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

This submission reflects the views of
Organisation Name: 
QUT Nutrition and Dietetics Department
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Educational Institution – tertiary
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General Comments

1st November, 2012


Thank you for the opportunity to respond to the public consultation for the draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens.

The Queensland University of Technology’s Nutrition and Dietetics Program provides high level teaching and research in the area of nutrition and dietetics and in particular the articulation of policy into practice as it relates to public health nutrition. This expertise draws on a range of paradigms including population health and nutrition.

Our program has an interest in the Australian Dietary Guidelines, as these guidelines have the potential to impact on nutrition and a broad range of health related factors for all Australians.

As evidence becomes more convincing, Australians are increasingly seeking advice from health professionals and practitioners about the impact of food choices on the environment. The proposed Appendix is a welcome step in meeting this need, however we are concerned that this information is too important to confine to an Appendix, and that a more critical summary of the evidence based on a more appropriate framework for evaluating the quality of environmental studies. Furthermore, we believe that more information and detail is required regarding practical and translatable recommendations for sustainable food choices.

Below are comments and recommendations as to how the proposed Appendix could be incorporated into the revised guidelines and the Australian Guide to Healthy Eating, to strength and assist in achieving the desired outcomes.  


Overview and general recommendations

We commend the inclusion of the impact of dietary choices on the environment and sustainability, however argue that this important information should not remain confined to an appendix, which currently marginalises the issue at hand. The confinement of environmental considerations to an appendix remains consistent with the approach taken in the 2003 iteration of the document, indicating a lack of progress on the part of the NHMRC to integrate sustainable eating practices into the guidelines and suggests unwillingness by the Government to take a leading role in addressing issues of sustainable dietary choices. Rather, the responsibility to make these changes is passed to consumer, however insufficient information or practical advice has been provided in this section to allow consumers to make the necessary choices that are conducive to environmental sustainability. Recent data collected in Victoria suggests that a majority (70%) of consumers are confused about the environmental impact of food systems and dietary choices (Worsley and Byrne, 2011).  If the government fails to take a leadership approach and provide clear, concise advice to assist in environmentally sustainable food choices, the Australian public are likely to remain confused.  As such it is imperative that practical information to assist in sustainable food choices be integrated with the nutritional advice provided throughout the Australian Dietary Guidelines.


Concerns pertaining to environmental sustainability, and the inclusion of recommendations to improve dietary choices conducive to environmental sustainability, were supported by a majority of submissions to the initial Dietary Guidelines public consult (Community Affairs Legislation Committee, 2012). Despite this, evidence provided in these original submissions has been provided insufficient consideration in the development of the current guidelines and appendix. We feel that our views, and the views of a vast majority of those who submitted responses to the initial Dietary Guidelines public consult, have merely been addressed superficially as evidenced by the relegation of this important information to an appendix, and the complete omission of a critical summary of the existing evidence. Based on the information that has been included, the document offers a simplistic view of the impact of dietary choices on environmental sustainability, claiming that the current available evidence is weak at best. However, this claim is based on the evaluation of existing literature using an inappropriate framework for assessing the quality of clinical evidence-based practice (rather than a framework appropriate for assessing the quality of concerns pertaining to environmental sustainability). There is actually sound evidence regarding the range of environmental impacts; it is well known that the food choices of the population affect environmental sustainability of the food supply, and conversely environmental sustainability of the food supply will affect the foods available for choice (Lea, 2005; Weber & Matthews, 2008; Lang, 2012; Steinfel et al, 2006; Commissioner for Environmental Sustainaility Victoria, 2008; Garnett, 2008; Lawrence et al, 2010; Marlow et al, 2009; Reijnders and Soret, 2003; Leitzmann, 2003, Frey and Barrett, 2007). We welcome a critical review of the existing literature, using a framework that is appropriate for evaluating studies pertaining to concerns about environmental sustainability.


The information provided in the appendix is only at the superficial level. Rather than providing a comprehensive summary of the evidence available, the appendix instead provides readers with relevant reference to assess the evidence themselves. This lack of critical discussion suggests the government does not take the issue of dietary choice and environmental sustainability seriously, despite a growing amount of convincing evidence to suggest significant associations and the importance of ensuring environmental sustainability to ensure national food security.


Content specific recommendations


Section G1 ‘

We note, with disappointment, that the relationship between food sustainability and national food security has not been sufficiently discussed. There is strong evidence to suggest that environmental sustainability is required to protect food security for Australians. Environmental sustainability concerns compromise the food security of the nation and consequently the food security of future Australian generations (UNEP, 2010; Larsen et al, 2011). Appropriate dietary guidance and/or recommendations are required to ensure a sustainable, and consequently secure, food supply through which Australians are able to access and consume a nutritious diet to protect and promote public health. Additionally, the importance of food sustainability in contributing to food security should be acknowledged within the guidelines and should be consistent with the National Food Plan (currently being developed). The benefits of peri-urban agriculture should also be further outlined/ discussed, as this has the potential to provide nutritious foods at an affordable price to consumers whilst being a more environmentally sustainable option as it would assist Australia in being a leader in decreased carbon emissions, due to lowered requirement for the transport of food (Houston, 2003).


This section appears to assume significant prior knowledge for the reader. In doing so, it fails to actually discuss the environmental impacts of the current food system. Rather, it implies the variation in impact depending on the outcome investigated then places the responsibility on the reader to use the references provided to investigate further. Failure to critically discuss the environmental impacts of the current food system in a transparent manner downplays the importance of the issue and suggests failure on the government’s part to provide sufficient consideration and attention to this important issue.


Additionally, this section utilises complex terminology such as ‘bidirectional relationship between food systems and environmental degradation’. It is our belief that national guidelines be appropriate for use among a broad range of consumers and as such these terms should be simplified or further explanation provided.



  •     Provide a critical summary of the important associations between environmental sustainability and national food insecurity
  •     Provide a critical summary of the environmental impacts of the current food system
  •     Simplify or provide further explanations for complex terminology


Section G2  ‘The nature and challenges of the evidence base’

This section provide an overview of the methodologies used to investigate environmental impacts. A glaring omission is an actual discussion of the evidence itself. A critical summary of the evidence would be of much greater use to consumers than a summary of methodologies for assessing environmental impact.

As discussed earlier, this section of the document implies that the evidence pertaining to environmental impacts of the food supply is weak at best, however this is not the case. We welcome reassessment of the existing evidence using a more appropriate framework for evaluation.



  • Provide a critical evaluation and summary of the evidence of environmental impacts of the current food system using a more appropriate framework for evaluation for environmental studies


Section G3 
’The guidelines through an environmental lens’

This section provides practical considerations and environmental benefits matched to relevant guidelines. However, the recommendations provided lack appropriate detail, are not integrated with the actual guidelines and fail to address the key issues pertaining to dietary choices and environmental sustainability. As such, the guidelines fail to provide clear advice about how to eat sustainably that could be acted on by health professionals or translated into advice for the general public.


We argue that the recommendations for environmental considerations provided for each guideline require more specific information regarding the specific foods to select to minimise environmental impact. It is common knowledge that there are certain foods that are compliant with the guidelines that have significant environmental impacts, for example beef, bottled water and fruits and vegetables that are produced all year round (as opposed to only grown seasonally). We would recommend that this section provide more specific advice regarding foods to select and foods to avoid to minimise environmental impact.


Additionally, these guidelines also avoid the key issue of the need to move to a more plant-based diet, that is lower in animal-protein diet, for which the strongest evidence of a positive effect on environmental sustainability exists.


Finally, the recommendations made in this section do not all appear to be underpinned by sound scientific evidence, in particular the recommendation to select a variety of dairy products rather than relying on one particular item from this food group. The inclusion of references to support the recommendations would provide solid and transparent justification for the development of the recommendations to ensure sustainable eating.


Guideline 1 ‘Avoid over-consumption of food and drinks’

Despite being based on sound evidence, we argue that this recommendation does not provide sufficient detail to allow for dietary choices that are consistent with environmental sustainability. This recommendation should encourage the avoidance of overconsumption of discretionary food items, or extras, with reference to some of the specific types of foods in this category such as soft-drinks, sweets and confectionary. These foods are energy dense, contribute minimally to nutrition and yet require large amounts of processing, packaging and transport, constituting an unnecessary waste of resources. Furthermore, not only are these options associated with undesirable impacts on environmental sustainability, but undesirable health consequences, in particular the development of overweight and obesity (Hensrud, 2004; Egger, 2008). A reduction in consumption of these items would provide significant benefits to both health and environmental sustainability (Health Council of the Netherlands, 2011).


Given the inclusion of physical activity for weight management in the first guideline, we would also welcome the development of practical considerations that highlight the benefits of physical activity to both health and environmental sustainability. For example practical considerations could include more regular use of public transport, or walking or cycling, instead of driving, which would serve to increase energy expenditure for the individual while reducing carbon emissions. (Egger, 2008).


Guideline 2 ‘Within food groups, choosing a variety of nutritious foods may minimise environmental impact and promote biodiversity in food production’

We argue that without discussion or explanation around the concept of biodiversity the full importance of this recommendation will not be realised. Biodiversity refers to the variety and variability of ecosystems, animals, plants and microorganisms that are required to both sustain human life as well as key functions of the organisms. As such, the inclusion of further information and strategies to maintain biodiversity are warranted within the guidelines, to ensure a sustainable, diverse food supply to benefits the health of all Australians. We request that the government include strategies that align with the various treaties and action plans as outlined by the Food and Agricultural Organisation of the United Nations (FAO, 2012).


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.’

A glaring omission from the recommendation is information about the importance of reducing the consumption of animal protein. There is strong and consistent evidence that a shift towards a more plant-based diet with lower consumption of animal protein is more conducive to both health and environmental sustainability and is the most significant step towards creating a food supply that is conducive to environmental sustainability (Health Council of the Netherlands, 2011). To provide correct, evidence-based advice to ameliorate the environmental impacts of the current food supply the document should be explicit in encouraging a reduction in intakes of meat and replacement with wholemeal breads and cereals, legumes, vegetables and fruits (Marlow et al, 2009; Reijnders and Soret, 2003; Leitzmann, 2003, Frey and Barrett, 2007; Health Council of the Netherlands, 2011.


Consuming quantities in line with the Australian Dietary Guideline for this food group, and consuming a mixture of milk, cheese and yoghurts, rather than rely on any one food, will help minimise the environmental burden associated with consumption of foods from this group.

This suggestion that consuming a mixture of dairy products rather than relying on one option within this food group will decrease burden on environmental sustainability does not appear to be underpinned by sound scientific evidence. The most significant environmental impacts associated with dairy products result from milk production on the farm (Dairy Australia, 2004), not the processing of milk into secondary products such as yogurt and cheese. As such, encouraging consumers to select from a variety of dairy products is unlikely to provide benefits for environmental sustainability. This guideline should be adjusted to suggest consumption of dairy in line with recommendations by the Dietary guidelines, and the replacement of extra unnecessary servings with wholemeal breads and cereals, legumes, vegetables and fruits. This has been identified as a key priority in reducing the environmental impact of the current food supply (Health Council of the Netherlands, 2011).


Failure to acknowledge the importance of lowering meat and dairy consumption as priority areas to enhance environmental sustainability suggests that the government is bowing to pressure by food industry to not include advice about sustainable eating in the guidelines. The existence of these pressures have been documented (Sweet, 2010; Creswell, 2010). We argue that dietary guidelines should be driven by evidence, rather than industry. The current food system, which is driven by industry and based on economic development, has produced a food supply that is abundant in energy-dense foods that are not conducive to environmental sustainability.


‘Choose fish and other seafood from stable stocks.’

We argue that this recommendation is vague as it fails to provide sufficient detail to assist consumers in making the recommended choices. Further information should be included, either here or in section G4 ‘Practical tips’, so provide specific guidance as to optimal selection of ‘better 
choices’  as identified in the Australian Marine Conservation Society’s Australian Sustainable Seafood Guide (AMCS, 2012).



  • Re-word Provide additional detail to the recommendation in guideline 1 to specifically encrouage the limitation/ avoidance of overconsumption of discretionary foods and drinks
  • Include an extra guideline, or be more explicit about the need to move to more plant- based diet, with lower consumption of animal protein
  • Adjust the guideline encouraging the consumption of a variety of dairy products rather than reliance on one type of food,  to encourage consumption within the recommendations of the guidelines and replacement of extra, unnecessary serves with wholegrains, and seasonal fruits and vegetables
  • Provide specific examples of sustainable fish species/ sources to select


Section G4 Practical tips

This section provides an opportunity to provide practical tips that are translatable to health practictioners and consumers. We note that there is limited detail provided for the information already included in this section, and that certain important information has been omitted. We would welcome the inclusion about more specific advice or information to encourage and assist consumers to reduce meat intake and increase consumption of wholegrains, legumes and seasonal fruits and vegetables. We would also welcome practical advice/ information on purchasing local or seasonally available foods


Section G5 ‘Key references’

This section provides limited information about the quality of evidence pertaining to the sustainability of different food choices. Additionally, there is no acknowledgement of how the quality of evidence was determined. 

We applaud the provision of references to allow readers to consult the evidence themselves, however note the omission of a critical summary of the evidence in the document. Failing to provide a critical assessment of the evidence suggests failure on the part of the NHMRC to acknowledge the importance of dietary choice on environmental sustainability.



  • The document should not only provide the references for readers to consult the evidence themselves, but should also provide a critical and comprehensive summary of this evidence using an appropriate framework for the evaluation of environmental studies


 Thank you for the opportunity to respond to the public consultation for the draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens. In summary, we welcome:

  • The addition of a critical analysis of the evidence pertaining to food choices and environmental sustainability
  • More detailed, practical and translatable recommendations for making food choices that are conducive to environmental sustainability
  • More explicit acknowledgement of the need to adopt diets that include more plant-based food options, such as wholegrains and seasonal fruits and vegetables, whilst lowering consumption of animal-protein
  • The integration of all of the above with the Dietary Guidelines


Yours sincerely,

Associate Professor Danielle Gallegos (AdvAPD)


On behalf of


Professor Lynne Daniels (APD)

Dr Katherine Hanna (APD)

Mary Hannan Jones (AdvAPD)

Kelly Stewart (APD)

Rebecca Ramsey (APD)

Helen Vidgen (APD)

Carolyn Keogh (APD)

Emma Richardson (APD)


School of Exercise and Nutrition Sciences

Queensland University of Technology

Kelvin Grove Campus


Locked Mail Bag No 2






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Page reviewed: 4 February, 2013