tfX response to Turning the Tables: Transforming School Food
Response on behalf of tfX by Oliver Tickell, tfX, 379 Meadow Lane, Oxford OX4 4BL, 5 December 2005.
1. General points arising
1.1 We wish to begin by quoting the following extract from the "Foreword from the Secretary of State" to Turning the Tables: Transforming School Food.
"Improving school lunches must be seen as part of a wider strategy for improving school food, which in turn is part of our goal to ensure every school is a ‘healthy school‘ ... We want to improve the health and well-being of school children; and ensure their readiness to learn ... The combination of food-based and nutrient-based standards represents a significant and positive change to the rules governing food in schools, not only tightening up on the types of food that should be offered but also stipulating the essential nutrients, vitamins and minerals required for a healthy school menu ... We would welcome your views on whether the combination of nutrient-based and food-based standards proposed will drive the necessary improvements in school lunches; and on how best the Government and the School Food Trust can support local authorities and schools in rising to the challenge of meeting the nutrient-based standards."
The intentions expressed are laudable, but incomplete. In order to "make every school a 'healthy school'" it is ncessary not only to include essential nutrients, but also to exclude harmful dietary elements. Our specific interest is with the trans-fatty acids which occur primarily in hydrogenated vegetable oil, which are responsible for a host of adverse health impacts. We note that, for example, the Danish Nutrition Council (now the Danish Fitness and Nutrition Council), on official agency of the Government of Denmark, concludes that, gram for gram, trans fats are ten times more deleterious to cardiovascular health than saturated fats.
See The influence of trans fatty acids on health, Fourth edition 2003. A report from the Danish Nutrition Council by Steen Stender and Jørn Dyerberg, available on-line in English at www.meraadet.dk/gfx/uploads/Rapporter_pdf/Trans%20fatty%20acids_4.th%20ed._UK_www.pdf . This report is the most complete, thorough and well-informed of which we are aware, and in our view supercedes the most recent official UK report [the Report of the Cardiovascular Review Group of the Committee of Medical Aspects of Food Policy number 46 (Department of Health 1994, HMSO) Nutritional Aspects of Cardiovascular Disease] as it has accommodated almost a further decade of scientific and medical investigation.
To quote but one summary paragraph from The influence of trans fatty acids on health:
Since 1994, the influence of a high intake of industrially produced trans fatty acids in promoting the development of heart disease has been further documented by, among other things, the presentation of four major prospective population studies. The studies indicate that, gram for gram, the intake of trans fatty acids as compared with saturated fatty acids is associated with an approximately 10-fold higher risk increment for the development of heart disease. The suspicion of an adverse effect of trans fatty acids early in life has been further confirmed. The possible effect of trans fatty acids on the development of cancer is still unclarified. Data from both epidemiological and mechanism studies gives rise to the justified suspicion that trans fatty acids increase the risk of type 2 diabetes. Studies have also been presented justifying further studies concerning the possible effect of trans fatty acids in promoting allergic diseases in children and concerning the possible influence of trans fatty acids on body fat distribution and insulin sensitivity.
1.2 We are therefore dismayed that there is no guidance on trans fatty acids in Turning the Tables: Transforming School Food, nor of the hydrogenated oils which contain them. This is a severe deficiency which needs to be rectified. It is also important to note that, in the context of concern about saturated fat, hydrogenation is, in effect, artificial saturation, and produces saturated fat from unsaturated oils.
1.3 We also note, as far as the contents of the document are concerned, a distressing ignorance of the important role of dietary fats. The overwhelming impression given could be summarised as "fat is bad, and saturated fat is especially bad". In fact, of course, fat is a necessary part of the human diet. Fat is an excellent source of dietary energy, and the historic European diet is fat-rich, with some 40 percent of dietary energy delivered by fat.
1.4 In addition we need to consider the role of the Essential Fatty Acids - in effect the vitamins of the fat world, which are needed by the human body for a host of functions and which it is unable to make itself. These comprise the omega-3 and omega-6 fatty acids. In general, omega-6 fatty acids are abundant in the diet, as they are present in common vegetable oils. However the less chemically stable omega-3 oils are generally deficient in modern diets, and often severely so.
Omega-3 oils, where present, are selectively destroyed by hydrogenation. They are present in cereal germ, but of course the germ is absent in white flours and other refined cereal products, and in any case the omega-3 oils do not survive prolonged storage. Omega-3 fatty acids are also present in most products of free-range animals, including milk, meat and eggs. However animals kept indoors and fed intensive diets produce low levels of omega-3.
Due to the essential role of omega-3 fatty acids in the development of the brain, and the nervous and ocular systems there it is essential to ensure a sufficiency of omega-3 in the school diet.
In addition it has been observed that the uptake and utlisation of omega-3 fatty acids in inhibited by trans fatty acids, and that this may result in functional deficiency of omega-3 fatty acids even where they are present in the diet. This therefore provides another important reason to exclude trans fatty acids from the school diet. We quote from the Report of the Cardiovascular Review Group of the Committee of Medical Aspects of Food Policy number 46 (Department of Health 1994, HMSO) Nutritional Aspects of Cardiovascular Disease:
"188.8.131.52. There are suggestions that trans fatty acids can compete with essential fatty acids, especially at low intakes of the latter, for delta-6 and delta-5 desaturases, the enzymes responsible for converting linoleic acid (C18:2 n-6) and alpha-linolenic acid (C18:3 n-3) to their longer chain derivatives, respectively arachidonic acid (C20:4 n-6) and eicosapentaenoic acid (C20:5 n-3) . Recent research suggests that this might occur even when essential fatty acid intake is not marginal, although this needs to be confirmed ."
2. Specific points arising
We now wish to raw attention to specific parts of the report and its Appendices.
2.1 Suggest rewrite:
"1.28. Eating and physical activity patterns have changed dramatically. Children's diets now contain too much saturated fat, sugar and salt; and too few fruits and vegetables, and foods containing essential vitamins and minerals."
"1.28. Eating and physical activity patterns have changed dramatically. Children's diets now contain too much saturated fat, trans fatty acids, sugar and salt; and too few fruits and vegetables, and foods containing essential vitamins, omega-3 essential fatty acids and minerals."
2.2 Part 1.30 should include information about the levels of trans fatty acids in children's diets.
2.3 Part 1.31 has a lot to say about the amount of fat consumed as a result of fried foods. However the health impact depends critically on the kind of fat employed. In particular if long-life partially hydrogenated frying oils are used, trans fats may have significant health impacts; saturated fats will also be present.
2.4 Referring to the tables in 2.5, we deplore the absence of any maximum level of trans fatty acids in these guidelines. At the very least the Panel should apply the Danish legal standard that trans fatty acids should comprise no more than 2% of the fat and oil content (note: not total energy) of any foodstuff, however we would argue for a more stringent 1% standard. Given the difficulties involved with obtaining a fatty acid profile for foods, we advise that this standard be achievable in two ways:
- if hydrogenated oil is present in any foodstuff, the trans fatty acid standard should be applied directly;
- if hydrogenated oil is absent from a food, that food should be deemed to meet the standard on trans fatty acids.
2.5 Also referring to the tables in 2.5, we deplore the failure to include minimum levels of omega-3 fatty acids to be achieved in school meals. In general, it has been found beneficial for children of school age to ingest at least one gram of omega-3 daily and we believe that school meals should provide this entire amount in view of the poor diet that many children will encounter outside school.
We note the recommendation that oily fish, rich in omega-3, be on the menu, however this measure, while welcome, is insufficient to ensure that sufficient omega-3 is in fact ingested since many children will not choose it. Omega-3 fatty may also be supplied from free-range animal produce, freshly-ground whole grain cereals, freshly-ground oil seeds including flax seed and hemp seed, and green leaf vegetables. We recommend that all such dietary sources of omega-3 be made use of in school meals to achieve desirable levels.
2.6 Referring to Appendix 2: Fat and Saturated Fat. We request that
- this section be renamed "Fats and Oils"
- it be amended to include information on the dangers of trans fatty acids,
- it be amended to include information on the nutritional role of the essential fatty acids, and the particular need to ensure that sufficient omega-3 fatty acids are present in the diet given that these are frequently deficient.
We note the paragraph on oily fish. However omega-3 fatty acids are also found in other foodstuffs and reliance should not be placed on oily fish alone to supply omega-3. It can also be supplied from free-range (and often by implication organic) animal produce, freshly-ground whole grain cereals, freshly-ground oil seeds inlcuding flax seed and hemp seed, and green leaf vegetables.
2.7 Referring to Appendix 3, part 40, which in a cursory fashion addresses the question of trans fatty acids, we quote in full:
"In addition some Panel members expressed concern over trans fatty acids, which are known to raise blood cholesterol. However adult survey data indicate that intakes are well below (1.2% energy) the maximum threshold level for health (2%). The Panel also felt that adopting a standard to limit the saturated fat content of school meals would contribute towards controlling levels of trans fatty acids, and that additional food based standards (see below) would include restrictions on foods which tend to be higher in trans fats."
We wish to point out:
- it is inappropriate to use adult survey data to estimate children's intake of trans fatty acids. Our children's health is sufficiently important that it deserves to be informed by data specific to children, not to adults or the general population.
- such FSA dietary surveys as the one quoted invariably measure average trans fatty acid consumption. Our main concern is for those who consume above average levels of trans fatty acids due to a a diet rich in fried foods, bakery products, cheap sweets, ice creams and other processed foods which are a rich source of trans fatty acids. These people will include many children especially those in lower socio-economic groups and it is unacceptable and irresponsible so blithely to dismiss this significant impact on their health.
- The idea that there exists a "maximum threshold level for health (2%)" is erroneous. Given that the cardiovascular impact of trans fatty acids is ten times more severe than that of saturated fat (Danish Nutrition Council) this is clearly untrue. The 2% figure arises from the Report of the Cardiovascular Review Group of the Committee of Medical Aspects of Food Policy number 46 (Department of Health 1994, HMSO) Nutritional Aspects of Cardiovascular Disease. The actual recommendation given is:
"6.2.10. Recommendations. We recommend that ... Trans fatty acid intake in the population should not increase beyond the current estimated average of 5 g/day or 2 per cent of dietary energy and consideration should be given to ways of decreasing the amount present in the diet."
The report does not state that 2% of energy is a safe level of trans fatty acids, but that intake should not rise above this level, and that ways should be found to reduce consumption. We deplore the misuse and misquotation of the Review Group's findings, of which this is only one of many examples. We also note that the major population studies (referred to in the Danish Nutrition Council report above) which provide up to date evidence of the dangers of trans fatty acids have all emerged after the publication of the COMA report and that a similar report taking in the evidence available today would need to take a considerably stronger view on trans fatty acids, as indeed was taken by the Danish Nutrition Council and subsequently by the Danish Government.
- The statement that "adopting a standard to limit the saturated fat content of school meals would contribute towards controlling levels of trans fatty acids" is entirely unsupported by any evidence or even reasoned argument. In fact, it is almost the opposite of the truth. By focussing on reducing the use of saturated fats, including animal fats, some caterers may be encouraged to use partially hydrogenated fats with a lower saturated fat content. Since trans fatty acids are ten times more dangerous for cardiovascular health than saturated fatty acids (See Danish Nutrition Council, above), this would have the opposite of the desired effect. We are not opposed to the standard on saturated fats, but believe it needs to be complemented a by a similar standard on trans fatty acids as set out above.
- The statement that "additional food based standards (see below) would include restrictions on foods which tend to be higher in trans fats" may be the case, or not, however it is hard to know since no evidence in support of the statement is given. Even if it is true the fact is that the health impacts of dietary trans fatty acids are seriously adverse and that trans fatty acids need to be limited in their own right, not merely as a possible or potential side effect of limiting the provision of particular foodstuffs which may or may not contain trans fatty acids. Since trans fatty acids present at even 1% are as dangerous to cardiovascular health as 10% of saturated fat (Danish Nutrition Council) every effort should be made to eliminate trans fatty acids as a primary objective, not as a secondary result.
This report dismisses the need to take action on trans fatty acids. It does so on the basis of inadequate evidence, guesswork, misunderstood COMA recommendations and apparent ignorance as to the seriousness of the impacts of trans fatty acids on health. This decision to dismiss the question of trans fatty acids and allow our children to be poisoned by them until the matter is revisited in 2011 is ill-informed, irresponsible and severely deleterious to the health of our children and especially those in lower socio-economic groups whose consumption of trans fatty acids is likely to be highest.
The Panel's further deliberations on trans fatty acids also need to be adequately informed before decisions are reached on this serious matter, and we therefore advise that all panel members should read the Danish Nutrition Council report already referred to, The influence of trans fatty acids on health, Fourth edition, available at www.meraadet.dk/gfx/uploads/Rapporter_pdf/Trans%20fatty%20acids_4.th%20ed._UK_www.pdf , as a matter of urgency.
We also note the inadequate attention given to the question of adequate consumption of essential fatty acids and omega-3 fatty acids in particular. This whole question needs to be revisited and the Panel's deliberations informed by an expert in the field such as Dr Alexandra Richardson of Food and Behaviour Research (www.fabresearch.org).