Draft Dietary Guidelines
General Comments
I have worked professionally for 40 years in wildlife research and management –
for the past 30 years specifically on solutions to conservation problems in
international and domestic fisheries. I participate in major international fisheries
management meetings such as CCSBT (Commission for Conservation of Southern
Bluefin Tuna).
The draft guideline is a valuable document with substantial economic and health
implications and as such, I believe it should be subject to regular review and
updating. I disagree with the omission of any practical guidance on sustainable
food choice. This omission is hard to justify, particularly when there is now so
much information available (since Dietary Guidelines 2003) and so much
attention generally on these issues. This document should aim to further
influence food suppliers to provide consumers with the most healthy and
sustainably-produced /sustainably-sourced food. This document does not do
this. The food industry needs ongoing financial incentive for healthy food
directions and this can only come from inclusion of appropriate wording in this
document, which guides consumer choice.
Unfortunately it must be said that the Review has failed to match the rapidly
growing body of information on the relationship between market-driven
responsibility towards sustainably-sourced food. These issues, only briefly
alluded to in the document are directly relevant also to the matter of healthy
food choice. Unless this issue is dealt with more comprehensively and at least in
sufficient detail to better inform and guide consumers a substantial area of the
document’s responsibility will have been largely neglected. This is simply
unacceptable. While the importance of guiding sustainable food choice (because
this has direct health implications) should be incorporated into all food groups, it
is particularly important for fish/seafood because unlike virtually all other food
groups:
a) Different fish species have different health impact potential
b) Fish species acquired from different production methods and localities can
have vastly different ecological and human health implications
c) Fish consumption is strongly encouraged for its health benefits and in fact
increased consumption is specifically recommended.
In conclusion, I suggest adding a new chapter specifically on the relationship
between environmentally sustainable food choice and health. This should
incorporate general guidelines to cover the principle that irrespective of cost, the
safer health choice in the absence of more information on sustainability,
environmental consequences or food growing conditions (including the
chemicals used) is to stick to Australian produce.
If not adding a specific chapter on this, the subject could possibly be covered
within the existing structure, which deals with the different food groups
separately. In the case of a wide variety of seafood and fish species, for which
specific information already exists in relation to environmental sustainability,
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the healthy choices need to be presented to the reader. There is little or no text
about reducing potential health risks by choosing, in preference, Australian
grown foodstuffs for which healthy and environmentally sustainable production
conditions apply. For the same foodstuffs of foreign source, (for which inevitably
a price incentive drives consumer choice) there is considerable uncertainty
about these same issues. One example would be the health and ecological
implications of consuming considerably cheaper, foreign-farmed prawns and
Australian wild-caught prawns. There are also sustainability implications of a
choice between Australian wild-caught and foreign wild-caught prawns
(especially if little or nothing is known about the sustainability of foreign
harvest).
The environmental effect of food choices is an increasingly important issue, and
because it has direct health consequences, therefore demands much more
attention than the passing references made here in the draft guidelines.
Specific comments
Preface
The first paragraph in the preface states that Australians need to improve their
health by making better dietary decisions. How is this possible if the source of
foods chosen to include in one’s diet, is unsustainable? (This unsustainability is
aided by a lack of advice about the importance of making a sustainable choice.)
Making sustainable food choices ensures maintenance of those choices.
Considering the amount of information on this subject, which is available as a
source for the Guideline, it is inappropriate to simply state “ Impact of food
choices and future food security“ is being jointly considered by NHMRC.
Chapter 1
Pg 20
The document states, that “evidence is insufficient to be able to provide advice
on the environmental impact of specific food items or brands.” This is not true,
particularly with respect to fish or seafood. The seafood source is of increasing
importance to certain ‘brands’ (Woolworths in Australia is endeavouring to
confine its seafood sourcing to those fisheries that have been certified as
environmentally-sustainable or under effective management). It is now
necessary to assist the consumer to become part of this ‘informed’ choice
process that may well ensure ongoing availability rather than resource collapse
and the ultimate loss of that health choice.
Chapter 2
“Consuming a wide variety of foods may also help to ensure that an adequate
variety of foods remains available into the future. Food choices to reduce the
impact on the environment are consistent with those to improve health” –
Without specific examples (of which there are many from all food types), this is
merely an abstract concept that a reader can neither learn from or act on.
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Pg 29
Pg 29 actually lists 4 fish species, all of which have serious sustainability issues
depending upon place of origin and precisely which species one is referring to
(in the case of “shark” and “marlin”).
Pg 51
Para 3 refers specifically to fish or other seafood benefits but fails to add
anything about the issue of sustainable choices and the pg 52 table clearly
advocates the importance of regular fish consumption as does text pg 54/55, but
again offers no text regarding choice based on sustainability or environmental
impact. Although different health issues are involved when considering fish as
opposed to livestock and poultry, the same issues of informed choice about the
source of these other animal products need to become as much a part of what
drives consumer choice (in particular the animal welfare aspect and the
uncertainty about environmental impact or food contaminants).
Pg 58 suggests there should be a 40% increase in certain foods such as fish to
meet recommended intake with only a cursory reference to the uncertainty of
sustainability (pg 59). The 40% recommended increase in fish consumption
should be especially considered in relation to Australian fish populations and the
fact that already 2/3rds to ¾ of fish consumed by Australians is imported. In
relation to the suggested increase in fish consumption, the paragraph ends with
the vague impression that availability is not really an issue because ‘initiatives
have now been developed to address the sustainability of fish stocks in
Australia”. Irrespective of whether this has occurred, this does not equate to
Australia being in a position to meet increased demand. There are even more
serious issues of sustainability, health mismanagement, surrounding imported
fish.
Pg 61
Source of product and consumer choice is not even mentioned in relation to the
important issue of food safety and fish consumption. Source of product may be
particularly relevant when a significant portion of fish consumed by Australians
is imported (and is by far the cheapest to tempt consumers). So the statement
that “exposure in Australia generally is low” has little relevance unless
consumers are encouraged to make the right choice.
The explanatory 5th para on pg 160 is not sufficient to address the issue of
relationship between responsible choice of sustainable food supply to
maintenance of a healthy diet. For seafood in particular, there already exists
considerable food supplier and consumer advice on the most sustainable, least
ecological impact fish species options. See material available from organisations
including TRAFFIC, Marine Stewardship Council, Blue Oceans Institute,
Sustainable Fish Partnership (fisheriesWiki.org), which provides impartial
advice on the sustainability of fisheries.
Appendix 8 –glossary
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Fish is mentioned as a “meat alternative” and yet from a health perspective this
is not true. Suggest fish (and or seafood) be specifically assigned in the glossary.
Seafood is referred to throughout the text but not identified in the glossary.
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