a risk of creating too many tiers/steps across the Bill’s documentation. We advocate a simple and seamless approach to the goals.

It would be helpful to quantify how ‘reasonable’ might be measured in ‘Public bodies must take reasonable steps to advance the primary food goal and the secondary food goals’?

We agree with the inclusion of primary and secondary goals, however suggest that the primary goal described in part 1 section 6 becomes an overachieving aim (as opposed to goal) beneath which there would be the more specific, secondary goals (akin to well written objectives). This allows more detailed and actionable targets throughout.

The British Dietetic Association (BDA) ,  agree with the areas identified and suggest further

•           Consider food advertising within the bill, the majority of food advertising is for less healthy foods and paid for by large companies.  Locally grown, unprocessed, fruits, vegetables, grains, meats etc do not receive the same advertisement and recognition yet are often healthier the healthier options and more sustainable.

•           Environment/ food waste areas – should these be combined.

•           Employ a joined-up approach with the Healthy Weight: Healthy Wales Healthy Food Environment goals

•           Audit the success of new and existing legislation e.g. Healthy Eating in Schools (Wales) Measure

•           Meeting food standards in all early year’s provision, educational establishments for children and young people should be a priority in line with UN Rights of the Child and The Wellbeing of Future Generations Act.

 Targets are necessary to measure outcomes and ensure advancement of goals, however we are concerned about the statement ‘Before making regulations which set or amend a target, the Welsh Ministers must be satisfied that the target, or amended target, can be met’. This implies that only achievable targets will be set. Whilst it is clearly not appropriate to set unachievable goals, goals should be aspirational and sufficient bold to allow advancement of the food agenda in Wales. Dietitians are key stakeholders in the development, setting and evaluation of national and local goals.

We support the requirement for an independent element and those with relevant expertise in setting targets but achievability and relevance of any targets set must be considered and be supported by all relevant parties.

We would like further clarity around reporting dates: Ref 36 in the consultation document- what might be the frequency for statements to be published?. We advocate an earlier review timescale with more frequent interim auditing supporting 5 yearly formal reviews.

Welsh Food Commission

The British Dietetic Association (BDA),  support the goals and function of a Welsh Food Commission to provide oversight of the Food Goals. However the functions are very broad and  the Bill lists as a two-part objective plus functions - not goals so we would advise this is revied for consistency of terminology.  We feel it is essential that public bodies will need to fully understand level of oversight of local plans, support available and level of scrutiny that the commission will provide.

 We suggest that the membership should comprise adequate and appropriate representation from all sectors ( both public and private)  and be mindful and transparent of any conflicting interests. Members need to be representative of their sectors and have an established means of communication to ensure views are reflective of the sector as a whole.  The Food Commission should have a strong nutrition representation and lead which is best provided by a Registered Dietitian.  We note, however,  that the Bill mentions that a local health board representative cannot be on the commission and therefore we seek clarification on this point as many of our expert Dietitians are NHS employees. The timescale for terms of office of member are appropriate and fit well with the formal review schedule.

The British Dietetic Association (BDA),  note that the Bill appears to detail remuneration/ allowances  these should be in keeping with other similar public duties. Members will also require the support of own employing organisation. We suggest hybrid of face to face and digital working would minimise expenses and maintain engagement. Renumeration should be appropriate to role and equitable in line with time commitment and workload.

National food strategy

The  British Dietetic Association (BDA)  strongly agree with the need for a National Food Strategy. The strategy should align with legislation in Scotland and England and link food related policies across many areas including health and social care, education, local authorities.

Regarding ref 62 in the consultation document – specified public bodies required to have regard / exercise functions related to primary food goal. We are keen to see more detail on how the Bill will engage the private sector including industry, retailers and manufacturers.  Influencing Welsh businesses can be done with this legislation but has consideration been given to implementation of certain approaches in Wales when a parent company (lying outside of Wales) can follow different guidance across the border? We would like to understand further the reach and scope of the strategy.

Currently we, feel there is disparity between initiatives that impact food in Wales. We agree with reference 17 in the consultation document that this Food Bill should be joined up with the Agricultural (Wales) Bill – all efforts should be employed to achieve this and indeed with any new or revised policies that are cross cutting. The food strategy underpins preventative actions in A Healthier Wales and the NHS Clinical Framework. Poor diet is a major cause of avoidable ill health and the Healthy Weight: Healthy Wales strategy and the All-Wales Diabetes Prevention Programme are examples of how Welsh Government supports a shift in amendable risk factors. The food strategy must give sufficient recognition/value of its role and purpose in this regard.

The  British Dietetic Association (BDA)   suggests that as a key part of implementation Welsh ministers have a directly accessible source of advice from key experts, community- based organisation representatives and professional bodies. The provision of a representative advisory committee will be key to the success of implementation. As part of this, 12 month interim progress reports would be helpful in ensuring momentum in the initial establishment period. The reports should be inclusive and appropriate for all stakeholders including the lay person. Regarding ‘assessing the effectiveness of the national food strategy’ at these reporting periods, we are keen t understand what actions would be undertaken if there has been little or no positive effectiveness evidenced?

The British Dietetic Association (BDA),  would like to see further detail about the planned lifespan of the strategy and suggest 5 yearly full review is appropriate of, like the Healthy Weight, Healthy Wales strategy the operational timescale is 10 years. As this bill has received cross party support can there be some commitment made to ensure the strategy is refreshed and updated for a further tenure? The issues outlined within this Bill will not be ‘fixed’ in the short to medium term; they will require an ongoing commitment to achieve longer-term change.

We agree with the overriding principle of a National Food Strategy and suggest further:

The National strategy should:

•           acknowledge and support strategies to address population nutrition knowledge and skills alongside food availability and provision as part of the whole systems approach.

•           recognise that there may be resource implications to ensure that the right expertise is utilised

•           reprioritise secondary food goals to ensure ‘economic’ be appropriately allocated priority

Local food plans

The British Dietetic Association agree the need for local food plans and through the Dietetic workforce we know that many projects already exist independently at local levels. It is vital that the Bill allows liaison with these providers and ongoing support of these projects will be essential, for example local community fridges to support at risk families and reduce food waste. Further, funding into education and providing greater knowledge and awareness of healthy and sustainable diets through all life stages will support the aim and proposals made. We welcome that this intrinsically included as part of the food goals. This should also be acknowledged throughout the Bill and associated documentation as a key element supporting the public in making healthier and more sustainable food choices. It needs to align to the new curriculum in Wales for young people but should not be exclusive to this.

An example of a Dietetic lead initiative working locally is Nutrition Skills for Life TM   Nutrition Skills for Life® . This is an established and trusted network of Public Health Dietitians working across Welsh health boards, providing high quality food and nutrition skills training, expert advice and network opportunities that support the wider community workforce and community to engage in and adopt healthier eating practices. 

Local food plans will ensure locally driven actions and priorities that take account of community needs assessments and engagement whilst ensuring alignment to the national strategy and Bill. Access to assets and resources (both positive, i.e. easy access to outdoor spaces, and negative e.g. abundance of cheap takeaways within walking distance) varies significantly within a given location in Wales; consideration is required for ensuring equitability for capacity to compile and act on information across all areas. Further detail is required with regards to the development of the local food plans, will this make the use of public service boards?  We suggest consideration of whether there will be additional financial support to ensure there is sufficient resource and capacity to allow successful implementation.

We suggest that local consultation with relevant organisations, professionals and communities is essential as experts in their fields to enhance the information accrued from the commission. The proposed timescales for implementation seem fair, however would question the necessity for each public body to consult with the commission prior to making a report against their local food plan? What may be more helpful is for the commission to provide some guiding principles or a framework by which they would like to receive the report.

The  British Dietetic Association (BDA) suggests:

•           Ministers should consider Local food plans will likely require investment and this funding will need to be considered, while some projects exist in some areas they do not in all, therefore current provisions across Wales are not equitable.

•           An all Wales template and toolkit for developing a local food plan would be useful to support public bodies development and leadership of the strategy.

General matters including meaning of terms, regulations, interpretation, and commencement

British Dietetic Association (BDA seek further clarification within the Bill around when or how stakeholders including  industry, retailers, producers and  manufacturers might be engaged in discussions around the food strategy and the evolving work around the food system.

We welcome this Bill and would advocate an early commencement, particularly given the current economic crisis, food poverty and global food supply disruptions and shortages .

Any potential barriers to the implementation of the Bill’s provisions and whether the Bill takes account of them;

Capacity to support local plans may prove challenging in some areas of Wales, for example in North Wales BCUHB serves 6 LA areas, if each derive their own local plan health board staff may struggle capacity-wise to support all areas. We would welcome recommendations/ guidance around scope for developing local plans?

Having local plans is important however, resources are stretched everywhere and so national strategy that includes key aspects such increasing food and nutrition education within schools (at various ages) is important. Positive national strategies set the tone for what can be reflected within local strategies.