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

This submission reflects the views of
Individual Background: 
Private individual/non affiliated
Personal Details
First Name: 
Last Name: 
General Comments

Note: numerical references pertain to the NHMRC’s full reference list (from October 2012).


In general, the draft Appendix G requires reworking so it can provide a more useful guide to practitioners in supporting individuals with positive guidance that who, for whatever reason, wish to reduce or eliminate foods that have high actual or unacceptable perceived environmental costs associated with their production and consumption.

In am looking forward to the NHMRC providing leadership on what is an important opportunity to include in this Appendix (if not detailed elsewhere in the Guidelines) suitable food pyramids/plates that are both solely plant-based (i.e. vegan) and acknowledge a general vegetarian diet. The basis for this is that plant-based diets generally do offer the lowest environmental impact from ‘farm to fork’, as I seek to briefly indicate below.

There has been an Australian and global movement towards more sustainable food supply, which is often linked to an environmental or animal rights ethic from a consumer point of view (examples, while perhaps biased, are summarised in Powell 2009, but see also Public Health Association of Australia 2012 and Biological Farmers of Australia 2012), but which is also reflected on the supply side with various certification labeling schemes (i.e. ‘organic’, ‘GMO-free’ etc.), corporate policies and similar effort to market ‘green credentials’. This said, I recognise that only 4% of respondents to the National Nutrition Survey that was executed in 1995 described themselves as vegetarian or vegan [46]. However, if we are to assume similar trajectories between Australia and the US, then the Academy of Nutrition and Dietetics claim in 2009 that “The number of vegetarians in the United States is expected to increase during the next decade” [358] should be considered and perhaps it would be found that since the 1995 ABS survey the number of vegetarians in Australia has increased (and will continue to increase), so such dietary patterns should be considered and recognised.

Although not possible for me to do here, it would be instructive to meld the economic cost of poor nutrition [5] and the economic cost of environmentally suboptimal food production methods to demonstrate why a nutritionally balanced environmentally sustainable dietary regime needs to be promoted by the NHMRC. Hence I believe that there is a compelling argument for more sustainable food choices to be captured in a much more compelling way by this appendix.

Specific suggestions for improvement

Section G1 Background: Part of this background should provide more positive guidance to practitioners in being supportive of people who wish to have a diet orientated towards more sustainable food sources or who otherwise have related environmental, religious or ethic-based views that encompass diets with higher (or exclusively) plant-based sources. Indeed, it would be remiss to not acknowledge the segment of the population who have ethical issues with farming practices that include ‘factory farming’, genetically modified organisms, animal products etc.

The present draft of the background indicates that there is not adequate quantitative evidence of the environmental impact of food choices. I contest that there is, indeed, plentiful quantitative support that the environmental impact of food choices, particularly surrounding intensive horticulture and factory faming of animals (see for example Steinfeld et al. 2006; Carlsson-Kanyama & Gonzalez 2009, Macdiarmid et al 2012), plus overfishing of natural fish stocks [566]. Indeed, the NHMRC reference list contains a number of additional examples. Australian legislation has also reflected a concern, for example the Gene Technology Act 2000 (this and broader issues in Australia are summarised in Office of the Gene Technology Regulator 2011). This said, Figure G1 provides an adequate summary that illustrates the impacts of the food production system, but could be enhanced to show feedback loops.

Section G2 The nature and challenges: The section needs to inform the practitioner on the background to the research on the sustainability of the food production system. As it is, this section does not add any great value in its present form: parts from Section G1 better belong here as well. Sustainability methodologies have moved on to a far greater extent than suggested in this section and have increasingly included quantitative methods of analysis that work well alongside qualitative methods. Australian evidence is also well represented in the literature, enhanced by self-reporting by industry bodies that recognise the link and the problems (i.e. the Australian Dairy Manufacturing Industry [1068] and Australian Pork Limited 2010 (see also Tucker et al. 2010) so appropriate references should be provided—a table would be instructive to show areas of the food production system (perhaps aligned to Figure G1) with corresponding references that demonstrate environmental impacts (and to be fair, the research that does not).

Section G3 The Guidelines through an environmental lens: This section seems misguided. In the first instance, this table has a bias towards animal products, so adjustment that also provides focus on plant alternatives should be considered. The Harvard School of Public Health (n.d.) has a Health Eating Plate, which as an example does at least provide alternatives. It may be instructive for alternative guidance. However, the NHMRC can take the initiative and include in this section a plate/pyramid with exclusively plant products and an additional alternative that prescribes to a general vegetarian diet. Both would provide nutritional guidance to those wanting environmentally sustainable food choices and confirm that the public consultation feedback pointing towards this kind of outcome has been considered.


Australian Pork Limited (2010) National Environmental Sustainability Strategy for the Pork Industry 2010–2015. Viewed 27 October 2012

Biological Farmers of Australia (2012) Organics, Booming $1.27 Billion Industry. Viewed 27 October 2012 < http://www.bfa.com.au/NewsandMedia/News/newsid367/240/mid/367.aspx>

Carlsson-Kanyama, A. and Gonzalez, A.D. (2009) Potential contributions of food consumption patterns to climate change, American Journal of Clinical Nutrition, 89 (5): 1704S-1709S. Viewed 29 August 2012 See also several other articles from the same publication.

Harvard School of Public Health (n.d.) Healthy Eating Plate and Healthy Eating Pyramid. Viewed 27 October 2012

Macdiarmid, J.I., Kyle, J., Horgan, G.W., Loe, J., Fyfe, C., Johnstone, A., and McNeill, G. (2012) “Sustainable diets for the future: can we contribute to reducing greenhouse gas emissions by eating a healthy diet?” American Journal of Clinical Nutrition, 96(3): 632-639. Viewed 31 October 2012

Office of the Gene Technology Regulator (2011) GTECCCC discussion paper - Environmental Ethics as it relates to Gene Technology in Australia. Viewed 27 October 2012

Powell, B.A. (2009) “The Groaning Table”, Sierra, 94(2): 66-67. Viewed 11 April 2012

Public Health Association of Australia (2012) A future for food: 2. Viewed 27 October 2012

Steinfeld, H., P. Gerber, T. Wassenaar, V. Castel, M. Rosales, and C. De Haan (2006) Livestock’s long shadow: Environmental issues and options. FAO, Rome.

Tucker, R.W., McGahan, E.J., Galloway, J.L. and O’Keefe, M.F. (2010) National Environmental
Guidelines for Piggeries - Second Edition, Viewed 27 October 2012

Page reviewed: 4 February, 2013