10 Jun 2009
IPH response to consultation on the Food Standards Agency Strategy for 2010 to 2015
The Institute of Public Health in Ireland
The Institute of Public Health in Ireland (IPH) promotes co-operation between Northern Ireland and the Republic of Ireland. It aims to improve health by working to combat health inequalities and influence public policies in favour of health. IPH promotes co-operation in research, training, information and policy in order to contribute to policies which tackle inequalities in health.
IPH welcomes the Food Standards Agency Strategy for 2010 to 2015 and the opportunity to comment on the publication. We restrict our comments to the “Healthy Eating for All” aspect of FSA’s purpose with particular reference to local development in Northern Ireland.
1. IPH applauds the rigorous approach the Food Standards Agency (FSA) has taken to its strategic planning and the delivery of its objectives. It welcomes the FSA’s plans to develop a diet-related illness approach and a Science and Evidence Strategy.
2. IPH supports the call for “Healthy Eating for All”. Given the disproportionate burden of diet-related illnesses experienced by people in the lower socio-economic groups, IPH urges the FSA to explicitly incorporate health inequalities in its strategy. Northern Ireland’s public health strategy “Investing for Health” has a strong emphasis on tackling health inequalities which is reflected in the prominence given by Northern Ireland’s regional Public Health Agency.
3. Many other agencies are working to “improve the balance of diet”. The FSA can maximise its impact on public health if it:
• Works from within a clear framework1
• Identifies, within that framework, the actions which it can uniquely contribute
• Works with other agencies2 which have responsibility for health improvement and tackling health inequalities
4. IPH supports greater North-South cooperation and encourages FSA to strengthen its collaboration with the Food Safety Authority of Ireland and safefood.1 In Northern Ireland, the Department of Health, Social Services and Public Safety (DHSSPS) is currently developing an Obesity Prevention Strategic Framework2 such as the regional Public Health Agency in Northern Ireland
Consultation question one
We intend to concentrate our efforts where we can have the most impact on public health. Do you agree that this should be our overall strategic approach (our purpose, objectives and outcomes)? If not, please explain briefly your reasoning.
IPH believes that concentrating on where the FSA can have the most impact on public health is entirely appropriate. The implications of this aspiration need to be described and incorporated into each level of the FSA’s strategic architecture. The development of a diet-related illness approach will help the FSA refine its priorities, plan its activities and maximise their impact.
Given the disproportionate burden experienced by the lower socio-economic groups, and the FSA’s plans to develop a diet-related illness approach, IPH suggests that FSA adopts a purpose which makes tackling inequalities a key objective.
It is unclear what the objective “Improve the balance of diet” means. As it stands, it is difficult to understand how the outcomes contribute to the achievement of this objective.
IPH suggests that this second objective is extended to include “reduce the disproportionate burden of diet-related illness experienced by the less advantaged”.
The outcomes listed will undoubtedly contribute to achieving the objective “Improve the balance of diet” but are unlikely to achieve it on their own. If the FSA identified the other outcomes that are required (from the framework suggested in point 3. above), then it could co-ordinate its activities with other activities aimed at delivering those outcomes.
Consultation question two
We have described the priorities on which we think we need to concentrate in the 2010 to 2015 period in order to make the most impact. Do you agree these are the right priorities? It would help if you could make it clear which priorities your comments relate to and explain briefly your reasoning.
1. A clear framework and established models for behaviour change (mentioned in point 3. above) would be useful in identifying priorities.
2. IPH believes that the need for action to reduce harm from obesity is urgent and urges the FSA to consider advocating for stronger government action including legislation.
3. All policies should be subject to a Health Equality Impact Assessment and local councils should strengthen their planning function to ensure greater control of “fast food” establishments.
4. The priorities “Increase consumption of healthier foods, especially fruit and veg” and “Stimulate demand for lower salt and saturated fat products” relate to outcomes that have not been listed. They relate more directly to consumer demand and food consumption, and IPH suggests that the FSA considers adding such outcomes.
5. The priority “… modelling the effects of changes in consumer habits and products” will be useful for several planning purposes but does not seem to sit easily under the outcome “Retail products and catering meals are healthier”. This priority relates to science and evidence and is perhaps better placed there. The meaning of the words “and products” are unclear.
6. Some of the cross-cutting priorities do not relate directly to the population-level outcomes and objectives on page 11 of the consultation document. They would perhaps better fit into the FSA’s new Science and Evidence Strategy.
Consultation question three
We have set out some key questions we need to address to ensure we have the
science, evidence and analysis we will need to support achievement of the proposed FSA strategy (paragraphs 41-46). Please let us have your views on the answers to these questions. Have we missed any key issues?
What are the major gaps in the science, evidence and analysis which need to be addressed in order to deliver our objectives?
1. This is the first time that obesity will be more common amongst poorer people than those who are well off. If the FSA is to achieve “safe food and healthy eating for all” we need to understand why this is so.
2. Food poverty – physical and financial access to safe, healthy food amongst disadvantaged, vulnerable and social groups – should be a key element of the FSA’s targeted risk-based research programme. This is especially important during the economic recession when it is likely that the quality of diets, particularly amongst these groups, is likely to deteriorate.
3. Further research will be needed to develop the FSA’s diet-related illness approach. In particular, this will involve
• a better understanding of the burden of diet-related illnesses and their causes (in terms of DALYs – disability adjusted life years lost)
• modelling the impact of alternative interventions designed to prevent diet-related illnesses. The latter is an extension of the FSA’s priority “modelling effects of changes in consumer habits and products”.
What types of science and evidence gathering should we undertake, or encourage others to undertake, to address these gaps?
If the FSA is to maximise its impact on public health, its research has to be translated into effective action. The FSA should support further research in the “dissemination and implementation sciences” which focus on the organisational, cultural and social, political, individual and professional, financial and practical barriers to change.
Who should we be working with to address these gaps and to use the science, evidence and analysis effectively?
1. The inclusion of the research and development function in the office in Northern Ireland’s new Public Health Agency offer the opportunity to bring the research agenda closer to the evidence needed to support better public health. In Northern Ireland, IPH encourages the FSA to work closely with the Public Health Agency when it develops its Science and Evidence Strategy.
2. To take into account the influence of local contextual issues on FSA’s activities, the transferability research finding across the four countries in the UK is critical. This may require allocating some part of the FSA’s research budget to address issues in each country.