CFG
24/05
Letter dated 25 October
2005 from Foodaware to Kevin Naylor, Nutrition Division, Food Standards
Agency:
Dear Mr Naylor
Consultation on UK target nutrient specifications for manufactured
products used in school meals
Further to my letter of 18 October, our members have now commented
on this issue. The text below represents a slightly amended version
of that letter. I would be grateful if you could consider this our
final response and replace the earlier letter accordingly.
Nutritional standards for school meals existed in the UK from the
Second World War until they were removed in the early 1980’s.
Specifying the nutrient content of manufactured products for use in
school meals is a useful step towards reintroducing full nutritional
standards for school meals. Foodaware welcomes this initiative from
the Food Standards Agency.
Working together with industry on this is a good way to ensure that
the recommendations are practical and are more likely to result in
substantial changes in practice.
Although the overall method of deriving the targets is set out, it
is difficult to look at the target nutrient specifications and understand
how each was derived. The system seems to produce anomalies and the
possibility that foods with poorer nutrient profiles may be considered
satisfactory because they meet the particular target set. For instance,
vegetarian sausages have a more stringent nutrient profile to meet
than meat sausages. Higher salt levels are accepted for meat sausages
– presumably because of the other sodium products used in sausage
meat production.
Where some foods in a category are at present reaching the targets
set, then it is reasonable to expect others to be able to do so with
reformulation. Garlic bread has been given a high total fat target
but still no products are available that meet this target. Chips are
widely regarded as being too high in fat and yet compared to garlic
bread, as currently used, they are much more acceptable. A danger
with these nutritional specifications may be that any foods meeting
the target are considered ‘healthy’ foods whilst this
is not necessarily a true reflection of the situation. We believe
that those foods that cannot be reformulated to produce a reasonable
nutritional profile should not be considered suitable for school meals.
Additional consideration would need to be given to how often such
foods with poorer nutritional profiles are acceptable in the midday
meal. We assume this will be considered in the nutritional standards
for school meals due in the autumn 2006.
The targets for vegetarian products often seem to be set more stringently
than meat based products – is this because it is assumed vegetarian
products should be able to meet these higher standards? At present
few vegetarian products are meeting these target specifications.
The suggestion that vegetarian products are moving away from both
nuts and soya needs further consideration. Nut allergy (but not all
nuts) can produce very severe reactions in some people and the reluctance
of caterers to use some nuts is therefore understandable. However,
soya allergy is not so severe and many other foods may also produce
allergic reactions: dairy products and eggs etc could also be restricted
if soya is considered too allergenic to be included. Reducing vegetarian
food choice by restricting the use of protein rich vegetarian products
may be counterproductive and a situation which nutritional targets
should not be reinforcing.
Quorn could become a dominant ingredient in school vegetarian catering
if this issue is not considered at this stage. This is a relatively
new product and over reliance on it would need to be considered by
the relevant Advisory Committee on Novel Foods.
It is important that minimum protein targets are set for vegetarian
products. However, these do not necessarily need to be as high as
for those in meat products (which are not set at a level of protein
requirement but are much higher).
We note that these specifications are voluntary and hope that this
will prove to be successful. All concerned wish to provide school
children with a healthy diet.
We urge FSA to actively encourage manufacturers supplying foods to
school caterers, and caterers supplying school meals, to adopt these
specifications once agreed. Their use by schools in procurement contracts
would be a useful way forward and would encourage their widespread
adoption by the food industry.
In conclusion, we welcome this initiative but stress that the situation
will need to be monitored and, if it is found that the targets are
not being widely adopted, consideration should be given to a legislative
route.
Foodaware is content for this response to be made publicly available.
Yours sincerely
Lucy Harris
UK Co-ordinator
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