The Chief Medical Officer’s recommendations affect the food system

England’s CMO, Professor Dame Sally Davies, made fifteen recommendations in her 2018 Report: Health 2040 — Better Health Within Reach. Of these, five are directly concerned with the food we eat, and two others (about multi-morbidity) have implications for the food sector.

The first is this:

Recommendation 1: A Health Index for England
The Cabinet Office to formally explore the development of a Health Index for England.


The next is about the capacity for futures thinking, followed by a other on curbing smoking among a key demographic:

Recommendation 2: Capability for futures thinking
The Department of Health & Social Care & the health system invest in ‘capabilities for futures thinking”.

Recommendation 3: Halving existing inequalities in smoking in pregnancy
The NHS and Local Authorities commit to halving the existing inequalities in smoking in pregnancy by geography by 2024.


The next five recommendations directly concern the food system:

Recommendation 4: Childhood Obesity
“I recommend that the UK government ensure that future developments of the Childhood Obesity plan include a specific target to halve current inequalities in childhood obesity by 2030 or sooner, with support for Local Authorities to meet this target.”

She then went on to say: “Chapter 8 of this report identifies interventions that alter the environment for health — ‘structural’ changes that require little or no action from individuals — are consistently more effective and see the largest population health gains in the most vulnerable communities when compared to individual-based approaches.”

We agree with her. on page 16 of our recent report, Global Risks to UK Food Supplies, we make three sets of recommendations for local resilience, itemised also in this blogpost. Our recommendations are more specific than the CMO’s, notably her Recommendation 5 (about the Soft Drinks Industry Levy) and Recommendation 6 (about fiscal disincentives and incentives).

Recommendation 5: Soft Drinks Industry Levy
“I recommend that HM Government extend the Soft Drinks Industry Levy to sweetened milk-based drinks with added sugar and take action to eliminate added sugar in infant and baby foods.”

She also stated: The Soft Drinks Industry Levy has been effective in reducing sugar consumption from soft drinks.”

Has it, though, reduced consumption of soft drinks per se, or just sugary ones?

This extension continues to companies to reformulate their products using artificial sweeteners instead of sugar, as they did with other soft drinks. The jury is still out on the effects of some of the sweeteners that are used. On others, we’ve known for some times about the ill-effects of some of them; see footnotes 20 and 21 on p8/8 of our report Coca Cola and its effects on us and the city (2015).

Another approach would be to have a levy on all soft drinks. In addition, the Industry Levy could be extended to all food and beverage products that carry standard-rate VAT; see our blogpost VAT: A really useful POS metric.

note: Although not within the remit of the CMO, it should be noted that the manufacture of these products use the increasing scarce global resources of soils, water and energy, as well as contributing significantly to ill-health.

Recommendation 6: Fiscal measures
“I recommend that HM Government review the use of fiscal disincentives in relation to foods that are high in sugar and salt and also incentives to increase fruit and vegetable consumption.”

In the Introduction to Chapter 8 of her 2018 Report, titled Changing behaviour for a healthier population, Dame Sally Davies says:

We agree with her statement that effective interventions are delivered at a population level.

We feel, however, that this recommendation as it stands will not make the difference necessary at a population level. We assess that taking fiscal and other measures against corporations that manufacture and distribute food and beverage products that carry standard-rate VAT would have such an impact.

Moreover, although we welcome her recommendation for HM Government to give incentives to increase fruit and vegetable consumption, we cannot see any clarity as to how this could be achieved, given the global pressures on the supplies of safe, nutritious food and the tight margins (0-2.5%) in the fruit and veg wholesale supply system.

Recommendation 7: Salt reduction in food
“I recommend that in 2019, HM Government through Public Health England, set more ambitious targets for salt reduction in food. This should apply equally to the out-of-home sector, which has lagged behind. If these targets are not met then they should be mandated and a range of other interventions considered, including mandating front of package labelling.”

We concur with this recommendation, although wonder how targets for salt reduction in the out-of-home sector can be monitored.

The CMO also said the following: “Those who shape the environment for health should be held to account. We have seen promising first steps, but to fiscally optimise the food environment from producer to plate in order to encourage healthy dietary patterns to be the norm for all, we need sustained and effective action. This approach has to encourage more focus upon quality, rather than quantity of food produced and sold. Those sectors that damage health must pay for their harm or subsidise healthier choices.

We put forward two points about the CMO’s words: Firstwe agree that any approach has to encourage more focus upon quality yet as the price of safe, nutritious food look set to rise and as stated under Recommendation 6, the margins in their supply are non-existent or very low, there is a need for some means to enable adequate production of sufficient supplies of safe, nutritious food, and for everyone to have access to it.

Secondly, we would go further in recommending ways of holding key corporations to account, as we will explain in the blogpost to follow.

Recommendation 8: Healthier food options on the high street
“I recommend that the Ministry of Housing, Communities and Local Government explore, with the Local Government Association, how it can better support local government action to encourage healthier food options on the high street.


Obesity is associated with some of the rapidly growing health challenges of multi-morbidity. The following two recommendations are about the challenges of multi-morbidity — and so with implications for the food system.

Recommendation 9: Understanding disease clusters that make up common multimorbidity
“I recommend that research funders, led by NIHR [National Institute for Health Research] and the MRC [Medical Research Council] commission to identify and understand the disease clusters than make up common multimorbidity.”

Recommendation 10: Multi-disease guidelines for common clusters
“I recommend that NICE [National Institute for Health and Care Excellence] alongside specialist bodies, develop multi-disease guidelines for common clusters of disease to avoid multiple single disease guidelines applying to the same groups of patients.


The remaining five recommendations are about emerging technologies, with the three final ones concerning artificial intelligence (AI):

Recommendation 11
NHS Digital to develop open source infrastructure.

Recommendation 12
The Secretary of State for Health & Social Care to seek advice re the best mechanisms to develop, deliver and maintain frameworks for regulation and evaluation of emerging technologies and devices.

Recommendation 13
NHS Digital to work with the Office for Strategic Coordination of Health Research and Health Data Research UK to develop, consult on and agree an appropriate system for research standards in AI health and care research studies.

Recommendation 14
NHS Digital, with Public Health England and partners, to develop and publish best practice standardised guidance for the NHS on data collection, standards, structure, handling, storage and sharing for the development of AI tools.

Recommendation 15
The Department of Health & Social Care to ensure that ‘data banks’ are available which are representative of the population of England to allow testing, quality assurance and validation of AI-based tools at scale before implementation into service, and for calibration of AI-based tools developed overseas to the England population for use in the NHS and broader health arena.

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