Dr Sinéad Furey - Written evidence (FPO0019)

 

SUMMARY OF RESPONSE

1) What are the key causes of food insecurity in the UK?

  1. In our 2019 Op-ed for RTE Brainstorm [Caraher, M & Furey, S. (2019) Are food banks merely a sticking plaster for food poverty? https://www.rte.ie/eile/brainstorm/2019/0207/1028061-are-food-banks-merely-a-sticking-plaster-for-food-poverty we cited the causes of food poverty to include insufficient income, benefit delays, benefit changes, debt and increasing housing and utility bills. All this is exacerbated by a low-tax, low welfare economy, where the agenda is to keep voters happy by keeping taxes low and penalizing and demonizing those on low-incomes.

 

  1. In Ulster University’s work on food poverty we devised a 6As model whereby food policy must consider the accessibility (physical, economic and informational), affordability; availability; adequacy; awareness and appropriateness of food to and by consumers. To this we could also add anxiety – to take account of the mental health implications arising from (food) poverty. To this end, we opine that access to basic services and choice – including food, socio-cultural activities, and informational access – must not be depleted for consumers.

 

 

Can you outline any significant trends in food insecurity in the UK? To what extent (and why) have these challenges persisted over a number of years?

  1. The appropriate measurement of food poverty, the inability to afford or access a healthy diet (Radimer et al., 1990), is critical for targeting food and economic aid and informing cross-sectoral government policy. However its progress is complicated by the complexity of the phenomenon and the multiple tools and approaches that exist to measure food poverty (Jones et al., 2013). In January 2019, the Environmental Audit Committee published its latest report on the Sustainable Development Goals in the UK, highlighting the need to ensure Government cross-departmental understanding and action on hunger, and implement strategies for improvement and monitor progress. With no agreed indicator, the Government has not measured the prevalence of food poverty over time to identify those who are unable to afford and access sufficient food. However, the Office for National Statistics in the United Kingdom will measure food poverty from April 2019 using the ten-item, adult-only HFSSM as a module in the Family Resources Survey, with first results available from April 2021 (Butler, 2019).

 

  1. Recent studies have highlighted how food poverty is a rising problem in affluent societies (Davis and Geiger, 2017; Torheim et al., 2010). This is particularly apt in the United Kingdom, which is recognised as the fifth richest world economy (OHCR, 2018), and of which Northern Ireland is part. The Food and Agriculture Organization estimates that 8.4 million (10.1%) people in Britain were living in households where the adult reported food insecurity (Taylor and Loopstra, 2016).

 

  1. There is no universally agreed food poverty indicator. Unsurprisingly therefore, there have been calls for the routine collection and analysis of data to determine the extent of food poverty in the United Kingdom and NI. An April 2016 workshop, Time to count the hungry: The case for a standard measure of household food insecurity in the UK (http://foodresearch.org.uk/wp-content/uploads/2016/04/Food-Pov-Alliance-report-25-04-04-16.pdf), achieved policy expert consensus calling for the UK government and its devolved regions to quantitatively monitor the extent of food poverty in their respective administrations.

 

  1. In the absence of an agreed indicator by which to measure food poverty, Ulster University Business School conducted research with Causeway Coast and Glens (CCAG) Borough Council in 2015. The full report is available from: https://www.causewaycoastandglens.gov.uk/uploads/general/CCAG_Food_Poverty_Report.pdf

 

  1. In summary, our findings concluded that food poverty has reached a concerning level within the CCAG Borough, with affordability and accessibility proving important points of concern. Two in five (41%) respondents at risk of fuel poverty also reported being unable to comfortably feed themselves and their families three meals per day all of the time, and this statistic worsened among larger households, where 45.7% reported not being able to comfortably afford to feed their families all of the time. Twenty-two respondents (6%) reported rarely or never being able to afford three meals per day, while one in six (17%) reported missing meals because their food budget was inadequate (24.8% of larger households), and one in eight (13% of all households) reported missing a meal in the previous fortnight due to budgetary restrictions – an indictment of the severity of food poverty among this cohort. Three in ten (31%) reported being forced to make a choice between food and other essentials. More than half of the respondents (54%) reported some anxiety about whether their budget would fulfil their food needs. An important minority (13% – 40%) cited their inability to afford social activities that their peers may take for granted. This sense of being socially excluded from both low-cost, routine to more expensive, occasional activities is worrying given how social inclusivity contributes to quality of life. Respondents indicated support for various local authority-organised activities including quality, local food and cookery demonstrations to help overcome the negative repercussions of food poverty. The research concluded that efforts must be ongoing to address the structural causes of food poverty for a truly sustainable solution.

 

  1. More recently, Ulster University Business School researchers conducted a Food Affordability survey (2018) using different food poverty measures to investigate the inter-reliability of various food poverty indicators and determine if there is a single best fit indicator for NI to inform evidence-based policy making. Our research concluded that between one in five and one in three respondents reported experiencing at least one food poverty manifestation.

 

 

2) What are some of the key ways in which diet (including food insecurity) impacts on public health?

  1. Rising food costs have implications for public health, whereby consumers for whom food becomes prohibitively expensive respond by reducing the nutritional quality and quantity of food they eat (Griffiths et al., 2013). Such coping strategies may result in malnutrition, overweight and/or obesity. Mental health issues are also related to the obesity cycle and this is important in the schools context, given the importance of body image and associated mental health conditions at this life stage. According to Safefood (2017, p.9[2]) “children and adolescents who are overweight or obese have lower self-esteem and social support, greater loneliness, sadness and nervousness, are more likely to drink and smoke and have lower health-related quality of life in adulthood.”

 

  1.          At the population level, in Northern Ireland the direct and indirect costs of overweight and obesity in 2009 were estimated to be £369,799,820 (Safefood, 2012); the equivalent of more than £1 million per day highlighting that a great deal of attention in public spending is focused on public health. In attempting to reduce this public health spending burden, a cross-departmental policy imperative – A Fitter Future for All: Framework for Preventing and Addressing Overweight and Obesity in Northern Ireland 2012-2022 – has focused the attention of relevant stakeholders to make a collective effort to combat the obesity epidemic. The Strategy recognises the importance of continuing to encourage NI food manufacturers to reformulate their food and drink products to reduce saturated fat, sugar, salt, calorific value and provide smaller portion sizes of energy-dense foods and beverages. Further, the Strategy recognises the role of retail promotions in consumers’ food and drink purchasing behaviour and has committed to encouraging and enabling food retailers to ‘consider reducing point of sale placement of foods which are high in fat, salt, sugar and increasing exposure to promotion of healthier foods’ (Department of Health Social Services and Public Safety, 2012, p.73).

 

  1.          These are important commitments given how British Retail Consortium (BRC) (2009) commissioned consumer research and concluded ‘price’ to be the main barrier to eating a healthier diet for one-fifth (21%) of shoppers. Shoppers opined that healthy foods are too expensive and unhealthy foods are promoted more than their healthy counterparts. 

 

 

Has sufficient progress been made on tackling childhood obesity and, if not, why not?

  1.          Evidence suggests that children are disproportionately over-represented in food poverty (DfC, 2019) estimates and that the nature, extent and effects of child food insecurity are poorly understood. (Food) poverty in children may have implications for educational attendance, engagement, attainment and progression (Food Foundation, 2019), life chances, and potential to be meaningfully economically active in adult life with the potential to result in a new epidemic and mental health emergency from widespread stress and anxiety associated with food poverty (Morgan, 2019, available from: https://www.thelancet.com/journals/laneur/article/PIIS1474-4422(19)30163-2/fulltext).

 

  1.          UNICEF estimates that 10% of UK children are living in severely food insecure households, but this survey is based on a relatively small sample. Meanwhile, an estimated 5.6% of people aged 15 or over in the UK reported that they were struggling to get enough food to eat and a further 4.5% reported that, at least once, they went a full day without anything to eat. It has been concluded, based on these preliminary estimates, that the UK ranks in the bottom half of European countries (Taylor and Loopstra, 2016).

 

  1.          According to the Children’s Future Food Inquiry (2018), an estimated 3.9 million children are living in poverty in the UK (in Northern Ireland proportionately more children experience poverty than any other sub-group of citizens: 22% – approximately 99,000 – of children are reported to be in relative poverty (before housing costs) and 18% – approximately 82,000 – are reported to be in absolute poverty (before housing costs) – Department for Communities, 2017). However, we know little about how many of these children experience food insecurity, how it impacts on their lives and what could be done about it.  The Trussell Trust has given out food parcels to more than 500,000 people in 2014/15 of which half are estimated to be for children. Trussell Trust data confirm that during the 2018-2019 financial year, more than 36,000 three-day emergency food packages (15,000 to children) were distributed in Northern Ireland at more than 20 food banks across the region (a 13% increase on the previous year) (Bain, 2019).

 

  1.          The published literature discusses the phenomenon of ‘mother buffering’ (when children are protected from the effects of food insecurity by alterations in maternal dietary intake (Maxwell, 1996)). Food security is a household level issue involving a managed process and parents sacrifice and try to buffer children against suffering (Radimer et al., 1992, Wehler et al., 1992). Adults first begin to decrease the nutritional quality of the foods purchased and as finances become further constrained adults then decrease the quantity of food consumed to make more food available for the children in the household (Radimer et al., 1990). Interestingly, the literature found that children are aware of food insecurity (Fram et al., 2011; Bernal et al., 2012) despite such buffering.

 

  1.          Evidence suggests that even where parents protect their children from having to cut back on food, the indirect effects are likely to be profound.  The cheapest foods are often the least healthy and the nutritional quality of diets varies substantially between rich and poor in UK. 

 

  1.          As above, Ulster University research found, worryingly, how 79 households with children (from a sample of 944 households) confirmed experiencing at least one food poverty measure. To reduce the quantity of food they serve to their child(ren) is an indication of the extent of the food poverty experience in these households.

 

  1.          Meanwhile, popular media sources report how teachers are using their own money to buy food and clothes for their poverty-stricken pupils. A recent media story in Scotland (BBC News Scotland, April 2018) outlined evidence from the NASUWT teachers' union’s submission to Holyrood’s Education Committee, that increasing numbers of children were given food, clothes and equipment by staff, at their own expense. A survey it carried out of teachers in Scotland in 2016 showed 71% had seen pupils coming to school hungry, while 81% noticed youngsters attending classes without the correct equipment. A further 79% were concerned about students lacking in energy and struggling to concentrate because of a poor diet.

 

  1.          With the implementation of Universal Credit and associated changes to the eligibility criteria for free school meals entitlement, it is anticipated that up to 2.6 million children whose parents are on benefits could be missing out on free school meals by 2022. Previous to the introduction of Universal Credit, all children of benefit recipients – who were all unemployed – were eligible for free school meals but in April 2018 the criteria were tightened based on income. In Northern Ireland, the net earnings threshold will be £14,000. Northern Ireland consultees raised concerns about the loss of eligibility for those families currently entitled, particularly relating to the receipt of tax credits and for whom this added criterion may create hardship, particularly for larger families.

 

  1.          UK statistics suggest that before the introduction of universal infant free school meals, 1.7 million children were eligible for free school meals on the basis of their family income – fewer than those living in poverty but many more than those receiving food parcels (Children’s Future Food Inquiry, 2018). 

 

 

3) How accessible is healthy food? What factors or barriers affect people’s ability to consume a healthy diet? Do these factors affect populations living in rural and urban areas differently?

 

  1.          Approximately 37% of the Northern Ireland population lives rurally; this is a significant minority and it is entirely appropriate that their experiences of poverty and social exclusion are ameliorated. It is our position that Northern Ireland must not typify a two-tier system whereby householders and consumers are disadvantaged by consequences of their rurality.

 

  1.          By virtue of our dispersed population, Northern Ireland consumers already experience high costs in relation to fuel and transport expenses which, in turn, increase their potential to experience poverty and social exclusion compared to their urban counterparts. For this reason, any collaborative effort is welcomed to reduce poverty generally and health inequalities; food, fuel, financial and transport poverty; and social exclusion more specifically.

 

  1.          Access to basic services and choice – including food, socio-cultural activities, and informational access – must not be depleted for our rural dwellers. Furthermore, physical access is compounded for rural dwellers where they may experience the double disincentive of car-lessness and/or problematic access to purposive public transport amenities. At Ulster University Business School we are currently developing a Food Poverty Risk Indicator which will be used to map and identify the above deficiencies in underserved rural areas.

 

  1.          PhD research at Ulster University is exploring if householders are disadvantaged as a consequence of their rurality. McClelland et al.’s (2018) preliminary study of food poverty and rurality identified the rural premium of food shopping as +£800 per year. (Further information is available at: McClelland, N., Furey, S., McKenzie, P. and Hollywood, L. (2018) Rural poverty: The impact of rurality on consumers’ access to food services, using a food poverty risk index. In Food and poverty in the UK: Taking stock, moving forward - Conference proceedings. London: King’s College, London. https://www.enuf.org.uk/sites/default/files/2018_food_poverty_conference_programme.pdf
  2.          and slide deck available at: https://www.enuf.org.uk/sites/default/files/resources/natasha_mcclelland_-_tuesday_17_april_pitch_session_3_exploring_the_need_for_targeted_interventions_-_natasha_mcclelland_ulster_university.pptx_read-only.pdf.

 

  1.          Given the links between diet and health, food and health policies should complement each other. Ulster University Business School (in conjunction with project partners) was commissioned to conduct research among Republic of Ireland food retailers. The report was commissioned to provide an overview of foods on promotions made available by retailers in the Republic of Ireland and to classify them in accordance with the healthy eating guidelines. By using the Food Pyramid as the primary tool for categorisation and by exploring consumer perceptions and buying behaviours of foods on promotion and how they relate to dietary practices,  an understanding of the influence of promotions on food choice was evidenced. Furthermore, insights on food promotions were elicited from public health stakeholders and retailers.

 

  1.          The research aimed to provide an evidence base to inform the development of recommendations for strategies to enhance consumer availability of healthier food products sold on promotional offer in retail stores in the Republic of Ireland. Our safefood[3]-funded research report on the classification of food promotions among Republic of Ireland food retailers, What’s On Offer?  The types of food and drink on price promotion in retail outlets in the Republic of Ireland[4], we independently audited the type and nutritional quality of food and drink on promotional offer in retail outlets. A total of 69,620 food products on promotional offer were identified from the audit of a range of supermarkets, discounters, and convenience stores in summer 2016 (July/August) and spring 2017 (February/March). The products were categorised in-line with the food pyramid and also categorised using a nutritional quality score. More than one-third (35%) of the total sample of food and drinks audited were categorised as high in fat, sugar and salt, a clear over-representation of their distribution in the food pyramid. This figure increased to 56.1% for the amount of high fat, sugar and salt foods on promotion in convenience stores. The nutritional quality score was based on the energy, fat, saturated fat, sugar and salt levels of each food product, rated as high, medium or low nutritional quality. Using this measure, almost equal proportions of foods classified as having a low (27.8%) or medium (27.3%) quality score while 45% of the foods audited had a high nutritional quality score. Most promotions were price-based i.e. reduced price or volume-based i.e. receiving more of a product for the regular retail price. We also collected information on 786 products that were being promoted online by two retailers during a 12-month period in 2016-17. The results are similar to those of the in-store audit in that there was an over-representation of foods high in fat, sugar and salt on promotion, particularly during the winter season.
  2.          We strongly support the Department of Health and Social Care’s recent proposals contained within the consultation on restricting promotions of products high in fat, sugar and salt by location and by price to restrict volume-based price promotions that encourage consumers to buy more. An academic study[5] found that people prefer a bonus pack to a price discount because consumers do not suffer from guilty feelings or a need to justify a larger purchase of healthy foods. In contrast, consumers cannot generate good justifications for buying less healthy foods in bonus pack promotions because this would result in consuming more of the vice.

 

  1.          We welcome too the intention to shift the balance of promotions towards healthier options and maximise the availability of healthier products that are offered on promotion. We believe that such restrictions may act as a further catalyst to food manufacturers’ reformulation efforts to deliver a healthier and informed choice for consumers at the point of choice. These accord with the conclusions and recommendations of our recent research in the Republic of Ireland.

 

  1.          We welcome also restricting the placement of all HFSS food and drink products (whether pre-packaged or non-pre-packaged) at key selling locations such as store entrances, checkouts and aisle ends which can lead to pester power and impulse purchases of HFSS products. We support the proposal to remove confectionery products from checkouts and, wherever practicable, replace them with healthier options, such as fruit.

 

  1.          It is clear that promotions are considered and accepted by consumers to be a part of the shopping experience and indeed are a key influence on purchasing behaviour. Our consumer survey explored consumer perceptions and behaviours of foods sold on promotion. The survey was conducted across the Republic of Ireland with the primary household shopper (n=1,948). The majority of consumers reported that they regularly bought food on promotion (91.6%) and showed a preference for “price reductions that offer a cost saving” (92.9% reported buying these always, almost every time, occasionally or sometimes) and volume-based (“Buy One get One Free”) types of promotions (85.4%). It was clear that consumers’ motivations for buying food on promotion is variable as consumers engage differently with promotional food items depending on the product category on promotion and the consumers’ impulsivity, health consciousness, deal proneness and use of shopping list.

 

  1.          We conducted an accompanied shopping exercise with 50 participants and identified primarily positive attitudes towards food retail promotions due to their contribution to cost savings, particularly on branded products. All shoppers displayed a level of awareness regarding the availability of promotions on offer but engaged with them differently.

 

  1.          However, the profit and health agendas of retailers and public health representatives remain at odds in terms of consistency between policy and practice. We therefore believe that more support should be targeted at encouraging the promotion of food that is consistent with healthy eating and dietary guidelines and directed towards the promotion of positive health messages.

 

 

4) What role can local authorities play in promoting healthy eating in their local populations, especially among children and young people, and those on lower incomes? How effectively are local authorities able to fulfil their responsibilities to improve the health of people living in their areas? Are you aware of any existing local authority or education initiatives that have been particularly successful (for example, schemes around holiday hunger, providing information on healthy eating, or supporting access to sport and exercise)?

 

  1.          We believe there is particular scope for super councils to assume some responsibility for monitoring food poverty and targeting effective interventions where evidence identifies constituents to be experiencing/at risk of food poverty. Localised community planning powers should also consider retail planning proposals on a case-by-case basis to prevent potential for food deserts to realise in town centres.

 

 

5) What can be learnt from food banks and other charitable responses to hunger? What role should they play?

  1.          Food poverty has become a public health emergency and the number of emergency food parcels distributed by food banks has increased in number. Caraher and Furey’s book (The Economics of Emergency Food Aid Provision: A Financial, Social and Cultural Perspective) attempts to quantify the social cost of food aid; and the cost of restoring dignity to the recipients of welfare. We ask: Can we afford not to address this?

 

  1.          In my co-authored 2019 Op-ed for RTE Brainstorm [Caraher, M & Furey, S. (2019) Are food banks merely a sticking plaster for food poverty? https://www.rte.ie/eile/brainstorm/2019/0207/1028061-are-food-banks-merely-a-sticking-plaster-for-food-poverty we argued that food banks should not be normalised as the default solution to food poverty.  In my co-authored book with Professor Martin Caraher, [Caraher, M. & Furey, S. (2018) The Economics of Emergency Food Aid Provision: A Financial, Social and Cultural Perspective. 1 edn, London: Palgrave Macmillan eBook ISBN: 978-3-319-78506-6; DOI: 10.1007/978-3-319-78506-6; Hardcover ISBN: 978-3-319-78505-9 available from: https://doi.org/10.1007/978-3-319-78506-6] we explain how food banks can be classified as ‘successful failures’ (Ronson and Caraher 2016). Successful because they continue to grow and expand in respect of prevalence and people’s reliance on them, and failures as Lorenz (2012a, b) argues, because such initiatives distract from the underlying issues of food insecurity. In our Food Research Collaboration briefing [Caraher, M. & Furey, S. (2017) Is it appropriate to use surplus food to feed people in hunger? Short-term Band-Aid to more deep rooted problems of poverty. Food Research Collaboration. [ISBN 978-1-903957-21-9] available from http://foodresearch.org.uk/wp-content/uploads/2017/01/Final-Using-food-surplus-hunger-FRC-briefing-paper-24-01-17-.pdf] we describe how it should not be the duty of individuals or our community and voluntary sectors to perform the social security functions of our Government. Food banks serve to absolve the Government from its moral obligation to provide social security; essentially it depoliticizes the issue.

 

  1.          In our co-authored Independent Food Aid Network blog [Caraher, M. & Furey, S. (2019) Redistribution of surplus food is NOT the solution to food poverty. Available from: http://www.foodaidnetwork.org.uk/blog/dr-martin-caraher-and-dr-sinead-furey-redistribution-of-surplus-food-is-not] we argue that the current go-to response of increased reliance on food banks resourced by uncertain supplies of surplus food has not been effective in reducing hunger or supporting clients out of poverty in the longer term. North America has implemented this emergency response for decades and there are fears that food banks have become institutionalized there. The UK must learn from this history and strive not to replicate the practice here. Food poverty needs to be located within a context of dignity and the stresses of worrying day-in/day-out about food, its price and suitability for your family.

 

 

6) What impact do food production processes (including product formulation, portion size, packaging and labelling) have on consumers’ dietary choices and does this differ across income groups?

  1.          It is important to note that consumers are not a homogeneous group and Foster et al. (2014, p. 1359[6]) note that lower socioeconomic groups may respond differently to price reductions than other socio-economic groups. The academic literature is clear that there is a dichotomy presented between the cost and healthfulness of food. For example, Waterlander et al. (2010) cite several studies (Jetter & Cassady, 2006; Drewnowski et al., 2007; Maillot et al., 2007; Honkaen & Frewer, 2009) confirming that lower-income consumers’ primary influencing factor when buying food is price. These studies explain that dietary quality and dietary costs are positively related and more price-sensitive consumers appear less concerned about the health aspects of food.

 

  1.          In a context of widespread food poverty in the UK, where unhealthy items are cheaper than healthier foods, we believe that it is in governments’ interest to promote healthy eating practices by stringently limiting promotion of unhealthy foods which makes them even more affordable, and create a regulatory retail environment where largely healthier foods are on promotion, making them more affordable.

 

 

7) What impact do food outlets (including supermarkets, delivery services, or fast food outlets) have on the average UK diet? How important are factors such as advertising, packaging, or product placement in influencing consumer choice, particularly for those in lower income groups?

  1.          Ulster University Business School (in conjunction with its project partners)  report, What’s On Offer?  The types of food and drink on price promotion in retail outlets in the Republic of Ireland[7], concluded that 35% of food promotions were from the top shelf of the food pyramid (foods and drinks high in fat, sugar and salt) indicating an over representation of these foods by Republic of Ireland retailers. It is clear that promotions are considered and accepted by consumers to be a part of the shopping experience and indeed are a key influence on purchasing behaviour. However, the profit and health agendas of retailers and public health representatives remain at odds in terms of consistency between policy and practice. We therefore believe that more support should be targeted at encouraging the promotion of food that is consistent with healthy eating and dietary guidelines and directed towards the promotion of positive health messages.

 

  1.          We believe that high fat, sugar and salt promotional restrictions should apply to all retailers where food of any kind is sold, even if the retailer does not primarily sell food and drink. This will reinforce a level playing field and serve to familiarise consumers with healthier food and drink choices anywhere food and drink is sold in a retail or foodservice capacity.

 

 

8) Do you have any comment to make on how the food industry might be encouraged to do more to support or promote healthy and sustainable diets? Is Government regulation an effective driver of change in this respect?

  1.          We support the compulsory restriction of the promotion of high fat, sugar and salt foods as voluntary approaches around food promotion have been ineffective to date. By restricting high fat, sugar and salt (HFSS) promotions and by making food promotions more visible to consumers across a range of healthy food products, this will help to make the healthier food choice the affordable and easy choice for consumers when shopping for food in both retail and foodservice outlets.

 

 

9) To what extent is it possible for the UK to be self-sufficient in producing healthy, affordable food that supports good population health, in a way that is also environmentally sustainable?

  1.         The primary purpose of any agricultural policy must be to produce food to ensure security of supply. This is especially important in the context of the need for increased sustainable production (and consumption) and the need to feed a growing population (estimated to be 9 billion people by 2050) with fewer resources.

 

  1.         Any agri-food policy should include ‘health’. The links between diet and health are well established. Any future agricultural framework/policy would be incomplete without regard to the relationship between food, choice, nutrition and health. However, neither is it enough to be producing food which is safe and affordable – we must also be producing the right kind of food whereby agriculture, food production and health policies more closely complement each other. We therefore recommend encouraging the production of food which is consistent with healthy eating and dietary guidelines. This will require food innovation in developing healthy choices that meet simultaneously consumers’/the market’s changing demands and preferences. We believe that these gains cannot be at the expense of environmental sustainability and that the twin objectives of productivity and environmental sustainability should be mutually inclusive.

 

  1.          We believe that further reform of the Common Agricultural Policy and/or any development of a future agricultural policy framework is to be welcomed and policymakers should continue to aggressively pursue the decoupling of payments from production. Any future Agricultural Framework should represent meaningful support to farmers in recognition of their contribution to primary production but be conditional upon certain food safety, food quality, environmental, animal welfare and occupational safety standards (cross-compliance) while delivering a supply and choice of safe, wholesome and nutritious food at affordable prices. In this way, food and farming may be truly market-oriented and exploit evidence-informed, consumer-led opportunities alongside complementary (agri-)food and health policies to contribute to the achievement of the triple bottom line, whereby farmers and private industry may succeed in delivering market-demanded food in an environmentally responsible way, mutually supportive of people, planet and profit.

 

 

10) Can efforts to improve food production sustainability simultaneously offer solutions to improving food insecurity and dietary health in the UK?

  1.          We believe that sustainable production and consumption methods, coupled with complementary (agri-)food and health policies can contribute to the achievement of the triple bottom line, whereby all relevant parties deliver market-demanded food in an environmentally responsible way, mutually supportive of people, planet and profit.

 

 

11) How effective are any current measures operated or assisted by Government, local authorities, or others to minimise food waste? What further action is required to minimise food waste?

  1.          In our Food Research Collaboration briefing [Caraher, M. & Furey, S. (2017) Is it appropriate to use surplus food to feed people in hunger? Short-term Band-Aid to more deep rooted problems of poverty. Food Research Collaboration. [ISBN 978-1-903957-21-9] available from http://foodresearch.org.uk/wp-content/uploads/2017/01/Final-Using-food-surplus-hunger-FRC-briefing-paper-24-01-17-.pdf] we discuss the calls for actions to reduce food waste and reduce food insecurity that have led to recommendations for enhancing systems to increase the redistribution of surplus food to emergency food aid charities as a solution to food insecurity. Our paper recommends that popular and political media need to disaggregate two distinct separate issues (food insecurity and food waste) and consider each as sufficiently significant as to merit its own informed and sophisticated debate.

 

  1.          In our co-authored Independent Food Aid Network blog [Caraher, M. & Furey, S. (2019) Redistribution of surplus food is NOT the solution to food poverty. Available from: http://www.foodaidnetwork.org.uk/blog/dr-martin-caraher-and-dr-sinead-furey-redistribution-of-surplus-food-is-not] we argue that the use of surplus, saleable food should not be viewed as the default solution for food poverty. To do so, may be viewed as serving “leftover food to left behind people” (Riches, 2018) which represents a two-tier approach to a rights-based food issue. We consider it concerning that the repurposing of wasted food continues to be the normalized response to the existence of food poverty among our people. The reduction of the problem to one of simple logistics and access to food misses the dignity and social justice issues of food poverty. We conclude that the Resources and Waste Strategy and appointment of a Food Waste Champion represent missed opportunities to urgently and radically address the main policy drivers that contribute to food poverty. We can still address the rising gap between income and food prices by pursuing policy actions that maximize income and benefit realization. If we focus on this approach, we have the greatest chance to achieve the sustainable and meaningful solutions required to lift our most vulnerable citizens out of food poverty. It is a disservice to our food poor to distract from the underlying issues of food insecurity; it is already proven to be ineffective to continue to rely on systems that encourage the use of waste and surplus food as they do not reduce the production of excess by our food system nor ultimately address the underlying socio-economic causes of food poverty.

 

  1.          You can read more about our opinions on surplus food in: The Economics of Emergency Food Aid Provision: A Financial, Social and Cultural Perspective where we discuss the issues of addressing hunger with waste or surplus food and how this is misaligned with the rights of citizens to an appropriate food supply.

 

 

12) A Public Health England report has concluded that “considerable and largely unprecedented” dietary shifts are required to meet Government guidance on healthy diets. What policy approaches (for example, fiscal or regulatory measures, voluntary guidelines, or attempts to change individual or population behaviour through information and education) would most effectively enable this? What role could public procurement play in improving dietary behaviours?

  1.          Price-based promotions and prominent placement tactics should be utilised to make food and drink innovations and product reformulations available to the broadest number of consumers as possible. To do so will help to realise the population benefits that are possible, with the potential to influence supply and demand and serve as a further catalyst for product reformulation, until saturation is achieved.

 

  1.          We further believe that efforts should be ongoing to support consumers to understand nutrition information through effective communication and awareness-raising.

 

 

13) Has sufficient research been conducted to provide a robust analysis of the links between poverty, food insecurity, health inequalities and the sustainability of food production? How well is existing research on the impact of existing food policy used to inform decision making?

  1.          We support the principle of evidence-informed policy and decision making.

 

 

14) What can the UK learn from food policy in other countries? Are there examples of strategies which have improved access and affordability of healthy, sustainable food across income groups?

  1.          We believe that the 2016 Food Foundation, UK Health Forum, World Obesity Federation, Food Research Collaboration and INFORMAS Food Environment Policy Index (Food-EPI available from: https://foodfoundation.org.uk/wp-content/uploads/2016/11/ENGLAND-Food-EPI-Report-FINAL1.pdf) may have applicable learnings in respect of creating healthier food environments. This approach rated policies against international examples of best practice (How well is England doing compared to other countries?). Secondly, policies were rated against the ‘gold standard’ as set out in the good practice statement (Is England doing as well as it should?).

 

  1.          Food is a basic right. According to the Universal Declaration of Human Rights everyone has a fundamental right to be free from hunger and have access to safe and nutritious food. The 1966 International Covenant on Economic, Social and Cultural Rights (ICESCR), and the 1989 Convention on the Rights of the Child are both legally binding. Both explicitly name adequate food and housing as basic human rights. Article 11 of the ICESCR states that: The States Parties to the present Covenant recognize the right of everyone to an adequate standard of living for himself and his family, including adequate food, clothing and housing, and to the continuous improvement of living conditions”.

 

  1.          With specific reference to food poverty, we consider access to food to be a rights-based issue whereby the primary responsibility for ensuring the right to adequate food and the fundamental right to freedom from hunger rests with national governments. According to the Food and Agriculture Organization of the United Nations, a number of countries have enshrined the right to food in their constitutions, yet no country to date has adopted national legislation to specifically realize this right. We believe this consultation represents an opportunity to realize this right via (1) incorporating the right into the national constitution; (2) adopting a framework law relating to the right to food; and (3) comprehensive reviewing of all or the most relevant sectoral laws affecting the enjoyment of the right to food for their compatibility with this human right (FAO 2009, p. 3).

 

 

15) Are there any additional changes at a national policy level that would help to ensure efforts to improve food insecurity and poor diet, and its impact on public health and the environment, are effectively coordinated, implemented and monitored?

  1.          Adherence to the DHSC proposed restrictions should be effectively monitored to ensure compliance, and reporting may be necessary to support traders’ adherence to same.

 

  1.          Associated action planning should be reviewed regularly as an evolving and working document with robust monitoring and evaluation activities attached and planned for from the outset. We recommend that evaluation is built in from the outset in order to measure success effectively and permit timely review and amendment. In this way, targeted interventions that have been formatively identified as effective are prioritised and more likely to achieve success.
  2.          We welcome any commitment to work closely with devolved administrations in Northern Ireland, Wales and Scotland for reasons of parity of approach for anticipated public health benefits by redressing the current imbalance and repetitious promotion that currently favour high fat, sugar and salt foods - as independent evidence demonstrates as existing in Republic of Ireland food stores. 

 

 

Dr Sinéad Furey, Lecturer of Consumer Management & Food Innovation at

Ulster University Business School

 

11 September 2019

 

 

 

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[1] Furey, S., McLaughlin, C., Hollywood, L., Burns, A., McMahon-Beattie, U., Price, R., Humphreys, P., McCarthy, M., Collins, A., Raats, M., Tatlow-Golden, M., Dean, M. and Murrin, C. (2019) What’s on offer? The types of food and drink on price promotion in retail outlets in the Republic of Ireland. Cork: safefood. [ISBN: 978-1-905767-86-1] (available from:  https://safefood.eu/SafeFood/media/SafeFoodLibrary/Documents/Publications/Research%20Reports/Whats-on-offer.pdf

[2] Safefood (2017) What are the estimated costs of childhood overweight and obesity on the island of Ireland? Available from: https://safefood.eu/Publications/Research-reports/What-are-the-estimated-costs-of-childhood-overweig.aspx

[3] This research was commissioned and funded by safefood. The views expressed reflect the research findings and the authors’ interpretation; they do not necessarily reflect the funders’ policy or opinions.

[4] Furey, S., McLaughlin, C., Hollywood, L., Burns, A., McMahon-Beattie, U., Price, R., Humphreys, P., McCarthy, M., Collins, A., Raats, M., Tatlow-Golden, M., Dean, M. and Murrin, C. (2019) What’s on offer? The types of food and drink on price promotion in retail outlets in the Republic of Ireland. Cork: safefood. [ISBN: 978-1-905767-86-1] (available from:  https://safefood.eu/SafeFood/media/SafeFoodLibrary/Documents/Publications/Research%20Reports/Whats-on-offer.pdf

[5] Mishra, A. and Mishra, H. (2011) The influence of price discount versus bonus pack on the preference for virtue and vice foods. Journal of Marketing Research. 48, 196 –206.)

[6] Foster, G. D., Karpyn, A., Wojtanowski, A. C., Davis, E., Weiss, S., Brensinger, C., Tierney, A., Guo, W., Brown, J., Spross, C., Leuchten, D., Burns, P. J. and Glanz, K. (2014) Placement and promotion strategies to increase sales of healthier products in supermarkets in low-income, ethnically diverse neighborhoods: a randomized controlled trial. American Journal of Clinical Nutrition. 99, 1359–68.

[7] Furey, S., McLaughlin, C., Hollywood, L., Burns, A., McMahon-Beattie, U., Price, R., Humphreys, P., McCarthy, M., Collins, A., Raats, M., Tatlow-Golden, M., Dean, M. and Murrin, C. (2019) What’s on offer? The types of food and drink on price promotion in retail outlets in the Republic of Ireland. Cork: safefood. [ISBN: 978-1-905767-86-1] (available from:  https://safefood.eu/SafeFood/media/SafeFoodLibrary/Documents/Publications/Research%20Reports/Whats-on-offer.pdf