Faculty of Public Health
Of the Royal Colleges of Physicians of the United Kingdom
Working to improve the public’s health
UK Faculty of Public Health response to the Welsh Government consultation of the
Public Health White Paper, “Listening to you – Health Matters”
About the Faculty of Public Health
The Faculty of Public Health is the standard setting body for specialists in public health in the United
Kingdom. The Faculty of Public Health is a joint faculty of the three Royal Colleges of Physicians of
the United Kingdom (London, Edinburgh and Glasgow) and also a member of the World Federation of
Public Health Associations. The Faculty of Public Health is an independently constituted body with its
own membership and governance structure.
The Faculty of Public Health is the professional home for more than 3,300 professionals working in
public health. Our members come from a diverse range of professional backgrounds (including
clinical, academic, policy) and are employed in a variety of settings, usually working at a strategic or
specialist level. The Faculty of Public Health is a strategic organisation and, as such, works
collaboratively, drawing on the specialist skills, knowledge and experience of our members as well as
building relationships with a wide range of external organisations.
Introduction
The Faculty of Public Health welcomes this opportunity to respond to the Welsh Government
consultation on the Public Health White Paper, ‘Listening to you – Your health matters’. The broad
ranging proposals set out within the White Paper are encouraging, including action to reduce the
harms to health caused by smoking, alcohol misuse and obesity. We are confident that, as the Welsh
Government indicate, they provide a set of practical actions which, when combined, will have a
positive impact on health and wellbeing in Wales.
Within this consultation response the Faculty of Public Health sets out ways in which these specific
proposals may be strengthened. While confident that the specific measures identified will make an
important impact on public health in Wales, it is nonetheless of deep concern that the direction of
travel presented within the Green Paper – that the Welsh Government would take action to ensure
that health in all policies would become a reality – has been omitted.
A firm commitment to upstream legislative action to ensure health is at the heart of all national and
local government policy formulation – thereby reducing health inequalities by taking action across all
social and economic determinants of health – is critical. The Faculty of Public Health strongly
advocates that a framework for health in all policies should form a central pillar of an eventual public
health Bill, ensuring strong cross-sectoral collaborative links may be made and a strategic national
approach adopted, supported by local initiatives.
Accordingly, the Faculty of Public Health places a firm emphasis on the introduction of a statutory duty
on Ministers to consider the health impact of all policies developed across the Welsh Government
which will be of practical utility in improving health outcomes and reducing health inequalities. This will
ensure that public health is at the heart of wide ranging departmental portfolios and central to policy
formulation, e.g. in relation to the economy, transport, town planning, housing and the environment,
early years, mental health and wellbeing and education (including adult education).
It is deeply regrettable that this White Paper does not build on the very positive signal made within the
Green Paper that preceded it, in which significant weight was given to this pioneering and progressive
public policy proposal which would have the potential to make a tremendous impact on the health of
the Welsh population. The Faculty of Public Health would welcome the opportunity to discuss this
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issue in greater detail and offers the support of our expert membership to the Welsh Government in
addressing these important concerns.
In particular, the Faculty of Public Health believes that a public health bill can and ought to incorporate
the following:
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Definitions / Interpretation – including wellbeing, health in all policies, Health Impact
Assessment
Duties and Powers (roles and responsibilities) to include
o Roles and responsibilities of various public bodies and positions,
o Duty on public bodies to consider Health in All policies
o Duty to undertake HIA
o Duty to engage the public at the centre of decision making (although this should be a
principle running through how Welsh policy is developed and implemented more
broadly rather than a duty in one specific Act )
The powers for the Minister to require secondary legislation for appropriate public health
matters, amenable to a legislative approach
The rest of this consultation response goes on to address some wide ranging and specific issues of
relevance to public health.
Mental health and suicide prevention
The UK Faculty of Public Health supports the submission to this consultation made by the National
Advisory Group on Suicide and Self Harm Prevention.
Accordingly, we welcome many proposals that are contained within the Public Health White paper in
relation to this specific area. In particular, the Faculty of Public Health draws attention to the following
key points:
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There is little strategic vision within the document in relation to the importance of a population
based approach to improve health
This is quite different to what appeared to be envisaged in the Green Paper and the title of the
Bill risks further reducing the status of a public health approach to health and well-being
The opportunity may be missed to set the long term direction and framework for public health
in Wales, and embed particular requirements, responsibilities and duties on bodies to support
positive changes in the health and wellbeing of our population
While health in all policies has been highlighted as being a part of the Future Generations Bill
there is no doubt that a Public Health Bill must contain a commitment to progressing this
In relation to mental health and well-being, the Faculty of Public Health makes the following
recommendations:
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‘Health’ in the Bill should be explicitly defined to include physical, mental and social well being
Both the Public Health Bill and the future Generations Bill must reflect the need to promote
mental well-being and prevent mental ill-health as set out in Together for Mental Health
‘Parity of esteem’ for physical and mental health should underpin public health legislation
Many measures and issues being addressed in the Bill such as smoking, alcohol consumption
and obesity are intrinsically linked to mental health well-being and this needs to be recognised
Where physical activity is highlighted in schools (section 4.15) this should be coupled with an
explicit statement regarding mental well-being
4 St Andrews Place  London  NW1 4LB  Tel: 020 3696 1452  Fax: 020 3696 1457
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
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Consideration should be given when discussing the public health agenda in section 1.22 to
including proportionate universalism, in relation to targeting those with serious mental illness,
with the concepts of prevention, early intervention and evidence based decision making
The Faculty of Public Health welcomes the recognition of the importance of community assets
for health and wellbeing and the description and exploration of what community assets are
There is an opportunity to recognise the significant environmental influences on health that
could be considered under this theme, including indoor and outdoor air quality, water quality,
housing quality, access to green spaces and tranquil areas, safe neighbourhoods etc
Limiting this to two sets of proposals relating to planning provision of pharmaceutical services
by health boards and the strengthening of the role of local authorities in planning provision of
and access to toilets for public use, seems underplayed and lacking in strategic vision.
In relation to suicide and self harm prevention:
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The Faculty of Public Health would welcome recognition within this and the Future Generations
Bill that suicide is a public health issue
Suicide prevention requires a cross departmental, cross sectoral collaborative approach and
action at all levels to prevent suicide impacts on many of the public health challenges
described within the document
It is important given the general principal of joined up policy making that both the Public Health
Bill and the future Generations Bill reflect and are reflected by the new strategy for Wales to
prevent suicide and self harm, Talk to Me 2/Too
This includes encouraging help seeking behaviour, promoting well being and building both
community and individual resilience.
Mental health is vital to public health; mental wellbeing is profoundly important to quality of life and the
capacity to cope with life’s ups and downs. It is protective against physical illness, social inequalities
and unhealthy lifestyles. There are now a large number of evidence-based approaches to promoting
mental wellbeing and preventing mental illness, and these are growing daily. FPH draws attention to
our own resource on mental health and wellbeing, which contains many relevant and useful tools to
empower individuals and communities: http://www.fph.org.uk/better_mental_health_for_all
We can empower individuals and use community assets to enable them to improve their own health
by building on the recommendations of the Marmot review in understanding and building on the
growing body of evidence which builds resilience, reduces material inequality and supports the
development of social, cultural, community – and individual capital
http://www.instituteofhealthequity.org/projects/fair-society-healthy-lives-the-marmot-review
Finally, the Faculty of Public Health supports our parent college, the Royal College of Physicians, in
urging the Welsh Government to invest in the health and wellbeing of its NHS workforce by
implementing NICE public health guidance for employers.
Alcohol pricing
The Faculty of Public Health is a member of the Alcohol Health Alliance UK, and supports its response
to this consultation. Accordingly, the Faculty of Public Health strongly supports the introduction of a
minimum unit price in Wales. This policy powerfully addresses the growing burden of alcohol
harm including liver disease, dementia, violence and accidental injury. We make the following
recommendations in relation to the alcohol pricing proposals outlined within the White Paper:
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A minimum price of at least 50p per unit of alcohol should be introduced for all alcohol sales,
together with a mechanism to regularly review and revise this price
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While 50p is a reasonable starting point, delays in implementation continue to erode the
effect of this level, and the original work of Sheffield University showing a marked
impact (nearly 3000 lives a year saved) were modelled on 2007-8 prices
With inflation, this would be equivalent to nearer 40p now
At least one third of every alcohol product label should be given over to an evidence-based
health warning specified by an independent regulatory body.
The sale of alcohol in shops should be restricted to specific times of the day and designated
areas. No alcohol promotion should occur outside these areas
The tax on every alcohol product should be proportionate to the volume of alcohol it contains.
In order to incentivize the development and sales of lower strength products, the rate of
taxation should increase with product strength
Licensing legislation should be comprehensively reviewed
Licensing authorities must be empowered to tackle alcohol-related harm by controlling total
availability for alcohol in their jurisdiction
All alcohol advertising and sponsorship should be prohibited. In the short term, alcohol
advertising should only be permitted in newspapers and other adult press. Its content should
be limited to factual information about brand, provenance and product strength
An independent body should be established to regulate alcohol promotion, including product
and packaging design, in the interests of public health and community safety
The legal limit for blood alcohol concentration for drivers should be reduced to 50mg/100ml.
All health and social care professionals should be trained to routinely provide early
identification and brief alcohol advice to their clients
People who need support for alcohol problems should be routinely referred to specialist alcohol
services for comprehensive assessment and appropriate treatment
A clear timetable for implementation should be agreed expeditiously
Alcohol – other measures
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The Faculty of Public Health would also welcome the introduction of other measures to reduce
the harms associated with excessive alcohol consumption, including better alcohol treatment,
and a public health licensing objective
There is historic underinvestment in alcohol treatment services, yet well-designed alcohol
treatment services are highly effective in terms of clinical outcomes as well as being highly
cost-effective
There is an estimated return on investment of £5 (in cost savings) for every £1 invested
The Faculty of Public Health therefore strongly supports increased investment in ‘brief
interventions’ for alcohol, from which it is estimate that 7.1 million hazardous or harmful
drinkers may benefit.
We also support the introduction of a public health licensing objective. This would empower
local authorities to make alcohol licensing decisions which fully take into account the public
health impact of licensed premises in their area
Currently, local authorities can consider public health data, but they cannot make a licensing
decision on this basis.
Tobacco and electronic cigarettes
Smoking accounts for approximately 5,450 deaths every year in Wales where it is estimated that
14,500 young people a year take up smoking, and there is some evidence to suggest that the smoking
prevalence rate is higher in the most deprived parts of the country. Measures aimed at reducing
smoking prevalence and uptake therefore contribute directly to improving the health and wellbeing of
the population in the most deprived areas of Wales.
4 St Andrews Place  London  NW1 4LB  Tel: 020 3696 1452  Fax: 020 3696 1457
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The Faculty of Public Health welcomes the proposal for a retail register. The introduction of a retail
register in Scotland has been an effective way of monitoring availability and trends in availability and
we would therefore support the introduction of a similar scheme in Wales. We also believe that a retail
register would help local authorities to tackle the problem of under-age sales and assist in the
enforcement of the display ban. Any measure that helps to reduce the prospect of under-age sales is
to be welcomed.
We believe that the proposed fee structure is reasonable and should not discourage applications.
However, we would also support a requirement for annual re-registration to ensure that records are
kept up-to-date for the purposes of enforcement. If this legislation is passed, the Welsh Government
should ensure that there are clear deterrents in place for those tempted to breach the new
requirements, and Ministers should issue detailed guidance for enforcement officers and magistrates.
The Faculty of Public Health recently published its policy position on electronic cigarettes. We are
deeply concerned about the high levels of marketing and exposure (e.g. through use in public places)
that non-smokers, and, in particular, young people, are exposed to. We therefore make the following
recommendations in relation to electronic cigarettes:
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urgent implementation of controls on marketing and use in public places in line with Articles 8
and 13 of the WHO Framework Convention on Tobacco Control1
Marketing controls should extend to bans on the sponsorship of sports clubs or sporting
events, product placement, use of flavours designed to appeal to youth and celebrity
spokespersons
All products should be required to clearly indicate the addictive nature of nicotine and
encourage smoking cessation by providing links to the NHS Smokefree website
Outlets selling electronic cigarettes provide information on the dangers of smoking and
encouraging cessation
All electronic cigarettes, including unlicensed products, should be subject to the same
marketing controls as tobacco products so that they cannot be marketed or advertised
The regulatory framework should aim to prevent initiation among youth and other non-tobacco
users, protect bystanders, regulate marketing and prohibit unsubstantiated claims
This regulatory framework should require manufacturers to present safety and efficacy data
A health authority should assess manufacturer’s claims as it would for any medicinal product,
impose health warnings as appropriate, and require ingredient and safety data disclosure
Independent data on both the exclusive and dual use of electronic cigarettes by socioeconomic
status should be collected
In light of evidence showing how the tobacco industry intends to misuse its claimed interest in harm
reduction, the Faculty of Public Health stresses that full weight should be accorded to Article 5.3 of the
FCTC.
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Developments should be closely monitored and independent data on use of electronic
cigarettes by socioeconomic status should be collected
Regulation should ensure that:
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products are consistent in quality and deliver nicotine as effectively and safely as possible;
no advertising and marketing can target children and young people or other non-smokers
(including through sponsorship of sporting events, product placement, use of flavours designed
to appeal to youth, or use of celebrity spokespersons);
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World Health Organisation, Guidelines for implementation of Article 13 of the WHO Framework Convention on Tobacco Control
http://www.who.int/fctc/guidelines/article_13.pdf?ua=1; and World Health Organisation, Guidelines on Protection from Exposure to Smoke,
http://www.who.int/fctc/cop/art%208%20guidelines_english.pdf?ua=1
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no advertising or use (for example, in public places) can ‘renormalise’ or ‘re-glamourise’
smoking and undermine smoking prevention policies;
 all products clearly indicate the addictive nature of nicotine and encourage smoking cessation
by providing links to the NHS Smokefree website;
 no advertising or marketing is based misleading or unsubstantiated health claims;
 un-licensed electronic cigarettes and other nicotine containing products is subject to the same
controls as tobacco products so that they cannot be advertised.
Please read the Faculty of Public Health’s policy paper on electronic cigarettes
The Faculty of Public Health supports our parent college, the Royal College of Physicians, in urging
the Welsh Government to take measures to ensure that all pharmacies across Wales offer advanced
smoking cessation Level 3 services. Currently, all pharmacies are expected to offer opportunistic
healthy lifestyle advice to smokers, or to take part in national or local health promotion campaigns.
The current arrangement is agreed on a local health board basis which means that delivery of these
services is inconsistent across Wales. Some local authority areas have no Level 3 pharmacy provision
at all.
Smoking in Cars with Children
The Faculty of Public Health urges the Welsh Government to ban smoking in cars carrying children.
Recent research in Wales shows that 81% would support legislation on banning smoking in cars to
protect young people from exposure to second-hand smoke. Passive smoking is still a real issue,
particularly for children and the vulnerable. We know there is a strong link between childhood
exposure to second hand smoke and asthma, chest infections and bacterial meningitis. Research by
the Royal College of Physicians has found that passive smoking causes around 9,500 hospital
admissions in the UK every year and results in around 40 sudden infant deaths.
Standardised packaging of tobacco products
The Faculty of Public Health strongly supports the introduction of standardised tobacco packaging. We
have welcomed the UK Government’s amendment to Children and Families Bill which will allow the
introduction of standardised packaging of tobacco products and we would urge the Welsh Government
to introduce this measure as soon as possible.
Obesity
The Faculty of Public Health supports the introduction of nutritional standards in pre-school settings
and care homes. We strongly advocate for such standards to be extended to hospitals, and to include
both in-patient menus and the wider catering offer available to staff and visitors in hospitals. We
believe that it is imperative that hospitals lead by example in supporting healthy weight, including
through promotion and, where necessary, subsidisation of healthier food options for patients, staff and
visitors.
However, the Faculty of Public Health shares the concerns raised by our parent college, the Royal
College of Physicians, and are disappointed to see that this is the extent of the Welsh Government
commitment in this white paper on measures to tackle obesity and physical activity in Wales. The
latest Welsh figures show that 58% of adults were classified as overweight or obese. Obesity puts
patients at high risk of developing conditions like diabetes, high blood pressure and stroke, and it
costs the Welsh NHS millions of pounds every year.
A comprehensive obesity strategy, with a focus on preventing this pressure on the NHS and involving
further strong and complementary measures will be necessary, firstly aiming to substantially reduce
intakes of sugars in children and adults, particularly given that Welsh adults and children consume
approximately 15% of energy from added sugars, whereas the World Health Organisation target
(supported by the Faculty of Public Health and Action on Sugar) is less than 5% energy.
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It is critical to ensure that the right emphasis is placed on prevention, and to that end, the Faculty of
Public Health make the following recommendations:
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Consider fiscal and regulatory policies
Local Directors of Public Health and Health Boards should act as strong advocates for the
most effective evidence-based interventions
Joint strategic needs assessments should reflect the obesity burden in populations
Health Boards should consider the guidance produced by the National Institute for Health and
Care Excellence on obesity, active travel, physical activity and other relevant guidance, and
how the guidance should be implemented locally
Free water in all children’s environments, including schools, parks, playgrounds, sports stadia
and cinemas
A ban on all junk food (high in saturated fat, salt or refined sugars) and sugary drink marketing
to children
Schools (including academies) and early years environments should abide by the nutritional
standards of the Children’s Food Trust and the School Food Plan
Active encouragement of breastfeeding
Policies to increase active travel (cycling and walking), such as lower speed limits, changes to
road design, designated cycle routes and cycle storage
Schools to encourage active travel through policies such as walking – buses, bike storage and
cycle training
All planning permission decisions to take the impact on health into consideration, including
through the use of Health Impact Assessments
Reformulation will also be necessary, to substantially reduce the added sugars hidden in junk
food and sugary drinks (Mandatory reformulation consistently works better than voluntary
reformulation)
to inform consumers, we need legislation requiring all manufacturers to adopt the consistent
food nutritional labelling system
We draw attention the report by the Academy of Medical Royal Colleges, “Measuring Up – the medical
profession’s prescription to the obesity crisis”, which sets out a range of practical recommendations
that we would urge the Welsh Government to adopt as part of a strategy on the most effective and
coherent way to tackle obesity, as set out below:
1. Education and training programmes for healthcare professionals: Royal Colleges,
Faculties and other professional clinical bodies should promote targeted education and training
programmes within the next two years for healthcare professionals in both primary and
secondary care to ensure ‘making every contact count’ becomes a reality, particularly for those
who have most influence on patient behaviour
2. Weight management services: The departments of health in the four nations should together
invest at least £100m in each of the next three financial years to extend and increase provision
of weight management services across the country, to mirror the provision of smoking
cessation services. This should include both early intervention programmes and, greater
provision for severe and complicated obesity, including bariatric surgery. Adjustments could
then be made to the Quality and Outcomes Framework, providing incentives for GPs to refer
patients to such services
3. Nutritional standards for food in hospitals: Food-based standards in line with those put in
place for schools in England in 2006 should be introduced in all UK hospitals in the next 18
months. Commissioners should work with a delivery agent similar to the Children’s Food Trust
to put these measures into place
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4. Increasing support for new parents: The current expansion of the health visitor workforce in
England should be accompanied by 'skilling up' the wider early years workforce to deliver basic
food preparation skills to new mothers and fathers, and to guide appropriate food choices
which will ensure nutritionally balanced meals, encourage breastfeeding and use existing
guidance in the Personal Child Health Record as a tool to support this.
5. Nutritional standards in schools: The existing mandatory food- and nutrient-based
standards in England should be applied to all schools including free schools and academies.
This should be accompanied by a new statutory requirement on all schools to provide food
skills, including cooking, and growing – alongside a sound theoretical understanding of the
long-term effects of food on health and the environment from the 2014/15 academic year
6. Fast food outlets near schools: Public Health England should, in its first 18 months of
operation, undertake an audit of local authority licensing and catering arrangements with the
intention of developing formal recommendations on reducing the proximity of fast food outlets
to schools, colleges, leisure centres and other places where children gather
7. Junk food advertising: A ban on advertising of foods high in saturated fats, sugar and salt
before 9pm, and an agreement from commercial broadcasters that they will not allow these
foods to be advertised on internet ‘on-demand’ services
8. Sugary drinks tax: For an initial one year, a duty should be piloted on all sugary soft drinks,
increasing the price by at least 20%. This would be an experimental measure, looking at price
elasticity, substitution effects, and to what extent it impacts upon consumption patterns and
producer/retailer responses
9. Food labelling: Major food manufacturers and supermarkets should agree in the next year a
unified system of traffic light food labelling (to be based on percentage of calories for men,
women, children and adolescents) and visible calorie indicators for restaurants, especially fast
food outlets
10. The built environment: Public Health England should provide guidance to Directors of Public
Health in working with Local Authorities to encourage active travel and protect or increase
green spaces to make the healthy option the easy option. In all four nations, local authority
planning decisions should be subject to a mandatory health impact assessment, which would
evaluate their potential impact upon the populations’ health.
We also draw attention to the 2013 report, Action on Obesity by the Royal College of Physicians,
which found that the response of the NHS to obesity is patchy at best. The Faculty of Public Health
supports the RCP’s recommendation that multi-disciplinary weight management clinics be made
available to cover severe and complex obesity, and in Wales, this could be done by centrally
commissioning and funding these services. We urge the Welsh Government to appoint a national
clinical lead for severe and complex obesity. This would help to provide a clear line of accountability
for delivering on the Welsh Government’s obesity agenda.
Sugar Sweetened Beverages
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FPH advocates the introduction, by the government and other relevant bodies, of a 20p per
litre excise duty on sugar-sweetened beverages, with the proceeds being used to fund healthy
improvements in child health and wellbeing.
Food Marketing to Children
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The Faculty of Public Health make the following recommendations with regard to food marketing to
children:
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Clearly communicate to stakeholders what is defined as high fat, sugar salt (HFSS) foods and
drinks
Support schools, early years settings, youth, leisure and other settings ‘where children gather’
to:
o discuss the reasons why children need to be protected from the marketing of HFSS
foods and drinks
o develop local food policies so that they are free from all forms of marketing of foods
high in saturated fats, transfatty acids, free sugars or salt
Ensure that services commissioned by the NHS and local authorities do not have any
marketing of foods that are high in saturated fats, transfatty acids, free sugars or salt, by
including this in service specifications
Influence stakeholders to ensure cultural and sporting activities in the local areas are free from
marketing of foods high in saturated fats, transfatty acids, free sugars or salt.
Work with enforcement agencies such as environmental health officers and other partners to
monitor these actions and explore further opportunities
Raise awareness and educate the wider public health workforce about the impact of food
advertising to children, and the wide range of forms food marketing can take
Use local media to advocate
The Built Environment and Physical Activity:
The Faculty of Public Health make the following recommendations with regard to the Built
Environment and Physical Activity:
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Build relationships with stakeholders including councillors, planning, regeneration and transport
teams in the local authority, local employers and across government departments
Ensure public health is considered in local plans and strategies
Ensure that built environment and planning are considered in Joint Strategic Needs
Assessment and by the Health Board
Make sure there is public health input at the earliest stages of planning proposals and that the
potential health impacts of proposals are assessed
Follow the recommendations in the FPH Position Statement on Transport to deliver measures
that achieve a modal shift away from cars in favour of walking, cycling and public transport.
Transport and Health
The Faculty of Public Health make the following recommendations with regard to the transport and
health:
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implement national and local policies which will deliver a modal shift away from cars in favour
of walking, cycling and public transport
ensure strong cross-sectoral engagement with the local authority transport planning team and
identify ways of working with them to deliver a modal shift away from cars in favour of walking,
cycling and public transport
Develop and implement NHS travel plans which deliver a modal shift away from cars in favour
of walking, cycling and public transport
Ensure that the policies advocated by FPH, NICE and the Association of Directors of Public
Health are implemented
Assess the potential health impacts (including effects on inequalities) of local and regional
transport policies and major transport projects
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Work with local authority planners and other key partners on new residential developments to
ensure that the most convenient, sustainable, active and affordable option for short journey
stages will be walking and cycling, and for longer journey stages cycling and public transport.
(see FPH’s Built Environment and Physical Activity statement detailed below)
Work with healthcare providers to promote active travel as a convenient and sustainable
means of maintaining good health and recovering from illness
Use Health Boards and local health strategies to include and promote public health and active
travel, as well as influence planning and transport policies
Follow the recommendations in the FPH position statement on The Built Environment and
Physical
Activity to integrate public health considerations into the design, delivery, adaption and
maintenance of the built environment.
Please find the Faculty of Public Health’s position and briefing statements on these key issues,
containing more detailed recommendations for action, at the following links:
 The built environment and physical activity briefing statement (pdf)
 The built environment position statement (pdf)
 Food marketing to children (pdf)
 Obesity (pdf) and
 Transport and health position statement (pdf)
 Transport and health briefing statement (pdf)
 Sugar sweetened beverages (pdf)
Health Services Public Health
The Faculty of Public Health in making this response draws attention to the importance of ensuring
that Health Services Public Health is firmly embedded in any legislative mechanism that the Welsh
Government develops to address public health. Health Services Public Health is:
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a discrete and identifiable branch of the speciality of Public Health concerned with maximising
the population benefits from health care
involved with commissioning, and ensuring the delivery of, clinically effective, cost effective and
high quality services for the population
is concerned with all aspects of health service provision, not only health improvement or
disease prevention initiatives
the skills and expertise of Health Services Public Health are central to the effective delivery of
public health in Wales
The NHS needs to ensure the health services public health function is appropriately positioned
to ensure the most effective and efficient NHS services to optimise potential health impact
HSPH will deliver Right Care, Better Care and Better Value Health Care.
Health Services Public Health (HSPH) is that branch of public health that is concerned with
commissioning all NHS services, including acute hospital services, for the population. It is universally
acknowledged that the majority of health spending is within hospitals, and that this is spiralling out of
control. GPs have a major impact on health spend; committing a large proportion of NHS spending
through prescribing and act as gatekeepers to the hospital sector.
To ensure the best possible use of NHS resources – particularly during this current financial climate –
Health Services Public Health needs to be embedded in all tiers of the NHS commissioning process.
Health Services Public Health can support the delivery of a more efficient, cost-effective health system
that delivers real gains to the population through its core functions of:
4 St Andrews Place  London  NW1 4LB  Tel: 020 3696 1452  Fax: 020 3696 1457
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
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Identifying and highlighting areas of potential gains in outcome, quality or safety of clinical
services that can make the biggest differences;
Balancing the needs of different groups of patients, ensuring fair access to treatments for all
members of the population;
Analysing the evidence for treatments, identifying those that are effective, and deciding which
are a fair use of commissioning resources;
Placing those interventions which are clinically and cost effective into a priority order;
Managing value in health care;
Translating this into the necessary service plans for local populations;
Supporting the development and improvement of local clinical services according to these
priorities;
Leading the innovation agenda, interpreting, prioritising, monitoring, industrialising and
continuously improving data and information, and getting the results into practice;
Monitoring and ensuring improvement in agreed clinical and functional service outcomes;
Ensuring high quality services, analysing risks and ensuring resolution, an increasingly
important function in the light of the forthcoming Francis report into Mid-Staffs;
Supporting building systems of health care.
Core Health Services Public Health Functions are not simply about giving advice. It is about ensuring
these vital functions are embedded in the process of commissioning, managing and delivering that
process, and ensuring it achieves its aims.
In order to achieve this, and to provide the essential skills critical to delivering an efficient and effective
health service, people trained in HSPH will have undergone their original clinical training and then
undertaken an additional five to ten years of training in statistics, epidemiology, health economics,
critical appraisal of the scientific literature, management and leadership, negotiation skills, the ethics of
priority setting and much more.
It is vitally important that this third domain of public health is embedded within any future public health
bill for Wales, so ensure that these vital skills and expertise are at the forefront of improving public
health. By embedding Health Services Public Health within the core NHS commissioning structures
the system as a whole will benefit from this vital function.
For further information, please contact Mark Weiss, Senior Policy Officer UK Faculty of Public Health
at: markweiss@fph.org.uk or on 0203 696 1479.
4 St Andrews Place  London  NW1 4LB  Tel: 020 3696 1452  Fax: 020 3696 1457
Email: enquiries@fph.org.uk  Website: www.fph.org.uk  Registered Charity No: 263894
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