A Healthier Scotland: Creating a New Food Body: Consultation Analysis

4. ROLES AND RESPONSIBILITIES

Background

4.1 The respective roles of the FSA and the Scottish Government are independent in relation to health improvement and nutrition, taking account of both food and wider health issues.

4.2 In recognition of this, the FSA and the Scottish Government work in partnership with each other, and with other relevant agencies, in particular, NHS Health Scotland, to ensure effective coordination of their complementary activities in order to achieve the FSA's objective of long-term improvements in the diet and nutrition of the Scottish population, and the Scottish Government's objective of making a step-change in Scotland's health and wellbeing a reality by improving and reducing dietary inequalities.

4.3 In practical terms, responsibility for taking forward specific aspects of tackling health inequalities is shared between the FSA and the Scottish Government. Annex A of the consultation document (reproduced here at Annex 2) outlines their respective responsibilities.

4.4 The consultation asked:

Question 2: Should the new food body and the Scottish Government continue the arrangements for independent and partnership work on diet and nutrition set out in Annex A? If not, what changes would you suggest, and why?

4.5 Eighty five (67%) of the 126 respondents provided a response to question 2 as follows:

Table 3: Views on whether the arrangements for independent and partnership work on diet and nutrition should continue

	No. of respondents	% of respondents
Yes	64	75
No	5	19
Commentary only	16	6
Total	85	100

4.6 Of those who provided a view, 75% considered that the new food body and the Scottish Government should, by and large, continue the existing arrangements for independent and partnership work on diet and nutrition. All respondent sectors were represented amongst those who supported the existing arrangements. Although many respondents suggested minor changes or different emphases, only five were of the view that more substantial revisions should be made.

General commentary

4.7 Recurring comments were that clarity over respective roles is very important, and although there will inevitably be some overlap between different bodies, delineation of responsibilities will contribute to an overall more coordinated and cohesive approach.

4.8 Eight respondents from a variety of sectors argued that clarity of roles between the new food body, the Scottish Government and NHS Health Scotland, could be improved, with potential for simplification identified.

4.9 A dominant theme was that once the arrangements for independent and partnership working are finalised, these should be well publicised to industry, NHS Boards and the public, so everyone is clear on who leads on what issue. Respondents also considered it important to make clear the independence of the new food body and its operation in an open and transparent manner.

4.10 Three respondents (IRB, LA, Ind) suggested that there should be time allocated for detailed consideration and review of the way roles and responsibilities had been allocated, with one (Ind) recommending that costs and benefits of respective input from different bodies be analysed in the review process. One academic argued that as diet and nutrition policy is wide-ranging and requires multiple areas of expertise, it may be timely to consider an entirely new department of health and wellbeing with responsibility for improvement in overall health in Scotland.

4.11 Areas of proposed partnership work for the new food body which were particularly welcomed by respondents (largely local authorities) were:

• paragraphs 34 and 35 in the consultation document (15 specific mentions) which referred to the new food body:
  • taking a lead role in science and evidence-based, consumer-focused public nutrition policy; and
  • taking the strategic lead for Scottish Government policies such as the Healthy Living Award for caterers, the Healthy Living Programme for neighbourhood shops and for technical support for small and medium food businesses to assist them to reformulate their products to be lower in salt, fats and sugars
• interface with the education system (10 mentions)
• work with NHS and local authorities to link with community planning partnerships and community health improvement partnerships (9 mentions).

4.12 Some respondents called for an expansion in the Food Standards Agency roles set out in Annex A of the consultation document (Annex 2 of this report):

• research and monitoring of some of the more common allergens and chemicals that many people react to (Ind)
• nutritional/allergy information provided by caterers (LA, LA)
• more input on behaviour change (linking with industry and consumers) (IRB)
• obesity (PB, Acad)
• general food and health promotion and programmes (IRB)
• greater partnership working with third sector organisations (Third)
• greater partnership working with service delivery partners (LA)
• consultation document Annex A item 9: rather than merely "engaging" with the UK food industry, the role should involve enforcement to strengthen the FSA input (Ind)
• Annex A items 17 and 18, currently with a Scottish Government lead, should be led by the new food body (PB, Ind)
• Annex A item 20, currently undertaken by the Scottish Government, should become the responsibility of the new food body (PB).

Views of those against the current arrangements continuing

4.13 Four third sector respondents and one industry representative body opposed the current arrangements for independent and partnership work on diet and nutrition continuing. One commented:

"Having examined the various roles carried out by FSA Scotland, Scottish Government and NHS Health Scotland in relation to nutrition and diet it is clear that there is duplication of activities and potentially some gaps. Therefore we believe that there should be a comprehensive review of the roles and responsibilities of the three bodies together with a gap analysis subsequent to which the role of the new food body can be decided" (British Hospitality Association Scotland).

4.14 Other views were that the new food body should be more independent than indicated by the arrangements set out in Annex A (Third); the arrangements appeared confusing and could be simplified by making the new food body the umbrella agency for the promotion of public messages about food and nutrition (Third); as there has been little improvement in Scotland's diet and nutrition since 1996, more of the same is unlikely to produce a different result (Third); and there should be a more explicitly stated role for the new food body in tackling health inequalities (Third).

4.15 The consultation asked:

Question 3: Are there any additional roles, responsibilities or functions in respect of diet and nutrition that you think the new food body could take on to help deliver an improvement to the health of the people in Scotland? Please give details and reasons.

4.16 Fifty four (43%) of the 126 respondents provided substantive responses to question 3. Others cross-referenced to their comments in response to other questions, or simply agreed that the roles, responsibilities or functions suggested in the consultation document appeared to be appropriate. General remarks which emerged repeatedly were that there must be a robust rationale for any expansion in the new food body's functions, which should be grounded in a cost-benefit analysis.

Partnership working

4.17 An area most commonly identified for expansion by the new food body was working in partnership with broader relevant bodies and sectors (19 mentions). The following were specified by respondents:

• Food industry (7 mentions from 4 different sectors). One comment was:

"work closer with industry to influence product development to make the healthy choice the easy choice" (NHS Grampian).

• NHS (4 mentions from 3 different sectors). Respondents recommended close liaison with NHS Health Scotland and health boards to ensure coordination of work on deprivation and health inequalities. One respondent was of the view:
  "The consultation suggests the new food body will be responsible for providing information to health professionals. To date, NHS Health Scotland have played a key leadership role in this area and have developed strong and effective partnerships with nutrition/dietetic staff in territorial NHS Boards. In contrast, the Food Standards Agency Scotland has very weak links with Board public health nutrition professionals and therefore these relationships would need to be established and strengthened" (NHS Ayrshire and Arran).

• Retailers (Acad, Acad, IRB). Local food producers and large food retailers were mentioned in this respect.
• The Scientific Advisory Committee on Nutrition (Prof A&U, IRB, LA).
• European authorities (Bus, Prof A&U). One respondent remarked:
  "...must be involved in all European discussions otherwise there is just confusion. Similar problems are extant in all member states and so a common approach is far more effective" (Food Solutions).

• Education bodies (PB, IRB) with Education Scotland, NHS Health Scotland and Curriculum for Excellence specified.
• Agencies working on social values around food (Acad).
• Consumers (Acad).

Education

4.18 Thirteen respondents identified the provision of education as an area into which the new food body should expand its roles, responsibilities and functions. Respondents considered the new food body to be the appropriate organisation for delivering consistent, evidence-based messages on diet and nutrition. It was envisaged that such messages could be delivered via:

• the education system in schools, further and higher education establishments (5 mentions from 5 different sectors)
• working with bodies such as the British Dietetic Association (Prof A&U)
• advice directly to the public (Third, Third)
• advising the Scottish Government (Third)
• those supplying food to institutions such as care homes (PB).

Research

4.19 Ten respondents considered that the new food body could take a significant role in aspects of research including coordinating, funding and commissioning, dataset collection, monitoring and evaluation and disseminating findings. One respondent expressed their view:

"At present, the majority of research undertaken by the FSA is food safety-focused. If the new food body is to play a key role in improving population health, it is important that more focus is placed on researching interventions that improve food choice. For example, providing expertise in evaluating pilot initiatives (making links between academics and practitioners) and collating and disseminating evidence on projects that have been successful in changing eating behaviour" (NHS Lothian).

National, regional and local initiatives

4.20 Nine respondents advocated the new food body being involved either strategically or directly in the implementation of initiatives aimed at tackling poor diet and nutrition. One (Ind) suggested a responsibility for rationalising the plethora of national, regional and local initiatives. Three public bodies recommended that the new food body takes a key role in leading and implementing the Obesity Route Map. Others envisaged involvement in Healthy Living Awards and other such initiatives. One local authority considered it appropriate for the new food body to work in conjunction with local authorities to take forward, "Eating for Health - the Challenge".

Social marketing

4.21 Six respondents identified social marketing as an area where the new food body should take a greater part. It was considered that efforts could be directed to influencing choice by changing perceptions on healthy food, in conjunction with tackling barriers such as affordability and availability. One respondent (Cons) argued that work on healthier choices should be integrated with work around more sustainable choice.

Focus on children's nutrition

4.22 Six respondents called for the new food body to have particular involvement in affecting the diet of children through:

• monitoring the nutritional value of meals for children in schools and other public places (Acad, Acad, Third)
• monitoring food advertising aimed at children (Ind)
• influencing the nutritional value of food sold to school children at lunch time by private outlets (LA)
• providing clear, consistent information for parents on child and infant feeding (Third)
• providing information to women on their diet pre-conception and between pregnancies (Acad).

Coordinating responsibilities

4.23 Four respondents suggested a wider role for the new food body in clarifying the landscape of responsibility for policy-making, provision of consumer information and research on diet and nutrition. One local authority advocated a coordinating role for the new food body to ensure consistency of approach across local authorities and community health partnership areas. An academic called for wider vision across the food system to include links with issues of climate change, food security, food poverty and social values around food.

Regulatory process

4.24 Three respondents (Third, Prof A&U, PB) suggested enhanced involvement in the regulatory process as appropriate for the new food body, although one public body queried whether there may be a conflict of interest between its regulatory function and its provision of technical support to small and medium businesses.

Views against additional roles, responsibilities and functions

4.25 Eight respondents from five different sectors argued against the new food body expanding its roles, responsibilities and functions. A view shared by four respondents was that the Scottish Government already works strategically to develop nutrition and other health-related policy with delivery organisations also already in place. One public body cautioned about the new food body expanding into these areas, creating confusion, and also becoming too large to be responsive and effective.

4.26 One view (IRB) was that the approach to tackling obesity should be multi-faceted and managed outwith the new food body. Another respondent (Prof A&U) recommended consolidating the new body first before considering expansion. An academic argued for reducing the remit of the new food body:

"We can see no persuading argument that the new food body should take on any additional roles, responsibilities and functions in the area of diet and nutrition. In fact....there may be an argument that the new food body should relinquish some of its previously held role in disseminating advice on health and diets to other bodies such as the NHS" (The James Hutton Institute).