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

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51
This submission reflects the views of
Organisation Name: 
Food Alliance
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Non-Government Organisation
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Public Consultation on draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens

 

Submission

 

 

 

2 November 2012

 

Food Alliance

Food Policy Unit

Population Health Strategic Research Centre

Deakin University

221 Burwood Highway

Burwood VIC 3125

 

Authorised by:

                       

Mark Lawrence

Director, Food Policy Unit

Population Health Strategic Research Centre, Deakin University

 

 

Introduction

The Food Alliance is pleased to respond to the NHMRC’s Public Consultation on the draft Appendix to the Australian Dietary Guidelines. The Food Alliance welcomes the inclusion of environmental considerations as part of the Australian Dietary Guidelines. However, the Food Alliance believes that the sustainability of Australia’s food system is too important an issue to be relegated to an appendix and that guidelines about sustainable eating should be integrated with nutritional guidelines in the main body of the document.  

The Food Alliance is an organisation funded by VicHealth (the Victorian Health Promotion Foundation) and auspiced by the Population Health Strategic Research Centre at Deakin University. The Food Alliance aims to identify, analyse and advocate for evidence-informed policies and regulatory reform to enable sustainable food security and healthy eating in the Victorian population (www.foodalliance.org.au).

Our submission is divided into two sections, preceded by a summary. The first section of the document discusses overarching issues in relation to the draft Appendix. The second section of the submission outlines specific feedback on the content of the proposed Appendix.

Summary

National dietary guidelines that provide clear guidance about how to eat sustainably are urgently needed. However, the proposed Appendix marginalizes the critical issue of a sustainable food supply and fails to provide clear advice about how to eat sustainably.

The key messages in our submission are:

  • Environmental considerations must be integrated with nutritional advice throughout the Australian Dietary Guidelines

 

  • Ensuring a secure supply of food for current and future generations is fundamental to promoting a nutritious diet and protecting health. Strong evidence exists that current and future generations of Australians are at risk of food insecurity due to environmental sustainability concerns, and urgent and substantial dietary guidance is needed to help protect and promote food security in Australia
  • Environmental considerations should not remain relegated to an appendix. This reflects a lack of progress on such considerations in the dietary guidelines since an appendix in 2003. Nine years later, the evidence has strengthened considerably but the NHMRC has not advanced its guidance on this priority public health issue
  • The first dietary guideline should be to ‘promote adequate and sustained food security’. The priority message within this guideline should be to ‘eat less discretionary foods’ – these foods provide low amounts of nutrients, contribute to dietary imbalances, are wasteful of natural resources and typically require significant energy and water usage to undertake high levels of processing

 

  • Guidance on environmental considerations should also be included as a theme in each subsequent dietary guideline
  • 72 submissions to the previous dietary guidelines consultation addressed the issue of environmental sustainability, making it the issue that generated most comment, and the majority of these submissions supported the inclusion of environmental sustainability advice in the guidelines
  • Evidence presented in submissions about the environmental impacts of dietary patterns have been given insufficient consideration in the development of the current version of the guidelines
  • Current NHMRC evaluative frameworks are inadequate for measuring relationships between dietary patterns, food selection and environmental sustainability. Environmental evidence put forward in submissions should be re-assessed using a grading framework appropriate for assessing environmental evidence, rather than a framework that was designed for clinical settings
  • The Appendix fails to provide clear guidelines about sustainable eating that could be acted on by health professionals or translated into advice for the general public
  • There are strong synergies between dietary patterns that are healthy and environmentally sustainable
  • There are increasing calls for national dietary guidelines about sustainable eating from the Australian health professions and from international organisations
  • Government must take the lead in the Australian Dietary Guidelines in ensuring that current dietary choices do not compromise the ability of future generations of Australians to feed themselves sustainably

 

Overarching issues

1. Sustainable eating guidelines should be integrated with nutrition guidelines 

“There is an urgent need to develop and promote strategies for sustainable diets”
Deputy Director-General,  FAO, Rome p14, [1].

Advice about how to eat sustainably to protect food security for current and future generations must be the priority message of dietary guidelines. It should be the first dietary guideline and should also be integrated with subsequent guidelines, rather than being relegated to an appendix. This was recommended in the consultation to the draft guidelines by many stakeholder groups

Placing environmental considerations in an appendix marginalizes the issue. However, ensuring a secure and sustainable supply of food for current and future generations is fundamentally important to the ability of Australians to consume a nutritious diet. A UK parliamentary inquiry in 2009 concluded that:

“Any method of food production that does have a negative impact on the ability of future generations to secure their own food supplies is merely creating the short-term illusion of security. Genuine food security cannot exist without sustainability”  [2]

Evidence about the environmental impacts of current dietary patterns has strengthened considerably since the release of the 2003 Australian Dietary Guidelines, when environmental considerations were addressed in an appendix (see below). Strong evidence has also emerged of synergies between a nutritious diet and an environmentally sustainable diet, suggesting that the two sets of guidelines could be integrated [3, 4].

There is growing interest among Australians in eating sustainably. In a 2011 consumer survey, over 45% of people said that it was important or very important to know about the environmental impact of food production systems, and a further 35% said that it was somewhat or quite important. However, the survey also showed that Australians lack knowledge about the environmental impact of food systems, with almost 70% of people saying that they were confused about the issue [5].

The nutrition, public health and medical professionals in Australia and overseas have called for the inclusion of environmental sustainability considerations into dietary guidelines [6, 7]. The UN Food and Agriculture Organization has also urged governments to develop policies and guidelines that promote sustainable diets [1], and a UK Parliamentary Committee has recently conducted an inquiry into sustainable food [8]. Australia must not fall behind by missing this opportunity to embed environmental considerations into the Australian Dietary Guidelines.

Recommendations

  • Environmental considerations should not be relegated to an appendix but should be integrated with nutritional advice in the Australian Dietary Guidelines
  • The first dietary guideline should be a guideline to promote adequate and sustained food security for current and future generations of Australians
  • Environmental sustainability should be integrated as a theme across all subsequent guidelines

 

2. Evidence has strengthened since the 2003 Australian Dietary Guidelines  

“There is already sufficient evidence as to food’s impact to warrant the creation of comprehensive sustainable dietary guidelines at national, regional and global policy levels” p25, [9]

The wording in the Appendix implies that the evidence about the environmental impacts of dietary patterns is too weak to support dietary guidelines for sustainable eating.  This is not the case. There is sound evidence about the broad environmental impacts of dietary patterns on which to base dietary guidelines [4, 10-17], and this evidence is too strong to justify inaction. Indeed, other national governments have used this evidence to formulate dietary advice about how to eat sustainably [4, 18, 19]. There is a lack of lifecycle analysis studies for specific food products, but this should not impede the development of dietary guidelines.

The NHMRC decision reflects a lack of progress in its position on diet and environmental sustainability since it first responded to this issue and listed it as an appendix in the previous iteration of the dietary guidelines in 2003. Now nine years later the NHMRC has not advanced its guidance on this priority public health issue, despite the rapidly growing evidence base, which includes evidence about the likely impacts of climate change on our food supply [12, 20] and the significant contribution of food production to Australia’s greenhouse gas emissions [12].

Strong and consistent evidence exists that current and future generations of Australians are at risk of food insecurity due to environmental sustainability concerns [10, 15, 21, 22]. Urgent and substantial dietary guidance is needed to help protect and promote food security in Australia (and elsewhere). Instead the decision of the NHMRC to restrict environmental sustainability considerations to an appendix in its proposed dietary guidelines is a missed opportunity for protecting and promoting public health in Australia.

The Food Alliance agrees with the conclusions of the Health Council of the Netherlands in its review of the ecological impacts of the food system in which it identified that there are two priority guidelines that would have significant health and environmental benefits [4].  The first is to reduce energy intake by eating less ‘discretionary’ foods such as sugary drinks, sweets, cakes and snacks, and the second is to adopt a more plant-based, less animal-based diet [4].

 

Pressure from the Australian food industry not to include advice about sustainable eating in the Australian Dietary Guidelines has been documented [23, 24]. Other national governments have come under similar pressure during the development of dietary guidelines that include advice about sustainable eating [23]. This pressure must be resisted and instead, the evidence should be allowed to drive dietary advice and guidelines.

Recommendations

Strong evidence exists about the environmental impacts of dietary patterns and food production systems and there is an urgent need to act now to reduce these impacts by providing dietary guidelines that give coherent and integrated advice on how to eat healthily and sustainably.

In terms of integrating health and sustainability evidence, the priority dietary guidance needs to be to ‘eat less discretionary foods’ – these foods provide low amounts of nutrients, contribute to overweight and obesity and other dietary imbalances, are wasteful of natural resources and typically require significant energy and water usage to undertake high levels of processing.

 

3.  Environmental evidence has been given inadequate consideration

Seventy-two submissions to the previous dietary guidelines consultation addressed the issue of environmental sustainability [25], making it the issue that generated most comment, and the majority of these submissions supported the inclusion of environmental sustainability advice in the guidelines. Many of these submissions provided detailed evidence of the environmental impacts of dietary patterns and systems of food production e.g. [3, 26].  However, the marginalization of environmental concerns in an appendix suggests that evidence put forward about the need for environmental guidelines was not given appropriate consideration.

The NHMRC appears to have overlooked the views of the vast majority of submitters who requested significant action to address this issue in the revised dietary guidelines – their requests are not reflected in the current outcome. Rather than questioning whether there is sufficient evidence to support dietary guidance on environmental sustainability, it would be more appropriate for the NHMRC to question the relevance of its evaluative frameworks for evidence-based practice in the context of environmental sustainability concerns. Evidently, the current NHMRC evaluative frameworks lack the ability to specify and measure the relationships between dietary patterns, food selection and environmental sustainability.

The NHMRC’s evaluative framework prioritises studies that are conducted using randomized control and systematic review methodologies, which are common in the field of clinical health sciences.  However, these methodologies are not well designed and rarely used to assess the environmental impacts of dietary patterns and food systems, so environmental studies were given less weighting during the assessment of evidence because they were judged against best practice in public health research rather than against best practice in environmental research.  These frameworks and the decision-making processes that they inform need to be urgently transformed so that they have the capacity to address priority diet and environmental sustainability policy issues facing Australians.

The weight and quality of the evidence presented in submissions about the environmental impacts of food production and the urgency of the need to act warrants the development of clear guidelines to encourage sustainable eating patterns.  

Recommendations
Evidence put forward in submissions about the environmental impacts of dietary patterns and food production should be re-assessed using a grading framework that is appropriate for assessing environmental evidence, rather than a framework that was designed for assessing public health and nutrition evidence. 

 

4. Government must take the lead in encouraging sustainable dietary patterns by providing clear advice to the public

The relegation of environmental considerations to an appendix of the Australian Dietary Guidelines suggests that Government intends to a take a back seat rather than a leadership role in encouraging sustainable dietary patterns and food production. The food industry is also currently taking a back seat on this issue, which places the responsibility for driving the necessary behaviour change firmly in the hands of consumers, without providing them with the information or food choices that would enable them to make this change.

However, consumer research on sustainable food production and consumption in the UK shows that consumers expect Government to lead this change and, indeed, that it will be difficult for consumers to shift to more sustainable patterns of food consumption without leadership from Government [27, 28]. A key area of government leadership is the provision of information that assists consumers to make more sustainable dietary choices and the Australian Dietary Guidelines are an important part of that. Australians are confused about how to make sustainable dietary choices [5] and without government leadership through the Australian Dietary Guidelines they are likely to remain confused.  

Recommendations

Government should show leadership in encouraging a shift towards more sustainable patterns of food consumption by integrating sustainability advice with nutrition advice in the Australian Dietary Guidelines.

 

Specific feedback on the content of the Appendix

We do not support environmental sustainability considerations being confined to an appendix of the Australian Dietary Guidelines. However, within the context of the Appendix, we make a number of comments as follows:

The Appendix fails to provide clear guidance about sustainable eating

The Appendix focuses on discussion of environmental issues, rather than giving clear advice about how to eat sustainably. The small section of the document on ‘practical tips’ is the only section in the document that aims to give advice. This section focuses on issues of minimizing food waste, packaging and over-consumption, and avoids explicitly addressing the need to reduce current levels of discretionary food consumption and the need to move to a less animal-based, more plant-based diet. 

The ‘guidelines’ in the Appendix are presented as ‘Guidelines through an environmental lens’. They discuss the ‘practical considerations and environmental benefits’ of dietary guidelines that are based on nutritional advice, but they do not attempt to integrate advice about how to eat sustainably with nutritional advice and again, they avoid the key issue of the need to move to a less animal-based, more plant-based diet. As such, they also fail to provide clear advice.

The Appendix leaves readers to do much of the work of assessing the environmental impacts of dietary patterns and food production for themselves. For example, the list of key references at the back of the document tells the reader where to look for information about the environmental impacts of different commodities, such as vegetables and fruit or meat and dairy, but no attempt is made in the document to analyse or summarise the evidence.  

The language in the document is complex and technical, and sentences such as the following are difficult to understand:

“The environmental impact of food production depends on the particular environmental outcome examined and each can have a significant environmental impact, which can also alter the Australian food system, with implications for yield, quality and affordability”

Recommendations

  • The primary aim of the document should be to provide clear, evidence-based advice about how to eat sustainably
  • The document should analyse and summarise the evidence rather than leaving readers to do this for themselves
  • The language in the document should be simplified, so that the document is accessible to nutritionists and dietitians who do not have significant existing knowledge of the issues

Section G1

The language and writing in this section are particularly complex and should be simplified. For example, phrases such as ‘maintaining environmental integrity’, ‘narrative evidence’ and ‘bi-directional relationship between food systems and environmental degradation’ should be simplified or given further explanation. The environmental impacts of food production are new to many nutritionists and dietitians, but the Background section of the document assumes significant prior knowledge.    

We welcome the diagram about ‘environmental impacts of the food system’, but this could be improved with better labeling. For example, the left-hand column could be labeled ‘inputs’ and the right-hand column ‘impacts’. It is also unclear what the phrase ‘air emissions’ means.

Recommendations

  • Complex phrases used in this section should be simplified or given further explanation
  • Labeling should be improved on the diagram about ‘environmental impacts of the food system’

Section G2

The section on the ‘Nature and challenges of the evidence base’ focuses on discussing the methodologies used to measure environmental impacts, but there is no discussion of the evidence base itself. The only section of the document that does cover the evidence base is section G5 (Key references), but this fails to analyse or summarise the evidence, only providing references. This section should focus on discussion of the evidence base, rather than focusing solely on the methodologies used.

The overall tone of this section suggests that the evidence base on the environmental impacts of food production is weak and confusing. As discussed earlier, this is not the case. This section should be re-written once the evidence has been re-assessed using an evaluative framework appropriate to studies of the environmental impacts of food production (see Overarching Issues, section 3).

Recommendations

  • This section should discuss the evidence base rather than focusing on the methodologies used to generate the evidence
  • This section should be re-written once the evidence has been re-assessed using an evaluative framework appropriate to studies of the environmental impacts of dietary patterns and food systems

Section G3

The guidelines presented in this section discuss the ‘practical considerations and environmental benefits’ of dietary guidelines that are based on nutritional advice, but they do not strongly integrate advice about how to eat sustainably with nutritional advice.

Guideline 3, ‘Avoiding foods produced with high levels …’ has a sound basis in evidence. However, this guideline should be strengthened to say, ‘Eating less discretionary foods, ie foods produced with … and waste disposal’. A second sentence should then be added to say, ‘Discretionary foods provide low amounts of nutrients, contribute to dietary imbalances, are wasteful of natural resources and typically require significant energy and water usage to undertake high levels of processing’.    

The suggestion under guideline 2 that ‘consuming a mixture of milk, cheese and yoghurts, rather than relying on any one food will help minimize the environmental burden associated with consumption of foods from this group’ is not clear. Each of these dairy products is made from the same primary commodity, milk, and the most significant environmental impacts associated with these products are related to milk production on farm, not the processing of milk into secondary products. For example, in relation to one of the most significant environmental impacts of dairy production, water use, 99% of the water use occurs on farm, not during secondary processing  [29].

Under the first section of guideline 2, which focuses on fresh fruit and vegetables, the phrase ‘and support Australian farmers’ could be added, so that the guideline reads, “Choose a variety of season and local fresh fruit and vegetables to reduce environmental impact and support Australian farmers”.

Recommendations

  • Re-word guideline 3 to say, ‘Eating less discretionary foods, ie foods produced with …’.
  • Add the phrase ‘and waste production’ to guideline 3, so that the guideline reads “… and waste disposal
  • Remove the suggestion under guideline 2, ‘consuming a mixture of milk, cheese and yoghurts, rather than relying on any one food will help minimize the environmental burden associated with consumption of foods from this group’
  • Consider including the phrase ‘and support Australian farmers’ under guideline 2 – “Choose a variety of seasonal and local fresh fruit and vegetables to reduce environmental impact and support Australian farmers

Section G4

A number of extra tips could be included in this section, including:

  • Eating more wholegrains, legumes, fruit and vegetables
  • Using local, seasonally available ingredients
  • Buying foods from farming systems that minimize harm to the environment
  • Only buying animal products produced to a high standard of animal welfare
  • Conserving water and energy when cooking
  • Avoiding bottled water and serving filtered or plain tap water in re-usable jugs or bottles
  • Only choosing fish from sustainable sources and species recommended as ‘better choices’ in the Australian Marine Conservation Society’s Australian Sustainable Seafood Guide

Section G5

Providing additional references so that readers can consult the evidence themselves is useful, but the document should not shy away from analyzing and summarising the evidence.

Recommendations
The document should go beyond providing references for readers to consult the evidence themselves and should analyse and summarise the evidence, using an evaluative framework appropriate to studies of the environmental impacts of food systems.

 

Contact

For additional information or clarification on this submission, please contact Rachel Carey, Kathy McConell or Mark Lawrence:

  

References

1.            Burlingame, B. and S. Dernini, Sustainable diets and biodiversity: Directions and solutions for policy, research and action 2012, United Nations Food and Agriculture Organization (UN FAO).

2.            House of Commons Environment, F.a.R.A.C., Securing food supplies to 2050: the challenges faced by the UK 2009, The Stationary Office by Order of the House: London.

3.            Public Health Association of Australia, Response to the draft Australian Dietary Guidelines 2012, Public Health Association of Australia: Canberra.

4.            Health Council of the Netherlands, Guidelines for a healthy diet: the ecological perspective. 2011, Health Council of the Netherlands: The Hague.

5.            Worsley, T. and S. Byrne, Food Knowledge Survey 2011: Preliminary Report 2011, Deakin University Melbourne.

6.            Holdsworth, M., Sustainability should be integral to nutrition and dietetics. Journal of Human Nutrition and Dietetics, 2010. 23: p. 467-468.

7.            Public Health Association of Australia, A Future for Food 2: Healthy, sustainable, Fair. 2011, Public Health Association of Australia: Canberra.

8.            House of Commons Environmental Audit Committee, Sustainable Food 2012, Eleventh report of session 2010-12: London.

9.            Lang, T. Sustainable diets and biodiversity: The challenge for policy, evidence and behaviour change. in International Scientific Symposium on Biodiversity and Sustainable Diets United Against Hunger. 2012: FAO.

10.          UNEP, The Environmental Food Crisis: The Environment's role in averting future food crises, C. Nelleman, et al., Editors. 2009, United Nations Environment Programme: Arendal, Norway.

11.          Steinfeld, H., et al., Livestock's Long Shadow: environmental issues and options. 2006, Food and Agriculture Organization of the United Nations: Rome.

12.          Garnaut, R., Issues paper 1: Land Use - Agriculture and Forestry. Garnaut Climate Change Review. 2008.

13.          Commissioner for Environmental Sustainability Victoria, Victoria 2008 State of the Environment Report. 2008.

14.          Larsen, K., C. Ryan, and A.B. Abraham, Sustainable and secure Food systems for Victoria: What do we know? What do we need to know? 2008, Victorian Eco-Innovation Lab (VEIL).

15.          PMSEIC, Australia and Food Security in a Changing World. The Prime Minister's Science, Engineering and Innovation Council. 2010: Canberra, Australia.

16.          Foresight, The future of food and farming. 2011, The Government Office for Science: London.

17.          Garnett, T., Cooking up a storm: Food, greenhouse gas emissions and oru changing climate 2008, Food and Climate Research Network, University of Surrey: Guildford.

18.          German Council for Sustainable Development, The Sustainable Shopping Basket: a guide to better shopping. 3rd edition. . 2008, German Council for Sustainable Development: Berlin.

19.          National Food Administration, The National Food Administration's environmentally effective food choices: proposal notified to the EU. 2009, National Food Administration: Stockholm.

20.          Gunasekera, D., et al., Climate Change: Impacts on Australian Agriculture. Australian Commodities, 2007. 14(4).

21.          Larsen, K., et al., Victorian Food Supply Scenarios: Impacts on availability of a nutritious diet. 2011, Victorian Eco-Innovation Lab (VEIL).

22.          Sobels, J., Summary of Research into the Long-Term Physical Implications of Net Overseas Migration to Australia in 2050 2010.

23.          Sweet, M., Unpicking the Oz's recent splash on NHMRC's 'green diet' push', in Croakey 2010.

24.          Cresswell, A., Green diet push angers experts, in The Australian 2010.

25.          Community Affairs Legislation Committee, Hansard 17/10/12 - Estimates Health and Ageing Portfolio - National Health and Medical Research Council 2012.

26.          Doctors for the Environment Australia, Submission on the draft Australian Dietary Guidelines 2012, Doctors for the Environment Australia: South Australia.

27.          SDC/NCC, I will if you will: Towards sustainable consumption 2006, Sustainable Development Commission/National Consumer Council

28.          WWF-UK/Food Ethics Council, A Square Meal: How encouraging greener eating fits the UK Government's ambitions for the environment, farming and the Big Society 2011, World Wildlife Fund UK and the Food Ethics Council

29.          Dairy Australia, Eco-efficiency for the Dairy Processing Industry. 2004, Dairy Australia Sydney.

 

 

Page reviewed: 4 February, 2013