tfX response to "A Framework for Setting Standards for School Food Other Than Lunch"
We are concerned to note that the Framework in its present form does not address the question of trans fats in children's food and snacks.
Given (The influence of trans fatty acids on health, Fourth edition, Danish Nutrition Council 2003) that trans fatty acids are, weight for weight, approximately ten times more deleterious to cardiovascular health than saturated fatty acids, as well as giving rise to a host of other adverse health consequences including type 2 diabetes and functional omega-3 essential fatty acid deficiency, this is a serious omission.
For example, section 2.5 of the Framework states:
2.5 Examples of how a food based standard might be qualified, using these different approaches, is shown below: "No savoury snacks to be sold in school unless they contain low amounts of fat, saturated fat, salt and sugar (i.e. uses FSA's proposed signposting scheme) "Only cakes and biscuits which contain low amounts of fat, saturated fat, salt and do not contain high amounts of sugar" (i.e. uses FSA's proposed signposting scheme) "Only breakfast cereals which meet the TNS for these products" (i.e. uses TNS) "The only products allowed in vending machines must meet a defined nutrient profiling score" (i.e. uses nutrient profiling).
As noted, there is no mention of trans fatty acids in this suggested standard. We also note that the example given in 2.8 excludes trans fatty acids from its breakdown of different types of fat. We therefore call for sections 2.5 and 2.8 to be amended to include mention of trans fatty acids and the need to exclude them from children's diet.
Based on Danish public health legislation, we propose that trans fatty acids be present in all children's food, including snacks, at a maximum level of 2 percent of total fat content (not of total energy content). This standard should, in general, be considered to be met other than in products containing hydrogenated oils, the main source of health-impairing trans fatty acids.
Ample justification for such a step may be found in the Danish Nutrition Council report already referred to, The influence of trans fatty acids on health, available at www.meraadet.dk/gfx/uploads/Rapporter_pdf/Trans%20fatty%20acids_4.th%20ed._UK_www.pdf .
We also strongly recommend that members of the Committee, before reaching a decision, inform themselves on the health hazards associated with trans fatty acids by reading this report, which led directly to the Danish legislation on trans fatty acids.
Oliver Tickell, 6 January 2006.
tfX - the UK campaign against trans fats in food.