A Healthier Future: analysis of consultation responses

5. Out of home sector (Q4)

5.1 The consultation paper discussed a proposal to work with Food Standards Scotland, NHS Health Scotland and other stakeholders to develop a sector specific strategy for out of home providers. Out of home ( OOH) providers include establishments such as restaurants, takeaways, sandwich shops, bakeries, coffee shops, school tuck shops, and community cafés where food and drink is purchased and consumed away from the home. Respondents were asked if any further or different action was required.

Question 4: Do you think any further or different action is required for the out of home sector? Please explain your answer.

5.2 A total of 278 respondents (133 organisations and 145 individuals) provided comments. These indicated that, in general, respondents thought that developing a strategy for the OOH sector was appropriate.

General views about a strategy for the out of home sector

Content of the strategy

5.3 It was recognised that the draft strategy for the OOH sector was not yet developed, and therefore comments were not made in response to specific proposals. Respondents discussed the issues it would be important to include, and gave their views on the best approach(es) for this sector. There was widespread recognition that any such strategy would be likely to involve substantial changes and would be challenging to introduce. Respondents therefore emphasised the importance of piloting and evaluating any new approach(es) and adjusting the strategy in line with the developing evidence.

5.4 In their comments respondents emphasised the importance of the strategy including actions relating to (i) creating a ‘level playing field’, (ii) increasing the availability of healthier options, (iii) developing better product information, (iv) portion sizes and reducing portion size, (v) the need for public sector procurement to set a good example, (vi) improving the availability of healthy options in food outlets near schools, and (vii) the role of the planning and licensing system. Each of these themes is discussed in more detail below.

Creating a ‘level playing field’

5.5 A range of respondents, particularly those in the manufacturing and retail sectors, but also respondents in the third sector as well as professional bodies, emphasised the importance of creating ‘a level playing field’ so that OOH outlets would be held to the same standards and requirements as those in place or proposed for supermarkets and other retailers. This would involve requiring the OOH sector, as a minimum, to provide nutritional information and calorie labelling on their menus. However, the point was also made by some of these respondents that many OOH outlets have already made progress in relation to the provision of this kind of information, and that the focus of any strategy should therefore be on requiring those OOH outlets who had not already been proactive to do so. Thus the ‘level playing field’ was thought to be important both between the OOH and the retail sector as well as within the OOH sector itself.

5.6 Respondents from the food and drink industry, and from public health and third sector bodies emphasised the diversity of the OOH sector. For retail sector respondents, this meant that a ‘one size fits all’ approach was not appropriate. In contrast, public health and third sector respondents asked for a ‘comprehensive strategy’ which would cover all OOH outlets in ‘a consistent way’.

5.7 Views about whether or not a standardised approach was desirable were often linked to comments about whether any changes which were introduced should be mandatory or voluntary. In general, respondents from public health and third sector organisations argued for a standardised approach and mandatory changes. By contrast, private sector and business organisations, as well as individual respondents were more divided in their views; some of these respondents suggested either that (i) any new regulations should be made mandatory and enforced only for larger businesses (i.e. SMEs and other more informal providers should not be bound by (new) regulations), or that (ii) there should be ‘no disproportionate burden’ for small businesses and SMEs.

Availability of healthier options

5.8 In general, respondents from all sectors wished to see more healthy options available in the OOH sector. There was a particular concern at the lack of healthy options in deprived areas where (it was thought) there were large numbers of outlets selling only food and snacks of poor nutritional quality. However, recent evidence from the Scottish Social Attitudes survey was also cited to the effect that those living in the most deprived areas were slightly less supportive of restrictions on the numbers of fast food outlets in their areas.

5.9 At the same time, some respondents also focused on improvements which had been made more recently. These respondents (from the third sector and from the food industry) described the efforts made both by hospitals and by larger food chains and outlets to develop healthier options. The OOH sector in particular described their work in support of Public Health England’s Childhood Obesity Strategy (including work towards sugar reduction targets) and their participation in the Out of Home Nutrition Code of Practice, a voluntary code of conduct for the OOH sector, introduced in response to a request from the UK Government.

Product information

5.10 It was common for respondents from all sectors and groups to highlight the importance of having more product information available within the OOH sector, especially in relation to calories and portion information and there were some suggestions that calorie labelling should be mandatory. However, representatives of the OOH catering sector said there was ‘business opposition’ to calorie content being (mandatorily) shown on menus and asked for evidence of the impact that this would have. The reasons for this opposition stemmed from the additional costs incurred in calculating calories (and they queried whether this could be done with any accuracy), training kitchen staff and maintaining the data, (especially if menus change frequently). In addition, it was not clear how this could work in a self-service context.

5.11 There were also suggestions about having traffic light labelling added to menus. Less often there were requests that product information should cover Recommended Daily Intake ( RDI), nutrient / macro nutrient profiles, and ingredients more generally. It was suggested that the strategy should support the development of online apps to provide this kind of point of sale information. Local authority participants in the engagement event organised by Food Standards Scotland ( FSS) referred to MenuCal as a useful tool. ^[29]

5.12 A representative body for the OOH hospitality sector emphasised the work which it had undertaken to provide guidance on nutrition and food preparation for hospitality professionals. Specific mention was made of the ‘Nutrition Guide for Catering Managers and Chefs’ which has been developed to ‘help facilitate best practice on nutrition and provide hospitality professionals with expert advice on how to develop, prepare and promote healthier meals’.

Portion size

5.13 Respondents (including one academic respondent who cited evidence) said that portion size had increased markedly over the last 10-20 years. This was seen to be an important issue to address in any strategy for the OOH sector, particularly as two recent evidence reviews have highlighted that larger portion size leads to higher consumption. This meant that – in theory at least – reducing portion size would reduce consumption.

5.14 Portion size was often discussed in the context of ‘upselling’ and other promotions, as well as in relation to – specifically – the takeaway sector. Respondents described a strong culture of ‘getting your money’s worth’ in the OOH sector but repeatedly emphasised that portion sizes were simply too large. The main suggestions for addressing this included: (i) using smaller plate sizes; and (ii) offering smaller portions or half portions (particularly but not only to children and older people).

5.15 Local authority environmental health participants in the FSS engagement event highlighted potential difficulties in implementing and regulating smaller portion sizes. They thought this was more of an issue for SMEs than big companies. However, they also thought that if there was mandatory calorie labelling, this would be likely to result in smaller portion sizes. There were also some suggestions that businesses could benefit from having regulated portion sizes as this would eliminate competition between businesses to maximise the amount of food served.

5.16 Respondents from the food industry (including the OOH sector) raised specific points in relation to (reducing) portion sizes. Specifically, they noted:

• Reducing portion sizes is unlikely to reduce prices to any substantial degree (given that most of the costs are accounted for by labour and other overheads). Thus consumers may be dissatisfied, and they may also then purchase additional snacks as a consequence. This might mean that reduced portion sizes do not have a positive impact on reducing obesity.
• The parts of the OOH sector which do business across the UK have been working with Public Health England to meet targets for reductions in portion sizes and calories; working towards potentially different targets in Scotland would be problematic.
• Many OOH outlets have already reduced their portion sizes and / or taken action to influence or control potions provided at self-service buffets.

Public sector leadership

5.17 Respondents from all sectors repeatedly commented that the public sector should be taking a lead in this area by providing good quality food and drink in public sector eating establishments (i.e. in schools, hospitals, local authority leisure centres, and public sector workplaces). Respondents were critical about current provision and insisted that more needed to be done within the public sector to exemplify high nutritional standards. Respondents also discussed the value of award and recognition schemes, and particularly the Healthy Living Award scheme. (The issues of public sector leadership and the use of award schemes in OOH food establishments are both discussed in more detail in Chapter 11.)

Children and schools

5.18 Respondents from all sectors often commented on issues relating to children, and especially to children’s eating choices during school time. There was concern expressed about the availability – and large numbers – of outlets around schools which sold ‘junk food’. Respondents called for these outlets to be controlled (or even eliminated).

The role of the planning and licensing system

5.19 Respondents from all sectors thought that the planning and licensing system could be used to great effect in developing the OOH strategy. They discussed this especially in terms of food outlets in the vicinity of schools; however, it was also mentioned more generally as a way of minimising the overprovision of outlets that were perceived to be offering only unhealthy foods. Respondents suggested that health impact assessments and specific licensing conditions (for example, in relation to opening times, or the amount of staff training given) could be used to good effect in this area.

5.20 Respondents from all sectors saw the potential for an enhanced role for local authority environmental health officers, who were seen as key partners in relation to this agenda. They suggested there was scope for these professionals to offer education, advice and support to the OOH sector in relation to the use of healthier ingredients, healthier menus and improved cooking practices as part of their official programme of visits to OOH establishments.