If you are responding on behalf of an organisation, please tell us the type of organisation for which you are providing a response.

Transcription

1 A HEALTHIER FUTURE ACTION AND AMBITIONS ON DIET, ACTIVITY AND HEALTHY WEIGHT - RESPONDENT INFORMATION FORM Please Note this form must be completed and returned with your response. Are you responding as an individual or an organisation? Individual Organisation Full name or organisation s name Diabetes Scotland If you are responding on behalf of an organisation, please tell us the type of organisation for which you are providing a response. Food and Drinks Industry Representative body Manufacturer Retailer Out of home provider (e.g. restaurant, fast food outlet, coffee shop) Public Sector Health Organisation Third Sector Health Organisation Other (please note in the text box provided) Phone number Address The Venlaw, 345 Bath Street, Glasgow Postcode G2 4AA

2 The Scottish Government would like your permission to publish your consultation response. Please indicate your publishing preference: Publish response with name Publish response only (without name) Do not publish response Information for organisations: The option 'Publish response only (without name) is available for individual respondents only. If this option is selected, the organisation name will still be published. If you choose the option 'Do not publish response', your organisation name may still be listed as having responded to the consultation in, for example, the analysis report. We will share your response internally with other Scottish Government policy teams who may be addressing the issues you discuss. They may wish to contact you again in the future, but we require your permission to do so. Are you content for Scottish Government to contact you again in relation to this consultation exercise? Yes No

3 Diabetes Scotland Response to Consultation Questions Question 1 Are there any other types of price promotion that should be considered in addition to those listed above? Yes Please explain your answer. Diabetes Scotland welcomes the introduction of legislation to restrict the promotion of food and drink high in total fat and saturated fat, sugar and salt through restricting multi buys, X for Y, and temporary price promotions as a first step in addressing the obesogenic environment that we live in. Evidence shows that products higher in sugar, or those that are less healthy, are more likely to be promoted. 1 We understand the important role that price promotions play in influencing buying behaviour, with 41 per cent of shopper expenditure being spent on price promotions in Britain. 2 We also know that price promotions result in consumers purchasing more than they otherwise would. 3 In light of this, rebalancing price promotions to favour healthier products would potentially make healthier options cheaper, encourage people to buy healthier food and drinks, or at the very least, take home fewer unhealthy foods. The McKinsey Global Institute (2014) 4 states that changing price promotions by restricting promotional activity in high-calorie impulse foods will decrease consumption and has a positive health impact across the full population. To accompany these changes, retailers can work closely with the voluntary sector to promote the benefits of eating a healthy, balanced diet and the benefits that this can have for improved health outcomes. In the Scottish context a recent survey (September ) by Cancer Research UK found that 89 per cent of parents in Scotland believe supermarket promotions impact what they buy. With more than half, 57 per cent, stating that multi-buy offers lead to them buying more junk food than they really want. In addition the survey found that more than two thirds, 71 per cent of parents think too much junk food is on promotion in supermarkets, and three quarters, 75 per cent of those surveyed would like to see the focus shifted towards healthier items. Banning food promotions should not see the overall price of food rise, indeed some price promotions make it harder to make price comparisons, the Competitions and Markets Authority found in that there were examples of pricing and promotional practices that have the potential to confuse or mislead consumers and found that more could be done to reduce the complexity in unit pricing to make it a more useful comparison tool for consumers. Price promotions are an important way of marketing unhealthy foods, it creates interest and can encourage loyalty. Removing this route will make it harder for unhealthy foods to be marketed, which is likely to see a reduction in purchases.

4 Diabetes Scotland welcomes Scottish Government proposals but the consequences for growing inequalities must be recognised and addressed. Diabetes Scotland believes that restriction does not go far enough and that a full ban on the promotion of food and drink that is HFSS will achieve the improvement Scotland s health. In addition, we would like to explore options beyond the supermarket for example, a consideration of restrictions on lunchtime fast food deals at outlets near schools. The long-term benefits of a healthier diet are harder to communicate than the immediate boost of junk food on promotion. Any policy that is implemented must take this into account and include other strategies that are needed as well notably education which empowers people to make informed choices. Question 2 How do we most efficiently and effectively define the types of food and drink that we will target with these measures? Please explain your answer. Diabetes Scotland believes that food and beverages should be defined by using the FSA/Department of Health nutrient profiling model. This is the nutrient profiling model currently used by the Committee of Advertising Practice (CAP) Code to determine which products should not be shown during programmes of particular appeal to children. We support this model because it considers the overall impact products will have on health rather than demonising one particular nutrient; reflecting the importance of a balanced diet. Diabetes Scotland supports Public Health England s review into the Department of Health (DH) nutrient profiling scheme. This is a necessary piece of work following new dietary guidance from the Scientific Advisory Committee on Nutrition (SACN) and development of a new Eatwell Guide to ensure that the model being used reflects the current dietary advice. As this is a long term piece of work, we support CAP in adopting the current DH model to ensure children are protected from HFSS advertising as soon as possible whilst the outcome of the review is awaited. When the proposals set out in PHE review are published they should be reviewed to assess whether they provide greater protection of children, and if they do CAP should adopt this model. Question 3 To what extent do you agree with the actions we propose on non-broadcast advertising of products high in fat, salt and sugar? Strongly agree Agree Neutral Disagree Strongly disagree Please explain your answer.

5 Scottish Government must be bold in tackling HFSS marketing aimed at children and Diabetes Scotland supports the call for a UK-wide ban. However, if this is not attainable then HFSS adverts should be restricted to after 9pm. The work being carried out throughout the UK by the Committee of Advertising Practice (CAP) will be ongoing and the impact of the marketing restrictions will be monitored. The Committee of Advertising Practice should automatically accept the new revised Nutrient Profiling Scheme on the basis that it will better protect children from harmful HFSS marketing. The revised nutrient profile model to identify high fat, salt and sugar products will be regularly assessed. Diabetes Scotland agrees with the proposal to consult on whether CAP s scope can be extended to local areas where there is a high footfall of children. Measures specific to these areas can then be explored, such as advertising restrictions as mentioned in the consultation. Scottish Government should examine the ability to restrict advertising on specific local council services such as on public transport, sports clubs, leisure centres. However, the new restrictions will only apply when it can be shown that at least 25 per cent of the audience are children. This is a low threshold and will mean that a substantial amount of advertising will be viewed by under 16 year olds. Scottish Government should look at raising this threshold substantially for it to have a meaningful effect. In addition, the lack of restrictions on child friendly mascots and packaging is not addressed. We consider that the use of brand characters should be prohibited from use to advertise HFSS products to children in the same way that licensed brand characters are. There is no justification for the different approach. The recent report on gambling and children by the Gambling Commission 7 and action by the Advertising Standards Authority 8 highlighted the actions of organisations targeting children: The use of particular colours, cartoons and comic book images, animals, child and youthorientated references and names of games such as Piggy Payout, Fluffy Favourites, Pirate Princess and Jack and the Beanstalk are likely, alone or in combination, to enhance appeal to under-18s. Whilst the situations are different, there are parallels in targeting children with consequences for their health and Diabetes Scotland would urge Scottish Government to address child friendly advertising in HFSS products. Question 4 Do you think any further or different action is required for the out of home sector? Yes No Don t know Please explain your answer.

6 Together with Food Standards Scotland and NHS Scotland, the Scottish Government will publish Scotland s first sector specific strategy for out of home by summer This will include action on calorie labelling; portion and calorie caps; promotions and marketing; advice on healthier cooking methods and nutritional standards for public sector procurement. Diabetes Scotland welcomes the intention behind the strategy but notes it is unlikely to be effective if only implemented on a voluntary basis. We would urge for steps to introduce legislation within the strategy. Eating out is no longer a treat with more than a quarter of adults and one fifth of children eating food from out of home outlets at least once a week. 9 These foods tend to be higher in energy intake, fat, sugar and salt. 10 Therefore, it is vital that people are informed about the nutritional information of the food choices they make when eating out so they can make like-for-like comparisons across supermarkets and the out of home sector. There is evidence to suggest that calorie labelling on menus can reduce the number of calories per purchase. 11,12,13 Diabetes Scotland supports the action that businesses in the out of home sector (cafés, restaurants, takeaways, sandwich bars) should adopt, as a minimum, calorie labelling at the point of choice on menus and menus boards. In addition, the inclusion of comprehensive and contextual nutritional information, such as traffic light labelling should be used on food bought in large-medium sized businesses in the out of home sector. Our societal environment is often not supportive or designed to enable people to live well. This is true for the general population and for people living with diabetes. Making positive choices is particularly important for people with diabetes as healthy eating and exercise are the foundation of good diabetes management. Understanding the nutritional profile of foods and drinks, including the calorie, fat, sugar and salt content, is vital for day to day and long term management of diabetes and this information is often limited. Clear and consistent carbohydrate information on labels is important to enable carbohydrate counting, a vital tool for people with Type 1 diabetes and some with Type 2 diabetes. It can lead to better blood glucose control and greater flexibility in the times and amount of carbohydrate eaten. Despite the importance of carbohydrate counting, healthy eating remains critically important for overall health and reducing the risk of long term diabetes complications. Giving people information on what they are eating will help and enable people make choices that work for them. Diabetes Scotland is supportive of Scottish Government proposals but more detail is needed on enforcement, the parameters of the strategy and stakeholder engagement. Question 5 Do you think current labelling arrangements could be strengthened? Yes No Don t know Please explain your answer. Current front of pack (FOP) labelling must become mandatory Diabetes Scotland is an advocate of the current colour-coded traffic light system and wants to use this as a springboard to more effective measures, including better

7 implementation of the existing model and making front of pack nutritional information mandatory. Equipping consumers with clear nutritional information across all food and drink is an important step to empower people to make informed food choices. Research demonstrates the value of clear labelling, stating: any structured and legible presentation of key nutrient and energy information on the front-of-pack label is sufficient to enable consumers to detect a healthier alternative within a food category when provided with foods that have distinctly different levels of healthiness. The House of Lords Science and Technology Select Committee Behaviour Change (2nd Report of Session ) Report highlighted evidence from retailers that the purchases of the healthier-labelled products increased while sales of less-healthy products decreased following introduction of labelling. FOP colour-coded labelling is not only beneficial for the purposes of providing consumers with enhanced information when they re making decisions, but it also may play a role in encouraging manufacturers to reformulate their less-healthy products. Companies should also be encouraged to educate their consumers on how to read and understand the FOP label. Question 6 What specific support do Scottish food and drink SMEs need most to reformulate and innovate to make their products healthier? Public Health England has created a reformulation plan. If the plan is delivering positive results, Scottish Government should examine proposals that could work for Scotland. Question 7 Do you think any further or different action is required to support a healthy weight from birth to adulthood? Yes No Don t know Please explain your answer. People in Scotland need to understand the risks of being overweight. There is no silver bullet to reducing the levels of overweight and obesity, as well as the prevalence of Type 2 diabetes, in Scotland. Ongoing investment in awarenessraising activities will continue to reinforce the value of eating a healthy, balanced diet and of regular physical activity. In addition to this, promoting information disseminated by the NHS (such as the Eat Better Feel Better and 5 a Day ) will ensure ongoing education and will help people to understand the serious risks and consequences of being overweight and obese. The recent Health Scotland survey 17 found that there was a relatively low level of concern with being overweight: Only a minority (39%)

8 disagreed with the statement that there is no reason to worry about being a bit overweight. Diabetes Scotland welcomes Scottish Government s decision to include healthy weight in children as a National Indicator. Healthy child weight is closely associated with deprivation. A greater proportion of children in the healthy weight range live in the least deprived areas. 18 While the gap between the most and least deprived children has stayed relatively static, the total amount of children with an unhealthy weight is still far too high. Diabetes Scotland supports the actions outlined in the consultation. Question 8 How do you think a supported weight management service should be implemented for people with, or at risk of developing, type 2 diabetes - in particular the referral route to treatment? People need to understand the link between overweight and Type 2 diabetes. While there are many factors that can contribute to a person s risk of developing Type 2 diabetes, maintaining a healthy weight is the one which they have the most control. Currently, there is no consistency regarding weight management across Scotland. 19 Throughout 2017, within individual Health Board areas, there has been some improvement in focus and creation of models of primary and secondary care working together. However, this is not available to everyone across the nation. People with Type 2 diabetes should receive ongoing dietary advice from a healthcare professional with appropriate expertise in nutrition, and be referred to a dietitian for tailored advice if necessary. They should have the opportunity to check their weight and get the support and information needed to manage their weight. In 2016, 85 per cent of people with Type 2 diabetes had their BMI recorded. This means nearly 40,000 people were not recorded. Of those recorded, 60 per cent were obese (a BMI over 30), addressing the people that have not been recorded, of those that were checked 16 per cent had lost more than 5 per cent of their body weight in the last year. There is a large untapped population that could use weight management to help improve their condition. A recent large scale study 20 in Glasgow in patients with Type 2 diabetes and obesity found that those who attended and lost at least 5 kg in the first 16 weeks maintained that weight loss over 3 years. Patients who successfully lost 5 kg in the programme also had an independent, clinically significant reduction in HbA1c compared with nonattenders. Successful completers of the weight management programme had a reduction in the number of diabetes medications. However, only a small number of potentially eligible patients were referred and fewer than half of those referred actually attended the service were referred to the weight loss service, and of those 1537 attended at least one session with 808 attending more than 7 sessions, completing the course. Of these 336 patients went on to lose 5 kg. These weight loss services were delivered by NHS Greater Glasgow and Clyde Weight Management Service. In addition, while the trial is still underway the Diabetes UK funded Diabetes REmission

9 Clinical Trial (DiRECT), which is investigating whether a weight management programme including a low-calorie diet can put Type 2 diabetes into remission, has shown promising first year results. Half (45.6 per cent) of those who took part in the programme are in remission after a year. Importantly the programme is delivered by GP practices. To inform our approach in Scotland, we can look to NHS England as it implements the NHS Diabetes Prevention Programme (NHS DPP). It is a new service developed via a partnership between NHS England, Public Health England (PHE) and Diabetes UK. The NHS DPP provides a behavioural intervention for individuals with non-diabetic hyperglycaemia. This consists of a series of predominantly group based sessions delivered in person across a period of at least nine months with at least 13 sessions and 16 hours of contact time. Sessions last between one and two hours and cover topics geared towards the programme s main goals of dietary improvements, increased physical activity and weight reduction. It is underpinned by behavioural theory and behavioural techniques are used. Weight Management Services form part of the obesity pathway. There is a scope to deliver this digitally, which is being piloted, and could work in a Scottish context. People need to understand the link between weight and Type 2 diabetes. One of the most important elements in reducing the risk of Type 2 diabetes is to lose weight. The NHS DPP in England targets people who have been identified with non-diabetic hyperglycaemia. People are identified as eligible for the NHS DPP through primary care registers of people with non-diabetic hyperglycaemia. They are found either through the NHS Health Check programme or opportunistic screening. (In Scotland, due to the smaller population size, it would be possible to widen the target group.) The programme team have learnt a great deal about how to get referrals through a mix of cold referrals such as letters from the GP practice as well as warmer routes. We have also learnt more about the best way to check that someone is eligible for the programme through HbA1c tests at the identification stage. Diabetes Scotland can supply further information about this if the Scottish Government would like more detail. The NHS DPP is a national programme for England and there are implications from having a national approach. Using the idea of Once for Scotland, instead of individual Integration Authorities looking at this, there is the possibility of having a nationwide policy with the local situation taken into account. The NHS DPP has recently had an initial evaluation 21 and it was found that there were over 43,000 referrals, 16 per cent higher than expected. Of those referred 49 per cent attended the initial assessment, higher that the 40 per cent projected uptake. Characteristics of the attendees suggest that the programme is reaching those who are both at greater risk of developing Type 2 diabetes and who typically access healthcare less effectively. The attendance rates for men, Asian, Afro-Caribbean, and other minority ethnic groups and participant from areas in the most deprived quintile further suggest that, in its early stages, the programme is reaching both those who are at greater risk of developing Type 2 diabetes and those who typically access healthcare less effectively. Taking this kind of initiative and looking for Scottish solutions to Scottish problems would help deliver the aims of A Healthier Future.

10 Whilst programmes like the English NHS DPP focus on helping those at greatest risk of developing Type 2 diabetes there is also a need to reduce the weight of the general population in order to decrease current and future risk of developing Type 2 diabetes. An evaluation of a pilot programme of eight local areas to demonstrate ways in which communities could be better engaged healthy eating, physical activity and healthy weight activities as part of a single coherent programme found evidence that a localised approach was effective 22. Communities must be involved with Integration Authorities for prevention programmes to succeed. Diabetes Scotland encourages Scottish Government to utilise elements of the NHS DPP and ensure that there is more consistency of weight management service delivery throughout Scotland to achieve the aims of A Healthier Future. Question 9 Do you think any further or different action on healthy living interventions is required? Yes No Don t know Please explain your answer. Diabetes Scotland has run a series of programs to support people living with or at risk of diabetes to live well. While we have only had capacity to run the projects in specific areas with target groups, we believe there is scope to develop and expand across Scotland. Chinikum at Home People of South Asian descent are up to six times more likely to develop Type 2 diabetes than white Europeans. What s more, they are deemed at high risk from the age of 25 and are more likely to suffer complications at a young age. However, despite its prevalence, the condition is still stigmatised and misunderstood which creates barriers for people who need support to manage their diabetes well. Diabetes Scotland s Chinikum at Home project aimed to change all that with a programme delivered in the family home (in either Urdu or Punjabi if preferable to English) over six to eight weeks. Designed to build sustainable support functions by using a new family-centred approach, it encouraged open dialogue and education for everyone in the family, not only the person living with diabetes. By talking more openly about diabetes, particularly Type 2 diabetes, we saw positive change within the families. This was made possible due to families taking ownership of their healthy living changes, identifying the need to do things differently, and making it happen together. *Chinikum means less sugar in Urdu and Punjabi Live For It! Schools programme

11 Delivered in partnership with Edinburgh International Science Festival, Live for It! is an interactive, fun way to engage with children through a series of workshops designed to help tackle childhood obesity and highlight the possible risks of developing Type 2 diabetes in later life. It is targeted at children living in areas of multiple deprivation. The programme was designed to tie in with Scotland s Curriculum for Excellence in Health and Wellbeing and reflects Scottish Government s Getting it right for every child (GIRFEC) approach for wellbeing priorities. During the four-session programme which is delivered in schools, children are taken on a journey through the digestive system, learn how to test blood glucose and gain an understanding of how our bodies convert food into energy. Making healthy food choices and the importance of eating a balanced diet is a valuable lesson learned through enjoyable cooking sessions. The learning is also taken out of the classroom as each child is encouraged to prepare healthy food at home. Participants are provided with a fun food diary which contains recipes for healthy snacks, weekly healthy eating and physical activity challenges, and space to record their achievements. At the end of the programme students can show off their knowledge in a series of challenges including Oscar; a life-size model patient with exposed organs and a flashing red nose modelled on the Operation board game. To date, Live For It! has visited over 7300 pupils at 100 schools across eight local authorities, primarily in areas of multiple deprivation, including Edinburgh, Glasgow, Highland, Renfrewshire, South Lanarkshire, Fife, Aberdeen and Aberdeenshire. Evaluation of the programme showed overwhelmingly positive feedback from both pupils and teachers. DEFT (Diabetes at your Finger Tips) The DEFT (Diabetes at your Finger Tips) project supports people who are over 55 years old from Black, Asian and minority ethnic communities and communities in areas of deprivation to manage their diabetes or reduce the risk of developing diabetes. Over the three years more than 350 people were supported through DEFT. The project used e-learning (specifically modules of Type 2 diabetes and Me) to engage older adults with living well with/reducing their risk of Type 2 diabetes including healthy eating, medication, the benefits of physical activity and the health checks they should be receiving from their healthcare teams. Tablets were used with older adults who were not as confident with computers as project leaders showed the group how to navigate the internet and find reliable health information and services online. The project resulted in increased skills in using the internet to access local resources/activities and national health information. Roughly only 10% of people who started DEFT sessions had used the internet before. As well as educating participants about Type 2 diabetes, the DEFT sessions also contribute to the Scottish Government s vision for our aging population through the Digital Inclusion Strategy where information technology can positively impact = the lives of older people. Question 10

12 How can our work to encourage physical activity contribute most effectively to tackling obesity? We know that many adults are not meeting the recommendations for physical activity, and that 77 per cent of children are not meeting them either. Setting ambitious targets for delivering active travel routes in local communities and sustained investment to support changes in the environment will make being physically active more attractive and safer. This may include more well-lit footpaths and cycling tracks, increased green spaces for recreational outdoor activities, and leisure centres. The objective of the above-mentioned policy proposals is to increase the number of people who meet the Chief Medical Officer s adult physical activity guidelines, and to support weight loss management. The recent Health and Sport Committee report, Sport for Everyone, highlighted for the need for the community to be involved in the planning, development and implementation of such programmes and initiatives, if they are to be successful. Public Health England published in January Healthy High Streets Good placemaking in an urban setting 23 which showed that the high street is a determinant of health. Poor design and a lack of diversity on high streets can have a direct influence on physical and mental health outcomes. High levels of traffic, crime and fear of crime, lack of access to health-promoting food and services, and inaccessible design can directly impact on health. Increased exposure to air pollutants, risk of trips and falls, injury and poor diet, also have a direct impact on health, leading to poorer health outcomes and higher mortality rates. High street design can also affect health outcomes indirectly. Rundown or inadequate communal areas, shelters, seating and focal points, can deter people from visiting or spending time in high streets and prevent community activities that enable people to integrate socially. This can increase the risk of social isolation and reduce the likelihood of community cohesion. Social isolation and loneliness can impact negatively on mental health, increasing the risk of depression, anxiety, cognitive decline and dementia. Neighbourhoods that are perceived to be less safe have lower levels of volunteering, socialising and trust in others. Communities with high levels of trust, social engagement and support are positively associated with health. This relationship appears to be interrelated: good health promotes trust and trust promotes good health. Scottish Government must ensure that the planning process recognises this and uses all the tools across government and local government responsibility to make a living space that addresses health inequalities and helps people live healthier lives. In particular, ensuring that regeneration and development of areas focuses on inclusive design for all, and that opportunities to reduce health inequalities are maximised. To improve our environments and make being physically active a more attractive and easy choice, the Governments and administrations across Scotland should explore introducing Active Transport Acts, learning lessons from the Active Wales Act. Physical activity and moving more can support weight loss and weight management. An estimated 64 per cent of adults (aged 16 years and over) met the guideline to do at least 150 minutes moderate or 75 minutes vigorous activity (or an equivalent combination of these) over a week in An estimated 76 per cent of children (aged

13 2-15 years) in Scotland met the physical activity guideline for children in 2016 when including activity done at school. Boys (79 per cent) were more likely than girls (72 per cent) to meet the guideline. However adults in the most deprived areas of Scotland were least likely to meet physical activity guidelines and the data shows little evidence that progress is being made towards meeting national targets for increasing walking, cycling and overall physical activity levels. It is important that there is enhanced communication of the Chief Medical Officer s guidelines for various age-groups (Early Years; Children and Young People; Adults; and Older Adults) so that people are aware of what is recommended. Setting ambitious targets for delivering active travel routes in local communities and sustained investment to support changes in the environment will make it more favourable for individuals to be physically active. This may include more well-lit and safe footpaths and cycling tracks, increased green spaces for recreational outdoor activities, and leisure centres. Increased and sustained investment in active transport provides better opportunities for all individuals, no matter their age, to be more physically active and may also have beneficial flow-on effects for local communities. Question 11 What do you think about the action we propose for making obesity a priority for everyone? The prevalence of diabetes has increased by 40 per cent over the last 10 years. In the previous ten years the levels of overweight and obese men and women in Scotland increased from 52 per cent to 65 per cent. There are over 257,000 people in Scotland registered with Type 2 diabetes, this does not cover undiagnosed people or those at high risk of developing the condition. This crisis shows no signs of stopping. Being overweight, obese and / or having a large waist circumference is the most significant risk factor for developing Type 2 diabetes, accounting for per cent of the overall risk of developing the condition. Reducing the number of people in Scotland who are overweight or obese would reduce the risk of people developing Type 2 diabetes. Diabetes Scotland supports Scottish Government s aims in A Healthier Future but recognises that it will demand strong leadership to implement effectively. Scottish Government must not shy away from the proposals within this consultation as the broad whole nation approach will all be needed across the system to deliver better health outcomes for all of Scotland. A Healthier Future is a positive start, Scottish Government must ensure that NHS Scotland has the focus and training to prevent obesity and deliver better health outcomes. Question 12 How can we build a whole nation movement? To build a whole nation movement, Scottish Government must engage on a community level to build a national level of traction. Introducing policies and activities relevant to the various communities across Scotland, and working for these

14 communities, can be helped by engaging with the third sector. Within this consultation response, Diabetes Scotland has highlighted three community based projects delivered by the charity to engage people and influence healthy behaviour change. We know that many other third sector organisations are also delivering on-the-ground community support, so there is much to learn from our collective experience. The need to tackle obesity and bring a healthier future for Scotland cuts across a wide array of policy areas from planning to health and media consumption. Working with community groups, the third sector and local leaders will help to create the grassroots for a whole nation movement. Reducing weight at an early stage will prevent complications and, within the family unit, one member losing weight leads to other family members losing weight. Which can be reinforced with a whole nation movement. Question 13 What further steps, if any, should be taken to monitor change? Diabetes Scotland would recommend using SCI-Diabetes to assess the success of the weight management programmes. However, work and investment is required to make the system fit for purpose. Question 14 Do you have any other comments about any of the issues raised in this consultation? There is a need for more evidenced-based policy and public health interventions and therefore more investment in public health research. Diabetes Scotland supports the proposal for extending the current restrictions on the advertising of food and drink HFSS to all programmes before the 9pm watershed if an outright ban is not achieved and would urge Scottish Government to press the issue with UK Government. The current rules mean that children will view adverts for food and drink products, high in fat, sugar and salt during the TV programmes they most watch. The majority (59 per cent) of food and drink adverts shown during family viewing time would be banned from children s TV 25. Children are classed as a vulnerable audience when it comes to advertising. 26 This is because young children lack understanding of the persuasive intent of advertising. 27 Ofcom defines children s media literacy as developing from the age of Children s viewing time peaks (with 1.8million children tuning in) not within children s programming but between 7-8pm which typically falls within family or adult programming. 29 For example in 2016, 64 per cent of children s viewing time took place in adult airtime. 30 Therefore falling outside of current regulations that restrict HFSS adverts during children s programming. Children s viewing figures decline on live TV from 22:00 therefore supporting the introduction of the watershed ban on HFSS marketing. A recent study by the Obesity Health Alliance showed that children were bombarded with up to nine HFSS adverts in a 30 minute period. 31

15 However for many young people the internet has replaced children s television. Research by Ofcom found that 12 to 15 year-olds are more familiar with YouTube than with the BBC or ITV, while the amount of television watched by four- to 15-year-olds has fallen by 25 per cent since Regulation must encompass the video on demand environment that we live in.

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