food as a public utility?

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by the National Food Alliance (4) for more detailed examples):. More attention could ... More judicious use could be made of in-store or mail-shot promotion and ...
ACCESS TO A HEALTHY DIET FOR LOW INCOME CONSUMERS: RIGHTS AND RESPONSIBILITIES

Elizabeth Dowler Public Health Nutrition Unit Department of Epidemiology and Population Health, London School of Hygiene and Tropical Medicine University of London 49-51, Bedford Square, London WC1B 3DP tel: ++ (0)171 299 4688 fax: ++ (0)171 299 4666 email: [email protected]

written by request of the Consumers’ Association, for Consumer Policy Review please do not copy or quote without permission

I have drawn on a number of reports and articles in writing this paper, and discussed 1 the ideas in it with authors and others working in the field . None other than myself is responsible for the text written here.

Introduction In November 1996 the World Food Summit affirmed the "right of everyone to have access to safe and nutritious food." and acknowledged that poverty was a major cause of food insecurity throughout the world (1). The Consumers’ Association manifesto of the same year endorsed this position, while adding that consumers should be able to make healthy lifestyle choices (2). These were the opening words of a recent Consumers’ Association Policy Paper: The Food Divide: eating on a low income (2). The paper set out the barriers to healthy eating for low income consumers from recent research, including the Consumers’ Association’s specially designed national study of availability and price of healthy food in areas where people on low incomes were known to be living. The views of low income consumers from focus groups in different parts of the country were also reviewed. The recommendations called for a national strategy to address food and poverty, and briefly highlighted key areas of concern: benefit levels, transport to shops, community provision, nutrition education, retailers and local strategies. This paper picks up where that paper ended, and explores low income consumers’ entitlement to a healthy diet: what rights do, or should, people have of access to food for health, and whose responsibility is it to implement those rights? It raises a number of questions which have not been sufficiently debated in society generally, or openly by those responsible for health and social policy within government. In so doing, it builds on many recent reports and articles, some of which are referenced here and in the earlier Consumers’ Association paper. In particular, it draws on the report of the Low Income Project Team to the Nutrition Task Force (3) and the recent discussion paper Food Poverty: What are the policy options? by the National Food Alliance (4).

Food Security The concept of food security, widely adopted by the international community in relation to food access and entitlement, has not been much explored in the British context. Functional definitions of food security vary, but Maxwell has broadly defined it as “access to sufficient, affordable, safe and nutritious food necessary and appropriate for a healthy life, and the security of knowing such access is sustainable in the future” (5). This highlights three key aspects:

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Particular thanks to Bill Buckley, John Godfrey, Michael Green, Elaine Kempson, Suzi Leather, Iain Macdonald, Esther Trenchard-Mabere and Amanda Watson.

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a) access itself has two components: economic access, or having sufficient money to buy appropriate food, which of course depends both on the price of healthy food and on how much money can be allocated to food expenditure, and physical access, which in Britain refers to the range and quality of food commodities available in shops people can actually reach, whether by foot, public transport, or, if they have access to one, by car. b) the food concerned has to be both safe, and necessary or appropriate for a healthy life (6). Food should be appropriate in social and cultural terms, as well as meeting established guidelines as to what constitutes a healthy diet. c) access should not only be sustainable, it must be perceived to be such by the consumer. As far as possible people should be free from fear and anxiety about being able to eat properly. In the international nutrition community, of multilateral, bilateral and nongovernmental organizations, there has been a long-standing commitment not only to supporting governments in achieving food security at household and individual levels, but also to monitoring conditions and circumstances of households whose food security is thought at risk (5). Measuring how much food people are eating at a given time is a relatively straightforward matter; the challenge is to be able to measure the risk that they will be unable to continue eating sufficient, appropriate food in the future, and why. Different categories of risk are distinguished: households with potential problems of food security but who have evolved sufficient “coping” strategies to avoid deterioration of nutritional outcomes (“enduring” households); households which face temporary severe problems or crises, but recover (“resilient” households) and households which become increasingly food insecure in response to problems (“fragile“ households) (5). There are parallels here with current social policy work in the UK on income mobility and “churning” and the characteristics of households, or of livelihoods patterns, that enable households to move in and out of low income (7). However, little work to date has been done looking at the subsequent effect on food security: what it is about particular livelihood conditions or household circumstances that makes some people regularly vulnerable to having to go without, whereas others somehow seem to get by? Other insights from international work on food security with strong parallels in the UK are the recognition of intra-household differentials, both of going without food, and of responsibility for feeding vulnerable members (8). Finally, governments and agencies elsewhere more and more ask for the perceptions of the food insecure; low income consumers’ ideas and practices are important both in defining problems and in generating solutions (9).

Food, citizenship and social exclusion There is increasing evidence that those who live for long periods on very low wages, or on state benefits, cannot afford to purchase sufficient basic, appropriate food for a healthy life. This evidence was reviewed in The Food Divide: eating on a low income (2). In summary, the key issues are access, availability and affordability. The majority of the poorest in Britain are concentrated in local authority housing in

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inner cities, especially older industrial areas, and peri-urban estates, where major sources of employment have closed. Shops and banks have withdrawn from these places, partly because the inhabitants spend little, and partly because of retail concentration in out-of-town and large superstores (2, 3, 10). Although about 15% of customers in the major supermarkets are from the lowest social class, many low income consumers cannot easily get to such stores (or to fresh produce markets) because they do not have cars and public transport is inadequate. This is true despite recent efforts towards regeneration of high streets, or the appearance of small city-based stores of the major supermarkets - they are still not where poorer people live, and carry a limited product range which may be more expensive than in the superstores. On the whole, the poorest have to use discounters, which carry a more limited range of goods and often little fresh produce, or small local supermarkets and corner shops, whose operating margins are such that their food is relatively expensive. Food budget studies, using prices typical of a major supermarket, show that a healthy food basket would cost a much higher proportion than could possibly be spent from benefit income (11). In fact of course, the costs typical of the shops generally found where poorer people live, are even higher, particularly for food recommended for health, such as fruit, lean meat, wholemeal bread (12). Unsurprisingly, surveys measuring diets of income support claimants show their intakes of many vitamins and minerals known to be protective against heart disease and cancer, to be well below reference levels. Where people’s benefits have been reduced to meet arrears or debts, or where they use key meters for fuel (which mop up ready cash for food), the situation is particularly bad. These findings are independent of ethnicity, smoking, shopping or cooking practices (13). It is not that those who are poor do not know how to budget or shop for health; it is that they are excluded from the means of doing so by virtue of their poverty. Food is then a marker of social exclusion. Those who cannot afford to eat in ways acceptable to society; who find food shopping stressful because they have insufficient money, or because the shops they can reach are inadequately stocked with poor quality goods; whose children cannot have a packed lunch similar to their friends' - these are people excluded from the "minimum acceptable way of life". The social, cultural and psychological functions of food have to be recognized in assessing basic needs or social exclusion (14). Two of the four central tenets of the Commission on Social Justice were that all citizens should be able as a right of citizenship to meet their basic needs for income, shelter, education, nutrition and health care; and that self-respect and personal autonomy depend on the widest possible spread of opportunities and life-chances (15). The present government has recognized both the injustice and economic inefficiency of current inequalities in health in the UK - inequalities which have worsened as the gap between rich and poor has widened (16, 17). Further, they acknowledge the contribution of food access, rather than inappropriate behaviour, to the problem, and its improvement to the solution (16). The argument needs to be followed through: “access to a standard of diet which will create and sustain health is constitutive of citizenship. [..] People have the right to an adequate supply of food. Government policy should be to recognize this right in

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law; to guarantee an income adequate to meet basic food needs; and to ensure easy access to, and diversity of choice in local shopping facilities in deprived areas.” (18) This makes clear that food should be regarded as a product of a basic utility, which, like water, is both consumed, and produced/distributed by private sector businesses run for profit. Like water, food must be safe, and food is a necessary condition of public health for all, rather than simply for those who can afford it. Food is treated as a utility by government in that no VAT is levied on it. People who live on low incomes themselves see food as on a par with water, gas or electricity: they weigh up which of their weekly bills (or bits of them) they will pay, juggling one versus another. Some try to protect food expenditure, running up other debts, with the consequence that that they regularly face “a week of jam sandwiches and tea” when there is no money left for other food. Others prioritize the utilities that can disconnect, fine or imprison a continual defaulter; food is what is continually cut (19).

Food as a utility: regulation and the Food Standards Agency The water industry is highly regulated: the economic regulator (Office of Water Services: OFWAT) ’s primary responsibility is to ensure that the industry provides customers with a good quality and efficient service at a fair price. This responsibility is discharged by controlling the prices water companies can charge. Although there is no specific onus on the Regulator to protect low income consumers, he (sic) does keep watching brief on household disconnections, which have fallen from 21,000 in 1991/2 to 1,900 in 1996-7 (20). The Drinking Water Inspectorate monitors the quality of drinking water provision, and the Environmental Agency regulates waste water to protect rivers, estuaries and coastal waters. Thus quality, safety and cost are monitored in relation to established standards and as conditions of licences to trade. Since privatization, water shortages and adverse publicity over water quality and leakages, combined with rising company directors’ pay and domestic water charges, has created considerable public pressure on the industry to improve. The parallels with food are instructive. Public confidence in the quality and safety of food - and the trust in government to safeguard them - has fallen very low. The forthcoming Food Standards Agency (FSA) (21) is designed to address this matter: “Food safety is an issue which concerns every man,woman and child in this country. It is one of the Government’s key priorities.” (foreword to the White Paper) The FSA is to take a strategic view of food safety and standards across the whole food chain, with wide-ranging powers to commission research and surveillance, propose legislation, monitor food law enforcement and take action. Its dealings are to be transparent, and the public’s voice is to be heard in the decision making process. Its essential aim is to protect public health in relation to food; it will have powers if necessary to take action to achieve this end (21). However, in contrast to regulation in other utilities, the FSA White Paper is focused almost entirely on quality: no role for economic regulation is mentioned. The potential is very great: the FSA public health mandate should be to ensure food security for all. This approach would then include food safety and quality, and access to sufficient, appropriate food for health. Such a role would fit with the wider

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brief for nutrition and food policy advocated in the public consultation over the FSA (22). The FSA could set standards for access to food towards achieving public health for all, (although it might need to commission more research on appropriate indicators, including some consultation, through participatory methods, with those who currently lack access). Having established food access standards, the FSA could work towards a statutory obligation on local authorities to comply with these standards, either through a code of practice under existing legislation, or if necessary, through new legislation. There would be four consequences of such a statutory function: i) local authorities would be empowered to implement a range of activities to ensure food access as one of their central functions, instead of the present rather peripheral role food access plays, as a component of health promotion, itself a discretionary activity for local authorities (and one readily subject to cuts). ii) access to food would be monitored, either in terms of geography or for specific groups of people thought to be at risk of poor access. Monitoring could be established as a duty of local health officers; for instance, by environmental health officers, who in their public health function, currently work with local food shops on food safety and standards. iii) indicators of food access for different population groups could also be used in planning departments, to contribute to decisions about location of different types of shops. iv) indicators of food access would be used to monitor the range and quality of goods stocked in different shops (operationalizing ideas such as a “green-shelf indices” “healthy basket indices” described in the Report: Low Income, Food, Nutrition and Health: Strategies for Improvement. (3). Again, various local health personnel could take on this role: health promotion officers, environmental health officers, public health nutritionists, local authority food poverty officers.

Food as a utility: costs and the Food Standards Agency There are a several points which could be made about food costs and the FSA. The first is that, among concerns expressed in the public consultation for the FSA, was a general opposition to the principle of levying some of the costs of work on food safety from the food industry, which could too readily be passed to consumers as indirect taxation on food (22). Such a cost would fall disproportionately on poorer consumers, who expend a higher proportion of their budget on food than richer households. Secondly, the FSA could take a proactive role in establishing routines for measuring differential costs of typical food baskets for a healthy diet, according to type of shop. Food baskets could be constructed for households of different demographic structures and ethnic group. Such an activity would form an essential part of measuring and monitoring food security and access. There are various approaches that have been documented (e.g., 11, 12). As in all other aspects of the agency’s work, there should be transparency in the calculations. If the budget standards

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approach was used, for instance, there should be clear statement of the technical aspects of choice of nutrient standards or foods; prices used (mindful of shop variations) and uprating; cost of other basic goods; what goods and practice the money is intended to cover, over the long and short term. Monitoring the price of food from different sources is clearly quite a complex task, not least because of rapid variation at local level: for instance, special offers targeted at store loyalty-card owners. One issue largely unexplored to date is regional variations in food prices. The major supermarkets, who capture about 80% of the food market, already exhibit differential pricing, partly on the basis of geography and of store size, to reflect local store sourcing and running costs (23). Such local price variations might be quite a small proportion of the cost of food for a household on average incomes and hardly noticeable. For those who live on low incomes, who spend 25% or more of that income on food (though low actual amounts: £13/person/week in government surveys; £5-£10/person/week from in-depth small surveys), having to pay a few pounds extra a week for basic foods can mean buying no fruit at all (24). Recent work by the Policy Studies Institute showed there was marked regional variation in basic living costs of rent, council tax, utilities (other than food) and domiciliary care: variations of more than £50 in housing costs, and up to £10 a week for other basics, were measured. The survey showed that price variations could absorb up to a fifth of benefit payments for claimants in identical circumstances, depending where they lived. Intra-regional variations were bigger still, especially in the regions with high average costs (25). It would be important to add the variation in price of food, particularly prices typical of corner shops, to such calculations. Thirdly, there is the issue of the adequacy of benefit levels to achieve a healthy life. Clearly, the issue is a sensitive one (for instance, it was explicitly excluded from the terms of reference of the Low Income Project Team). At present, there is no transparency in the value of the food element in benefits; it is impossible to calculate what the rates are intended to cover. Nonetheless the Department of Social Security has sought advice in the past from the Department of Health and MAFF over the possibilities of purchasing an adequate diet for health. The FSA White Paper states that consideration of vulnerable groups and issues of inequalities would be a responsibility retained by the Department of Health. Were the FSA to be given responsibility for defining and monitoring food access, it would be in a strong position to contribute to such discussion and negotiation. Not least, would be the possibility of reviewing the needs of particular groups whose food security was highly at risk: for instance, families with school-aged children, during school holidays (when no free mid-day meal is provided); or rural households in areas where costs of basic utilities are high. Leather has also argued for consideration of ring-fencing the food element in benefit levels; for instance, when fines or mandatory deductions are made for debts or arrears, sufficient money to enable the household to purchase sufficient food must be left (24).

Food access: responsibilities and possibilities I began with current work on food security in the international scene and highlighted useful lessons for the UK. Food security (food access) is a complex issue, seen in

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different ways by different people. This complexity demands a flexibility of response, by both government, the private sector, and the food insecure themselves: there is no one solution that will meet all needs. The current political climate chimes with the diversity of policy initiatives needed: of “horses for courses”, of “enabling”, of partnership (5, 16, 26). Individuals, households, communities - and partnerships of local authority, healthy authority and private sector actors - need opportunities to develop a variety of approaches and ideas (27), some of which are listed in the figure. Central government’s role is still crucial: to recognize the achievement of food access for all as a priority, and to set it as a statutory obligation on local authorities. Regulation to monitor achievement of food access then requires designation of appropriate indicators and mechanisms for measuring them. The current and potential roles of other groups and sectors are set out below. a) manufacturers and retailers (see Food Poverty: What are the policy options? by the National Food Alliance (4) for more detailed examples): More attention could be paid to the quality of foods typically eaten by low income households, in terms of contamination, and of nutrient content (fat, type of fat, salt, vitamins, minerals). The price of goods is clearly critical. The range of products packaged or sold as economy lines which contribute to a healthy diet could be increased (such as fresh fruit and vegetables, lower fat and lower salt in processed and packaged foods, leaner cuts of meat, oily fish, whole-wheat products). Stores typically have a range of promotional activities, some of which are involve healthier products. More judicious use could be made of in-store or mail-shot promotion and loyalty-card incentives to buy healthier foods targeted to low income customers (identified either by income bands from application forms, or through patterns of purchase). Smaller supermarkets and local corner shops typically stock very few products which are recommended for health; they could extend into such items as are known to be popular, since they cannot usually carry stock which does not sell rapidly, and consider cost promotions (“3 for 2“, etc.) (26). Location of stores is another critical issue. There are some initiatives underway exploring partnerships with local authorities over inducements to locate in low income areas. Examples include: negotiations over land price, business rate relief, grants for installing extra security. Recent legislation has provided some support for village shops in rate relief; attempts to secure similar relief for inner city small shops has not so far met much success. There has been some support from major supermarkets for village shops where these are under threat as non-viable. Another possibility for private sector inducement to locate in deprived areas mooted in private discussions is the transfer of a proportion of individuals’ benefits to the store of a major chain store, with some kind of voucher for the claimant to spend in that local store There are some parallels here with direct transfers of income support to gas or electricity companies, to recover arrears. It is not clear what the implications of diversity of private sector fuel utility provision will mean for such practices. Certainly, to insist effectively that low income consumers who are benefit claimants have to shop in one store rather than another would be a considerable departure from principles of consumer freedom for the UK.

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There is clearly anxiety in government about the withdrawal of banks from low income areas (10, 28), not least because that precludes the DSS increasing its use of automatic credit transfer for payment of benefits. The major supermarkets are expanding into banking as into many other areas; is it too fanciful to imagine an inducement to a supermarket to site a store in a high claimant area, where they would otherwise not locate, and offer current accounts to customers through which the DSS would transfer their benefits (income support, child benefit, pensions)? The idea raises a number of immediate questions, such as: would small accounts where little was saved be worth running? what would happen to sub-post offices in the area? what are the implications for consumer freedom of choice? However, it would still leave people notionally free to choose where to shop; it would certainly leave them free to buy whatever they wanted with cash, (which vouchers or food stamps sometimes do not), and there is evidence that people in general trust the major supermarkets more than they trust the major banks (or even the government). Finally, rather a different avenue is that being explored by the CWS (29) among others: support for local initiatives. The Scottish Co-op has begun work with local food co-ops to help in sourcing and training (30). Similarly, other major chains have offered start-up costs, training, advice and other ad hoc support to local projects. b) central government The most important points were made in the sections above on the Food Standards Agency. However, the role of the FSA notwithstanding, some co-ordination of policy to decrease nutritional inequalities needs to be taken, probably by the Department of Health. Such co-ordination was a recommendation of the Low Income Project Team, and would be a prerequisite for meeting the targets of the Green Paper Our Healthier Nation. Among specific initiatives would be more support for food and nutrition through schools, both in the national curriculum and in the quality and costs of school meals. Some schools are developing local food policies; such initiatives need supporting, not least in protecting costs of providing healthy school meals in school budgets. There needs to be active support for food initiatives in health action zones and healthy living centres, rather than exhortation. Unless food access is a mandatory target it is seen as a soft, secondary target, ripe for cuts. c) local government and local health authorities If food access becomes a statutory obligation, local authorities will be empowered to implement and monitor a raft of local activities towards achieving it. Some have been mentioned already, such as negotiating inducements to retailers to site stores where poor people live. In addition, there is scope for simplifying schemes to support such local food stores as exist (e.g. grants towards security) to be manageable for small, family run businesses. Local authorities and/or health authorities already provide some support to community based initiatives; they could provide considerably more. Possibilities include: training and advice; facilities rentfree or low cost; transport; access to grants for running costs as well as start-up costs; support of professionals; inclusion of food initiatives in SRB applications.

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Food access: individuals and society “Poverty is when you draw your dole money and it belongs to the man in the grocery shop, so they have to shop there, and it is a very expensive shop. He lets them run up a bill, provided they leave their book there. And he lets them go on and on.” (woman in her fifties, quoted in Leather, 1996 [ref 14]). One key principle of access to food is precisely the element of security: as far as possible, people should be free from fear and anxiety about being able to eat healthily, or even at all. In discussing responsibilities for ensuring access above I have not mentioned individuals or households. Society generally expects that those who have little money will manage that money with care, budgeting to meet essential needs, particularly for children and other dependants. However, until recently, the members of households with low incomes, whether benefit claimants or those earning very low wages, have in effect borne all the responsibilities: they have had no say in how much money they earn or can claim, under what conditions, what happens to the local shops, what prices they have to pay, how they get to cheaper shops. They have had to struggle to make the best they could in extreme circumstances, and the consequences for health and well-being have been widely documented. There is much focus now on partnership and participation. Consultative committees where consumer/local voices are to be represented are much in vogue, and local collaborative initiatives that tap into real, articulated local needs are seen to have greater possibilities of sustainability. However, food still gets left out, too readily regarded as “very important but not our responsibility”: food is seen as a matter of private choice and consumption, rather than a basic entitlement. Of course people should be free to eat what they want, within reason. But many who live on low incomes (more than one in five households) currently have very little choice at all: they cannot participate in one of the dynamic, leading sectors in society, which produces, distributes and retails an ever expanding range of foodstuffs. Exhortation to take part is of little use without the statutory entitlement to food being recognized by government, with local obligation to implement access to food for all, whatever their circumstances. This acknowledgement would release the necessary flexibility of response and private/public sector partnerships to enable those on the lowest incomes to obtain and eat sufficient, appropriate food for their present and future well-being. “I am talking about dynamic community partnerships coming up with innovative solutions to tackle the health inequalities and social exclusion which are endemic in our society. So if people are saying healthy eating is fine in principle but in practice the shops don't stock the food or it isn't affordable, then a Healthy Living Centre might work with local shops and local transport bodies to see what can be done. Or they might help set up a food co-op so that the community can help itself. And if black market debt is creating community poverty so that mothers are going hungry to feed their kids, then I hope that Healthy Living Centres will be able to work with local authorities and the police to tackle loan sharks and perhaps establish credit unions. What I really hope is that the centres will have an all-encompassing vision” (Tessa Jowell, Minister for Public Health, 2nd April 1998).

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references 1. FAO (1996) Rome Declaration on World Food Security and World Food Summit Plan of Action. Rome 13-17th November 1996. 2. Consumers’ Association (1997) The Food Divide: eating on a low income. Policy Paper, October. 3. Department of Health (1996) Low Income, Food, Nutrition and Health: Strategies for Improvement. A Report from the Low Income Project Team to the Nutrition Task Force. London: Department of Health 4. National Food Alliance, (1998) Food Poverty: what are the policy options? London: National Food Alliance. 5. Maxwell, S. (1996) Food Security : a post-modern perspective. Food Policy, 21, 2, 155-170 6. Davey Smith,G. & Brunner, E. (1997) Socio-economic differentials in health: the role of nutrition. Proceedings of the Nutrition Society, 56, 75-90; James, W.P.T., Nelson, M., Ralph, A. & Leather, S. (1997) The contribution of nutrition to inequalities in health. British Medical Journal, 314, 1545-9. 7. Jarvis, S. & Jenkins, S.P. (1998) Low income dynamics in 1990s Britain. IDS Bulletin, 29,1, 32-41; Hills, J. (1998) Income and Wealth: the latest evidence. York: Joseph Rowntree Foundation. 8. Dowler, E. (1996) Women, food and low income: a cause for concern? Health Visitor, 69, 9, 359-3; Goode, J., Callender, C. & Lister, R. (1998) Purse or wallet? Gender inequalities and income distribution within families on benefit. London: Policy Studies Institute. 9. In the US, indicators of household food security have been incorporated into national nutritional surveys. see KL Radimer, CM Olsen and CC Campbell (1990) Development of indicators to assess hunger. Journal of Nutrition, 120, 1544-1548. 10. Jones, R. (1998) Postcode victims get a champion. The Guardian, Sat July 18th, p6-7. 11. Nelson, M., Mayer, A.M. & Manley, P. (1993) The Food Budget. ch5 in: J. Bradshaw, (ed.) Budget Standards for the United Kingdom. Aldershot: Avebury Press, pp35-64. 12. among many authors, see Piachaud, D. & Webb, J. (1996) The price of food: missing out on mass consumption. Suntory and Toyota International Centre for Economics and Related Disciplines, London: London School of Economics; Mooney, C. (1990) Cost and availability of healthy food choices in a London health district. Journal of Human Nutrition and Dietetics, 3, 111-120.

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13. Dowler, E. & Calvert, C. (1995) Nutrition and Diet in Lone-parent Families in London. London: Family Policy Studies Centre with the Joseph Rowntree Foundation; Dowler, E.A. & Dobson, B.M. (1997) Nutrition and Poverty in Europe: an overview. Proceedings of the Nutrition Society, 56, pp51-62. 14. for example, see: Leather, S. (1996) The making of modern malnutrition: an overview of food poverty in the UK. London: The Caroline Walker Trust; Lang, T. (1997) Dividing up the cake: food as social exclusion. ch14 in: Walker, A. & Walker, C. (eds) Britain Divided: the growth of social exclusion in the 1980s and 1990s. London: Child Poverty Action Group; Dowler, E. (1998) Food poverty and food policy: poverty and social exclusion north and south. IDS Bulletin, 29, 1, 58-65. 15. In practice, definition of rights as an attribute of citizenship can bring its own problems: the marginalized in a society, or those labelled as refugees or asylum seekers, have needs and rights to food too. 16. Department of Health (1998) Our Healthier Nation: a contract for health. Green Paper February 1998. Cm 3854 London: The Stationery Office. 17. Among many who have written on inequalities, see Phillimore P, Beattie A & Townsend P. (1994) Widening inequalities of households in northern England 1981-91. British Medical Journal 308, 1125-8. 18. Leather, S. (1996) op cit 14. See also writing from the Glasgow based Poverty Alliance’s Foodworks Enquiry, where the language of rights, entitlement and food security has consistently been used to great effect. 19. Kempson, E., Bryson, A. & Rowlingson, K. (1994) Hard Times: How poor families make ends meet. London: Policy Studies Institute. see also Dowler, E. (1998) Budgeting for food on a low income: the case of lone parents. Food Policy, 22, 5, 405-417. 20. OFWAT Press release, Water disconnections fall for the sixth year running. 14th May, 1998. 21. MAFF, The Food Standards Agency: a Force for Change. Cm 3830, January, 1998; see also: James, W.P.T. Food Standards Agency Report: an interim proposal. April 1997. 22. MAFF/DH Joint Food Safety and Standards Group, Responses to the public consultation ont he Government’s White Paper “ The Food Standards Agency” (CM3830). May 1998. 23. for example: the same size and version of a commodity does not necessarily cost the same in the same superstore located in two different towns. I also heard in a radio discussion that supermarkets are considering differential pricing by time of day to attract different niche markets: e.g. pensioners. 24. Leather, S. (1996) op cit ref 14.

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25. Kempson, E. & Bennet, F. (1997) Local Living Costs. London: Policy Studies Institute. In fact, the difference between the highest and lowest private rent was £115/week; for council rent the difference was £63/week; council tax differences were £13.68/week for band D. 26. Green, M. (1997) Institute of Grocery Distribution Annual Report. 27. Nelson, M. (1997) Developments in the UK: the work of the Low Income Project Team. Proceedings of the Nutrition Society 56, 91-100. 28. E Kempson. Outside the banking system: a review of households without a current account. HMSO 1994 (Social Security Advisory Committe Research paper 6). 29. see New Sector Supplement (1998), containing an account of CWS current thinking about, and activities to support, local initiatives among low income communities. New Sector (Magazine of Community & Co-operative Enterprise), 32, June/July, pp7-14. 30. There is a National Food Alliance / Health Education Authority database of local food projects aimed at low income groups (contact HEA). There is also a Scottish Federation of Community Food Initiatives (c/o Money Matters, 986-988 Govan Road, Glasgow). Most local projects use local volunteer labour, although there are sometimes inputs by professionals from various sectors. A Joseph Rowntree Funded project is currently underway to look at the sustainability of such initiatives; it report later in 1988.

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