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DfES School Food Consulation

Submission of tfX - the campaign against trans fats in food. 29 March 2005

As extended and amended, 31 March 2005.

0. Contents.

  1. Introduction.
  2. What are trans fats?
  3. What health problems are associated with trans fats?
  4. Does school food contain trans fats?
  5. What specific health problems regarding trans fats apply in a school context?
  6. What other factors apply to the use of hydrogenated oil?
  7. The present situation.
  8. Our recommendations.
  9. Further information and contacts.

1. Introduction

We welcome the initiative of Government to improve the quality of school meals, including nutritional quality. The tfX campaign was founded for a specific purpose - to bring about the exclusion of health-damaging trans fats from the human diet. However we will also address the question of optimising the fatty acid profile in the school diet for nutritional benefit.

2. What are trans fats?

Trans fats are fats (triglycerides of fatty acids) which contain trans fatty acids. These are the trans isomers of unsaturated fatty acids, which normally exist in nature in the cis configuration.

The trans fatty acids of concern from a health perspective are the articifial trans fatty acids, especially those formed during the process of hydrogenation (hardening) of unsaturated oil. The negative health impacts which we refer to below arise solely as a result of eating these artificial trans fatty acids. Naturally-occurring trans fatty acids, such as those found in dairy produce and the meat of ruminant animals (many of them conjugated trans fatty acids) present no apparent health risks.

In the following paragraphs, therefore, the term "trans fat" is used to describe only trans fats formed from the artificial trans fatty acids. The main source of such trans fat is hydrogenated oil. This is mostly labelled as "[partially] hydrogenated vegetable oil". However sometimes the vegetable oil will be named, for example as "soybean oil" or "palm oil".

3. What health problems are associated with trans fats?

A wide range of health problems are associated with trans fats. These problems are believed to arise because they are not found in nature, and so we have no inherited ability within our bodies to recognise them and deal with them appropriately.

The following negative effects have been reported. Dietary trans fats

More information on these health impacts, including references to original scientific papers, are to be found on the tfX website at www.tfx.org.uk.

4. Does school food contain trans fats?

We are not aware of any specific information on the quantities in which trans fats occur in the school diet. However it is probable that the school diet does contain significant levels of trans fat, and is richer in trans fat than the UK diet as a whole. This is because:

In the absence of specific information on trans fat levels in school meals, it must therefore be assumed that school food, in general, is rich in trans fat. We advise that research be undertaken to verify the actual levels encountered.

5. What specific health problems regarding trans fats apply in a school context?

A number of the health problems associated with trans fats are of specific concern to school children. These are:

6. What other factors apply to the use of hydrogenated oil?

When a liquid oil is [partially] hydrogenated, there are two effects:

So far we have discussed the negative health impacts of trans fats. However we should also take into account:

In replacing liquid vegetable oils with hydrogenated vegetable oils, therefore, the food industry is converting health-promoting fats with both health-damaging trans fats, and saturated fats which are generally held to be in surplus in the UK diet as a whole.

7. The present situation.

We are concerned to discover that there appears to be no existing regulation of, or guidance about, the quantities of trans fat in children's food. For example, the school food guidelines which came into effect on 1 April 2001 (to be found on the DfES website at www.dfes.gov.uk/schoollunches/) make no mention of trans fats or hydrogenated oils.

Insofar as these guidelines refer to dietary fats, the concern is wholly focussed on the total quantity of fat, and saturated fats. In both cases the presumption appears to be that fat is bad, and that saturated fat is especially bad. Specific advice is even given to avoid coconut oil, although this is actually a very healthy oil.

The DfES also places considerable reliance on the The Caroline Walker Trust (CWT) Nutritional Guidelines for School Meals, to the extent of publishing these guidelines on its own website. Again, the CWT Guidelines contain no reference to trans fats or hydrogenated oils, and the exclusive focus as far as fats are concerned is on limiting both total fat, and saturated fat. The CWT advise that total fatty acids should provide no more than 35 percent of food energy, and that saturated fatty acids should provide no more than 11 percent of food energy.

We also note that neither CWT nor DfES make any mention of the essential omega-3 and omega-6 essential fatty acids, as found in oily fish and flax oil, which play a particular role in the development of the juvenile brain and nervous system.

8. Our recommendations.

Based on the above considerations tfX recommends that:

  1. Nutritional standards and guidelines for school meals should include standards and guidance limiting the levels of trans fats.
  2. These limits should be set at a very low level, effectively eliminating trans fats from school food.
  3. The best way of reducing trans fat levels in school food may be to ban the use of hydrogenated oils and fats as ingredients. We realise that the level of trans fat in hydrogenated oil is highly variable, and in the case of fully hydrogenated oil that there is no trans fat present. However as a general rule the lower the fraction of trans fat in hydrogenated oil, the higher the fraction of saturated fat, and saturated fat is, in general, already in dietary surplus. In addition a minority of persons suffer from allergic or other intolerance to hydrogenated oil and this will satisfy their dietary needs.
  4. Positive efforts be made to optimise the fatty acid profile of school food. As a general rule:
    1. trans fatty acids should be eliminated;
    2. monounsaturated and polyunsaturated fatty acids should be encouraged, subject to a general limit on total fat intake, and present in roughly equal proportions;
    3. saturated fatty acids should be constrained to no more than one third of the overall fatty acid intake (in line with CWT guidance).
    4. the essential omega-3 and omega-6 fatty acids should be present in an average school meal at a level to satisfy 100% of daily dietary needs;
  5. These requirements should be legally binding on all providers of school meals.
  6. DfES, in association with the Food Standards Agency and Local Education Authorities, should monitor the fatty acid profile of school food to ensure adherence to the principles set out above, and take appropriate action enforcement action as necessary.

9. Further information and contacts.

Further information on trans fats is available on the tfX website at www.tfx.org.uk .

tfX may be contacted by way of the campaign's founder: Oliver Tickell, 379 Meadow Lane, Oxford OX4 4BL. email: info@tfx.org.uk.

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