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

ID: 
47
This submission reflects the views of
Organisation Name: 
Grains and Legumes Nutrition Council
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  Grains & Legumes Nutrition Council Ltd

(Formerly Go Grains Health & Nutrition)

 Submission

 Draft Australian Dietary Guidelines, Appendix G

Australian Dietary Guidelines Through and Environmental Lens

 November 2012       

 

 Grains & Legumes Nutrition Council Contact:

Michelle Broom

Nutrition Manager

Grains & Legumes Nutrition Council

1 Rivett Road, North Ryde, NSW, 2013

Ph:

PREFACE

 

This submission has been prepared by Grains & Legumes Nutrition Council Ltd (GLNC), an independent voice for grains and legumes in health and nutrition. GLNC is an organisation that links the Australian grains and legumes industry value chain from grain growers to food manufacturers, providing scientifically-based evidence about the role of grains and legumes in health and nutrition, to develop resources to support health promotion and education.

 

GLNC members are:

 

  • Grains Research and Development Corporation
  • GrainGrowers
  • Bakers Delight
  • Campbell Arnott’s
  • CSIRO Food Futures Flagship
  • George Weston Foods Baking Division
  • Goodman Fielder
  • Heinz Australia
  • Kellogg Australia
  • Nestle / Cereal Partners Worldwide
  • Sanitarium
  • Simplot
  • SunRice
  • UniGrain
  • Ward McKenzie

 

 

Associates:

  • Australian Food & Grocery Council
  • Pulse Australia
  • Healthgrain Forum

 

 

 


 

 

Grains & Legumes Nutrition Council Ltd (GLNC) welcomes the opportunity to comment on the National Health and Medical Research Council’s (NHMRC) Appendix G Australian Dietary Guidelines through an environmental lens.

 

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

 

GLNC considers the evidenced-based approach to developing the ADG the foundation to their purpose. All supporting documents must be based on this premise, or run the risk of creating unnecessary confusion and limit their effectiveness in achieving public health outcomes.

 

The guidance in Appendix G should therefore be consistent with these principles to avoid confusion when it comes to communication and adoption of healthy eating patterns to promote health and wellbeing. In particular, advice should be consistent with the best available scientific evidence.

 

GLNC notes the following inconsistencies with the Guidelines’ core principles which risk undermining the credibility of the Australian Dietary Guidelines as an evidence-based guide to healthy eating.

 

  • Practical Considerations and Environmental Benefits outlined in G3 which are not based on the best available scientific evidence may be misleading.
  • The best available scientific evidence suggests the most effective strategy for reducing the environmental impact of the food supply resulting from food consumption is to reduce overconsumption and household waste from the total diet.

 

 

GLNC recommends the ADG limits the advice on diet and reducing environmental impact to high level statements consistent with the evidence. This evidence shows the most effective strategy for reducing the environmental impact of the food supply is to reduce overconsumption and household waste from the total diet rather than targeting specific food groups

 


 

 

GLNC Recommends:

 

  1. GLNC recommends the ADG limits the advice on diet and reducing environmental impact to high level statements consistent with the evidence.

 

  1. Sections G1 and G2 are re-written with the assistance of experts from relevant government and industry organisations to provide public health and nutrition practitioners with:

 

a)      a description of the issues in the broader context of the global food supply chain including key stakeholders and initiatives; and

 

b)      a description of their role within the broader context as key influencers in reducing overconsumption and household waste from the total diet

 

 

 

 

GLNC supports:

 

  • The acknowledgement that there is limited evidence and this in an evolving area of research.

 

  • The inclusion of practical tips. 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. This strategic alignment is conducive to achieving price signals for encouraging producers and manufacturers of food to adopt more efficient practices.

 

 

 

 

 

 

 

 

 

 

 

Recommendation 1

Recommendation

GLNC recommends the ADG limits the advice on diet and reducing environmental impact to high level statements consistent with the evidence.

 

 

 

 

 

 

Rationale

 

GLNC, with its focus on the grain and legumes food system, recognises that food production has an impact on the environment but also acknowledges the lack of Australian evidence. 

 

Appendix G acknowledges the limited data and evidence base for the development of an ‘environmental lens’. The background to the appendix acknowledges this fact “….the measurement of the environmental impact of production and processing methods in the food industry is rudimentary”. From this and other references with respect to the strength of the evidence, GLNC questions the basis for the statement in G3 Practical considerations and environmental benefits, related to grain foods. This statement along with those related to the other groups of core foods, demonstrates a lack of evidence that has been used to develop the Appendix when compared to the modelling and extensive evidence that has been used to develop the ADG.

 

 

Recommendation 2

Recommendation

Sections G1 and G2 are re-written with the assistance of experts from relevant government and industry organisations to provide public health and nutrition practitioners with:

 

a)      a description of the issues in the broader context of the global food supply chain including key stakeholders and initiatives; and

 

b)      a description of their role within the broader context as key influencers in reducing overconsumption and household waste from the total diet

 

 

 

 

 

 

 

 

 

 

 

 

 

Rationale

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.

 

Sections G1 and G2 do not include a description of the broader food system or the key role of practitioners in reducing environmental impact through reducing waste and overconsumption.  

 

The broader context of the food system

 

  • The background information in G1 does not acknowledge the enormous investments and achievements by government and industry organisations towards improving the sustainability of the Australian food supply.

 

  • The background information in G1 does not acknowledge that the key focus of government and industry initiatives is on 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 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.

 

  • There is no explanation 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.

 

 

Meaningful contribution to reducing the environmental impact of the food system

 

  • The most effective strategy for reducing the environmental impact of the food supply is to reduce overconsumption and household waste from the total diet rather than targeting specific food groups.

 

  • 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. This strategic alignment is more conducive to achieving price signals for encouraging producers and manufacturers of food to adopt more efficient practices.

 

 

Evidence

 

  • Globally, food waste in storage, distribution, marketing and at the household level account for nearly 50 per cent of the human edible kilojoules that are produced.2

 

  • The FAO suggests a 50% reduction in losses and wastage in the production and consumption chain is a necessary and achievable goal.2

 

 

  • An assessment of UK and US data indicates household wastage accounts for between 40 – 50% of total waste.3

 

  • An environmental impact assessment conducted by Unilever of their product supply chain reported 26% of environmental impact from growers, less than 10% manufacture and distribution and 62% consumers (preparation, storage and waste).4

 

  • Compared with a normal weight population, a population with 40% obese requires 19% more food energy.5

 

  • A 10kg weight loss of all obese and overweight people would result in reduction of 50 metric tonnes of CO2 per year.5

 

  • There is strong positive correlation between Greenhouse Gas Emissions and amount of food and kilojoules eaten.6

 

  • Foods contributing more than 1.5 million tonnes of waste per year include drink; fresh vegetables and salads; bakery; and home-made and pre-prepared meals.2

 

 

REFERENCES

 

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

 

  1. United Nations Environment Programme, 2011 Version -- 02.11.2011

 

  1. Lundqvist, J., C. de Fraiture and D. Molden. Saving Water: From Field to Fork – Curbing Losses and Wastage in the  Food Chain. SIWI Policy Brief. SIWI, 2008

 

  1. Unilever Breakfast Seminar: How do we achieve a Sustainable and Healthy food supply? International Congress of Dietetics. 2012

 

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

 

  1. Vieux, F., et al., Greenhouse gas emissions of self-selected individual diets in France: Changing the diet structure or consuming less?, Ecol. Econ. 2012

 

 




 

Page reviewed: 4 February, 2013