Scottish Cancer Prevention Network

Good Food Nation Proposals for Legislation March 2019

21st March 2019

Statement submitted from Prof Bob Steele and Prof Annie S. Anderson, Co-directors of the SCPN

The Scottish Cancer Prevention Network (SCPN) is focused on moving evidence on cancer risk reduction into everyday life, practice and policy (  As an advocacy group we raise the profile of cancer prevention and screening research and action through a range of communication channels (newsletter, conference, workshops, social media and web-based activities) and support ongoing work in reducing the prevalence of cancer risk factors. The SCPN is funded by the Scottish Cancer Foundation charity (SCO28300).

The evidence base for diet, alcohol and obesity and cancer are provided by World Cancer Research Fund ( 2018).

In terms of cancer risk it is becoming increasingly clear that food and nutrition (including excess body fat) during early development influences later cancer risk. In terms of the relationship between early nutrition and later health we welcome action that will help achieve equitable, optimal growth trajectories in infancy and childhood and specific action at supporting breast feeding, increased uptake of a nutrient dense diet and obesity prevention. Cancer risk is also affected by diet, alcohol and body size in adult life. There is an evidence base to direct people towards healthy eating (e.g. Scottish dietary goals) but there are many challenges to achieving good dietary patterns ranging from factors effecting individual food choice (marketing, price availability) to social position. The latter is clearly related to the development of cancers, response to treatment and future survivorship.  Food (and drink) policies needs to have equity as a key component to improving the nation’s health.


  1. To what extent do you agree with the framework proposals for Ministers and public authorities to prepare statements of policy, have regard to them in the exercise of relevant functions, and report on implementation, with regard to international obligations and guidance?


However, the Scottish Government has already written national food (and drink) policies and these have not been fully implemented (for example with respect to combining dietary goals with sustainability issues). It is essential that all policies are implemented, monitored and reported in an open and transparent manner.

It is increasingly clear that policies that involve food need to much more joined together (e.g. obesity and climate change) and involve a much wider range of sectors, citizens and scientists. The issues around food security are often described but responsibility for action, reasons for planned actions, magnitude of change and impact are too rarely reported in a meaningful manner (if at all).


  1. Whilst we do not plan to require all sectors to prepare statements of policy on food, they do all have a role to play in achieving our Good Food Nation ambition. To what extent do you agree that Government should encourage and enable businesses in particular to play their part? 

Strongly agree

WE support The Food Commission’s recommendations that requirements are placed on private food related businesses. Whilst government feels that this would place significant additional costs on businesses operating in Scotland the costs of not including food related businesses are also high.

The business community (from producers, manufacturers, retail and catering) provide an opportunity to create major differences in dietary intake but this potential is far from being realised. A cultural emphasis on sugary drinks, confectionery, baked goods, processed meats, pies has been a major hindrance to dietary change. If we are serious about changing food intake across all sector of the Scottish population we must include and support significant changes within the business community.

Societal actions that impact favourably on vulnerable groups of all ages and backgrounds offer the greatest potential for equitable effects.


  1. To what extent do you agree with the proposed approach to accountability of Scottish Ministers and specified public authorities? 

Strongly disagree

Swinburn et al (2015) describe in detail why action by government on food should be monitored and accountable at every level1. They argue that strengthened accountability systems would support government leadership and stewardship, constrain the influence of private sector actors with major conflicts of interest on public policy development, and reinforce the engagement of civil society in creating demand for healthy food environments and in monitoring progress towards relevant objectives. The accountability system needs to be credible, and a strong case can be made by for key components to be assessed by independent and credible third parties empowered with authority and enforcement capabilities such as an independent statutory body.

1Swinburn B, Kraak V, Rutter H, Vandevijvere S, Lobstein T, Sacks G et al (2015).  Strengthening of accountability systems to create healthy food environments and reduce global obesity.  Lancet. 385(9986):2534-45

  1. To what extent do you agree with the proposal for targeted legislation relevant to specific policy areas as an alternative to a single piece of legislation? 

Neither agree nor disagree

It is important to have approaches that address food related challenges across the whole food system. Approaches to improve food security need to include health dimensions, food production and food safety. Framework approaches enable a whole systems approach to be set out but targeted legislation is also useful for specific purposes. The Good Food Nation Bill could include statutory targets to drive urgent actions in an equitable and sustainable manner.