Food in Scotland's Schools, the Scottish Government Invites Views - Let's Encourage Plant-Ba


Image from Bloomfit https://bloomfit.net/brazilian-school-districts-commit-to-100-percent-plant-based-menus/

The Scottish Government is consulting on the ‘Nutritional Requirements for Food and Drink in Schools’. This is an opportunity for us all to comment on the current position and the proposals the government is making. Submissions must be in by 29 August 2018. For full information on the consultation and to make submissions see: https://consult.gov.scot/support-and-wellbeing/food-and-drink-in-schools/ We are making a submission, set out below for reference, and the more of us who contribute the better.

Context

Earlier this year we published the results of our survey on vegan provision in state entities in Scotland, which revealed (among other things) that many of our schools are not providing plant-based food suitable for vegans. See: https://docs.wixstatic.com/ugd/d95b36_f4bccc9845854533ba8aea3cf8e590b2.pdf This has meant that children who ought to be benefiting from the free meals and drinks at school are missing out and others are being denied access to food services in schools.

We meet vegan children and their parents on our vegan information stalls every week who tell us that they are not being given plant-based options suitable for vegans at school. We have also been made aware that in at least one Local Authority area of Scotland the school caterers for the region are under the impression that they are not to provide plant-based meals containing no animal products, as veganism is a “special diet” requiring specific NHS approval. This is of course not the case, as the NHS recognises that a well-planned plant-based diet can provide us with everything we need and some schools are already providing good plant-based options suitable for vegans.

Vegans have the same legal protections as people with religious beliefs, because our moral conviction that it is wrong to use and kill non-human animals unnecessarily is protected under law. See: https://www.goveganscotland.com/product-page/paperback-vegan-rights-in-the-uk-promoting-animal-liberation-using-vegan-rights ; https://www.goveganscotland.com/product-page/ebook-vegan-rights-in-the-uk-promoting-animal-liberation-using-vegan-rights We believe our state is failing to comply with its legal obligations by failing to provide food suitable for vegans in our schools (and other state entities) and we have made this clear to the Scottish Government.

We are all entitled to accurate and up to date nutritional information, but our current general nutritional guidelines and the specific nutritional requirements for schools undermine vegans and veganism by failing to recognise the nutritional adequacy of plant-based eating.

This consultation is an opportunity for us all to point this out, and to call for the Scottish Government to take steps to ensure that:

1 – plant-based food and drink that is suitable for vegans is made available to all on a day to day basis, without the need for special arrangements, in all of our schools (for every type of food or drink available, from canteen to vending machine, there ought to be good plant-based equivalents that are suitable for vegans);

2 – update our nutritional guidelines (general and school nutrition) to bring them into line with the fact that a fully plant-based diet is recognised as nutritional adequate by, for example, the British Dietetics Association (https://www.vegansociety.com/society/whos-involved/partners/british-dietetic-association) and the NHS (“With good planning and an understanding of what makes up a healthy, balanced vegan diet, you can get all the nutrients your body needs.” https://www.nhs.uk/live-well/eat-well/the-vegan-diet/; the NHS has also recognised the benefits of a plant-based diet for diabetes: https://www.nhs.uk/news/diabetes/going-vegan-may-help-prevent-diabetes-overweight-people/)

3 – ensure that the school curriculum adequately reflects the fact that a fully plant-based diet is recognised as nutritional adequate, including the Food and Health Experiences and Outcomes (intended to “support[] children and young people to develop their understanding of a healthy diet”) and in the Better Eating, Better Learning curriculum (said to provide “currently provides guidance and support to schools, local authorities, caterers, procurement departments, parents, children and young people to work in partnership to make further improvements in school food and food education.”)

4 - shift the focus in our school meals generally, away from animal products and towards plant-based meals, in recognition of the health benefits of doing so. This would also be in line with the government's policies on sustainability and the environment. Plant-based food is inclusive, as it can be enjoyed by everyone.

We set out below the four Consultation questions and our responses. The most relevant of the four sections sections are Theme One, where the government proposes to increase access to fruit and vegetables, and Theme Three, where the government recognises "robust evidence" linking the consumption of red meat to cancer, but then proposes to continue to use red and red processed meat in our schools, ignoring the excellent plant-based sources of protein and iron. The UK wide Eatwell Guide recognises that we can obtain these nutrients from plant-based sources.

Consultation Questions and Responses

We set out here the questions in the Consultation document and our responses:

“Theme One – Increase access to fruit and vegetables

Dietary data presented in the Scottish Health Survey 2016 tells us most children and young people are consuming far fewer portions of fruit and vegetables than is recommended within the Scottish Dietary Goals. The Scottish Ministers are committed to ensuring every pupil leaves school equipped with the skills, knowledge and experience they need to make better health choices and live longer, healthier lives free from avoidable, diet related conditions. The food and drink they are offered in school can have a big influence in habit setting which is why fruit and vegetables form part of the current school food and drink Regulations. We propose to amend the school food and drink Regulations to ensure it is easier for children and young people to access more fruit and vegetables as part of their school day.

In particular, we propose to amend the school food and drink Regulations to require a minimum of two portions of vegetables and a portion of fruit to be offered as part of a primary school lunch. In addition, full portions of fruit and/or vegetables must also be made available in any place within the school where food is provided, for example a tuckshop.

For secondary schools, we propose to amend the school food and drink Regulations to require two portions of vegetables and a portion of fruit to be offered as part of a full school lunch. In addition, where secondary pupils are choosing to take a main meal rather than a full lunch, that main meal must include salad or vegetables as part of the price. Full portions of fruit and/or vegetables must also be made available in any place within the school where food is provided for example a morning break service.

Question One: What are your views on our intention to amend the current school food and drink Regulations to ensure children and young people are able to access more fruit and vegetables as part of their school day.”

GVS Answer:

We are fully supportive of amending the current school food and drink regulations to ensure young people are able to access more fruit and vegetables as part of their school day. However, further steps must be taken to ensure that meaningful changes are made.

The school nutrition guidelines and the general nutrition guidelines should be updated to reflect the fact that (1) we can get everything we need on a fully plant-based diet, and (2) there are many health benefits to eating plant-based.

This is essential in order to ensure that children who are following a fully plant-based diet are supported in doing so, and that they are provided with good quality, tasty, nutritious plant-based food and drink when at school. Many vegan children are currently not supported in school as they are not provided with plant-based options that are suitable for vegans. We meet children in this position every week on our stalls and we heard from many of them when we conducted a survey last year. https://docs.wixstatic.com/ugd/d95b36_f4bccc9845854533ba8aea3cf8e590b2.pdf

We have also been advised that in at least one local authority area in Scotland the school caterers are under the impression that they cannot provide fully plant-based meals, as they believe veganism is a special diet requiring NHS sign off on a case by case basis. Of course, this is not the case. A fully plant-based diet is recognised as nutritionally adequate by, for example, the British Dietetics Association (https://www.vegansociety.com/society/whos-involved/partners/british-dietetic-association) and the NHS (“With good planning and an understanding of what makes up a healthy, balanced vegan diet, you can get all the nutrients your body needs.” https://www.nhs.uk/live-well/eat-well/the-vegan-diet/. The NHS has also recognised the benefits of a plant-based diet for diabetes: https://www.nhs.uk/news/diabetes/going-vegan-may-help-prevent-diabetes-overweight-people/).

Nevertheless, many of Scotland’s schools are failing to provide suitable food to vegan children, and it appears that this is at least in part due to a lack of understanding of the nutritional adequacy of plant-based eating.

This is perhaps unsurprising when we look at our national guidelines. The March 2016 Revised Dietary Goals for Scotland do not support plant-based eating. The Goals, set out in Table 1, include consuming a fish at least once a week. Vegans obviously do not consume fishes, and nor do we need to meet our nutritional needs. To state in our national dietary goals that we should all eat a fish every week is to fail to support vegans and veganism, and to undermine our ability to live in accordance with our protected convictions. Similarly, there is a goal of consuming around 70g of “red meat” a day. Again, vegans do not consume the flesh of animals and our dietary goals ought to be drafted in a way that recognises that it is entirely possible to get everything you need on a fully plant-based diet, and indeed there is increasing evidence that it is far better for human health to avoid animal products. This filters through to our school nutrition guidelines, which state that “Oily fish must be provided at least once every three weeks.”

The guide goes on to give suggestions as to how to encourage children to eat fishes, including ensuring that all staff understand the benefits of consuming fish. (page 25-26) There is no guidance regarding vegan children, and the fact that they should not be encouraged to consume fish, nor be given incorrect information regarding their ability to secure Omega 3 from other sources.

The guidance does not appear to account for vegan children at all (nor other children who avoid dairy and other animal products for other reasons). Presumably there is an intention to at least update our guidance to reflect the 2016/17 Eatwell Guide and guidance, in which express provision is made for alternatives to dairy, and the recommended amount of “dairy and alternatives” is reduced (from 15 to 8%).

It is essential that our school food and drink regulations and related guidance are updated to put it beyond doubt that fully plant-based meals comply with the nutrition guidelines and that good quality, tasty, nutritious plant-based options must be made available to vegan children. It is a legal requirement that the vegan conviction that it is wrong to use and kill non-human animals unnecessarily be respected, including in relation to access to food. Vegans have equivalent rights to those held by people who have religious beliefs. It is unacceptable that many vegan children are not provided for in our schools, so that they are missing out on free meals and are not given the same access to food services in schools. Encouraging greater provision of fruit and vegetables will not address this situation in any way if caterers provide foods with more fruit and vegetables but which also contain dairy, eggs and/or honey. Without any direction from the government regarding the necessity to provide options that are suitable for vegans, that may well be what caterers do. Even if the fruit was made available whole, although that would obviously be suitable for vegans it would not address the fact that vegan children are not being provided with proper meals.

Moreover, as there are many health benefits to eating plant-based, the guidelines ought to encourage a greater emphasis on fully plant-based options for all children. Requiring the inclusion of fully plant-based options (suitable for vegans) on every menu, every day, would ensure that vegan pupils were provided for, but it would also ensure that everyone else had access to tasty, nutritious meals. Vegan food can be enjoyed by everyone. There is no need for a vegetarian option when there is a vegan option, as vegetarians can eat vegan food. Similarly, there is no need for a separate meal for those who are allergic to dairy, as they too can eat vegan food. If good vegan options were required on every menu, every day, and these were tasty, interesting, satisfying and nutritious meals, everyone could enjoy them. Vegan food is inclusive.

We emphasise interesting, tasty and satisfying as well as nutritious, because we are not going to encourage young people to form a good relationship with vegetables and fruit by forcing them to consume meals or items that they do not enjoy. Overcooked vegetables, limp salad and dry, tasteless dishes will do nothing to inspire them to eat more fruit and veg. The most delicious plant-based meals can be made in bulk and on a very tight budget. We would encourage the relevant people to contact The Vegan Society as they have a lot of experience working with government bodies as well as in the private sphere, designing menus that fit a particular budget and procurement arrangement: https://www.vegansociety.com/take-action/campaigns/catering-everyone/schools They would be delighted to offer free advice.

The health and other benefits associated with shifting the focus from animal products to plant-based foods have been recognised elsewhere in the world, and examples of a greater emphasis on plant-based school meals include:

http://www.organicauthority.com/v-is-for-vegan-plant-based-school-lunches-on-the-rise

https://www.ecowatch.com/brazil-schools-plant-based-meals-2553155526.html

https://www.plantbasednews.org/post/mexican-state-serve-925-000-vegan-school-meals

We have a duty to take into account the voluminous studies which demonstrate the negative health implications of consuming animal products, and on the other hand the health benefits of adopting a fully plant-based diet, and to adjust our school meals accordingly. It is not good enough for our government to continue to promote the consumption of animal products in our schools in the face of this information. To do so would be to disregard the health of our school children. Studies which support plant-based eating for good health, and for the prevention and in some cases reversal of serious illnesses, include the following; please take into account the quoted passages and refer to the full studies for more detail, and please note the findings related to consumption of fish, dairy and eggs, as well as meat:

Position of the Academy of Nutrition and Dietetics: Vegetarian Diets J Acad Nutr Diet. 2016;116:1970-1980: “It is the position of the Academy of Nutrition and Dietetics that appropriately planned vegetarian, including vegan, diets are healthful, nutritionally adequate, and may provide health benefits for the prevention and treatment of certain diseases. These diets are appropriate for all stages of the life cycle, including pregnancy, lactation, infancy, childhood, adolescence, older adulthood, and for athletes….…vegans are at reduced risk of certain health conditions, including ischemic heart disease, type 2 diabetes, hypertension, certain types of cancer, and obesity.”

Hever J & Cronise RJ. (2017) Plant-based nutrition for healthcare professionals. Journal of Geriatric Cardiology) 14: 355-368. “Ultimately the dietary change needed in society requires the leadership of all healthcare professionals. A whole food, plant-based diet pattern can be easily achieved and is at least one solution to the tremendous socioeconomic burden that nutritionally-induced, non-communicable chronic diseases places on all of humanity….Plant-based diets are associated with lowering overall mortality and ischemic heart disease mortality; reducing medication needs; supporting sustainable weight management; reducing incidence and severity of high- risk conditions, such as obesity and obesity-related inflammatory markers, hyperglycemia, hypertension, and hyperlipidemia; and even reversing advanced cardio-vascular disease and type 2 diabetes…..These advantages are likely the result of both the consistent consumption of innate health-promoting compounds found in whole plant foods and the reduction of exposure to harmful substances found in animal products and highly pro-cessed foods. Meat (including processed, red, and white assortments), fish, dairy, and eggs contain health-damaging saturated fats, heme iron, Nglycolylneuraminic acid (Neu5Gc), carnitine, and chemical contaminants formed when flesh is cooked, such as polycyclic aromatic hydrocarbons, hetero-cyclic amines, and advanced glycation end products. Highly processed foods encompass a class of commercially produced items made with adulterants including oils, salts, sugars, and other food additives. These aforementioned constituents in animal products and processed foods con-tribute to inflammation, oxidation, and carcinogenesis, promo-ting disease and, therefore, are better omitted from the diet. “

A study conducted by researchers at the Oxford Martin Programme on the Future of food in 2016, which considered the potential health, environmental and financial benefits of four types of diet by the year 2050, concluded that the fewer animal products consumed the greater the benefits. They found that adopting a vegan diet could avoid 8.1 million deaths globally. This was due to a combined impact of cutting out meat and increasing intake of fruit and vegetables. They concluded: “Our analysis indicates that dietary changes toward fewer animal and more plant-based foods are associated with significant benefits due to reductions in diet-related mortality.” In terms of the economic benefits, they found that the US alone could save $700-$1,000 billion per year on healthcare and lost work days. There was also an economic benefit in terms of reduced greenhouse gas emissions of as much as $570 billion. The study highlights the specific impact on coronary heart disease, stroke, cancer and type 2 diabetes. http://www.pnas.org/content/113/15/4146.long

Tonstad S, Butler T, Yan R, Fraser GE. (2009) Type of vegetarian diet, body weight and prevalence of type 2 diabetes. Diabetes Care. 32(5):791-796. “This study demonstrates that while elimination of animal flesh from diet is beneficial, the more closely diet approaches complete elimination of animal foods, the better the outcome with respect to Type 2 diabetes.. ..The main finding was that vegan and lacto-ovo vegetarian diets were associated with a nearly one-half reduction in risk of type 2 diabetes compared with the risk associated with nonvegetarian diets after adjustment for a number of socioeconomic and lifestyle factors, as well as low BMI, that are typically associated with vegetarianism. Pesco- and semi-vegetarian diets were associated with intermediate risk reductions: between one-third and one-quarter. These data indicate that vegetarian diets may in part counteract the environmental forces leading to obesity and increased rates of type 2 diabetes, though only vegan diets were associated with a BMI in the optimal range. Inclusion of meat, meat products, and fish in the diet, even on a less than weekly basis, seems to limit some of the protection associated with a vegan or lacto-ovo vegetarian diet. These findings may be explained by adverse effects of meat and fish.”

Crowe FL, Appleby PN, Travis RC, Key TJ. (2013) Risk of hospitalization or death from ischemic heart disease among British vegetarians and nonvegetarians: Results from the EPIC-Oxford cohort study. Am J Clin Nutr. 97(3):597-603. “The results from this prospective analysis involving 15,000 vegetarians and 30,000 nonvegetarians with 1200 cases of IHD show that vegetarians in the United Kingdom have a 32% lower risk of developing IHD than do people who consume meat and/or fish.”

Rizzo NS, Sabaté J, Jaceldo-Siegl K, Fraser GE. (2011) Vegetarian dietary patterns are associated with a lower risk of metabolic syndrome: The Adventist Health Study 2. Diabetes Care.2011;34(5):1225-1227.

Pettersen BJ, Anousheh R, Fan J, Jaceldo-Siegl K, Fraser GE. (2012) Vegetarian diets and blood pressure among white subjects: Results from the Adventist HealthStudy-2 (AHS-2). Public Health Nutr.2012;15(10):1909-1916. “This study demonstrates that complete elimination of animal foods from diet has more favourable results in term of hypertension than other diets.”

Wang F, Zheng J, Yang B, Jiang J, Fu Y, Li D. (2015) Effects of vegetarian diets on blood lipids: A systematic review and meta-analysis of randomized controlled trials. J Am Heart Assoc. 2015;4(10):e002408. “This systematic review and meta-analysis provides evidence that vegetarian diets effectively lower blood concentrations of total cholesterol, lowdensity lipoprotein cholesterol, high-density lipoprotein cholesterol, and non–high-density lipoprotein cholesterol. Such diets could be a useful nonpharmaceutical means of managing dyslipidemia, especially hypercholesterolemia. Dslipidemia is a primary risk factor for the development of cardiovascular diseases, such as heart disease, stroke, and coronary artery disease.”

Huang T, Yang B, Zheng J, Li G, Wahlqvist ML, Li D. (2012) Cardiovascular disease mortality and cancer incidence in vegetarians: A meta-analysis and systematic review.

Ann Nutr Metab. 2012;60(4):233-240. “Our results suggest that vegetarians have a significantly lower ischemic heart disease mortality (29%) and overall cancer incidence (18%) than nonvegetarians.”

Ornish et al (1990) Can lifestyle changes reverse coronary heart disease? The Lifestyle Heart Trial. The Lancet, 336: 129-33.

Esslestyn et al (2014) A way to reverse CAD? The Journal of Family Practice, Vol 63, No 7. “The results of this evaluation provide further evidence that plant-based nutrition may prevent, halt, and reverse CAD.”

Esselstyn, BC (2017) A plant-based diet and coronary artery disease: a mandate for effective therapy. Journal of Geriatric Cardiology 14: 317-320.

Ornish, D, Weidner, G Fair, WR et al (2005) Intensive lifestyle changes may affect the progression of prostate cancer. J Urol, 174(3):1065-9 in Greger, M (2016) How Not To Die, McMillan: London.

Hana Kahleova, ID, Susan Levin, and Neal Barnard (2017) Cardio-Metabolic Benefits of Plant-Based Diets, Nutrients 2017, 9, 848. “Evidence suggests that plant-based diets may reduce the risk of coronary heart disease events by an estimated 40% and the risk of cerebral vascular disease events by 29%. These diets also reduce the risk of developing metabolic syndrome and type 2 diabetes by about one half. The use of plant-based diets as a means of prevention and treatment of cardio-metabolic disease should be promoted through dietary guidelines and recommendations. Plant-based diets are associated with decreased all-cause mortality and decreased risk of obesity, type 2 diabetes, and coronary heart disease. Plantbased diets are characterized by a reduction or elimination of animal product consumption.” “BMI values tend to increase with increasing frequency of animal product consumption. In the Adventist Health Study-2, BMIs were lowest among vegans (23.6 kg/m2), higher in lacto-ovovegetarians (25.7 kg/m2), and highest in nonvegetarians (28.8 kg/m2).” “Diabetes prevalence has been found to be the lowest among vegans (Odds ratio (OR) 0.51; 95% CI 0.40–0.66) and lacto-ovo-vegetarians (OR 0.54; 95% CI 0.49–0.60), compared with nonvegetarians….The benefit of omitting meat, cheese, and eggs was as much as 0.7 points in some studies, and averaged about 0.4 points overall.” “High protein intake, especially from meat, increases blood pressure. High potassium intake, however, lowers blood pressure among people with hypertension. Vegetarian diets typically have higher fiber and potassium and lower fat, compared with omnivorous diets….“a recent meta-analysis of randomized clinical trials and observational studies showed clear benefits of plant-based diets for blood pressure. Given the consistent results between the studies, the evidence is strong.” “Saturated fat increases plasma LDL cholesterol concentrations. According to a report published by the American Heart Association, replacing saturated fat in the diet and replacing it with polyunsaturated vegetable oil can reduce the risk of cardiovascular disease by about 30%, similar to the effect of statins. The authors concluded that the incidence of cardiovascular disease (CVD) would decrease with such a dietary shift. Dietary cholesterol increases serum total and LDL-cholesterol concentrations. Dietary cholesterol is found only in animal products including meat, dairy, and eggs. Vegetarian and especially vegan dietary patterns improve both fasting and postprandial blood lipids compared with conventional therapeutic diets, with effects similar to those seen with statin therapy. In summary, the findings of interventional trials are in accordance with those of observational studies, and the evidence for improved blood lipid profiles in response to plant-based diets is strong.”

Esselstyn, CB (2000) In cholesterol lowering, moderation kills. Cleveland Clinical Journal of Medicine, Vol 67. No 8. “The high-fat American diet is responsible for an epidemic of coronary artery disease. A plant-based diet with less than 10% fat will prevent coronary disease from developing, halt the progress of existing disease, and even reverse the disease in many patients. “

Roberts WC (2010). It's the cholesterol, stupid! Am J Cardiol. Nov 1;106(9):1364-6.

Kim Allan Williams (2017) Introduction to the “A plant-based diet and cardiovascular disease” special issue J Geriatr Cardiol 2017; 14: 316. “…the “truth” (i.e. evidence) for the benefits of plant-based nutrition continues to mount. This now includes lower rates of stroke, hypertension, diabetes mellitus, obesity, myocardial infarction and mortality, as well as many non-cardiac issues that affect our patients in cardiology, ranging from cancer to a variety of inflammatory conditions….Our goal must be to get data out to the medical community and the public where it can actually change lives—creating healthier and longer ones…Reading the existing literature and evaluating the impact of plant-based nutrition, it clearly represents the single most important yet underutilized opportunity to reverse the pending obesity and diabetes induced epidemic of morbidity and mortality.“

Spencer EA, Appleby PN, Davey GK, Key TJ. (2003) Diet and body mass index in 38000 EPIC-Oxford meat-eaters, fish-eaters, vegetarians and vegans. Int J Obes Relat Metab Disord.27(6):728-734. “Vegans had the lowest mean age-adjusted BMI and meat-eaters the highest. The difference in mean BMI between vegans and meat-eaters was 1.92 kg/m2 in men and 1.54 kg/m2 in women. Mean age-adjusted BMI in both fish-eaters and vegetarians was significantly less than mean age-adjusted BMI in meat-eaters, but significantly greater than mean age-adjusted BMI in vegans.”

Turner-McGrievy GM, Barnard ND, Scialli AR. (2007) A two-year randomized weight loss trial comparing a vegan diet to a more moderate low-fat diet. Obesity. 15(9):22762281.

Barnard NB, Levin SM, Yokoyama Y. (2015) A systematic review and meta-analysis of change in body weight in clinical trials of vegetarian diets. J Acad Nutr Diet. 115(6):954969.

Barnard N, Cohen J, Jenkins DJ, et al. (2006) A low-fat vegan diet improves glycemic control and cardiovascular risk factors in a randomized clinical trial in individuals with type 2 diabetes. Diabetes Care. 29(8):1777-1783

Barnard ND, Katcher HI, Jenkins DJ, Cohen J, Turner-McGrievy G. (2009) Vegetarian and vegan diets in type 2 diabetes management. Nutr Rev.67(5):255-263. “Vegetarian and vegan diets offer significant benefits for diabetes management. In observational studies, individuals following vegetarian diets are about half as likely to develop diabetes, compared with non-vegetarians. In clinical trials in individuals with type 2 diabetes, low-fat vegan diets improve glycemic control to a greater extent than conventional diabetes diets. Although this enect is primarily attributable to greater weight loss, evidence also suggests that reduced intake of saturated fats and high-glycemic-index foods, increased intake of dietary fibre and vegetable protein, reduced intramyocellular lipid concentrations, and decreased iron stores mediate the influence of plant-based diets on glycemia. Vegetarian and vegan diets also improve plasma lipid concentrations and have been shown to reverse atherosclerosis progression. In clinical studies, the reported acceptability of vegetarian and vegan diets is comparable to other therapeutic regimens. The presently available literature indicates that vegetarian and vegan diets present potential advantages for the management of type 2 diabetes.”

Bradbury KE, Crowe FL, Appleby PN, Schmidt JA, Travis RC, Key TJ. (2014) Serum concentrations of cholesterol, apolipoprotein A-I and apolipoprotein B in a total of 1694 meateaters, fish-eaters, vegetarians and vegans.

Eur J Clin Nutr. 68(2):178-183. “In conclusion, this study compares the serum lipid concentrations of British meat-eaters, fish-eaters, vegetarians and vegans, and finds lower serum concentrations of total and non-HDL cholesterol in vegans. Vegans also had very low saturated fat intakes and higher intakes of polyunsaturated fat and fibre.”

Appleby PN, Davey GK, Key TJ. (2002) Hypertension and blood pressure among meat eaters, fish eaters, vegetarians and vegans in EPIC Oxford. Public Health Nutr. 5(5):645-654

Orlich MJ, Singh PN, Sabaté J, et al. (2013) Vegetarian dietary patterns and mortality in Adventist Health Study 2. JAMA Intern Med.173(13):1230-1238. “In conclusion, in a large American cohort, we found that vegetarian dietary patterns were associated with lower mortality. The evidence that vegetarian diets, or similar diets with reduced meat consumption, may be associated with a lower risk of death should be considered carefully by individuals as they make dietary choices and by those offering dietary guidance.”

“Theme Two – reduce the sugar content of school food and drink provided in schools

It is well documented that children and young people in Scotland are consuming too much sugar in their diets and that this can have a serious impact on their health. The sugar content of school food and drink is already restricted by the existing school food and drink Regulations. But since they were introduced, the Scottish Ministers agreed to the Scottish Dietary Goals being updated to reflect dietary advice from the Scientific Advisory Committee on Nutrition (SACN) recommending that sugar intake is reduced further. As such our intention is to amend the school food and drink Regulations to reduce the amount of sugar provided by food and drink at lunchtimes and at all other times of the day, for example morning break or from vending machines.

In particular we are proposing to introduce a limit on the frequency of provision of sweetened and baked foods typically high in sugar in primary schools at lunchtime, along with introducing sugar limits for products such as breakfast cereals, yoghurts, sweetened and baked products across the school day. This is designed to reduce sugar provision over the school day and encourage more consumption of fruit and lower sugar alternatives.

In addition we are proposing changes to the lists of permitted drinks.

For primary schools we aim to reinforce the message that water, plain lower fat milk and calcium enriched milk alternatives should be the main focus with no added sugar, lower fat milk drinks (for example flavoured milk and hot chocolate) and drinking yoghurts being permitted at the discretion of schools and local authorities to allow additional choice. Fruit juice, vegetable juice, smoothies and fruit juice combinations will no longer be on the permitted drinks list, due to their high sugar content.

For secondary schools we aim to reinforce the message that water, plain lower fat milk and calcium enriched milk alternatives should be the main focus with tea, coffee, no added sugar, lower fat milk drinks (for example flavoured milk and hot chocolate), drinking yoghurts and sugar free drinks (excluding high caffeine) being permitted at the discretion of schools and local authorities to allow additional choice. Fruit juice, vegetable juice, smoothies and fruit juice combinations will no longer be on the permitted drinks list, due to their high sugar content.

There is already a duty on schools to ensure drinking water is made available to pupils, free of charge.

Question Two: What are your views on our intention to amend the current school food and drink Regulations to ensure the amount of sugar children and young people can access over the course of the school day is reduced?”

GVS Answer:

As above, steps should be taken to ensure that plant-based equivalents that are suitable for vegans are made available at all times.

Care should also be taken to ensure that any measures introduced to reduce sugar intake distinguish between refined sugar and fructose found in fruit. Fruit consumption is to be encouraged, as noted in question 1. It would be counterproductive to then have measures intended to reduce sugar intake which may cut across the aim of encouraging fruit consumption.

On the critical distinction between added, industrial sugar, and natural fruit sugar see for example: https://nutritionfacts.org/2016/08/09/what-about-all-the-sugar-in-fruit/

“Theme Three – provision of red and red processed meat

In 2010, the Scientific Advisory Committee on Nutrition (SACN) published robust evidence linking red and red processed meat to an increased risk of colorectal cancer in later life. In 2013, the Scottish Ministers agreed a new Scottish Dietary Goal limiting red and red processed meat. More recently, in 2017, the World Cancer Research Fund, published updated evidence which strengthens the links between red and red processed meat and risk of developing colorectal cancer in later life, particularly with respect to red processed meat.

Red meat can provide a good source of vital nutrients such as iron and inclusion in the school meal menu can contribute to meeting the nutrient standards. In order to retain this benefit but minimise the risk to children’s health, we propose to introduce a maximum level for red and red processed meat as part of school food and drink provision across the school week.

Question Three: What are your views on our intention to amend the school food and drink Regulations to set a maximum for red and red processed meat in primary school lunches and for overall provision in secondary schools.”

GVS Answer:

Given the available information regarding the harmful health effects of consuming animal proteins we fail to see what justification there can be for continuing to include meat in school meals at all.

Processed meat (e.g. bacon, ham etc) has been classed as carcinogenic to humans, while red meat has been classed as a probable carcinogen. See for example IARC Monographs evaluate consumption of red meat and processed meat: http://www.iarc.fr/en/mediacentre/pr/2015/pdfs/pr240_E.pdf and the WHO Classification of Meat as Carcinogen: http://www.who.int/features/qa/cancer-red-meat/en/

The Scottish Government acknowledges this in the consultation document, and yet it then proceeds to suggest that we continue to feed carcinogens to children in school. No convincing justification is provided for doing so.

There is no nutritional justification for the continued inclusion of carcinogens in our school meals. As set out in answer to question 1, we can obtain all of the nutrients we required on a fully plant-based diet. Specifically, there are far superior plant-based sources of protein and iron than animal flesh.

Protein:

It is very easy to consume sufficient protein on a fully plant-based diet. The idea that we need to carefully combine certain plant foods to obtain the necessary combination of amino acids has been shown to be incorrect. Most people consume too much protein (and not enough fiber). Consumption of animal proteins carries with it saturated fat, cholesterol and other substances which have a serious negative impact on our health. Plant protein is far superior; see for example:

https://www.pcrm.org/health/medNews/replacing-animal-protein-with-plant-protein-lowers-risk-for-mortality

https://www.pcrm.org/health/diets/vegdiets/how-can-i-get-enough-protein-the-protein-myth

https://nutritionfacts.org/video/plant-protein-preferable/

https://nutritionfacts.org/topics/plant-protein/

https://www.vegansociety.com/resources/nutrition-and-health/nutrients/protein

Iron:

The reference to iron as a justification for continuing to include probable carcinogens on our school menus, ignores the fact that there are excellent plant sources of iron, which do not carry with them the negative impacts of consuming animal protein. Plant-based iron is superior in terms of our health. See for example:

https://nutritionfacts.org/2017/06/15/plant-versus-animal-iron/

https://nutritionfacts.org/video/the-safety-of-heme-vs-non-heme-iron/

https://www.vegansociety.com/resources/nutrition-and-health/nutrients/iron

https://www.vegansociety.com/resources/nutrition-and-health/nutrients/iron; https://nutritionfacts.org/topics/iron/

Beyond processed and red meat, studies indicate more generally that the consumption of meat, fish, dairy and eggs are detrimental to our health. We have listed a number of sources on this point at the end of this answer.

The Scottish Government has shown itself to be prepared to take bold steps in other areas. If health in our schools is truly an important issue then we ought to address it head on. We should remove meat from our school menus and shift the focus away from animal products and onto plant-based food.

Other considerations, such as protection for established industries, ought not to be persuasive when we are considering if it is morally acceptable to continue to serve carcinogens to our children.

We have a vastly subsidised animal agriculture industry in Scotland. It is time to shift our focus from animal use and killing to plant-based agriculture, and to support our farmers to transition to growing good quality, nutritious plant food for all. If we had a joined up approach, as the Good Food Nation Bill gives us the opportunity for, we could transform Scotland's agricultural sector to the benefit of all. With a joined up approach we could see our schools supplied with locally grown, healthful, sustainable plant foods, with skilled cooks preparing delicious plant-based meals in our schools (and our other public institutions).

The Vegan Society has done a substantial amount of work looking in detail at how we can transition from animal agriculture to plant-based food growth, and they continue to work in this area: https://www.vegansociety.com/take-action/campaigns/grow-green It is a myth that our land could not sustain plant-based farming. Until the Vegan Society began its work in this area very little time or effort had been expended assessing the true potential for plant-based agriculture in this country, because we have complacently accepted the animal use status quo. With a shift in focus we will find all manner of ingenious techniques to improve the plant output from our land, techniques which are environmentally sound and sustainable.

The studies referred to above are:

• Barnard, ND, Nicholson, A, Howard, JL, (1995) The Medical Costs Attributable to Meat Consumption Preventive Medicine, 24, 646-655

• Li Y, Zhou C, Zhou X, Li L. (2013) Egg consumption and risk of cardiovascular diseases and diabetes: a meta-analysis. Atherosclerosis. Aug;229(2):524-30. “Egg serves as the major source of dietary cholesterol, containing 213 mg cholesterol per egg. Evidence from animal and human metabolic studies have found that dietary cholesterol from egg could raise serum levels of low density lipoprotein cholesterol (LDL-C), a well-established independent risk factor for cardiometabolic diseases including cardiovascular diseases (CVD) and diabetes. ….In conclusion, our meta-analysis indicates that there is positive dose-response association between egg consumption and the risk of CVD and diabetes.”

• Milk & Prostate Cancer: The Evidence (http://www.pcrm.org/health/health-topics/milk-andprostate-cancer-the-evidence-mounts ) “Major studies suggesting a link between milk and prostate cancer have appeared in medical journals since the 1970s. Two of six cohort studies (research studies following groups of people over time) found increased risk with higher milk intakes. Five studies comparing cancer patients to healthy individuals found a similar association…..In 1997, the World Cancer Research Fund and the American Institute for Cancer Research concluded that dairy products should be considered a possible contributor to prostate cancer. …Whole grains, beans and other legumes, vegetables, and fruits are cancer fighters. Plant foods are low in fat, high in fiber, and loaded with protective cancer-fighting nutrients. But animal products—meat, dairy, eggs—are linked to several forms of the disease. …..The most healthful diets eliminate meat, dairy products, eggs, and fried foods.”

• Lifestyle Medicine: A Brief Review of Its Dramatic Impact on Health and Survival http://www.thepermanentejournal.org/files/2018/17-025.pdf

• Dairy product consumption and risk of hip fracture: a systematic review and meta-analysis, Shanshan Bian, Jingmin Hu, Kai Zhang, Yunguo Wang, Miaohui Yu and Jie Ma BMC Public HealthBMC https://doi.org/10.1186/s12889-018-5041-5

• Lu W, Chen H, Niu Y, Wu H, Xia D, Wu Y. Dairy products intake and cancer mortality risk: a meta-analysis of 11 population-based cohort studies. Nutrition Journal. 2016;15:91. doi:10.1186/s12937-016-0210-9.

• Wang J, Li X, Zhang D. Dairy Product Consumption and Risk of Non-Hodgkin Lymphoma: A Meta-Analysis. Nutrients. 2016;8(3):120. doi:10.3390/nu8030120.

• Sun Y, Lin L-J, Sang L-X, Dai C, Jiang M, Zheng C-Q. Dairy product consumption and gastric cancer risk: A meta-analysis. World Journal of Gastroenterology : WJG. 2014;20(42):15879-15898. doi:10.3748/wjg.v20.i42.15879.

• Food for Life Cancer Project, PCRM (https://www.pcrm.org/health/cancer-resources/dietcancer/facts/foods-for-cancer-prevention ): “Although the total amount of fat one eats is of concern, there is evidence that animal fat is much more harmful than vegetable fat. One study noted a 200 percent increase in breast cancer among those who consume beef or pork five to six times per week. Dr. Sheila Bingham, a prominent cancer researcher from the University of Cambridge, notes that meat is more closely associated with colon cancer than any other factor. Meat and milk are also linked to both prostate and ovarian cancers.”

• Bingham SA. (1988) Meat, starch, and non-starch polysaccharides and bowel cancer. Am J Clin Nutr. 1988;48:762-767.

Rose DP, Boyar AP, Wynder EL. (1986) International comparisons of mortality rates for cancer of the breast, ovary, prostate, and colon, and per capita food consumption. Cancer. 1986;58:2363-2371.

• PCRM Factsheet on Eggs http://www.pcrm.org/sites/default/files/pdfs/health/Nutrition-FactSheets/Eggs-fact-sheet.pdf “There are many reasons to eliminate eggs from your diet. Recent studies suggest that egg consumption can cause heart disease, diabetes and even cancer.”

• Michaëlsson, K, Wolk, A, Langenskiöld, S, Basu, S, Warensjö Lemming, E, Melhus, H, Byberg, L (2014) Milk intake and risk of mortality and fractures in women and men: cohort studies. British Medical Journal,;349:g6015. “A higher consumption of milk in women and men is not accompanied by a lower risk of fracture and instead may be associated with a higher rate of death.”

• Li-Qiang, Q et al (2007) Milk consumption is a risk factor for prostate cancer in Western countries: evidence from cohort studies. Asia Pac J Clin Nutr;16 (3):467-476 “We have previously found a positive association between milk consumption and prostate cancer risk using meta-analysis to analyze published case-control studies. In the present study, further meta-analysis was conducted to estimate the summary relative risk (RR) between the consumption of milk and dairy products and prostate cancer from cohort studies published between 1966- 2006…These findings, together with the previous study, suggest that the consumption of milk and dairy products increases the risk of prostate cancer.”

• Chan, JM, Stampfer, MJ, Ma,J, Gann, PH, Gaziano, JM and Giovannucci, EL (2001). Dairy products, calcium, and prostate cancer risk in the Physicians’ Health Study. Am J Clin Nutr 74:549–54. “These results support the hypothesis that dairy products and calcium are associated with a greater risk of prostate cancer.”

• Susanna C Larsson, SC, Bergkvist, L, Wolk, A (2004) Milk and lactose intakes and ovarian cancer risk in the Swedish Mammography Cohort .Am J Clin Nutr 80:1353–7.“Our data indicate that high intakes of lactose and dairy products, particularly milk, are associated with an increased risk of serous ovarian cancer.”

• Kroenke, CH, Kwan, ML, Sweeney, C, Castillo, A, Caan, BJ (2013) High- and Low-Fat Dairy Intake, Recurrence, and Mortality After Breast Cancer Diagnosis. Natl Cancer Inst;105:616– 623 “Greater intake of high-fat dairy was related to higher risk of breast cancer–specific and non–breast cancer mortality in this cohort of long-term, early-stage breast cancer survivors. "

“Theme Four - A change to the application of nutrient standards in secondary schools

Young people in secondary schools buy and consume food and drinks in a very different way to primary school children. For a wide range of reasons, most tend not to sit down and eat a hot two course lunch in the middle of the day, and the consumption of foods outwith the lunch period is far more prevalent. Furthermore, most services sell items individually meaning planning provision to meet the nutrient standards does not always lead to the outcome intended. This makes applying nutrient standards in secondary schools challenging.

Our intention is to change the school food and drink Regulations so school meal providers need to demonstrate that young people can still choose and consume a meal which meets their nutritional requirements, whilst simultaneously introducing a wider range of food and drink standards across the full school day. These additional food and drink standards, for example, a restriction on the number of pastry products, and a restriction on the amount of sugar and fat contained in sweetened and baked goods, aim to bring all food and drinks provided in secondary schools closer to the Scottish Dietary Goals.

Question Four: What are your views on our intention to amend the school food and drink Regulations to enable caterers to provide a service which better supports secondary age pupils to make balanced and nutritious food and drink choices as part of their school day.”

GVS Answer:

We are fully supportive of amending the current school food and drink regulations to enable caterers to provide a service which better supports secondary age pupils to make balanced and nutritious food and drink choices as part of their school day. As set out in answer to questions 1 and 3, in making these changes to our school food and drink regulations we have an obligation to take into account the voluminous studies that support plant-based eating as the most healthful option, and to ensure that plant-based options that are free of all animal products (and so suitable for vegans) are available for all meals and snacks. This is very often overlooked for things like vending machines, where those procuring the products often don’t realise that a product that is marketed as a “health bar” will often contain milk and other animal derived ingredients. There are many fully plant-based snack options. We are always happy to help with suggestions.

As set out in answer to question 1, the school nutrition guidelines, the general nutrition guidelines and the dietary goals guidance should be updated to reflect the fact that (1) we can get everything we need on a fully plant-based diet, and (2) there are many health benefits to eating plant-based. It is essential that our school food and drink regulations and related guidance are updated to put it beyond doubt that fully plant-based meals and snacks comply with the nutrition guidelines and that good quality, tasty, nutritious plant-based options must be made available to vegan children.

“Question Five: Do you have anything else you wish to comment on in relation to the nutritional content of food and drink provided in local authority, and grant maintained, schools in Scotland via the School food and drink Regulations?”

GVS Answer:

We would like to reiterate that currently many children are missing out on school meals because they hold a moral conviction that is not being recognised or respected, in breach of the law. That is not acceptable. Whether you agree with our moral conviction or not, you should agree that it is wrong that someone should be denied access to food because they hold a moral conviction.

It is essential that all of our schools have good plant-based options that are suitable for vegans, on every menu, every day. For this to happen we need top down instruction and guidance, making it clear to all involved that fully plant-based options that are suitable for vegans do comply with nutrition guidelines, but we also need education for all involved in the provision of food and drink in schools, to ensure that they understand what veganism is and what someone who is vegan does and does not consume.

To that end we should ensure that:

1 – plant-based food and drink that is suitable for vegans is made available to all on a day to day basis, without the need for special arrangements, in all of our schools (for every type of food or drink available, from canteen to vending machine, there ought to be good plant-based equivalents that are suitable for vegans);

2 – update our nutritional guidelines (general and school nutrition) to bring them into line with the fact that a fully plant-based diet is recognised as nutritional adequate by, for example, the UK Dietetics Association (https://www.vegansociety.com/society/whos-involved/partners/british-dietetic-association) and the NHS (“With good planning and an understanding of what makes up a healthy, balanced vegan diet, you can get all the nutrients your body needs.” https://www.nhs.uk/live-well/eat-well/the-vegan-diet/; the NHS has also recognised the benefits of a plant-based diet for diabetes: https://www.nhs.uk/news/diabetes/going-vegan-may-help-prevent-diabetes-overweight-people/)

3 – ensure that the school curriculum adequately reflects the fact that a fully plant-based diet is recognised as nutritional adequate, including the Food and Health Experiences and Outcomes (intended to “support[] children and young people to develop their understanding of a healthy diet”) and in the Better Eating, Better Learning curriculum (said to provide “currently provides guidance and support to schools, local authorities, caterers, procurement departments, parents, children and young people to work in partnership to make further improvements in school food and food education.”),and

4 - shift the focus in our school meals generally, away from animal products and towards plant-based meals, in recognition of the health benefits of doing so. This would also be in line with the government's policies on sustainability and the environment. Plant-based food is inclusive, as it can be enjoyed by everyone.

We are happy to assist in any way we can, as are The Vegan Society.

Previous Consultations

GVS made a submission to the last Scottish Government Consultation on food and weight: https://docs.wixstatic.com/ugd/d95b36_829289de59484917b8b3adf1917d3a07.pdf The Scottish Government recently published an analysis of the submissions made during that consultation: http://www.gov.scot/Resource/0053/00534794.pdf In their summary of the responses they referenced a number of the points made in our submission, and presumably in many others, including: the need to have a greater focus on the root causes of inequalities in health, with a focus on health and wellbeing rather than weight and diet alone; having a more ‘joined-up’ approach across all the relevant policy areas (e.g. education, transport, economy, health, food, environment, sustainability etc.); the need to encourage the consumption of healthier alternatives such as fruit and vegetables rather than simply target “bad” foods; the need to ensure that healthy options should always be more affordable than unhealthy ones; the need for a clear connection to Scotland’s Good Food Nation policy, and the link between plant-based diets and the environment, sustainability and health. They noted that there was widespread support for increased investment in community food initiatives including community gardens, which are important for education about food as well as supporting social interaction and wellbeing. The Scottish Government has now published a Delivery Plan which we are currently reviewing in detail: https://www.gov.scot/Topics/Health/Healthy-Living/Food-Health

We believe it is essential that we all continue to engage in these processes as it is essential that we continue to draw attention to these issues and press for positive change. We hope many vegans will make submissions to this Consultation.

​© 2016 Go Vegan Scotland.