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Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens submission

This submission reflects the views of
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Public Health Section

Research Translation Group

NHMRC GPO Box 1421



31 October 2012

Dear Sir/Madam,

Public Consultation on draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens

 Thank you for the opportunity to comment on the NHMRC’s draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens.

The Victorian Health Promotion Foundation (VicHealth) was established by the Victorian Parliament (in accordance with the Tobacco Act 1987) with a mandate to promote good health for all Victorians. Our health promotion investments target the greatest preventable risk factors for ill health, including poor nutrition and the harmful use of alcohol, and the social, cultural and environmental conditions that influence them.

VicHealth recognises that poor diet and nutrition lead to ill health and premature death, and thus has the strategic objective to increase optimal nutrition for all Victorians. It is understood that the factors that influence food choice are complex and often beyond the control of individuals, and as such VicHealth takes a broad approach to the issue by looking at the barriers that prevent people from accessing nutritious food for healthy eating. VicHealth’s nutrition investments are targeted at food system wide factors including: a secure supply of healthy food; access to healthy food; and a culture that supports the consumption of healthy foods.

VicHealth agrees that “the sustained good health of any population depends on reliable access to basic resources such as food, water, shelter and energy” as recognised in the Government’s own report on climate change and health (Hughes & McMichael 2011). As such, VicHealth is concerned about the environmental impacts of the food system on the sustainability of a food supply that is nutritionally adequate, equitable, and promotes good health for all.  We expressed our disappointment of the apparent downgrading of this issue in our original submission on the Draft Australian Dietary Guidelines (ADGs) and the Australian Guide to Healthy Eating (AGHE), in February this year.

VicHealth is thus pleased to see the addition of the ADGs through an environmental lens and are generally supportive of the content of the draft Appendix G. VicHealth is particularly supportive of the addition of the practical environmental considerations of the Guidelines and the practical tips outlined in G4.

However, VicHealth is very disappointed that the detail relating to the environmental aspects of food choice is contained within an appendix, essentially giving it lesser importance than other dietary considerations. 

A healthy environment is essential for good health

A secure supply of nutritious foods is a key determinant of food choice and dietary behaviour, thus ensuring our environment can sustainably provide such a supply is essential to food security and public health. As noted in the NHMRC’s draft Appendix to the ADG’s, the relationship between food systems and environmental degradation is bi-directional, with environmental threats impacting on our food system, as well as our food system (influenced by dietary patterns) threatening the stability of our environment. There are sound links between dietary patterns that are healthy and those that are environmentally sustainable. Just reducing the total amount of energy consumed and consuming less processed foods within the population has the potential to significantly reduce the use of fossil fuels in the food system (Pimentel et al 2008).

Ensuring the Dietary Guidelines are considerate of the impacts dietary patterns have on our environment is very much in keeping with their stated purpose, being to “...have information about the types and amounts of foods, food groups and dietary patterns that aim to:

  • promote health and wellbeing;
  • reduce the risk of diet-related conditions, such as high cholesterol, high blood pressure and obesity; and
  • reduce the risk of chronic diseases such as type 2 diabetes, cardiovascular disease and some types of cancers.” (NHMRC 2012)

In light of the threats our dietary patterns and food system pose on the environment, Dietary Guidelines which do not take environmental considerations into account in a meaningful way will not sustainably promote health and wellbeing.

Thus it is recommended that the important environmental considerations of Australia’s food system are made an integral part of the Dietary Guidelines and not just considered as a lens in which to view them in an appendix.

In addition we would like to make several recommendations for further development of the application of an environmental lens to the ADGs and the AGHE, as follows:

G1 - Background

  • To provide relevant context to the background of why environmental considerations have an important and pertinent place in the dietary guidelines, greater documentation needs to be given to the relationship between health and the environment upfront.
  • The reference to “new, often narrative evidence” around the environmental implications of food choices appears to be pejorative and thus downgrades the evidence in this area and should be reconsidered.
  • Whilst the reference to the “rudimentary” measurement of the environmental impact of production and processing methods of the food industry may be true in some instances, it is not just the production and processing of food but the entire food system (as is rightly noted in the Figure), from production to consumption, which impacts on the environment and of which measurements are undeveloped.

G1 - Figure

  • This is a good illustration of the environmental impacts of the food system, but could we suggest that: 1) that the ‘system’ is better represented rather than a purely linear depiction; 2)  ‘machinery’ is added as an input to agriculture; 3) ‘nutrient loss’ is added as an impact of agriculture; 4) a definition/clarification is given for ‘energy’ and difference between this and ‘fuels, oils’; 5) the figure is labelled appropriately to highlight the use of/input of resources and outputs/environmental impacts.

G2 – The nature and challenges of the evidence

  • Whilst we agree that there are some challenges relating to the evidence in this area, it is worth noting that challenges and flaws also exist within the methodologies used to study nutrition science, which has been developing for over 50 years. In the case of the evidence relating to environmental impacts of food, the precautionary principle should apply. In order to protect the environment, the Rio Declaration on Environment and Development (UN 1992) applies a precautionary approach in Principle 15, stating that cost-effective measures to prevent environmental degradation shall not be postponed due to a lack of scientific certainty when there are threats of serious or irreversible damage. Such an approach would suggest decisions around the environmental considerations of the dietary guidelines should be made when there is a possibility of harm (to the public or the environment) even when extensive scientific knowledge on the matter is lacking.

G3 - The Guidelines through an environmental lens

Guideline 1

  • Whilst avoiding “over-consumption of food and drinks” has a sound basis in terms of health and environmental considerations, this guideline should in particular address avoiding over-consumption of highly processed, highly packaged, energy-dense nutrient poor foods and drinks. These foods are typically associated with negative health implications (often providing limited nutritional value and being high in fat, sugar, salt and/or energy), and  unnecessary/adverse environmental impacts, due to the additional use of resources and outputs associated with their processing, packaging and waste disposal, compared with the production and consumption of foods from the five food groups. The environmental burden of these products is demonstrated in the Appendix in Figure G1 and in the reference to discretionary choices in Key references G5.

Guideline 2

  • As well as choosing “a variety of seasonal and local fresh fruit and vegetables to reduce environmental impact”, Australians could also be encouraged to grow their own.
  • The reference to “choose protein sources that have a lower environmental impact, such as pork, poultry, eggs, tofu, tempeh, nuts and seeds, and legumes/beans” should place a greater emphasis on the plant sources of protein as being the best choice in terms of their impact on climate (in terms of GHG emissions) and health benefits. E.g. order the food items in terms of their dual-benefits, i.e. plant-based protein sources followed by eggs, poultry and pork.
  • As noted in our previous submission all recommendations for food groups should be described with quantifying words, as has been done with “plenty of vegetables”. Thus practical consideration could be given to the amount of animal protein versus vegetable protein which could be recommended, based on their beneficial impacts on health and the environment.
  • The reference to choosing fish and other seafood from “stable stocks” deserves further of clarification if this guideline is to be of practical significance for the general public.

Guideline 3

  • Quantifying language used in the environmental considerations should remain consistent with that used in this guideline, thus “avoiding foods” should be replaced with “limiting foods”.
  • The term “highly processed” foods should be added to include those foods which aren’t snacks or sweet foods, such as ready-to-eat meals, soups and sauces, but are still high in saturated fat, added salt and/or sugar and have much higher environmental impacts through their production than whole foods.
  • The environmental impacts caused by not only the production, but also the packaging and waste disposal of highly processed foods should also be noted in this guideline.

G4 – Practical tips

  • To ensure both the public and health professionals can use these tips, they should be incorporated into a consumer-friendly resource as part of the AGHE. As noted in our previous submission, the AGHE needs to provide pictorial guidance, serving size suggestions, examples of daily dietary patterns and a suite of resources that meet the needs of different users.
  • “Buy and consume foods and drinks that are consistent with the Australian Dietary Guidelines” - Whilst a diet consistent with the ADGs is quite sensible from an environmental perspective, the extra guidance given in the Appendix is even more relevant for those wishing to consider the environmental impacts of their dietary choices. The wording of this tip should thus indicate this extra guidance, e.g. ‘Buy and consume foods and drinks that are consistent with the Australian Dietary Guidelines and the environmental lens considerations found in Appendix G’.
  • “Consider what you buy: avoid overbuying and overconsumption of food”  - again avoiding the over-consumption and overbuying of highly processed, highly packaged, energy dense nutrient poor food and drinks should be emphasised here. The addition of ‘particularly highly processed, highly packaged, energy dense and nutrient poor foods and drinks’ could be added to this tip.
  • “Minimise waste” – could also encourage recycling food waste through methods such as composting, worm farming, or keeping chickens.

G5 – Key references

  • The inclusion of a summary of the evidence and key references used to inform these guidelines is useful however it would be more valuable to see a complete evidence review provided here. In addition, more detail about the actual evidence found would be more useful than the current suggestion that the reader consults the references themselves to get more information.

We appreciate the work the NHMRC has done in addressing the evidence, and the significant concerns expressed in the earlier public consultation to the Australian Dietary Guidelines, about the environmental perspectives of Australian dietary intakes. We are hopeful that the arguments proposed for inclusion of the appendix into the main document as well as the other considerations outlined in this submission are successful to ensure the next iteration of the ADGs and the AGHE are explicit in relation to the crucial part our environment plays in ensuring our current and future food system can provide health for all and the part our dietary choices play in protecting the environment.

If you have any questions about the submission or need any further information, please contact ................. or email at ...........@vichealth.vic.gov.au

Yours sincerely

Jerril Rechter


Victorian Health Promotion Foundation (VicHealth)


Hughes, l, and McMichael, A.J, (2011), The Critical Decade: Climate change and health, The Climate Commission Secretariat, Department of Climate Change and Energy Efficiency, Commonwealth of Australia.

NHMRC, (2012), Frequently Asked Questions about the revision of the Australian Dietary Guidelines, Review of the Dietary Guidelines, National Health and Medical Research Council website, Australian Government, Available at < http://www.nhmrc.gov.au/your-health/nutrition/review-dietary-guidelines>, Viewed 17 November 2012.

Pimentel, D, Williamson, S, Alexander, CE, Gonzalez-Pagan, O, Kontak, C and Mulkey, SE, (2008), Reducing Energy Inputs in the US Food System, Hum Ecol, 36:459–471.

United Nations, (1992), Report of The United Nations Conference On Environment And Development, Rio de Janeiro, Available at <http://www.un.org/documents/ga/conf151/aconf15126-1annex1.htm>, Viewed 17 October 2012.

Page reviewed: 4 February, 2013