Download (Sustainable Food) Bill 2010-11

Written Submission to: Public Bodies (Sustainable Food) Bill 2010-11
From: The Weston A Price Foundation – http://www.westonaprice.org/
Publication: Bill 12 2010-11 as introduced:
http://www.publications.parliament.uk/pa/cm201011/cmbills/012/11012.i-i.html
About Us
The Weston A. Price Foundation is a nonprofit, tax-exempt charity founded in 1999 to disseminate
the research of nutrition pioneer Dr. Weston Price, whose studies of isolated nonindustrialized
peoples established the parameters of human health and determined the optimum characteristics of
human diets. Dr. Price's research demonstrated that humans achieve perfect physical form and
perfect health generation after generation only when they consume nutrient-dense whole foods and
the vital fat-soluble activators found exclusively in animal fats.
The Foundation is dedicated to restoring nutrient-dense foods to the human diet through education,
research and activism. It supports a number of movements that contribute to this objective including
accurate nutrition instruction, organic and biodynamic farming, pasture-feeding of livestock,
community-supported farms, honest and informative labeling, prepared parenting and nurturing
therapies. Specific goals include establishment of universal access to clean, certified raw milk and a
ban on the use of soy formula for infants.
SUMMARY
The Public Bodies (Sustainable Food) Bill 2010-11 proposes that public bodies and Industry create
a code for “sustainable” and “healthy” food.
It is likely that these guidelines will be based on the Food Standards Agency's “Eat Well Plate” and
Dietary Guidelines. This top down approach concerns the Weston A Price Foundation, because
these guidelines demonize many of the traditional, nutrient dense foods necessary for human health,
particularly those that contain vitamin rich traditional fats, from grass fed animals. The guidelines
also place undue emphasis on carbohydrate rich food groups that provide limited nutrient value and
contribute to obesity. This advice has therefore caused serious nutritional deficiencies and chronic
disease. Its statutory codification will therefore only serve to amplify public health issues.
We are also concerned that the food industry, faced with demands to reduce salt, sugar and fat, will
be forced to replace them with processed, unhealthy alternatives to keep food palatable. This could
have the unintended consequence of further reducing food quality.
Simplistic calls to reduce general ingredient types will also ignore traditional, unrefined and healthy
alternatives to refined sugar and salt, and could eliminate from our diet vitamin rich traditional fats,
from grass fed animals, which have been falsely blamed for the problems caused by modern
processed fats, such as vegetable oils. This will also have the affect of reducing demand for artisan
foods from traditional and sustainable family farms, thereby reducing opportunities for achieving
the stated goal of a sustainable food supply.
The Weston A Price Foundation therefore objects to any food procurement guidelines that fail to
recognize the benefits of traditional nutrient dense foods and that do not warn against toxic
additives. We fear that the proposed legislation will make malnutrition mandatory and disease
unavoidable.
FSA Dietary Guidelines
Current Food Standards Agency (FSA) dietary guidelines are based on the flawed notion that
cholesterol and saturated fat are unhealthy. Attempts to curtail access to saturated fats with the
Public Bodies (Sustainable Food) Bill 2010-11 will significantly reduce access to traditional
nutrient dense foods.
Vitamin rich traditional fats, from grass fed animals, have been blamed for the problems caused by
modern processed fats, such as vegetable oils. Application of the FSA's policies to date has resulted
in widespread nutrient deficiencies and contributed to a proliferation of obesity and degenerative
disease, including problems with growth, behaviour and learning in children. The UK government
is promoting a low fat, plant-based diet that ignores the vital role animal protein and fats have
played in human nutrition throughout the ages. All of these problems will be amplified should the
FSA's dietary guidelines be imposed via procurement controls.
The FSA's Eat Well Plate with its strictures against fat consumption does not recognize variations in
human metabolism. Recommendations for fat restriction are predicated on the assumption that fat
causes weight gain and heart disease; several recent studies have shown that that restriction of
natural fats actually leads to more obesity in both children and adults, while the refined
carbohydrates, polyunsaturated and trans fats that frequently replace natural saturated fats
contribute to weight gain and chronic disease. Restriction of animal fats in children leads increased
markers for heart disease and to deficiencies of vitamins A, D and K2, needed for growth, strong
bones, immunity, neurological function, and protection from tooth decay.
We note that higher saturated fat content and associated higher levels of fat soluble vitamins A, D &
K2, are a signatures of high quality food from grass fed and heritage breed animals from sustainable
family farms. Beef, for example, can only be hung for 21 days or more, in the traditional manner, if
grass fed. This is why Mrs Beeton and others once warned against buying lean meat, repeating the
wisdom of their forebears.
RECOMMENDED NEW GUIDELINES:
The Weston A. Price Foundation strongly urges Ministers to not use the Public Bodies (Sustainable
Food) Bill 2010-11 to impose the FSA's Eatwell Plate on food procurement by Public Bodies,
because this will eliminate access to nutrient dense foods for all those who rely on Public
Authorities for their food.
We urge those promoting this Bill to instead pay regard to the following Healthy 4 Life guidelines,
based on four groups of whole foods.
Every day, eat high quality, whole foods to provide an abundance of nutrients, chosen from each of
the following four groups:
1. Animal foods: meat and organ meats, poultry, and eggs from pastured animals; fish and
shellfish; whole raw cheese, milk and other dairy products from pastured animals; and broth made
from animal bones.
2. Grains, legumes and nuts: whole-grain baked goods, breakfast porridges, whole grain rice;
beans and lentils; peanuts, cashews and nuts, properly prepared to improve digestibility.
3. Fruits and Vegetables: preferably fresh or frozen, preferably locally grown, either raw, cooked
or in soups and stews, and also as lacto-fermented condiments.
4. Fats and Oils: unrefined saturated and monounsaturated fats including butter, lard, tallow and
other animal fats; palm oil and coconut oil; olive oil; cod liver oil for vitamins A and D.
Avoid: foods containing refined sweeteners such as candies, sodas, cookies, cakes etc.; white flour
products such as pasta and white bread; processed foods; modern soy foods; polyunsaturated and
partially hydrogenated vegetable oils and fried foods.
SATURATED FATS
The demonization of saturated fats is unscientific and has had an extremely detrimental effect on
the health of the whole nation, particularly on growing children. The human body contains high
levels of saturated fat in the cell membranes and in protective fat around the organs. When
saturated fat is not available in the diet, the body very efficiently turns refined carbohydrates into
saturated fat;1 thus restriction of saturated fat can often lead to cravings for refined carbohydrates.
Saturated fatty acids are said to cause cancer, heart disease and obesity. Yet these diseases were rare
at the turn of the century when consumption of saturated fats was much higher than it is today. The
likely culprits for these conditions are polyunsaturated fatty acids and trans fats, which came into
widespread use after WWII.2
Saturated fats play many important roles in the body chemistry:

As saturated fats are stable, they do not become rancid easily, do not call upon the body’s
reserves of antioxidants, do not initiate cancer and do not irritate the artery walls.3

Vitamins A and D, which are vital for proper growth and for protein and mineral
assimilation, are found only in mostly saturated animal fats.

Saturated fats enhance the immune system, thereby protecting us against infection and
cancer.4

Saturated fats help the body lay down calcium in the bones and help prevent osteoporosis.5

Saturated fats provide energy and structural integrity to the cells.6 At least 50 percent of
many, if not most, of the cell membrane must be saturated fat for the cells to work properly.

Saturated fats protect the liver from alcohol, drugs, pesticides and other poisons.7

Saturated fats enhance the body’s use of essential fatty acids, which the body needs in small
amounts and obtains from whole foods.8

Stearic acid, found in beef tallow and butter, has cholesterol-lowering properties and is a
preferred food for the heart.9

Saturated fats are needed for the kidneys to work properly.10

The lung surfactants are composed of saturated fatty acids.11 The lungs cannot work
without adequate amounts of saturated fats.
Warnings against dietary saturated fats are predicated on the assumption that saturated fats
contribute to atherosclerosis and therefore to heart disease; yet, as saturated fat consumption has
declined in Britain over the last one hundred years, heart disease has increased. Recent
epidemiological evidence from Mainland Europe does not support a correlation of saturated fat with
heart disease, as shown in the chart shown above.12
What happens when children are put on lower fat diets? When researchers prominently associated
with the American Heart Association fed children lower fat diets and measured some of the markers
they consider important predictors of heart disease, they found that these lower fat diets were
causing the very problems they wanted to prevent. The children whose genes would normally have
been producing the desirable light and fluffy form of LDL started to make the dangerous small and
dense form of LDL.13 Thus the US dietary recommendations are likely to be causing heart disease,
not preventing it.
For more information on fats, visit: http://www.westonaprice.org/know-your-fats.html
SATURATED FAT AND WEIGHT GAIN
The FSA's Dietary Guidelines have led to the restriction of saturated fat in children’s diets;
paediatricians now advise parents to put their children on reduced-fat dairy products and avoid meat
and dairy fats starting at the age of two; and school children no longer have the option of whole
milk in school lunches.
Authorities justify these restrictions of nutritious foods by claiming that fat, especially saturated fat,
results in weight gain. Yet a recent study from Sweden found that a higher intake of fats, including
saturated fats, in childhood resulted in lower body weight; children on reduced fat diets had higher
body mass and greater insulin resistance.14
Furthermore, in a study of Swedish adults, consumption of whole fat milk and cheese was linked to
lower weight gain;15 and dairy fat was not linked with weight gain in a longitudinal study of
adolescents.16
Individuals who try to restrict saturated animal fats according to the FSA's guidelines often end up
consuming more trans fats. Yet animal research indicates that in calorie-restricted diets containing
the same number of calories, those diets containing trans fats result in increased weight gain.17
For more information about our position on obesity, visit: http://www.westonaprice.org/obesity-aweight-loss.html
CHOLESTEROL
Restriction of saturated animal fats is also justified with the argument that animal fats contain
cholesterol, and therefore cause heart disease. Yet even the amount of cholesterol found in three to
four eggs per day produces no change in blood cholesterol levels in 70 percent of the population, as
shown in randomized, placebo-controlled trials; in the other 30 percent, dietary cholesterol
increases both LDL-cholesterol and HDL-cholesterol equally and turns small, dense “pattern B”
LDL into light, buoyant “pattern A” LDL, changes that are widely regarded by promoters of the
cholesterol theory as beneficial.18
Cholesterol restriction is particularly harmful for pregnant women and growing children. Pregnant
women need extra levels of cholesterol for the formation of the fetus, and cholesterol-lowering
drugs can lead to extremely serious birth defects.19 Growing children cannot produce all the
cholesterol they need for the formation of the brain and gut, but need to obtain it from a cholesterolrich diet. Just a few decades ago, experts on child feeding agreed that the best foods for infants
were cholesterol-rich foods such as egg yolk, liver, butter and whole milk; today, thanks to the
FSA's Dietary Guidelines, children are denied these nutrient-dense foods so important for growth
and neurological development.
Roles of cholesterol include:

Along with saturated fats, cholesterol in the cell membrane gives our cells necessary
stiffness and stability. When the diet contains an excess of polyunsaturated fatty acids, these
replace saturated fatty acids in the cell membrane, so that the cell walls actually become
flabby. When this happens, cholesterol from the blood is "driven" into the tissues to give
them structural integrity. This is why serum cholesterol levels may go down temporarily
when saturated fats are replaced with polyunsaturated oils in the diet.20

Cholesterol acts as a precursor to vital corticosteroids, hormones that help us deal with stress
and protect the body against heart disease and cancer; and to the sex hormones like
androgen, testosterone, estrogen and progesterone.

Cholesterol is a precursor to vitamin D, a very important fat-soluble vitamin needed for
healthy bones and nervous system, proper growth, mineral metabolism, muscle tone, insulin
production, reproduction and immune system function.

The bile salts are made from cholesterol. Bile is vital for digestion and assimilation of fats in
the diet.

Research shows that cholesterol acts as an antioxidant.21 This is the likely explanation for
the fact that cholesterol levels go up with age. As an antioxidant, cholesterol protects us
against free radical damage that leads to heart disease and cancer.

Cholesterol is needed for proper function of serotonin receptors in the brain.22 Serotonin is
the body's natural "feel-good" chemical. Low cholesterol levels have been linked to
aggressive and violent behavior, depression and suicidal tendencies.

Mother's milk is especially rich in cholesterol and contains a special enzyme that helps the
baby utilize this nutrient. Babies and children need cholesterol-rich foods throughout their
growing years to ensure proper development of the brain and nervous system.

Dietary cholesterol plays an important role in maintaining the health of the intestinal wall.23
This is why low-cholesterol vegetarian diets can lead to leaky gut syndrome and other
intestinal disorders.
OTHER NUTRIENT DEFICIENCIES
It is very difficult, if not impossible, to construct a diet based on the FSA's Dietary Guidelines that
meets the nutritional requirements of either adults or growing children.24 Meals based on the
dietary guidelines will not only contain an excess of carbohydrates and not enough fat (or high
levels of processed fat), they are also likely to be deficient in a number of nutrients:

Vitamin A: Since FSA Guidelines severely restrict animal fats and do not specifically
recommend liver and other organ meats, meals based on these guidelines will be virtually
devoid of vitamin A. FSA has recognized this problem and tried to solve it by insisting that
adequate vitamin A can be obtained from vitamin A precursors found in fruits and
vegetables; in fact, contrary to statements in biochemical textbooks and the Merck Manual,
FSA falsely labels these carotenes as vitamin A. Yet the precursors to the true animal form of
vitamin A are very poorly converted, especially in babies and children who need vitamin A
the most.25 Vitamin A is an extremely important nutrient, needed for growth, hormone
production, healthy bones, skin and eyes and protection against infection.

Vitamin D: A consensus is building that vitamin D deficiency is widespread in the U.K.
population. According to advocates for supplements, adequate vitamin D cannot be
obtained from food. This is certainly a true statement if one is following the FSA
Guidelines. Yet there are many food sources of vitamin D including butter, whole milk, egg
yolks, organ meats, lard and other animal fats from animals raised in sunlight, cod liver oil,
shellfish and oily fish. The problem is that the Guidelines have demonized these high-fat,
nutrient-dense foods and they have largely disappeared from the American diet.

Vitamin K2: Recent research indicates that the animal form of vitamin K is needed for
numerous processes, not just the clotting factor in the blood. Vitamin K2 is needed for
healthy bones, normal growth, freedom from tooth decay, proper neurological function,
reproduction and protection against heart disease. The FSA's Dietary Guidelines result in a
diet largely devoid of vitamin K2, which is found in meat fats, organ meats, whole cheeses
and butterfat.26

Zinc: A critical nutrient for reproduction and neurological function. The best sources are red
meat and shellfish. Diets high in whole grains—recommended in the FSA Guidelines—tend
to block absorption of zinc.

Vitamin B12: A critical nutrient for healthy blood, neurological function, protection against
depression and other psychological disorders, and protection against heart disease, cancer,
anemia and multiple sclerosis. Best sources are organ meats like liver and shellfish.
Soy as a meat substitute:
Attempts to reduce saturated fats often result in reduced meat consumption and increased use of
meat substitutes such as soy. Regarding sustainability, many are now aware the effects soy has on
soil fertility, deforestation and that much of the imported soy is GMO. Modern processed soy
products also have many profoundly negative affects on human health.
Soy is used in the eastern countries such as Japan and China, but is not used as a primary source of
protein. That would be pork in China and fish in Japan. Soy is used in these countries in modest
quantities, primarily as a heavily fermented, probiotic condiment to aid digestion. This
fermentation, which generally takes between one and three years neutralizes soy's high levels of
phytic acid. Indeed, fermented soy condiments are such potent probiotics because of the unusually
high levels of phytic acid that must be neutralized by the process. However, modern, industrially
processed soy products used in high quantities by vegetarians in western countries are not
fermented and retain high levels of phytic acid. It reduces assimilation of calcium, magnesium,
copper, iron and zinc, causing mineral deficiencies.
Phytoestrogens found in soy are not a significant public health issue in the east, where soy is
generally consumed in small volumes as a condiment. However, they become problematic when
consumed in high volumes as a meat substitute. Soy phytoestrogens disrupt endocrine function and
have the potential to cause infertility and to promote breast cancer in adult women. They are also
potent antithyroid agents that cause hypothyroidism and may cause thyroid cancer. In infants,
consumption of soy formula has been linked to autoimmune thyroid disease.
Vitamin B12 analogs in soy are not absorbed and actually increase the body's requirement for B12.
It is therefore a myth that soy products can be a suitable substitute for the B vitamins found in meat,
and soy foods increases the body's requirement for vitamin D. The best sources of both of these
vitamins are products from grass fed animals.
Modern unfermented soy products must be highly processed to render them palatable. This causes
many other problems, similar to those caused by other processed foods. Fragile proteins are
denatured during high temperature processing to make soy protein isolate and textured vegetable
protein. Processing of soy protein results in the formation of toxic lysinoalanine and highly
carcinogenic nitrosamines. Free glutamic acid or MSG, a potent neurotoxin, is formed during soy
food processing and additional amounts are added to many soy foods. As a result of the processing,
soy foods contain high levels of aluminium which is toxic to the nervous system and the kidneys.
The Weston A Price Foundation runs a “Soy Alert” Campaign:
- http://www.westonaprice.org/soy-alert.html
Salt
Salt is essential to life. The human body cannot sustain itself without it. We need salt for protein
digestion, carbohydrate digestion, adrenal function, cellular metabolism and brain development.
Unrefined salt also provides us with many trace minerals. Unfortunately, the refined salt found in
table salt and most processed foods is pure sodium chloride. Salt in this form has been processed at
high temperatures. This changes the molecular structure and removes vital minerals from the salt.
Table salt also contains additives, anti caking agents, and even sugar. Excess consumption of
refined table salt is associated with high blood pressure, fluid retention, heart and kidney disease.
Conversely, natural, unrefined salt, such as traditional sea salt, is essential for maintaining proper
fluid balance and utilization in the body. It also normalizes blood pressure, enhances digestion, and
nourishes the adrenal glands.
Attempt to reduce table salt content in foods without encouraging moderate use of natural unrefined
salt will reduce people's access to the minerals that unrefined sea salt provides and will limit
opportunities to develop artisanal salt production in coastal areas. This policy will also have the
damaging affect of encouraging toxic salt substitutes such as mono sodium glutamate (msg).
More information on msg: http://www.westonaprice.org/msg-updates.html
Sugar
Only during the last century has man’s diet included a high percentage of refined carbohydrates.
Our ancestors ate fruits and grains in their whole, unrefined state. In nature, sugars and
carbohydrates—the energy providers—are linked together with vitamins, minerals, enzymes,
protein, fat and fiber—the bodybuilding and digestion-regulating components of the diet. In whole
form, sugars and starches support life, but refined carbohydrates are inimical to life because they
are devoid of bodybuilding elements. Digestion of refined carbohydrates calls on the body’s own
store of vitamins, minerals and enzymes for proper metabolization. When B vitamins are absent, for
example, the breakdown of carbohydrates cannot take place, yet most B vitamins are removed
during the refining process.
We should avoid all refined sugars including table sugar, so-called raw sugar or brown sugar (both
composed of about 96 percent refined sugar), corn syrup, fructose and large amounts of fruit juice.
However, it is perfectly acceptable to satisfy your sweet tooth by eating limited amounts of certain
natural sweeteners high in vitamins and minerals, such as raw honey, date sugar, dehydrated cane
sugar juice (commercially available as Rapadura) and maple syrup.
Failure to promote natural sweeteners to replace refined sugar could lead to proliferation of harmful
modern alternatives such as aspartame. When aspartame is digested it breaks down into the amino
acids phenylalanine and aspartic acid, plus methanol. Methanol, or wood alcohol, is a known
poison. Aspartame’s breakdown products, or metabolites, are even scarier than its components.
Phenylalanine decomposes into diketopiperazine (DKP) a known carcinogen, when exposed to
warm temperatures or prolonged storage. Even at cold temperatures, methanol will spontaneously
give rise to a colorless toxin known as formaldehyde. Independent studies have shown
formaldehyde formation, resulting from aspartame ingestion, to be extremely common. It
accumulates within the cells, and reacts with cellular proteins such as enzymes and DNA. This
cumulative reaction could spell grave consequences for those who consume aspartame-laden diet
drinks and foods on a daily basis. Attempts to reduce sugar content have led to harmful proliferation
of aspartame in diet soda's and most chewing gum.
More information on artificial sweeteners: http://www.westonaprice.org/modern-foods/570-sugar-
free-blues.html
CONCLUSION
As formulated, the FSA's Dietary Guidelines and Eatwell Plate have resulted in widespread nutrient
deficiencies and have had the effect of conferring official approval on very unhealthy processed
foods containing trans fats, processed vegetable oils, refined carbohydrates and neuro-toxic
additives such as MSG and aspartame. These Guidelines have undermined the traditional healthy
diets of the various populations that have immigrated to the United Kingdom, Most seriously, they
have influenced the makeup of baby formula, allowing manufacturers to use vegetable oils and
sucrose rather than the animal fats and lactose that mother’s milk provides.
The consequences of the flawed guidelines are extremely serious; we are already seeing the tragic
effects in the current epidemic of chronic disease in adults and low birth weight, growth problems
and learning disabilities in our children.
Any attempts to impose the FSA's Dietary Guidelines via statutory codification will merely
reinforce the problems that this bill attempts to cures. The Bill will also discourage sustainable
farming practices should it reinforce the government's ongoing demonization of traditional animal
products that contain saturated fats.
The Weston A. Price Foundation urges the government to review inconsistencies in the FSA's
dietary guidelines prior to them being imposed upon public bodies and food manufacturers. We urge
the government to start over, scrap the unworkable Eatwell Plate, abandon the strictures against
saturated fats and cholesterol, and provide useful, science-based guidelines that will steer Britons
towards a diet of nutrient-dense whole foods.
Prepared by Sally Fallon Morell, President
The Weston A. Price Foundation
Washington, DC
0011 (202) 363-4394
www.westonaprice.org
Philip Ridley, MSc, PGDip.
London Chapter Leader, The Weston A. Price Foundation
01962 620910
[email protected]
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