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

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General Comments

Thank you for the opportunity to make a submission on the draft Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens.

 General points

 Ample evidence

There is ample evidence to support the inclusion of a specific Dietary Guideline on the relationship between environmental sustainability, the security of the future food supply and relevant individual (and healthful) dietary choices. This evidence includes that contained in:

  • the Prime Minister's Science, Engineering and Innovation Council’s (PMSEIC) recent report, the Garnaut Climate Change Review as well as information available on websites from government departments;
  • published papers from many leading scientific researchers;
  • support from governments in countries such as the Netherlands, Norway, Germany, Sweden, Switzerland and the United Kingdom;
  • a statement from the United Nations’ Food and Agriculture Organization urging governments to develop policies and guidelines that incorporate sustainability issues related to diet.

 A missing guideline?

In its goals for revising the Dietary Guidelines, the NHMRC had originally included a statement to develop guidelines that were “culturally acceptable, socially equitable and environmentally sustainable“. This point produced considerable antagonism (and resultant publicity) from some sections of the food industry.

While I appreciate that NHMRC is aiming to work with other government departments in looking at future food sustainability, I am concerned that the issue of sustainability did not appear to be a priority in the recent Green paper for the National Food Plan. This suits some sections of the food industry that appear keener to take a ‘business as usual’ approach to issues related to sustainable food futures.

NHMRC is renowned as taking an evidence-based approach, but it appears in this instance that groups with a conflict of interest have seized the issue. While I understand the need to work with industry, I do not believe a viewpoint from a group with a conflict of interest should take precedence over the evidence backing the need for a particular Dietary Guideline. Governments should set the agenda; industry should respond to that agenda rather than the reverse.

 Public Submissions

The list of experts and others included above could be greatly expanded, but serves to illustrate the fact that this is an important issue both within Australia and throughout the world. Australia is not on its own in considering this topic. Indeed, by omitting a Dietary Guideline specifically related to sustainable food choices, Australia lags behind the evidence and many experts.

The interest in a Dietary Guideline for sustainable food choices was obvious from the public submissions received. Of the public submissions received, 71 out of 201 commented on the environment and dietary choices, only two wanted less reference to the issue. One of these was from an industry body that had been openly critical of any suggestion to include sustainability issues; the other was specifically critical of a particular sentence included in the main text.

On other issues raised in public submissions, any valid evidence presented was taken into consideration and appropriate explanations or changes were made. By contrast, the bulk of the information on the subject of sustainability – mostly raised by jurisdictions and others who supplied many valid references - was not incorporated.

 An appendix?

Failing the inclusion of a specific Dietary Guideline on sustainable food choices, an Appendix is the next best (although inadequate) option. In view of the fact that the 2003 Dietary Guidelines includes an Appendix on sustainability, it would indeed be a backward step to omit an Appendix in the current Guidelines. I would therefore support including an Appendix on this issue, if that is the best we can have.

This submission includes some small suggested changes to the draft Appendix.

Specific points

Ample evidence exists

Much evidence on the need for sustainability in food production and selection of foods has been presented, including in

  • the PMSEIC report1 (quoted in the Draft Appendix);
  • statements from the UN’s Food and Agriculture Organisation2, the UK House of Commons3 and official government reports such as The Foresight Report4 and Professor Garnaut’s report for the Australian government5.
  • Reports from various countries, such as the Netherlands6, Norway7 Germany8.

 Government departments also include data supporting action, including the

  • Department of Climate Change9;
  • Department of Sustainability, Environment, Water, Population and Communities10;
  • Department of the Environment, Water, Heritage and the Arts11,12.

Many well-known researchers, including some currently working in Australia, have presented evidence of the importance of considering environmentally sustainable foods in health policies and specifically consideration in dietary guidelines (including Holdsworth (2010)13; Kickbusch (2010) 14 Larsen et al (2008)15; Mozaffarian (2010)16 Yngve and Tseng (2010)17.

Others have included details of the economic importance of including sustainability for future food production and food security, including FAO18, Lang (2012)19, McMichael et al (2007)20, the United Nations Environment Program21, Friel22, Tapsell et al (2011)23 and others.

The Dietary Guidelines Working Group also included a well respected world expert on the issue of environmental sustainability and the security of the future food supply. This also provided an excellent opportunity for NHMRC to formulate a Dietary Guideline relating to this issue.

 An Appendix

As mentioned earlier, including an Appendix on the important topic of sustainable food choices is very much a second-best choice. Its inclusion, however, might at least lead to full consideration for the next iteration of the Guidelines.

A few small changes I would suggest include:

1. A concise summary of the evidence for why more sustainable choices are important.

2. More definite advice on the need for changes to ensure future sustainability of the food supply. This should include information on specific food choices within food groups – for example,

  • information on why plant food choices from the ‘protein’ food group should be encouraged rather than choosing animal products5,6, 24;
  • information on the importance of biodiversity in food choice;
  • information on sustainable seafood choices;
  • more information on using seasonal produce from Australian farms;
  • more information on use of tap water.

3. Omit the strange advice about consuming a mixture of milk, cheese and yoghurt. This section appears to ignore the fact that different sized portions of dairy products reflect the amount of milk used in their manufacture. Some comparisons with obtaining nutrients found in milk with obtaining similar nutrients from plant based alternatives would be useful.

4. The writing in the Appendix could be simplified to make it more accessible to a wider audience.

References cited

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

2. Burlingame, B. and S. Dernini, Sustainable diets and biodiversity: Directions and solutions for policy, research and action 2012, United Nations Food and Agriculture Organization.

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

4. 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

5. Garnaut R. 2008. The Garnaut Climate Change Review. Canberra, Australian National University: 680.

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

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

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

9. Department of Climate Change. 2009. Australian National Greenhouse Accounts: National Inventory by Economic Sector. Canberra, Department of Climate Change, Australian Government.

10. Department of Sustainability, Environment, Water, Population and Communities. 2010. Biodiversity: A summary of Australia's Biodiversity Conservation Strategy 2010-2030. Canberra, Natural Resource Management Ministerial Council, Department of Sustainability, Environment, Water, Population and Communities.

11. Department of the Environment, Water, Heritage and the Arts. 2009. Assessment of Australia's Terrestrial Biodiversity 2008. Canberra, Biodiversity Assessment Working Group, National Land and Water Resources Audit

12. Department of the Environment, Water, Heritage and the Arts. 2010. National Waste Report 2010. Canberra, Department of the Environment, Water, Heritage and the Arts, Australian Government.

13. Holdsworth M. Sustainability should be integral to nutrition and dietetics, Human Nutrition and Dietetics. 2010; 23: 467-468.

14. Kickbusch I. The Food System: a prism of present and future challenges for health promotion and sustainable development. 2010. Health Promotion Switzerland.

15. Larsen K, Ryan C, Abraham AB. Sustainable and secure food systems for Victoria: What do we know? What do we need to know? 2008. Melbourne, Victorian Eco-Innocation Lab (VEIL), University of Melbourne.

16. Mozaffarian D, Ludwig, DS Dietary Guidelines in the 21st Century: a Time for Food, JAMA. 2010; 304(6): 681-682.

17. Yngve A, Tseng M. Dietary guidelines and goal-setting, Public Health Nutrition 2010; 13(8): 1149-1150.

18. FAO. The State of Food Insecurity in the World 2006. Rome, Food and Agriculture Organisation.

19. 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.

20. McMichael A, Powles J, Butler C, Uauy R. Food, livestock production, energy, climate change and health, The Lancet. 2007; 370: 55–65.

21. UNDP. Human Development Report: Fighting climate change: human solidarity in a divided world. 2007. New York.

22. Friel S. Climate change, food insecurity and chronic diseases: sustainable and healthy policy opportunities for Australia, NSW Public Health Bulletin, 2010; 21(5-6): 129-133.

23. Tapsell LC, Probst Y, Lawrence M, Friel S, Flood V, McMahon A, Butler R Food and nutrition security in the Australia-New Zealand region: impact of climate change. World Rev Nutr Diet. 2011;102:192-200.

24. Haines A, McMichael AJ, Smith KR, Roberts I, Woodcock J, Markandya A, Armstrong BG, Campbell-Lendrum D, Dangour AD, Davies M, Bruce N, Tonne C, Barrett M, Wilkinson P. Public health benefits of strategies to reduce greenhouse-gas emissions: food and agriculture. Lancet. 2009;374(9706):2016-25.

Page reviewed: 4 February, 2013