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

ID: 
37
This submission reflects the views of
Organisation Name: 
National Heart Foundation of Australia
Please identify the best term to describe the Organisation: 
Non-Government Organisation
Personal Details
General Comments
Comments: 

 

 

National Heart Foundation of Australia

 

 

Submission

 

on

 

 

A draft appendix to the Australian Dietary Guidelines

 

G  Australian Dietary Guidelines through an environmental lens

 

 

October 2012

 

 

 

 

To:

Project Officer – Emma Breen
Public Health Section
Research Translation Group
NHMRC GPO Box 1421
CANBERRA ACT 2601

 

 

 

Heart Foundation Contacts:

 

Dr Lyn Roberts

CEO - National
  Heart Foundation,

 

Barbara Eden

Senior Manager, Food Supply

Heart Foundation - NSW

 

 


Background

 

The National Heart Foundation of Australia (the Heart Foundation) understands that this Appendix, Australian Dietary Guidelines through an environmental lens, considers new issues in relation to national food based guidelines for the health of all Australians.

 

Our comments are based on our experience as the leading non-government organisation in cardiovascular health and a key agency in the area of healthy lifestyle, including healthy eating; physical activity; and active, healthy communities. Also for over 20 years, the Heart Foundation has successfully encouraged the food industry to produce, promote and ‘sign post’ foods that are healthier choices within their category.

 

While the environmental impact of food systems is not key work for the Heart Foundation, for many years we have advocated that there needs to be a national, integrated, whole-of-government approach to all policies in relation to food. We feel this type of coordinated effort is needed to ensure a safe, nutritious, secure and environmentally sustainable food system accessible for all Australians for health, wellbeing and prosperity now and into the future.

 

The Heart Foundation has participated in previous consultations to the NHMRC on the Australian Dietary Guidelines (ADG) and associated documents, and we welcome the opportunity to comment on the draft Appendix: Australian Dietary Guidelines through an environmental lens.

 

 

Executive Summary

 

The Heart Foundation supports the inclusion of the discussion of the relationships between environment and the food system in Australia. However, to ensure the availability of an ongoing healthy food supply, there needs to be a real linkage between environmental factors and impacts, the food system and health which is addressed through an across department health-in-all-policies approach at a federal, state and local levels.

 

The Heart Foundation recommends:

  • That environmental considerations form part of the core Australian Dietary Guideline statements
  • The inclusion of more detail outlining the impact of consumer food choices on the environment
  • Stronger linkages across all Government policies, plans and documents are needed to ensure an ongoing sustainable healthy food supply
  • Explanation of      differences in phrasing of practical considerations and environmental      benefits be included
  • That the      practical tips on environmental impact be an important part of the      consumer awareness campaign material developed for the ADG communications.
  • Further clarity      on the intended audience is for this environmental impact information.


 

Appendix: Australian Dietary Guidelines through an environmental lens

 

 

 

The   Heart Foundation supports the inclusion of the relationship between   environment, food and health.

 

 

 

 

 

 

 

Stronger linkages across   all Government policies, plans and documents are needed to ensure an ongoing   sustainable healthy food supply.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The   environmental considerations should form part of the core dietary guideline   statements

 

 

 

 

 

 

 

 

 

 

 

The   inclusion of more detail outlining the impact of consumer food choices on the   environment is needed.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Explanation  

of differences in   phrasing of practical considerations and environmental benefits would help   understanding

 

 

 

 

 

 

 

The   reference to health impact in Guideline 3 is not consistent with other   Guideline sections

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Include   the practical tips in the consumer awareness campaign material

 

 

 

 

 

Further clarity on   who the intended audience is for the information

 

 

 

G1   Background

 

The Heart Foundation is pleased to see the inclusion   of a discussion of linkages between the environment, food and health as it   emphasises the potential significant impact various different sector policies   can have on our food system and subsequently how it affects the health of all   Australians.

 

To achieve optimum health for all   Australians, health must be the key driver and outcome of any food based   recommendations in Australia. It is important to develop a coordinated approach   for policies, plans and activities across all Government departments   including environment, agriculture, planning, health, finance, community   development and climate change, to ensure a sustainable healthy food supply   for future Australians.

 

The   Heart Foundation feels the discussion in this section and Figure G1, while   highlighting the multi-facetted aspects of the food system, fails to indicate   the strong cyclic nature of the link between environmental impact, the sustainability   of the food supply and health. In the whole document, there is only one use   of the word ‘sustainable’ – in the first line of this Background section.

 

The   primary purpose of our food system should be to nourish populations; however,   public health cannot be separated from the economic objectives of food   production. For the benefit of consumers, health must be factored into each   step of the food supply chain (production, processing, packaging, labelling,   distribution, marketing and consumption). A health-in-all-policies approach   is needed at a federal, state and local level of policy making.[1]

 

There   needs to be stronger links between related Commonwealth documents around our   food supply include the NHMRC ADG, especially this environmental impact   discussion and the National Food Plan. This could be feasible as both   documents are still in their draft stages. The Heart Foundation would like to   see reference to the need for such connectedness outlined in this document as   an impetus for coordination in the future.

 

 

The Heart Foundation believes the   inclusion of environmental considerations as an Appendix is a backwards step   from that proposed in the original 2010 draft. All the evidence about the   converging threats on the food supply suggests that environmental   considerations should be integrated into the main dietary guidelines   discussion. Environmental considerations are central to the future security   of our food supply and population health. If we wait another 10 years for the   next round of Dietary Guideline Review to recognise the importance of this   issue, we will have failed in our obligation to future generations.

 

 

 

G2   The nature and challenges of the evidence base

 

The   Heart Foundation acknowledges the complexity and disparity of the evidence   sources for the environmental impact of the food system and the   sustainability of our food supply.

 

In   the last paragraph of this section, the alignment has been done really at the   consumer or individual action level, primarily around food choices, practices   and behaviours. This should be expressed more clearly in the text of this   last paragraph as it explains the reasoning for the table in Section G3.

 

 

 

G3   The guidelines through an environmental lens

 

Guideline 2

 

The   Heart Foundation notices that the Practical   considerations and environmental benefits in the right hand column are   not consistently written with same action verb. While, we acknowledge this is   likely to be due to the strength of the evidence for the relationship between   the Guideline action and the environmental outcome, it appears inconsistent   to read. One in particular is under Guideline 2: 5th dot point -   ‘Milk, yoghurt, cheese  ....’. The   Heart Foundation suggests the wording be changed to “Consuming quantities in   line ……and yoghurt, rather than relying   on any one food, …”

 

The   Heart Foundation recommends including some explanation of why different   phrasing is used in the second column for different Guideline statements. The   inclusion of footnotes would better help explain the reasons to health   professionals, teachers and academics using the ADG documents.

 

The   Heart Foundation supports the inclusion of the consideration to “Choose fish   and other seafood from stable stocks” and has such recommendations in its position   paper on Fish, fish oils, n-3 polyunsaturated fatty acids and cardiovascular   health[2]   and in accompanying consumer information[3].  

 

 

Guideline 3

 

For   each of the Guidelines 1, 2, 4 and 5, there is no mention of health issues in   the right hand column. However under Guideline 3, a health benefit has been   included along with the environmental impact of production. While the Heart   Foundation is in favour of promoting the message about the health benefits of   reducing saturated fats, salt, added sugar and alcohol as much as possible,   it is not consistent with other Guideline sections. Keeping the statements to   the practical considerations and the environmental benefits is more relevant   in this section of the ADG Appendix.

 

 

 

G4   Practical Tips

 

The   Heart Foundation supports the inclusion of practical tips for Australians to   reduce the environmental impact of food behaviours.

 

In   Point 3,’Minmimise wastage’, the phrase ‘… check use by dates’ only partially   covers the date stamps that appear on food packages. Including terms such as   ‘best before’ and ‘expiry date’ would more fully explain this issue.

 

The   Heart Foundation suggests these practical tips for reducing environmental   impact, be incorporated into the consumer information package and/or   awareness campaign messages being developed for the ADG public communications.  

 

 

 

Overall comment

 

It is unclear who   the intended audience is for the information in this Appendix. Some of the text   is highly technical and other sections overly simplistic. While it is   included elsewhere in the full ADG document, if the environmental discussion   is not to be an integral part of the ADG statements, the Heart Foundation   recommends the inclusion of some explanation as to the purpose of this   information to better clarify the audience for this ADG Appendix.

 

 


 

Conclusion

 

The Heart Foundation supports the inclusion of a discussion on the environmental factors and impacts in relation to the food system. However, we urge the NHMRC to reconsider inclusion of the environmental elements/considerations into the core Australian Dietary Guideline Statements. The Heart Foundation strongly recommends highlighting the need for stronger linkages across all government portfolios to ensure progress toward a sustainable secure food system.

 

 

 

References

 




[1] McQueen D, Wismar M, Lin V, Jones C, Davies M. Intersectorial Governance for Health in All Policies: Structures, actions and experiences. World Health Organization; 2012[cited 23 October 2012]; Available from http://www.euro.who.int/en/what-we-publish/abstracts/intersectoral-governance-for-health-in-all-policies.-structures,-actions-and-experiences

[2] Heart Foundation. Position paper on fish, fish oils, n-3 polyunsaturated fatty acids and cardiovascular health.2009. [cited 22 October 2012]. Available at http://www.heartfoundation.org.au/information-for-professionals/food-professionals/Pages/guides-policies-position-statement.aspx

[3] Heart Foundation. Table of omega-3 levels in fish and seafood [cited 22 October 2012]. Available at http://www.heartfoundation.org.au/information-for-professionals/food-professionals/Pages/guides-policies-position-statement.aspx

 

 

 

Page reviewed: 4 February, 2013