NHMRC Public Consultations

Skip Navigation and go to Content
Visit NHMRC website

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

ID: 
32
This submission reflects the views of
Organisation Name: 
Meat & Livestock Australia
Please identify the best term to describe the Organisation: 
Non-Government Organisation
Personal Details
General Comments
Comments: 

Meat and Livestock Australia

 

 

SUBMISSION

 2 November 2012 

To: National Health and Medical Research Council

 In response to: Draft Australian Dietary Guidelines, Appendix G,

Australian Dietary Guidelines Through An Environmental Lens

 Contact:

Veronique Droulez

Marketing Manager - Nutrition

Preface

Meat and Livestock Australia (MLA) welcomes the opportunity to comment on the National Health and Medical Research Council’s (NHMRC) Appendix G. Australian Dietary Guidelines through an environmental lens.

Meat and Livestock Australia (MLA) is a marketing and research delivery company for the beef, sheep and goat meat industries. We are primarily funded by levies on farmers and government contributions for our research and development portfolio.

Sustainability is a serious concern for these industries and every aspect of our work is geared to delivering world-class services and solutions for a profitable and sustainable beef, sheep and goat meat and livestock industry.

Through MLA, the Australian cattle and sheep industry invests over $13 million annually in research and programs aimed at improving and encouraging the adoption of more sustainable practices. These practices aim to reduce the environmental impact of production and processing by reducing the depletion of natural resources and reducing their contribution to greenhouse gas emissions, whilst ensuring the economic and social sustainability of the industry. 

Research has enabled the industry to adapt to changes in climate variability, water availability and changed landscapes. As caretakers of nearly half (47%) of Australia’s landmass, cattle and sheep farmers aim to continually improve their sustainable farming practices to ensure they continue to produce food sustainably in a changing environment for the world’s growing population.

The livestock industry has made a significant contribution to emissions mitigation in Australia. Since 1990, emissions from beef production in Australia have decreased by 6.5% per kilogram (calculated from Australian Government national emissions data for 2007 and beef production data from the same year).

As a major exporter, the beef, sheep and goat meat industries make an important contribution to global food security as well as the Australian economy, particularly in rural and regional Australia.

Executive summary

The primary purpose of the Australian Dietary Guidelines is to “provide recommendations on healthy eating that are realistic, practical and most importantly, based on the best available scientific evidence” to promote health and wellbeing and prevent chronic disease[1].

Advice in Appendix G should therefore be consistent with these principles to avoid compromising adoption of healthy eating patterns required to promote health and wellbeing.

MLA is concerned that information included in the Appendix risks undermining the credibility of the Australian Dietary Guidelines as an evidence-based guide to healthy eating because:

Advice in Appendix G3 is inconsistent with the recommended amounts of foods indicated in the Modelling System and may compromise nutrient intakes:

  • Advice to “choose protein sources that have a lower environmental impact” which excludes beef and lamb is inconsistent with their role as a source of iron and zinc in the Modelling System (Foundation Diet includes approximately 400g/week of beef and lamb).
  • Since there is evidence which suggests young females, who are at risk of iron deficiency, need to eat more red meat, this discrepancy could cause confusion and compromise their nutrient intake. 

 “Practical considerations” are not based on evidence and may be misleading:

  • There is no evidence supporting the environmental benefit of practical considerations for Guideline 2 within the Australian context.
  • There is insufficient evidence to conclusively state that specific food choices have a lower environmental impact. Evidence is evolving and the environmental impact of foods varies considerably between regions. Furthermore, there are many environmental impacts and it is dangerous to base recommendations on a single indicator.      
  • The available evidence suggests that the most effective dietary strategy for reducing the environmental impact of food is to reduce overconsumption and household waste from the total diet rather than target selected foods as per practical considerations for guidelines 1 and 5.

 The narrow approach is inconsistent with the approach of other stakeholders along the supply chain and may result in perverse outcomes:

  • The practical considerations ignore efforts by other sectors who are focusing on improving efficiencies throughout the supply chain and who consider sustainability from a much broader perspective in order to avoid the risk of burden shifting or adversely affecting other aspects of sustainability.
  • It does not provide practitioners with an understanding of the issues and evidence base and hence how they can make a meaningful contribution to reducing the environmental impact of the food system as part of their core nutrition-related practice.

Recommendations 

1. Remove the practical consideration next to Guideline 2 in section G3 to “choose protein food sources which have a lower environmental impact” since:

a) There is no evidence that this advice has an environmental benefit.

b) There is no evidence to conclusively state which protein foods have a lower environmental impact.

c) Contradicts the amounts of foods required to meet nutrient requirements indicated in the Modelling System.

2. Amend Guidelines 2 to promote consumption of core foods in amounts consistent with energy and nutrient requirements as indicated in the Modelling system.

3. Amend Guideline 3 to prioritize consumption of nutrient-rich foods over energy-dense, nutrient poor foods

4. Maintain practical considerations next to Guideline 1 and 5 only

a) Promoting efficient consumption by reducing overconsumption and household waste will improve the efficiency of the whole supply chain thereby complementing efforts by other sectors.

 5. Amend Practical tips in G4 should focus on strategies for reducing overconsumption and household food waste including:

a) Practical advice on how to prepare meals using nutrient-rich foods in amounts consistent with energy and nutrient requirements; and

b) Food purchasing, preparation and storage tips for minimising food waste.

6. Rewrite sections G1 and G2 with the assistance of experts from relevant government and industry organisations to:

a) Provide public health and nutrition practitioners with a good understanding of the issues; and

b) Place their role in reducing the environmental impact of the food system in context with other key stakeholders and initiatives in the supply chain and which reflects their core business.

7. Remove section G5 and include references as part of the discussion in G1 and G2, consistent with the rest of the draft dietary guidelines.

1.       Introduction

The main purpose of the Australian Dietary Guidelines is to “provide recommendations on healthy eating that are realistic, practical and most importantly, based on the best available scientific evidence” to promote health and wellbeing and prevent chronic disease[2].

 To avoid confusion and facilitate achievement of public health outcomes, advice in Appendix G should be consistent with these principles. In particular, it should:

  • Be consistent with recommended amounts of foods indicated in the Modelling System
  • Be informed by the best available scientific evidence

 2.       Inconsistent with Modelling System and may compromise nutrient intakes

The “practical consideration and environmental benefit” indicated in G3, Guideline 2 is to “Choose protein sources that have a lower environmental impact, such as pork, poultry, eggs, tofu, tempeh, nuts and seeds, and legumes/beans. Choose fish and other seafood from stable stocks”. Beef and lamb are excluded from this list which suggests that their consumption is not recommended.

There is good evidence that beef and lamb are important sources of iron and zinc in the Australian diet:

  • The Modelling System[3] acknowledges the contribution of beef and lamb makes to intake of bioavailable iron and zinc as well as LCn3 in the Australian diet and consequently, approximately 400g/week of trimmed beef and lamb were included in the Foundation Diet.
  • The benefit of meat’s superior iron and zinc bioavailability is well established with low meat intake shown to be the only dietary predictor of iron deficiency in women[4].

 There is evidence of iron deficiency in young women, particularly in those that restrict meat intake:

  • Iron deficiency is common in young women with between 16.9 to 34% with low iron stores[5],[6].
  • Young women who are restrained eaters (due to dieting) restrict meat intake and were shown to have lower iron status, despite similar dietary iron intakes6.
  • Furthermore, beef and lamb consumption in Australian girls, 9 to 16 years is associated with healthier eating patterns, including increased vegetable consumption[7].

The implication that the exclusion of beef and lamb will reduce the environmental impact of the food system risks not only compromising nutrient intake and potentially vegetable intake, particularly in vulnerable population groups in Australia, it also risks causing confusion since this advice is inconsistent with the suggestion that young females need to eat more red meat in other parts of the document2.

 3.       No evidence of an environmental benefit

The following available evidence suggests that the most effective dietary strategy for reducing the environmental impact of food is to reduce overconsumption and household waste from the total diet rather than target selected foods.

  • Whilst various studies have reported a higher greenhouse gas (GHG) impact of meat-based diets compared to plant-based diets, the impact of replacing meat with lower impact foods in self-selected diets has been shown to be modest[8]. This is because diet-associated GHG impacts have been shown to be most strongly associated with the total quantity of food and energy consumed. Reducing caloric intake to meet individual energy needs could reduce diet-associated GHGE by approximately 2.4%8.
  • Since energy intakes are increasing globally with the greatest increases from vegetable sources in both developing and industrialised countries, this focus on reducing intake of animal food sources alone is unlikely to be effective[9].
  • Household food waste represents the total loss of the product’s nutritional value and the natural resources required throughout the entire production process, and consequentially, have a greater GHG impact than waste earlier in the production chain, particularly in the Australian context[10].
  • Reducing overconsumption and household food waste and ultimately obesity, reduces GHG impact at many levels, including resources required to produce wasted food; household waste; and emissions from transport[11]. Gryka showed that a 10 kg weight loss of all obese and overweight people would result in a decrease of around 0.2% of CO2 emitted globally in 2007[12].

There is no evidence that choosing the protein food sources indicated in G3, instead of beef and lamb, will deliver an environmental benefit within the Australian context, particularly when other environmental and food security issues are considered, such as competition for arable land.

  • Current assessments of the environmental impact of food production are limited to GHG emissions and water and do not consider the impact on other environmental factors relevant to food security.  Besides GHG emissions, the impact on water stress and use of fossil fuel and phosphorous of Australian beef and lamb production systems is moderate to low and the cattle and sheep industries provide important ecosystem services[13].  A thorough assessment of environmental benefit should consider the unique ability of ruminants to produce nutritious food using non-arable land and converting human inedible inputs into human edible outputs is unique and critical for food security, particularly in Australia where arable land is scarce[14].
  • Considering the decreasing availability of arable land and the increasing demand for food globally, strategies which improve production efficiency and reduce waste of finite resources; increase intensification of agriculture; and use of non arable land for grazing are more likely to be effective than changing consumer food choices14,[15]. The impact of improving production efficiencies for climate mitigation, without reducing total production, is evident in Australia where production efficiencies have delivered a 5.3% reduction in emissions per tonne of beef produced[16].

 It is misleading to conclusively state that the protein sources indicated in G3 have a lower environmental impact.

  • Evidence for many foods in the Australian context is lacking, making it impossible to conclusively state that the foods indicated have a ‘lower environmental impact’.
  • Furthermore, environmental impacts of food production varies considerably both between regions and even within regions and many of the foods recommended are imported from countries with different environmental standards, particularly in relation to land-clearing (for cultivation of crops such as soy, a common feed for pork and poultry production) which has significant environmental impacts.
  • Existing evidence may change due to the evolving nature of the evidence base as well as the dynamic nature of food production systems10. For example, research released by CSIRO in 2011 found the amount of methane emitted from cattle fed on tropical grasses in northern Australia is up to 30% less than the figures currently used to calculate the northern cattle industry’s contribution to Australia’s GHG accounts. In addition, the current international Kyoto Protocol carbon accounting system does not fully account for the capacity of trees, grass and soil to store carbon as part of the carbon cycle. A Queensland Government funded study found that if all carbon sinks were taken into consideration, the Queensland beef industry (47% of Australia’s cattle) would be close to carbon neutral, following the ban on tree clearing in 2009.

There is no evidence of environmental benefits of choosing seasonal, local and a variety of foods within food groups. Benefits associated with affordability, access and health should not be confused with environmental benefits.

 There is clearly no evidence to support the practical considerations and environmental benefits suggested in G3, other than for Guideline 1 and Guideline 5.

 Practical considerations for Guidelines 2 and 3 should be amended to be consistent with the foods and their amounts recommended in the Modeling System.

 

Recommendation

Remove   the practical consideration next to Guideline 2 in section G3 to “choose protein   food sources which have a lower environmental impact” since:

  1.   There is no evidence that this advice has an   environmental benefit
  2.   There is no evidence to conclusively state   which protein foods have a lower environmental impact
  3.   Contradicts the amounts of foods required to   meet nutrient requirements indicated in the Modelling System

 

Amend   Guidelines 2 to promote consumption of core foods in amounts consistent with   energy and nutrient requirements indicated in the Modelling System and Guideline   3 to prioritize consumption of nutrient-rich foods over energy-dense,   nutrient poor foods

Maintain   practical considerations next to Guideline 1 and 5 only which are consistent   with the best available scientific evidence.   

4.       Inconsistency with the approach of other stakeholders

The information provided in G1 and G2 is confusing and indicates a lack of understanding of the issues and evidence within the broader context of the supply chain which is informing decision-making at a national and global level. In addition, it does not reflect the core business of the majority of practitioners.

To make a meaningful contribution to reducing the environmental impact of the food system, the appendix should provide practical advice that practitioners can realistically adopt as part of their practice. In addition, it should provide practitioners with some understanding of their role within the broader food system and the evidence underpinning the advice given.

The broader context of the food system

The Appendix should consider the following issues within the context of the broader supply chain:

  • The background information in G1 ignores the enormous investments and achievements by government and industry organisations towards improving the sustainability of the Australian food supply. Consequently, there appears to be a lack of awareness that the key focus of government and industry initiatives is around improvements in efficiencies throughout the supply chain, since this is considered the most effective strategy for reducing the environmental impact of the food system without compromising its sustainability.
  • The focus on a narrow set of environmental outputs disregards the need to consider the economic and social aspects of sustainability. It provides no appreciation of the global nature of the food system and its impact at the local level. Consequently, there is no appreciation that alignment between initiatives aimed at reducing the environmental impact throughout the supply chain is necessary to achieve meaningful price signals – a key driver of change.

Understanding the evidence base

The discussion on the evidence base suggests ignorance of the evolving and complex nature of the evidence base and in particular, how it should be interpreted. This is particularly reflected in the statement “Despite the above challenges, enough evidence exists to begin developing informed, pragmatic and guiding principles to reduce the environmental impact of the food system”.

This statement is at odds with experts in sustainability who suggest caution when making judgements based on limited evidence. Importantly, it ignores the need for consequential studies to consider the potential for negative trade-offs resulting from changes in the food system.

Role of practitioners

Results from a survey amongst a representative sample of dietitians in Australia (n=328) on their use and understanding of sustainability in their practice, conducted by Deakin University and funded by MLA found that respondents had a narrow understanding of sustainability and of the food system. This is because their core business relates to the promotion of healthy eating which is mainly focused at the household level. Dietary strategies for reducing the environmental impact of the food system must therefore be consistent with their core business. 

Considering the evidence base; the role of practitioners; and the broader context of the food system, the most meaningful contribution that practitioners can make to reduce the environmental impact of the food system is to focus on reducing overconsumption and household food waste by providing practical advice aimed at improving the efficiency of food consumption. Practical advice on how to prepare meals using nutrient-rich foods in amounts consistent with energy and nutrient needs and ways in which to purchase, prepare and store foods will contribute to improvements in efficiencies throughout the supply chain, thereby complementing initiatives by other sectors.

Recommendation

Practical   tips in G4 should focus on strategies for reducing overconsumption and   household food waste including:

  1.   Use of nutrient-rich foods in amounts   consistent with energy requirements; and
  2.   Food purchasing, preparation and storage   tips for minimising food waste.

Rewrite   sections G1 and G2 with the assistance of experts from relevant government   and industry organisations to:

  1.   Provide public health and nutrition   practitioners with a good understanding of the issues; and
  2.   Place their role in reducing the   environmental impact of the food system in context with other key   stakeholders and initiatives in the supply chain

Remove   section G5 and include references as part of the discussion in G1 and G2,   consistent with the rest of the draft dietary guidelines.

 

 

 

 




[1] Australian Dietary Guidelines, draft for Public Consultation, December 2011, p.2

[2]NHMRC.Australian Dietary Guidelines, draft for Public Consultation, December 2011, p.2

[3]NHMRC A Modelling System to inform the Revision of the Australian Guide to Healthy Eating, 2011

[4]Heath AL, Skeaff CM, Williams S, Gibson RS.The role of blood loss and diet in the aetiology ofmild iron deficiency in premenopausal adult NewZealandwomen.Public Health Nutr.2001; 4:197–206.

[5]Fayet F, Samman S. Eating behaviour andbiomarkers of nutritional status in femaleuniversity students. Nutrition Society of Australia Abstracts 2007.

[6]Cheng HL, Bryant CE, O’Connor HT, et al. Ironstatus of overweight and obese young womenpresenting for weight management (awaiting publication).

[7]Grieger J.A., Scott J, Cobiac, L. “Cluster analysis and food group consumption in a national sample of Australian girls.” Journal of Human Nutrition and Dietetics, (2011).

[8] Vieux F, Darmon N, Touazi D, Soler LG. Greenhouse gas emissions of self-selected diets in France: Changing diet structure or consuming less? Ecological Economics 2012;(75):91-101

[10] Place SE, Mitloehner FM. Beef production in balance: Considerations for life cycle analyses. Meat Science 92 (2012): 179-181

[11]MichaelowaA, Dransfeld B. Greenhouse gas benefits of fighting obesityPaper 4-8 by the  HWWI Research Programme International Climate PolicyHamburg Institute of International Economics (HWWI) | 2006 ISSN 1861-504X

[12]Gryka ABroom JRolland C. Global warming: is weight loss a solution? Annu Rev Public Health. 2011;32:179-97

[13] Ridoutt B, Sanguaransri, Freer M, Harper GS. Water footprint of livestock: comparison of six geographically defined beef production systems. Int J Life Cycle Assess (2012);17:165-175

[14] Gill M, Smith P, Wilkinson JM. Mitigating climate change: the role of domestic livestock. Animal (2010);4(3):323-333

[15]FAO (2011).World Livestock 2011- Livestock in food security. Rome: Food and Agriculture Organization of the United Nations

[16] Calculated using 2010 beef production data from MLA and from the 2009 National Greenhouse Gas Inventory

Page reviewed: 4 February, 2013