Response to Soil Association, Food for Life Catering Mark 2016 Standards Consultation on Making Healthy Eating Easy (Schools)
Introduction
This response has been prepared on behalf of the Board and members of the Lead Association for Catering in Education (LACA).
The Food for Life Catering Marks, Bronze, Silver and Gold for school meals providers is a very important standard to achieve and a nationally recognised accreditation. It gives creditability to the food provided to pupils/students, school staff and visitors. It adds considerable value to the catering operation in a number of ways. It is a unique award, as it confirms the purchase of a high standard of food and provenance to the customer.
It is not easy to achieve, which of course is important so that gaining the catering mark ensures that really high standards have been attained. It is complicated and although Food for Life provides clear information and instructions it does take individual schools, local authority caterers and private sector contract caterers a great deal of time and commitment to succeed.
The Food for Life Catering Mark links to the School Food Plan and the Food Based Nutritional Standards set in statute by the Government.
Comment on the Consultation Document
Members of LACA who have been responsible for achieving accreditation for the Gold Mark have been consulted.
It is not our intention to criticize but to draw the attention of the Standards Committee of Food for Life to some issues that have arisen in preparing the LACA response.
· We refer to the document Catering Mark standards consultation, the contents of which apply to all the categories of the catering mark. In the paragraph Making healthy eating easier, it states the following: “In some sectors caterers are required to meet nation guidelines on food and nutrition under the bronze standard. The proposed new silver and gold standards aim to better recognise this by adjusting the points thresholds for schools, early years, residential care and community meals settings and hospital patient food”. For school caterers the requirement is to meet the Food Based Nutritional Standards, which are encompassed in law.
The paragraph is Environmentally friendly and ethical food states that “there are also additional fixed points proposed for two areas of this part of the standards. These changes will recognise the efforts made by many caterers to avoid, or use more sustainable palm oil and source more ethical and sustainable drinks. The additional points would also help to ensure a consistent balance of available points in light of the proposed changes to Making healthy eating easy”. Within the consultation document there is not any description of the details about the drinks or how many extra points it is possible to gain to ensure compliance with drinks or palm oil.
· It is not clear at the start of Menu Cycle – Schools what is meant by the proposed Standards that Apply to Schools i.e. 10 points required for Silver; and 25 points required for Gold. Thanks to Jen Collins Standards Project Manager and her advice following a very helpful phone call, this has now been clarified.
· It is not explained whether to earn 1 point or points under each heading it is necessary to meet every guidance step. Again Jen has helped to clarify this by saying that it is 2 out of 4 in the current handbook. However in order for organisations to measure whether they can achieve Silver or Gold more detail and definitive information regarding this needs to be provided.
Set out below is the feedback from LACA to the proposed changes to the Food for Life Catering Mark for Silver and Gold Standard.
Support to Eat Well
Steps are taken to support children to eat well
LACA supports this proposal.
Customer surveys are carried out regularly, to identify popular healthy dishes
LACA agrees with this proposal.
Food tasting events are held for children and their families and carers.
LACA agrees with this proposal and its guidance although it may be difficult to invite parents and other family members along to roast dinner days due to lack of capacity for the extra meal numbers.
Information about eating well is on display
LACA supports this proposal.
Adequate time is available for meals to be eaten
LACA recommends that the guidance of at least 30 minutes should be allowed for lunch service should be amended. Generally lunch times in schools are between 30 minutes and 1 hour. The difficulty of ensuring enough time for lunch to be served in a very short time has been a fact for many years. However the decision of the duration of the lunchtime is made by the school, Head Teacher and Governors. It is not in the caterers control and therefore this cannot be used to achieve these criteria. In practice the same applies when it is suggested to consider a staggered meal service, this also is not the caterer’s decision.
Cooking and Serving Practices
Only polyunsaturated or monounsaturated oil is used in cooking
The guidance states that palm oil is not a poly or monounsaturated oil so should be avoided. Generally palm oil is not a product used by school caterers. Some bought in convenience manufactured foods do contain palm oil which if caterers ensure that it is sustainable palm oil has been accepted for the Gold Award.
Use of alternative seasoning methods to salt (herbs, spices, lemon etc.).
LACA agrees with this proposal. We would draw to your attention that in both the present guidance and the consultative document guidance, using homemade stock is suggested. School caterers are not permitted to make homemade stock.
Test recipes to ensure minimum amount of salt is used
LACA agrees with this proposal.
Sweet recipes use wholegrain flour and less sugar
LACA supports the reduction of sugar in recipes and most caterers have already achieved this aim.
Wholegrain flour is widely used in recipes and has been for many years using a ratio of 50:50. Would this meet the guidance requirement?
Steps taken to reduce the amount of food left uneaten (plate waste)
We are unsure of the benefits of weighing the amount of plate waste? This was a practice carried out for many years a long time ago and a very few caterers still do it. However it is time consuming and our experience tells us that when a popular dish is served the plate waste will be small and on other days if the pupils are not so keen on the sides on offer the plate waste will be much higher. If this guidance is to be included it needs a measurement of what level of plate waste is acceptable, for example 28g (1 ounce).
Healthier Menus
Fruit and Vegetables
Fresh fruit is always available and 80% desserts are fruit based
The Food Based Nutritional Standards set by Government which all state schools, most academies and most free schools are legally required to follow and implement state that fresh fruit is available every school day.
LACA does not support the proposal that 80% of desserts should be fruit based and then the Food Based Nutritional Standards require that 50% of desserts are fruit based.
Whilst every encouragement to children to eat more fruit is important 80% of fruit based desserts will not be welcomed or eaten by the pupils and will place too many constraints on the menu.
A range of pre-prepared easy-to-eat fruit and/or vegetables is available as a snack or dessert choice
LACA supports this proposal.
Raw vegetables are available as salads
LACA agrees with this proposal.
Salads have dressing provided separately
LACA supports this proposal.
Starchy Foods
Real Bread is served
LACA agrees with this proposal.
More than 50% of bread on offer is wholegrain
LACA agrees with this proposal.
Two or more complex carbohydrates are provided on the menu each week in addition to bread
LACA agrees with this proposal.
At least one main dish each day includes a healthier starchy food choice
LACA agrees with this proposal.
Milk and Dairy
Natural yoghurts are the only available yoghurt
LACA cannot agree with this proposal. In general children do not like or consume natural plain yoghurt. It should be available as an option on the menu.
The guidance suggesting the use of nuts needs amendment. Nuts are a huge no on school menus and packed lunches brought in from home. School caterers provide completely nut free foods and recipes including any manufactured convenience foods that they purchase. This is in response to the increasing number of children who suffer from life threatening nut allergies. We recommend that any reference to the use of nuts in the Food for Life Catering Mark are removed.
The removal of fruit yoghurt which is often organic within the Silver and Gold Mark will not only affect the diet of the children but purchasing practices. In particular small suppliers including farmers who produce locally sourced yoghurt. Surely this could affect the very ethos of Food for Life’s overall policy of local organic and healthy produce?
LACA asks you to reconsider this proposal.
Meat, fish eggs and beans
Oily fish is on the menu at least twice a week
LACA does not support this proposal. The Food Based Nutritional Standards demand oily fish once every three weeks. This requirement has been very hard to achieve. It is easy to place it on the menu but persuading the children to eat it has not been highly successful. In real terms the only oily fish that children do enjoy is canned tuna, which of course does not count. We believe that vacuum packed tuna would meet the criteria and the provision of this product is being researched.
Many primary schools only provide one choice, plus a vegetarian option. If it is a requirement to provide oily fish on the menu at least twice a week, the overall menu would not comply with the Food Based Nutritional standards.
In our view this proposal is not workable and should be deleted.
Pulses are incorporated into recipes to reduce the meat content
LACA agrees with this proposal.
Promoting healthy protein options: 5 points for 2 days per week, 10 points for 3 days per week
This proposal is complex and needs more research. It could be that in order to achieve this it may conflict with the Food Based Nutritional Standards.
Display, pricing and marketing
Serving staff are knowledgeable about healthy choices and actively promote them
LACA agrees with this proposal.
Menus and counter signage promote healthier options, including healthier drinks: healthier choice dishes and accompaniments are placed as first options or in prime positions to encourage selection: 5 points
LACA supports this proposal.
RECOMMENDATIONS AND COMMENTS
LACA respectfully makes the following recommendations and comments for the Food for Life Catering Mark Standards Committee to consider.
· Clarification of the points system and more information on how if there is a reduction from 20 requirements for Silver and 50 for Gold to 10 for Silver and 25 for Gold, yet at the same time the total of 150 for Silver and 300 for Gold remain. How the applicants and present holders make up the extra points is not clearly evident or explained.
· The proposals appear not to mirror the existing Hand Book 2015, which has made comparisons more difficult. Will the new proposals supersede the existing handbook?
· Some of the proposals will be difficult to achieve and more stringent than the Food Based Nutritional Standards.
· We recommend that the proposals for oily fish and yoghurt be reviewed for the reasons stated in our response.
· LACA asks that Food for Life gives consideration as to how it is going to monitor compliance of the School Catering Mark standards. We appreciate that as the numbers of caterers who attain the School Catering Mark increase that this places extra finance and staff resources for Food for Life.
However the issue of effective monitoring is very important to retain the integrity of the awards. The majority of school catering providers follow the School Food Based Standards set out in law. Since the reinstatement of nutritional standards in 2000, 2005 and 2014 via the Government only marginal monitoring has taken place carried out by Ofsted. With regard to the Food for Life Catering Mark sadly amongst the industry it is a well-known fact that there are a small number of organisations who if scrutinised more robustly in reality would not meet the Food for Life Standards that they have achieved. This comment does not detract from the majority of colleagues who ensure that compliance to the criteria is genuine and in place.
CONCLUSION
LACA has welcomed the opportunity to respond to the Soil Association Food for Life Catering Mark on their 2016 Standards consultation on Making healthy eating easy (schools).
In our opinion the timing of the consultation is arguably too early. We are waiting for more information about the Childhood Obesity Strategy and as part of that a review of the Food Based Nutritional standards to be carried out by the Department of Health and the Department for Education.
LACA fully supports the Food for Life Catering Mark and its aims. However there is a risk that if it is made too difficult, complicated and onerous to achieve, school caterers will not join. There is a danger that the existing holders of the mark may give up. Although the fee paid for Food for Life is very reasonable, there are considerable costs incurred by the recipient in achieving and maintaining the mark.