March 3, 2026
Dear President’s Choice Children’s Charity Team,
Re: Marketing Strategies within the Power Full Kids School Nutrition Funding Program
Ontario Dietitians in Public Health (ODPH), representing public health dietitians across Ontario, appreciates the financial contribution that President’s Choice Children’s Charity (PCCC) makes to school nutrition. Through the Power Full Kids™ program—which aims to empower children with good food and food skills and remove hunger as a barrier to education—many Ontario schools and students have benefited from food access and food literacy supports (1).
Recently, ODPH members working directly with school coordinators and regional Ontario Student Nutrition Program (OSNP) leads have raised a concern, that some schools report receiving promotional food items as part of the Power Full Kids™ grant. Specific foods provided to students include PC Rich and Chewy Chocolate Chip Granola Bars and Fruitsations Fruit Flavoured Snacks. Both granola bars with chocolate chips and fruit flavoured candies are on the Do Not Serve list per the Ministry of Children, Community and Social Services (MCCSS) Student Nutrition Program Nutrition Guidelines (3). After reviewing PCCC’s publicly available program pages and FAQs, we find no indication that promotional or branded items are part of the program’s design.
This is a concern for our members because ODPH supports the comprehensive restriction of all food and beverage marketing to children. Our position is further detailed in Ontario Dietitians in Public Health’s response to Health Canada’s Proposal to Limit Food Advertising to Children (June, 2023).
Introducing promotional or branded materials into school food programs risks creating commercial influence in environments where children are particularly susceptible to marketing. Marketing directed at children has been demonstrated to adversely affect their health and well-being and raises significant ethical concerns (2). This concern is particularly relevant given that Power Full Kids™ is positioned around universal, school-based meal and snack provision and food skills learning ‒ not brand promotion or the use of charitable programming as a platform to highlight or normalize specific food products. The program’s public materials describe a commitment to providing “good food” and empowering students with skills to discover food, not exposing them to branded content or commercial messaging within the school food environment.
To ensure alignment between program implementation and the child-centred goals set out in Power Full Kids™, we respectfully request that PCCC consider:
- Prohibiting the use or distribution of promotional or branded items within school meal and snack programs; and
- Updating program agreements and guidance to explicitly state that food and materials used within Power Full Kids™ supported programs be free from commercial branding.
- Food and beverage items provided to schools in Ontario by Power Full Kids™ supported programs follow the MCCSS Student Nutrition Program Nutrition Guidelines (3).
ODPH would welcome the opportunity to discuss these recommendations and to support your organization to develop clear, public facing guidance that ensures schools that receive funding from PCCC remain non-commercial.
Thank you for your consideration.
Sincerely,
Luisa Magalhaes, RD, MHSc Kimberly Leadbeater, RD
Chair, ODPH Co-Chair, ODPH School Nutrition Workgroup
cc.
Hon. Michael Parsa, Minister of Children, Community Social Services
Hon. Paul Calandra, Minister of Education paul.calandra@pc.ola.org
References:
- President’s Choice Children’s Charity. Power Full Kids™ program overview [Internet]. Available from: https://www.pcchildrenscharity.ca/program-overview/ [cited 2026 Feb 12].
- Ontario Dietitians in Public Health. (2019). ODPH backgrounder: Marketing of food and beverages to children and youth. Ontario Dietitians in Public Health.
Ministry of Children, Community and Social Services. (2021). Student Nutrition Program – Nutrition Guidelines 2020. Government of Ontario. https://files.ontario.ca/mccss-2020-student-nutrition-program-guidelines-en-2021-11-29.pdf
January 23, 2026
By email to:
Ministry of Children, Community and Social Services
RE: Ontario Student Nutrition Program (OSNP) and Public Health
We are writing on behalf of Ontario Dietitians in Public Health (ODPH) to share a concern regarding the recently communicated requirements for OSNP Local Planning Partnerships (LPPs).
ODPH members who work closely with Student Nutrition Programs have learned of a new requirement for Lead Agencies to establish and chair LPPs—previously optional under the 2018 Ministry Guidelines. These partnerships are intended to support local decision-making, volunteer recruitment, fundraising, and communication with school boards. We were surprised to learn that this new requirement does not include local public health agencies in the list of recommended partners. This is a notable shift from the 2018 Program Guidelines, which identified public health agency staff as key contributors to program governance and local planning committees (pp. 16–17).
In many communities, public health dietitians have long served as chairs and/or members of local planning committees that support the implementation of SNPs. Public health dietitians provide essential expertise by helping ensure foods served align with the evidence‑informed guiding principles and specifications of the SNP Nutrition Guidelines (2020). We also support volunteer recruitment and training, as well as communication with school boards and the broader school community, ensuring OSNPs remain universally accessible to all Ontario students.
We respectfully request that public health be added to the list of potential LPP members and/or that regional Lead Agencies be advised that public health staff, including public health dietitians, should be included in LPPs wherever possible.
We value our relationship with MCCSS and greatly appreciate your ongoing commitment to supporting the health and well‑being of Ontario students.
Sincerely,
KA Leadbeater
Kimberly Leadbeater, RD Luisa Magalhaes, RD, MHSc
Co-chair, ODPH School Nutrition Workgroup Chair, ODPH
June 13, 2024
Riffaat Mamdani,
Manager, Child Development and Specialized Services Branch, Children with Special Needs Division, Ministry of Children, Community and Social Services
Ziyaad Vahed,
Director, Child Development and Specialized Services,
Ministry of Children, Community and Social Services
RE: Feedback regarding SNP Review and Consultations
Thank you for including Ontario Dietitians in Public Health in the consultation process and recent feedback sessions.
ODPH is the official voice of Registered Dietitians working in Ontario’s public health system. As members of the College of Dietitians of Ontario, ODPH’s Registered Dietitians are credible food and nutrition experts, and are also uniquely educated to promote healthy eating at the population-level. ODPH is also a member of the national and provincial Coalition for Healthy School Food and supports their guiding principles. Our members work with SNPs in all regions of the province to ensure the foods served in local programs align with the SNP Nutrition Guidelines (2020).
Inadequate provincial funding and an over-reliance on fundraising and corporate charity is the primary limiting factor for SNPs to meet current and future needs across the province. We encourage MCCSS to work with other partner ministries and agencies to ensure:
- the annual provincial investment in the Ontario Student Nutrition Program (OSNP) and the First Nations SNP increases from $32.2 million to $64.4 million so that all existing programs have sufficient funds to operate at full/ideal capacity (i.e., operate 5 days per week during the school year offering culturally appropriate meals and/or snacks for all students),
- funding for paid program coordinator positions in schools, and
- additional capital funding for the specific infrastructure that is necessary to support student nutrition programs (e.g., adequate kitchen and storage space and equipment including a designated handwashing sink, additional sink(s) for food preparation, refrigerator(s), freezer(s) and dishwasher; bright, non-stigmatizing eating area(s); and external building features such as transportation access for food deliveries).
We are particularly concerned with the participation of Loblaw – President’s Choice Children’s Charity (PCCC) in the recent consultation. As you know, they offer the Power Full KidsTM program which provides financial grants to schools for school feeding programs. ODPH and other SNP partners including Student Nutrition Ontario (SNO), school boards, local SNP agencies and even school administrators have been unsuccessful in obtaining details from PCCC about their granting process, program resources, and other details. Their website states that they are “independent of other charities and governments”, yet they are at the MCCSS tables potentially influencing thefuture direction of our programs.
Our concerns include:
- the granting system is not transparent or universally available. This year, only schools that received an access code were able to apply, the criteria for obtaining a code was not shared although may have included schools on a waiting list from last year and total amounts available provincially and regionally are also not shared.
- schools that accept their funds in PC gift cards receive more money than schools that accept funds into their school accounts (the latter allows SNPs to use their local purchasing system rather than having to shop at a Loblaw franchise)
- their nutrition standards do not align with MCCSS SNP Nutrition Guidelines (e.g., their meal is defined as containing at least 1 serving of fruit or vegetables, plus 1 serving of whole grain or protein per day, based on Canada’s Food Guide – MCCSS guidelines state a meal contains 1 fruit or vegetable, 1 whole grain and 1 protein food)
- if schools receive funding, the amount is not always shared with their local program lead agency and schools cannot rely on funding year to year. This lack of transparency often results in unequitable distribution of other provincial/regional/local funding and impedes program sustainability at the school and local/regional level.
- the Charity uses hunger as a proxy for food insecurity to solicit donations and, by not providing funding in a universal and transparent way, perpetuates the myth that food charity is a solution for food insecurity.
We request that MCCSS consider limiting PCCC access to planning tables along with other commercial entities that stand to benefit from SNPs (e.g., food commodity boards and foundations, other grocers, etc.) and that these commercial entities be required to disclose their relevant financial statements.
We also request that MCCSS consider ensuring that any organizations (commercial or charitable) that provide food or funding for food be required to provide products that meet the SNP Nutrition Guidelines 2020 (or as current) and work with SNO and the regional Food and Logistics Coordinators to coordinate access and distribution that is available to all local programs.
Finally, we request that you consider sharing the consultation report or at least a summary of the report including the key findings with the non-commercial stakeholders so that we can better collaborate to achieve the best program possible.
Thank-you for considering these issues, and for your support and continued collaboration so that students have access to nourishing food in a welcoming and safe environment, free from stigma and marketing to children.
Sincerely,
Elizabeth Smith, RD
Luisa Magalhaes, RD
ODPH School Nutrition Workgroup
Cc.
Viviane Dégagné, Manager, Student Nutrition Ontario
Tyler Arsenault, co-chair Student Nutrition Ontario
Alexandria Pasiak, co-chair Student Nutrition Ontario
apasiak@algomafamilyservices.org
Sarah Keyes, Ontario Coalition for Healthy School Food,
Carolyn Webb, Ontario Coalition for Healthy School Food,
June 15, 2023
The Right Hon. Justin Trudeau, P.C., M.P Office of the Prime Minister of Canada House of Commons
Ottawa, Ontario K1A 0A6
By email: justin.trudeau@parl.gc.ca and pm@pm.gc.ca
The Hon. Jean-Yves Duclos, P.C., M.P. Minister of Health
House of Commons Ottawa, Ontario K1A 0A6
By email: jean-yves.duclos@parl.gc.ca and hcminister.ministresc@canada.ca
Bureau of Policy, Intergovernmental and International Affairs, Food Directorate Health Products and Food Branch, Health Canada
251 Sir Frederick Banting Postal Locator 2204C Ottawa, ON K1A 0K9
By email: bpiia-bpaii@hc-sc.gc.ca
Subject: Health Canada Consultation on restricting food advertising primarily directed at children on television and digital media.
Dear Prime Minister Trudeau and Minister Duclos:
We thank you for your continued commitments to supporting healthy eating initiatives including the recent announcements on a policy update for restricting food advertising to children and proposed regulatory changes.
Ontario Dietitians in Public Health (ODPH) is the independent and official voice of Registered Dietitians (RDs) working in Ontario’s public health system. We are writing to offer additional considerations for the policy and future regulatory frameworks.
It is the position of ODPH to support a ban on commercial advertising of all food and beverages to children and youth under the age of 18 (M2K Backgrounder 2019).
Additionally, it is our position that focusing this policy on obesity prevention exacerbates weight bias which contributes to discrimination, oppression and social injustices (Addressing Weight Bias). Instead the focus should be on creating a supportive food environment for children and youth.
Health Canada should consider:
- Restricting food advertising of all foods not just foods that are high in sodium, sugars and saturated fats
- Broadening the definition of children to include all children under the age of 18.
- Expanding restrictions to include other forms of advertising beyond television and digital media
- Reframing this policy away from obesity prevention which exacerbates weight bias and subsequent consequences.
- We strongly encourage Health Canada to consider restricting advertising of all foods to have a stronger impact. All forms of marketing to children and youth is an ethical concern because it intentionally takes advantage of the inability of children and youth to understand the intent of the advertising and make an informed decision (ODPH, 2019). Restricting advertising to certain categories of food will moralize food choices and reinforce harmful dietary attitudes and behaviours that are major risk factors for the development of eating disorders and growth issues (Haines et al., 2006; Hilbert et al., 2014; Larkin et al., 2005; Stice et al., 2017). Creating criteria for what can and cannot be advertised to children does not support the development of a positive relationship to food among children and youth, and opens the door for loopholes and further manipulation of food products and the criteria.
- ODPH also recommends that Health Canada broaden the definition of children to encompass individuals under the age of 18. Children are targeted because they are unable to critically assess advertisement messages, they can influence family spending, and they provide an opportunity to establish brand loyalty at a young age (ODPH, 2019). However, it is crucial to acknowledge that adolescents are equally susceptible to the influence of food marketing (Quttenia, De Backer & Smits, 2019). Due to their ongoing brain development and the vulnerable nature of adolescence, they tend to make impulsive decisions and may rely on brands and materialism to enhance their self-esteem (Harris et al., 2021; Quttenia, De Backer, & Smits, 2019; Truman & Elliot, 2019). We know that industry uses this additional vulnerability intentionally. Furthermore, industry is likely to increase intensity of advertising to older children in response to restrictions on food marketing to younger children (Powell et al, 2013; The Regional Office for Europe, 2018). Moreover, it is worth noting that marketing efforts targeting older children, youth, and/or adults often reach younger children. Consequently, a narrow age definition may not adequately safeguard the interests of younger children (Hawkes, 2004), warranting an extension of the age restriction to all under the age of 18.
- Although television remains the main source of advertising targeting children, food and beverage manufacturers use multiple channels and locations to strategically target children and influence their purchasing requests. We encourage Health Canada to consider broadening the restrictions to include other forms of advertising beyond television and digital media (e.g., product packaging, print, radio, signage, promotional items) and settings (e.g., child care, schools, cinemas, recreation centres) to align with past versions of Health Canada’s policy proposal that were more comprehensive.
The policy should also include brand advertisements (even if no identifiable food is shown or referenced by name). Advertising works to raise awareness of brands and instilling brand loyalty is a commercial interest (Elliot, 2012). Children are explicitly targeted with using a brand logo or mascot without reference to a specific food because this tactic can be influential on children’s purchase requests (Wilking 2011). Restaurants frequently use brand advertisements with missing nutritional information (Potvin Kent et al., 2023) and are likely to continue to take advantage of this policy loophole. - Finally, it is our position that focusing this policy on obesity prevention exacerbates weight bias which contributes to discrimination, oppression and social injustices (ODPH, 2018). Weight bias, stigma and discrimination are independently linked to poorer mental and physical health including for children (Public Health Agency of Canada, 2019). Additionally, it ignores the fact that all children and youth regardless of body size can benefit from improved nutritional intake (Alberga et al., 2018).
As part of ongoing monitoring and evaluation on the impact of the policy, we suggest Health Canada consider using the Healthy Eating Food Index (Brassard et al., 2022) to measure changes in dietary patterns of children (e.g. decreased consumption of salt, sugar and saturated fat and/or improved overall diet quality), which is the overall goal of the policy. The focus on obesity and obesity related metrics (i.e. BMI) should be removed from all aspects of the policy and/or legislation (Bill C-252). Removing the focus on obesity prevention would ensure a healthy public policy and the creation of supportive environments for children.
Children need to be protected from advertising and harmful industry tactics. Moving forward on this federal commitment to begin restricting food advertising will help protect children from manipulative advertising strategies and support families and caregivers. We encourage Health Canada to continue their efforts to expand beyond television and digital media and to include children and youth under 18 years of age.
Thank you for the opportunity to provide our feedback on this very important public health issue and look forward to participating in the next phase of consultation.
Sincerely,
Laura Abbasi, MHSc RD
Co-Chair ODPH Executive
Elizabeth Smith, MPH RD
Past Chair ODPH Executive
CC:
Stephen Lucas, Deputy Minister, Health Canada, stephen.lucas@hc-sc.gc.ca
Pam Aung Thin, Associate Assistant Deputy Minister, Health Canada, pamela.aung-thin@hc-sc.gc.ca Dani Saad, Senior Policy Advisor, Prime Minister’s Office, dani.saad@pmo-cpm.gc.ca
John Broadhead, Dir of Policy, Prime Minister’s Office, john.brodhead@pmo-cpm.gc.ca
Jared Valdes, Sr. Parliamentary Affairs Advisor, Ministry of Health, Jared.Valdes@hc-sc.gc.ca Nathanielle Morin, Policy Advisor, Ministry of Health, nathanielle.morin@hc-sc.gc.ca
Celia Lourenco, Associate Assistant Deputy Minister, Health Products & Food Branch, Health Canada, celia.lourenco@hc-sc.gc.ca
References:
Alberga, A.S.,, McLaren, L., Russell-Mayhew, S., & von Ranson, K.M. (2018). Canadian senate report on obesity: Focusing on individual behaviours versus social determinants of health may promote weight stigma. Journal of Obesity, 2018, 1-7.https://doi.org/10.1155/2018/8645694
Brassard, D., Elvidge Munene, L.A., St-Pierre, S., Guenther, P.M., Kirkpatrick, S.I., Slater, J., Lemieux, S., Jessri, M., Haines, J., Prowse, R., Olstad, D.L., Garriguet, D., Vena, J., Vatanpatast, H., L’Abbe, M.R., & Lamarche, B. (2022). Development of the Healthy Eating Food Index (HEFI)-2019 measuring adherence to Canada’s Food Guide 2019 recommendations on healthy food choices. Appl Physiol Nutr Metab,47, 595-610. https://doi.org/10.1139/apnm-2021-0415
Elliot C., Marketing Foods to Children: Are We Asking the Right Questions? (2012. Childhood Obesity 2012 8:3, 191-194. https://doi.org/10.1089/chi.2012.0013
Haines, J., & Neumark-Sztainer, D. (2006). Prevention of obesity and eating disorders: a consideration of shared risk factors. Health Education Research, 21(6), 770-782. https://doi.org/10.1093/her/cyl094
Hawkes, C. (2004). Marketing Food to Children: the Global Regulatory Environment. World Health Organization. http://nepc.colorado.edu/files/CERU-0405-215-OWI.pdf
Government of Canada. (2023). Policy update on restricting food advertising primarily directed at children:
Overview. Government of Canada. Retrieved June 8. 2023 from
https://www.canada.ca/en/health-canada/services/food-nutrition/healthy-eating-strategy/policy-update-rest ricting-food-advertising-primarily-directed-children.html.
Harris, J.L., Yokum, S., & Fleming-Milici, F. (2021). Hooked on Junk: Emerging Evidence on How Food Marketing Affects Adolescents’ Diets and Long-Term Health. Current Addiction Reports, 8, 19-27. https://doi.org/10.1007/s40429-020-00346-4
Hilbert, A., Pike, K., Goldschmidt, A., Wilfley, D., Fairburn, C., Dohm, F-A, Walsh, T.A., & Weissman, R.S. (2014). Risk factors across the eating disorders. Psychiatry Res, 220(1), 500-506. https://doi.org/10.1016/j.psychres.2014.05.054
Larkin, J., & Rice, C. (2005). Beyond “healthy eating” and “healthy weights”: Harassment and the health curriculum in middle schools. Body Image, 2(3), 219-232. https://doi.org/10.1016/j.bodyim.2005.07.001
Ontario Dietitians in Public Health. (2018). Health and Wellbeing Philosophy and Approach to Weight. https://www.odph.ca/upload/membership/document/2018-06/odph-version-of-health-and-wellbeing-appro ach-final.pdf
Potvin Kent M, Soares Guimarães J, Amson A, Pauzé E, Remedios L, Bagnato M, Pritchard M, Onwo A, Wu D, L’Abbé M, Mulligan C, Vergeer L, Weippert M. (2023). Sex differences in children’s exposure to food and beverage advertisements on broadcast television in four cities in Canada. Health Promot Chronic Dis Prev Can, 43(5), 222-230. https://doi.org/10.24095/hpcdp.43.5.02
Powell, L., Harris J., Fox, T. (2013). Food Marketing Expenditures Aimed at Youth: Putting the Numbers in Context. American Journal of Preventive Medicine, 45(4), 453-461. https://doi.org/10.1016/j.amepre.2013.06.003
Public Health Agency of Canada (2019). Addressing stigma: Towards a more inclusive health system. The Chief Public Health Officer’s Report on the State of Public Health in Canada (Pub: 190383). Health Canada.https://www.canada.ca/content/dam/phac-aspc/documents/corporate/publications/chief-public-he alth-officer-reports-state-public-health-canada/addressing-stigma-what-we-heard/stigma-eng.pdf
Qutteina, Y., De Backer, C., & Smits, T. (2019). Media food marketing and eating outcomes among pre-adolescents and adolescents: A systematic review and meta-analysis. Obesity Reviews, 20(12), 1708-1719. https://doi.org/10.1111/obr.12929
Stice, E., Gau, J,M,, Rohde, P., & Shaw, H. (2017). Risk Factors that Predict Future Onset of Each DSM-5 Eating Disorder: Predictive Specificity in High-Risk Adolescent Females. J Abnorm Psychol, 126(1),
38-51. https://doi.org/10.1037/abn0000219
Truman, E., & Elliot. C. (2019) Identifying food marketing to teenagers: a scoping review; Int J Behav Nutr Phys Act, 16(1), 67-77. https://doi.org/10.1186/s12966-019-0833-2
Wilking, C. (2011). Reining in Pester Power Food and Beverage Marketing. The Public Health Advocacy Institute. https://www.phaionline.org/wp-content/uploads/2011/09/Pester_power.pdf
The Regional Office for Europe. (2018). Evaluating implementation of the WHO Set of Recommendations on the marketing of foods and non-alcoholic beverages to children: Progress, challenges and guidance for next steps in the WHO European Region. World Health Organization. https://apps.who.int/iris/handle/10665/345153
January 30, 2023
Mr. Paul Henry
Council of Ontario Directors of Education, Chair c/o Laura Elliott, Executive Director laura@ontariodirectors.ca
Dr. Eileen de Villa
Council of Ontario Medical Officers of Health, Chair eileen.devilla@toronto.ca
Re: Follow up – Priority and Proactive Steps to Ensure Universal Access to Student Nutrition Programs
Dear Chairs of CODE and COMOH
Ontario Dietitians in Public Health (ODPH) would like to take the opportunity to recognize and congratulate CODE-COMOH on its advocacy and progress in supporting and sustaining Student Nutrition Programs (SNP) in our province. The correspondence with the Premier on January 28, 2021 outlined CODE-COMOH’s support of the priority and proactive steps identified as key to ensuring universal access to SNPs. Research tells us that when properly fed, a child can thrive and thus achieve greater developmental, social, and academic success.
The recommendations made through the CODE-COMOH partnership serve to strengthen provincial SNP. While there has been progress including enabling language in Return to School Plans (2021, 2022) and the posting of the Student Nutrition Program – Nutrition Guidelines (2020 version) on the Ministry of Child, Community and Social Services website, four of the six recommendations have not yet been addressed. They include:
- Ministry of Health to support a unified approach, by creating a free, online SNP specific Food Handler Training and Certification for SNP volunteers across the province.
- Adequate funding for SNPs from both the Ministry of Education and the Ministry of Children, Community and Social Services to enable local school programs to have the benefit of paid coordinators and sufficient funds to purchase food.
- Ministry of Education to include specific infrastructure criteria for capital funding that support a healthy school food environment (e.g. adequate kitchen and storage space and equipment including a designated handwashing sink, additional sink(s) for food preparation, refrigerator(s), freezer(s) and dishwasher); bright, non stigmatizing eating area; and external building features such as transportation access for food deliveries and outdoor lighting to facilitate after hours food preparation).
- Government of Ontario to be a willing partner in a National School Food Program to secure the policy and funding instruments to grow SNP in our province.
Safe food handler certification continues to be an issue for volunteers in schools, with health units approaching requirements differently, and the financial and logistical burden training places on volunteers. A number of fee-for-service Food Handler Certification programs (some virtual) are approved by the Ministry of Health. While these address logistical barriers and show that virtual training is possible, the cost is prohibitive.
Toronto Public Health has created a free, online, SNP-specific food safety training resource. We would like to encourage CODE-COMOH to continue to ask the Ministry of Health (MOH) to collaborate with the Ministry of Children, Community and Social Services (MCCSS) to develop a similar online Food Handler Certification program specifically for Student Nutrition Program coordinators and volunteers in the province.
Adequate funding is also a challenging issue for SNPs. Food costs have increased significantly over the past year and many programs report that they are likely to run out of funding before the end of this school year. Now is the time for additional funding for SNPs so that they can continue to provide nourishing meals and snacks to children and youth until the end of the school year in June. We recommend that CODE-COMOH continue to ask the Government of Ontario to increase their investment in SNPs and support the health and achievement for all our young learners.
ODPH is the independent and official voice of Registered Dietitians working in Ontario’s public health system. As members of the College of Dietitians of Ontario, ODPH’s Registered Dietitians are credible food and nutrition experts, and are also uniquely educated to promote healthy eating at the population-level. ODPH is also a member of the national and provincial Coalition for Healthy School Food, and supports their guiding principles.
We appreciate your commitment to SNPs in Ontario and look forward to working with you, as well as our active community partners, to address these recommendations for SNPs.
Sincerely,
Elizabeth Smith, RD
Co-Chair School Nutrition Workgroup
Luisa Magalhaes, RD
Co-Chair School Nutrition Workgroup
cc:
Dr. Kieran Moore, Chief Medical Officer of Health, Ontario Ministry of Health
Loretta Ryan, Executive Director, Association of Local Public Health Agencies (alPHa)
December 16, 2022
Re: Consultation on building a pan-Canadian school food policy
The Honourable Karina Gould
Minister of Families, Children and Social Development
The Honourable Marie-Claude Bibeau Minister of Agriculture and Agri-Food marie-claude.bibeau@parl.gc.ca
The Honourable Jean-Yves Duclos Minister of Health
Employment and Social Development Canada
EDSC.ALIMENTATION_SCOLAIRE-SCHOOL_FOOD.ESDC@hrsdc-rhdcc.gc.ca
Dear Minister Gould, Minister Bibeau, and Minister Duclos,
Ontario Dietitians in Public Health (ODPH) is the independent and official voice of Registered Dietitians (RDs) working in Ontario’s public health system. ODPH is pleased to have the opportunity to inform the Government of Canada’s process to build a School Food Policy. We are supportive of the efforts to develop this policy and a nutritious meal program with the following considerations and recommendations.
ODPH recognizes household food insecurity as an income-driven problem requiring income-based solutions. Policies that improve the income of vulnerable households are urgently needed to effectively address food insecurity[1].
ODPH agrees with concerns raised in a recent open letter from Food Insecurity Policy Research (PROOF) that “universal, high-quality, and nutritious school food that fits community priorities is important in its own right, but that such programming cannot substitute for dedicated action on income adequacy”[2]. Furthermore, we share their concern that conflating a national school food policy with food insecurity reduction will negatively impact ongoing work at all levels of government on reducing household food insecurity by focusing on income redistribution policies.
There is no evidence that a school food program can alleviate poverty and household food insecurity [2] [3]. Despite this, the press releases, discussion paper and consultation questions have framed school food programs as solutions to “reduce food insecurity and hunger”. This framing fails to realize the very real financial hardship and
material deprivation faced by students and their families experiencing food insecurity that impedes academic achievement and health and well-being.
We also wish to express caution about other language in the consultation document and survey that implies that initial funding may be targeted to programs for “children who need school food the most”. As noted in the consultation discussion document, data from the 2017 Canadian Community Health Survey indicate that over 70% of all Canadian children would benefit from improved access to more nutritious food. Any programs that attempt to reach specific more disadvantaged children and families will not only result in shame and stigma, but it will also fail to reach the expectations of improving academic achievement and child health and well-being [4] [5]. A universally accessible program will reduce inequality, build social connectedness, promote healthy school food environments, support children to develop healthy life-long habits, and foster a sense of community.
While poverty and household food insecurity cannot be solved by school meals, school food programs have other benefits. School food programs can play a role in improving nutritional intake, supporting healthy growth and development, academic success, attendance, education attainment, mental health, and overall well-being [4]. In order to effectively do so, we recommend to:
- emphasize academic and nutritional benefit for all students, providing full meals that are culturally relevant, tasty and nutritious;
- ensure universally accessible programs rather than targeted ones to prevent stigma; programs need to be available and financially accessible to all;
- ensure the policy includes considerations for how school food programs can support improving food literacy including training and educational support for school staff so they can adopt age-appropriate food literacy education strategies and supportive food environments; and
- integrate hands-on food neutral learning opportunities to build practical skills, self-confidence, and make cross-curricular connections.
In addition, ODPH believes that to be fully realized, a national school meal program should be:
- sustainably funded by the federal government along with continued provincial, territorial, municipal, and community funding to expand existing and initiate new programs;
- flexible and locally adapted to reflect the local context of the school and region
- informed by existing programs and relationships between students and their families, as well as support a variety of food service models (breakfast, lunch, before and during the school day);
- committed to Indigenous autonomy and food sovereignty of programs for Indigenous students;
- connected to community economic development by using local and sustainably produced foods, creating jobs for Canadian farmers and food producers as well a staff to implement the programs in schools;
- supported by guidance, accountability measures, and an evaluation framework including national nutritional standards and safeguards to prevent programs from marketing unhealthy/ultra-processed foods and specific products to children and youth;
- equipped with a combination of commercial-compliant school facilities and partnerships with off-site community commercial-standard kitchens, food hubs, and distribution systems to ensure efficient supply, preparation, and delivery of school meals.
Thank you for the opportunity to contribute to this discussion and we look forward to the development and implementation of a Pan-Canadian National School Food Policy.
Sincerely,
Elizabeth Smith, RD
Executive Co-Chair
Co-Chair School Nutrition Workgroup
Mary Ellen Prange, RD
Co-Chair Food Insecurity Workgroup
CC:
The Honourable Patty Hajdu Minister of Indigenous Services patty.hajdu@parl.gc.ca
The Honourable Marc Miller
Minister of Crown-Indigenous Relations
The Honourable Carla Qualtrough
Minister of Employment, Workforce Development and Disability Inclusion
References
- Ontario Dietitians in Public Health. December 2020. Position Statement and Recommendations on Responses to Food Insecurity. https://www.odph.ca/odph-position- statement-on-responses-to-food-insecurity-1
- PROOF. December 9, 2022. Open Letter: Stop headlining the pan-Canadian school food policy as a way to reduce food insecurity among children. https://proof.utoronto.ca/resource/open-letter-on-school-food-policy-consultation/
- Alberta Health Services (2021) School Meal and Snack Programs: A review of the effectiveness of school meal and snack programs on household food insecurity, learning and health. Nutrition Services, Population and Public Health, Calgary , Alberta, Canada https://www.albertahealthservices.ca/assets/info/nutrition/if-nfs-pph-evrev-fullreport- school-meal-snack-programs.pdf
- Coalition for Healthy School Food https://www.healthyschoolfood.ca/the-evidence
- Single Mothers Alliance (2022) A Universal School Food System for BC, SMA Research and Policy Brief, other reference: Research and Policy Brief on Universal School_Food for BC.
