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Welsh Government Healthy eating in schools Consultation May 2025

Summary of response from Cwm Taf Morgannwg  University Health Board (CTMUHB)  Public Health Team (PHT) 

Authors of response: Helen Walters, Libby McIntosh, Rachel Reed, and Claire Turbutt 

Summary prepared by: Shakira Leslie 

 

Executive Summary 

Cwm Taf Morgannwg University Health Board (CTMUHB) Public Health Team (PHT) contributed to the Welsh Government Healthy eating in schools' consultation. The PHT response addressed four of the consultation questions in relation to regulatory and wider impact assessment and promoting healthy eating statutory guidance: primary and secondary schools. 

The CTMUHB PHT advocates for the adoption of several approaches to improve school food environments across CTM.  Particularly a learning and adaptive approach to the implementation of the food regulations. Encouraging Welsh Government to support the educational system by creating learning groups, involving schools, families and communities, to feedback from local to national level which can help expand understanding and inform and improve practices.  

The response further highlights the importance of embedding a Whole Systems Approach (WSA) combined with Appreciative Enquiry (AE) — a strengths-based approach to creating change — as an effective approach for examining the underlying causes, challenges, and potential solutions to complex problems that arise within a system. 

Behavioural science and social marketing support are highlighted as useful tools and can enhance the promotion and uptake of healthier food choices in schools. It is noted that Public Health Wales have resources readily available for behaviourally informed strategies, including a behavioural science toolkit. Our Publications - Behavioural Science Unit 

CTM, comprising Rhondda Cynon Taf, Merthyr Tydfil and Bridgend Local Authority areas, has been identified as having a higher density of fast-food outlets compared to the Wales average, which are often situated in close proximity to schools, further contributing to the poor-quality food environment and increase risk of overweight and obesity. For change to occur, multi-sector collaboration is required to address these systemic issues.   

Insights gathered from pupils in Treherbert, Rhondda Cynon Taf, highlight challenges relating to the prevalence of fast food, limited healthy options, and the need for better food initiatives and education. To improve school food environments across CTM, it is recognised that a WSA can help foster learning, adaptation, and collaboration among stakeholders to enhance access to healthy and affordable food within the local context.  

 

Introduction 

The PHT consultation response addressed four of the consultation questions in relation to regulatory and wider impact assessment and promoting healthy eating statutory guidance: primary and secondary schools. We have provided a summary of each response below.  

 

Regulatory and wider impact assessment 

Consultation Questions:  

11. What challenges, if any, do you feel should be further recognised within the draft regulatory impact assessment? 

The CTMUHB PHT highlighted complexity as a challenge and urged the Welsh Government to consider this as part of the implementation. Systems thinking is an effective approach for examining the underlying causes, challenges, and potential solutions to complex problems that arise within a system. The team have worked closely with the community recently to help understand the factors affecting access to good quality, affordable food in our towns, villages, and educational settings and these wide-ranging factors need to be considered.  A learning approach was recommended to help create conditions for those applying the regulations to listen, test, learn, feedback and adapt. This approach also recognises the ‘unknown’ of how an intervention is truly going to react in a system and the impact it may have. Feedback from all key stakeholders will inform the learning and adaptation elements in the whole school and educational approach, including the support around the school (parents, carers, families, and children). Welsh Government are urged to support schools and the educational system to create learning groups whereby feedback on implementation can be fed back through existing or newly formed information routes from local to national level.  

Benefits were noted of adopting a WSA to a healthy weight1, and using Appreciative Enquiry2 (AE), a strengths-based approach that can be applied when collaborating with participants to explore their views on what is working well. AE promotes openness and helps identify a system's strengths and improvement areas (NHS England, 2024). By embedding AE intervention into a WSA, it will foster an approach to continual learning, through engaging with multiple organisations and the communities they serve. 

 

12. What positive effects, if any, do you feel should be further recognised within the draft regulatory impact assessment?  

As aforementioned, taking a learning and WSA can add value to mechanisms and ways of working. Furthermore, taking a behaviourally informed approach could be beneficial to the implementation of the regulations and the increased uptake of healthy food. Public Health Wales were urged to support the educational system as part of the launch, promotion of the regulations and new food menus through a behavioural science lense. Utilising existing tools to support a behaviourally informed approach.  Behaviour Science Discovery Tool by Public Health Wales. (Public Health Wales, 2023). A social marketing campaign was identified as a potential method to support the WSA and facilitate its implementation across the system.  

 

13. What comments, if any, do you have on the draft impact assessments, particularly the impact of the draft regulations on children, families living in socio economic disadvantage and people with protected characteristics (including evidence you feel should be considered)? 

The evidence shows that CTM has a higher-level fast-food outlet density than the Wales average. A recent study by Bangor University reported the average number of fast-food outlets per 100,000 head of population as, 111 (average across Merthyr, Bridgend, and RCTCBC) compared to the Wales average of 101. (Rhiannon Tudor Edwards, 2025).  

At a recent stakeholder event, we asked delegates to map factors that affect access to good quality affordable food in settings across Rhondda Cynon Taf. Stakeholders noted that poor-quality food options contribute to, and reinforce, challenges in the food environment that are hard to resolve. This brings to light the importance of procurement and availability of healthy food options for both influencing consumption of healthy food and disrupting the challenging cycle around the consumption of unhealthy food. People with greater exposure to fast-food outlets are twice as likely to have obesity. With this knowledge, we recognise addressing this issue can be an enormous undertaking and may only be achievable by working in collaboration with key partners and stakeholders from local authority, food, and regulatory industries. Furthermore, raising awareness of the WSA with key players within the system and empowering them to make small changes within their power, where possible, can contribute to the goal of making access to healthy and affordable food options easier for our populations.  

 

Promoting healthy eating statutory guidance: primary and secondary schools 

Consultation Questions:   

16. How can we achieve a nutritionally balanced and appealing food offer in secondary schools? 

Whilst carrying out community engagement work in Treherbert, Rhondda Cynon Taf, we gained insights on food offers for children and young people by engaging with primary school pupils, secondary school pupils and sixth form pupils, to learn more about their access to food within the school setting and their knowledge of school/ community food initiatives. We compiled key themes from this engagement work, and it revealed: frequent use of Spar and Premier shops, frequent use of fast food - particularly fish and kebab shops, and preferences for snacks and fizzy drinks with the healthy alternative not being prioritised. Pupils told us they actively avoided school meals due to long queues, resulting in a reliance on using the local Co-op for meal deals and other food shops such as Greggs.  

Similarly, the insights we gathered regarding school/ community food initiatives demonstrated a similar picture, sixth form pupils stated that there were no formal school food initiatives available to them, whilst year 8 pupils identified the unhealthy food offers at youth provisions such as football sessions. The Youth Engagement and Participation Service (YEPS) team told us they want to explore alternative food provisions e.g., fruit and water sales at the local field. Pupils expressed a preference for healthy choices, particularly wanting more water refill stations at school and in the community. There was interest in offering cooking skills classes since some pupils find it difficult to prepare basic meals. Furthermore, pupils discussed advertising of unhealthy food options and expressed that if healthier options were available and advertised, that they would be inclined to buy them (they believe healthy food options in their area are currently extremely limited). Pupils hope healthy food and drinks will be cheaper and would like to see it available at the local sports field. A pupil said, “In Treherbert you’ve got Spar, Paul’s, Premier, a lot of takeaways. I wouldn’t say there’s a lot of healthy food options available. It needs something that does, and we’d buy it!”.  

The focused work that took place in CTM to gather community insights3 gave real life examples of the lived experience of young community members, particularly on their views around their food environment. These insights enable a better understanding of the challenges around access to affordable and good quality foods in CTM.   

 

References 

  1. NHS England (2024) Appreciative inquiry. A tool to see the world in a different way. Available at: https://library.hee.nhs.uk/knowledge-mobilisation/knowledge-mobilisation-toolkit/appreciative-inquiry  

  2. Public Health Wales (2023) Behaviour Discovery Tool. Explore your problems from a behavioural perspective. Available at: https://publichealthwales.qualtrics.com/jfe/form/SV_exv0EG8pCOELI2O  

  3. Edwards, R. T. (2025) ‘Financial analysis of the impact of overweight and obesity on Cwm Taf Morgannwg University Health Board and overview of the impact of potential mitigation scenarios’. Available at: https://research.bangor.ac.uk/en/projects/financial-analysis-of-the-impact-of-overweight-and-obesity-on-cwm-3  (Accessed: 4 September 2025).  

  4. Public Health Wales (2022) Whole Systems Approach for a Healthy Weight. Available at: https://phw.nhs.wales/topics/whole-systems-approach-to-healthy-weight/ (Accessed: 5 September 2025).  

  5. Cwm Taf Morgannwg Unversity Health Board (2025) Edible Playground Feedback May 2025. Available at: https://ctmuhb.nhs.wales/services/public-health-team/areas-of-focus/healthy-weight/key-publications-and-information-for-professionals/healthy-weight-team-events-and-updates-links/healthy-weight-case-studies/edible-playground-feedback-may-2025/ (Accessed: 5 September 2025).  

  6. Public Health Network Cymru (2025) Food and Nutrition. Available at: https://ctmuhb.nhs.wales/services/public-health-team/areas-of-focus/healthy-weight/food-environment/gathering-lived-experiences-to-promote-healthy-diets-in-cwm-taf-morgannwg-pdf/ (Accessed: 5 September 2025).  

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