Introduction

1. The Educational Institute of Scotland (EIS), the largest teacher union and professional association for teachers and lecturers at all career levels in Scotland, welcomes the opportunity to contribute to this consultation, particularly in the context of growing incidence of child poverty and its manifestation in our schools with regards to hunger.

2. The EIS welcomes the intent of the Scottish Government (SG) to seek to increase the consumption of fruit and vegetables by children and young people, and acknowledges the role of schools, teachers and other school staff in contributing to this endeavour, though we may not entirely agree with SG on the approach outlined in this consultation document.

1. 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?

The EIS welcomes the intent of the Scottish Government (SG) to seek to increase the consumption of fruit and vegetables by children and young people, and acknowledges the role of schools, teachers and other school staff in contributing to this endeavour, though we may not entirely agree with SG on the approach outlined in this consultation document.

It states:

"…we propose to amend the school food and drink Regulations to require a minimum of two of vegetables and a portion of fruit to be offered as part of a primary school lunch."

"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."

It is not entirely clear from this wording whether the intention is to 'offe'’ a choice as to whether vegetables and fruit will be included in the child’s meal or not. Neither is it clear, if there is a choice as to which fruits and vegetables the child may wish to have as part of their lunch.

With a quarter of children in Scotland now living in poverty, many of whom will be experiencing daily hunger, we would signal caution against any move towards an 'all or nothing approach' to children's school lunches, whereby if a child does not wish to eat fruit or vegetables with a meal, then either the portion of food served to them, or eaten by them because they reject the fruit and veg, diminishes in size.

Such an arrangement would serve to exacerbate the hunger, malnutrition  and resultant difficulties with engagement in learning, that many children and young people who live in poverty are already experiencing in school.

The most recent survey of EIS members on their perceptions of the impact of poverty in the classroom pointed to increased incidence of hunger among children in school. More than 50% of those who took part in the survey reported an increase in the number of children coming to school without play-pieces, snacks or money for the tuck-shop.

16% of respondents said that they had observed greater incidence of children demanding or stealing food from others because they were hungry, while almost a quarter signalled increased attendance at breakfast clubs, and more than 10% highlighted that a greater number of families were requesting local foodbank referrals.

This clearly points to the need for urgent measures to prioritise children getting enough to eat in the course of a school day.

Of course, vegetables and fruit should be available to children to choose (and education on healthy eating a strong feature of schools' curricula, to promote understanding of balance in diet and how choices made can achieve this). But children should not go hungry, or hungrier at school than many already do, because their eating habits that are formed at home (where for at least a quarter of them, money is tight and emotional pressures are great) do not currently involve the regular and adequate consumption of fruit and vegetables and are likely to result in rejection of them at school.

Shaping children's healthy eating habits should be done over time, with their involvement and 'buy-in', and without inadvertent harm being done to them in the process. For some children at present, though, having more fruit and vegetables available on a school lunch menu may be attractive - in particular, pupils who have come to Scotland from other countries and don't like/eat what is otherwise on offer. 

The EIS is in favour of fruit being made available as a choice to children and young people who make use of school tuckshops and vending machines where these exist, but would urge consideration of the lack of affordability of these for children whose families are on low incomes. Many children and young people from have no access to the snacks that tuckshops and vending machines have on sale.

Children and young people living in poverty have no ability to make any choices, let alone healthy choices, in this regard.

The EIS favours the universal provision of free school meals for all children and young people in school. We would be interested in exploring the application of the same principle to the provision of snacks. The importance of fruit and vegetables as part of a balanced diet should feature consistently, too, in the curricula of early learning establishments.

The EIS is concerned that schemes that did provide free fruit to nurseries and primaries for snack time have had their funding cut, with the result that opportunities for young children to taste and find that they enjoy different kinds of fruit, have reduced or disappeared from many establishments entirely.

2. 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?

The EIS would not disagree with the principle of sugar reduction in the food and drink supplied in schools but, again, would suggest that care must be taken to ensure that an over-zealous approach does not lead to children – particularly those living in poverty - missing out on valuable nutrients, for example, those in cereal, fruit juice, some smoothies and yoghurts.

In the case of cereal, if only no or low sugar kinds are on offer, children may not eat it, thereby them falling short of the recommended daily intake of fibre and calcium. Pure fruit/vegetable smoothies and juices, without added sugar, are a good way of getting children to consume high concentrations of the nutrients contained in fruit and vegetables which, often in their regular forms, are less attractive options and which, for many, are not available at home.

For these reasons, the EIS would not be in favour of banning fruit juices and smoothies; instead we would suggest that these remain available in school, particularly those that contain no added sugar. Regarding sugar reduction in cereals and yoghurts, where this occurs, there should be no compromising on the flavour and attractiveness of these foods to children at the risk of them simply not eating them.

Breakfast clubs serving a variety of cereals and yoghurts are the only means by which many children living in poverty can eat in the morning, breakfast being a very important meal in the day. We would stress that it’s imperative that the basic nutritional needs of the poorest of children are not forgotten or compromised in pursuit of the aspiration to reduce the nation's intake of sugar.

The EIS agrees that drinks which are high in caffeine and in artificial colours and additives are not conducive to learning. We concur that the drinking of water should be encouraged among school pupils but would advise that greater  consideration should be given to maximising the availability of fresh drinking water in schools, this not always being easy to access.

Schools should be equipped with adequate numbers of properly serviced water coolers/ water fountains for the numbers of pupils and to be able to locate them strategically throughout school buildings.

3. 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?

While recognising the need to avoid children's and young people's overconsumption of red meat, we would again flag up that thousands of children and young people living in poverty do not have adequate access to foods at home, such as red meat, that are an essential source of iron.

The danger of setting a maximum amount for all children is that for a sizeable minority of children – at least one in four nationally, and more than one in three in some communities – it will result in further under-consumption of iron and greater incidence of immediate health-related issues associated with iron deficiency.

Rather than reducing the availability of red meat overall, with detrimental impact on the poorest children, a better course of action may be to offer greater choice.

This would enable children and young people who have enough access to red meat and other iron sources at home to vary their diet in school and might enable more consideration to be given to the dietary needs of those pupils from different faith communities, without restricting the poorest children in terms of what might be their only red meat/ iron source in their weekly diets.

4. 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?

The EIS is supportive of an holistic approach to educating and encouraging all children and young people – nursery, primary and secondary - to make choices leading to a healthy, balanced diet, and to ensuring that all children and young people get enough to eat during the school day. 

This requires a careful approach that takes into account a range of needs, and demands some more nuanced measures, than perhaps, for example, the suggestion to limit the number of pastry products available per day within a school – with such a simplistic approach, the same young people, by being 'first come and first served', could consume two pastries per school day, indefinitely if they wished, without more sophisticated intervention.

As previously stated, care must be taken, also, to avoid scenarios in which young people from poor families, who are likely to be experiencing food poverty and hunger, are inadvertently restricted in the amount that they can eat at school.

Food habits cannot, for the most part, be changed overnight, and in the case of young people living in poverty, should not, be forced to change overnight. The EIS view is that it would be better to alter menus incrementally rather than all at once.

5. 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?

We would wish to see explicit reference in the Regulations to how the needs of those with food intolerances should be accommodated. 

A key element in influencing the menu choices that children and young people make, is the appearance of food. It is therefore important to give consideration, not only to the nutritional content of the food served in school, but to how it looks. If food is appealing to the eye and then to the taste buds, children, like adults, will be more likely to choose it and to choose it again.

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