HES 22 - Cymdeithas Arlwywyr Awdurdodau Lleol (Saesneg yn unig)
Re: Healthy Eating in Schools (Wales) Measure 2008
On behalf of the Local Authority Caterers Association (LACA) in Wales I am writing in response to the consultation document and your letter dated 16th May 2008.
The membership of the LACA Welsh region includes the catering providers in 18 of the 22 local authorities in Wales who produce and serve approximately 340,00 meals each day in Welsh schools, together with the suppliers of goods and services for the provision of school meals in schools.
In response to the questions posed:
1.Is there a need for an Assembly Measure to promote healthy eating in schools in view of existing initiatives within this policy area?
It is the view of the Welsh LACA members that there is no need for a measure as school meal providers are currently working within existing legislation. The statutory nutritional standards required for school lunches are laid down in the Education (Nutritional Standards for School Lunches (Wales) Regulations 2001.
The guidance documents provided by the Welsh Assembly Government provides advice for school governors, head teachers and caterers on the statutory standards required for school lunches.
Local authority caterers’ in Wales are totally committed to the healthy eating principles and are already providing healthy and nutritious meals within the financial constraints and budgets within their authorities.
From the perspective of providing school meals, caterers’ have the view that guidance and partnership working has been sufficient and has worked well to date and believe that regulation and enforcement would be an additional and unnecessary burden and cost.
The LACA members welcome and support The Appetite for Life Action Plan that was launched in November 2007. This sets out the strategic direction and actions required to improve the nutritional standards of food and drink provided in schools in Wales. Its development was formed as a result of a consultation exercise with various stakeholders that included children and young people’s views, together with lessons learnt from other parts of the UK.
The pilot research project will commence in September 2008 for two years and four Welsh authorities will partake in the implementation of the seven actions as laid out in the plan.
This will enable the testing of the actions to ensure they are workable and will raise any practical implications prior to implementation as regulation.
Caterers will be supporting colleagues in the four authorities involved in the project and will be able to discuss issues and problems together with sharing ideas and “show casing” best practice.
A Whole School Approach is the underlying “thread” throughout the plan and encourages co operation and partnership with key stakeholders together with cross border working.
As with any initiative, caterers in the local authorities work closely and engage with the children and young people in schools as their views need to be reflected in any outcomes or decisions and changes that affect the school meal service.
2.Do you support the key provisions set out in the proposed Measure,
i.e.
The duty of Welsh Ministers, governing bodies, head teachers and local education authorities to promote healthy eating in schools
Healthy eating should be part of an inspection regime and includes reporting requirements on Welsh Ministers,the Chief Inspector of Education and training in Wales and governing bodies
Power of Welsh Ministers to specify maximum levels of salt, sugar and artificial additives in food and drink provided for pupils on school premises
Encouraging take up of school meals and protection of identity of those who receive them; and
The duty on local education authorities to ensure availability of drinking water for pupils
The consultation with LACA members shows that there is support of the key provisions in principle as they are broadly similar to those outlined in the Appetite for Life Action Plan.
The key difference is that the time frame for the Appetite for Life Action Plan provides a period to “try and test “ the actions to ensure that they are workable prior to regulation.
There will be a requirement as part of this process to engage with school colleagues so they are aware of the duty and the impact this may have during the school working day.
1. What are the practical implications of putting these provisions in place?
The main concerns that local authority caterers’ have in Wales are the financial aspects and implications on existing budgets together with the time frame of bringing in the regulation.
We have strong concerns about the current position in which the school meals service finds itself in with regard to being ”singled out” as the way forward in improving children’s diets. The school meal represents less than a third of a child or young persons food intake per day and the services only operate for five days per week, 75% of the year as the school terms total 39 weeks.
The legacy of policy, legislation and bureaucracy over the past few years has left the school meal service in its current under funded state and has undermined caterers’ ability to provide higher levels of food provision now being called for.
Additional funding will be required and time will be needed to engage with pupils in respect of the importance of a balanced diet and healthy eating particularly in secondary schools.
It is the view of LACA members that the cost estimate outlined in the measure of “an anticipated maximum investment £17million - £38 million for Wales over a three year period (Annex A) falls short of the amount that we believe is actually required to provide healthier school meals in Wales.
Due to the lack of investment over the last ten years the kitchens and equipment will require upgrading/replacing/improving to meet the standards.
Not withstanding the huge increase in the cost of food items experienced over the last six months and estimates of 10 – 15% for the forthcoming year, the financial estimates outlined do not include additional funding resources required to meet the cost of the food on the plate to meet the new standards and nutritional requirements.
More funding is required for authorities to increase the hours worked by kitchen staff to enable them to produce meals from raw ingredients.
Due to the volumes of meals required, staff hours will need to increase as they will be required to commence work early in the morning to prepare, cook and provide meals for the school lunch breaks which commence at noon.
It is for these reasons that it is recommended that more research is carried out to form a more realistic and accurate cost of the provision of healthier meals is carried out as a matter of urgency.
A return to health and welfare values will require a serious determination and commitment by government to fund the service and to make the improvements to the service that will appeal to today’s discerning young people.
2. Are there further provisions that you would like to see added to the proposed Assembly Measure?
Packed Lunches should be included in any regulation or legislation
LACA members are of the view that any regulation or legislation made by the Welsh Assembly Government should include food that pupils bring in from home – i.e. the packed lunches and food for breaks etc. that are currently not controlled.
If pupils are allowed to bring in crisps, sweets, chocolate and other sugary food and fizzy drinks into school then this will undermine the healthy eating work going on in schools.
Legislation to ensure the lunch period should be a minimum of one hour
Nutritional education and cookery lessons as part of the curriculum activity recently introduced in our Welsh schools is welcomed by LACA members as it is vital that what is learnt in the class room is put into practice and taken from the classroom to practice in the dining hall.
However with the current trend of schools shortening lunch breaks nutritional education is not going to be much benefit if schools do not allow pupils sufficient time to eat lunch.
Caterers in some schools in Wales are serving 600 – 800 pupils in a 35-minute lunch period!! This is contrary to the beliefs and commitments we all have in giving pupils time to make educated healthy choices and sit and eat in a social environment.
Healthy schools and healthy pupils should be seen as important as academic achievement.
The school lunch period should be treated as the “9th lesson” of the day and not just as a means of escape for teaching staff and a commercial sideline that is someone else’s problem.
Free School Meals for all pupils in Wales
The question is raised by members that if the Welsh Assembly Government is truly serious about improving the long term health of our children and young people in Wales then should we not be considering or calling for school meals to be available to every pupil free of charge?
School meals should be regarded as an integral part of the academic day for all pupils. Just as lessons are free for all, free school meals for all would ensure that every pupil is treated equally with the same chance for a healthier diet and future life.
There would be a significant amount of cost savings if free meals for all were provided. Current school administration costs would reduce as there would be no requirement to separately record free meal and paid meal pupils. Both the school and caterers’ would save money in the labour costs attributed to cash taking, recording and cash collection areas. Till costs and maintenance costs would also be another area of cost saving together with the external contracts with companies like Securicor that collect cash from schools and bank on their behalf.
Although there will be a need for investment – long term benefits will include the reduction of the health bill and cost to our National Health Service in Wales.
Policy of keeping Years 7 8 & 9 in at lunch time in secondary schools
Currently there is no clear guidelines or policy relating to the requirement of keeping pupils on school premises during the lunch time period.
The caterers’ in Wales are of the view that this is undermining the work currently going on in schools to providing healthier options through the services that they provide.
Pupils are going to nearby food outlets and purchasing non healthy options and bringing them back and consuming on school premises.
This then has a detrimental impact on the motivation and morale of kitchen staff who are actively encouraging children and young people to make healthy choices whilst members of their peer group are sitting with them and eating items like chips, pies and pasties etc.
The aims of improving the health of the young generation in Wales will not significantly improve to meet the targets set if this area is not addressed.
It is recommended by the caterers’ that the Welsh Assembly Government should regulate this area of concern and as a minimum schools should not allow pupils from Years 7,8 & 9 off school premises during the school day.
3. Do you think the proposed Assembly Measure will achieve its overall purpose and aim, i.e.to enable a holistic, comprehensive “made in Wales” policy on nutrition in schools to be developed and implemented?
Unfortunately in Wales and unlike our European counterparts, we live in a processed food culture and the reality is that children and young people will not eat items that they do not recognise on their plate.
We cannot be expected to enforce a radical change of eating on children in school when we as a nation have yet to embrace this healthier eating philosophy.
We need to nurture a social environment in this country that renders healthier food more attractive and accessible. This together with a policy of positive price discrimination in favour of healthier food options will encourage greater family purchase and thereby greater recognition/acceptance by children and young people of these food in their every day lives.
It therefore has to be recognised that this change in eating culture will take a long time – at least another generation to make the marked improvements in healthy choices.
It is for this reason that LACA members are unclear as to how an enforcement route will speed the process up?
LACA is still of the view that based on the current food culture in this country, imposing yet more radical regulatory changes is unlikely to bring about the major improvements everyone is anticipating in the school meal consumption made by the children and young people in Wales. Potentially there will be further confusion and food waste that will not help meet the aims and targets of improving the health and reduce the levels of obesity in Wales.
On behalf of the LACA Welsh region members, I would like to thank the National Assembly for Wales for the opportunity for the involvement in the consultation process for the Measure and would be pleased to discuss any parts of the response if required.
Yours sincerely
Mrs Anne Bull
Chair – LACA Welsh Region
