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Food Act and ECE - A Classic Failure of Risk Assessment

Food Act and Early Childhood Education Services - A Classic Failure of Risk Assessment

I am a specialist in ECE wellbeing and design with over 30 years Public Health experience and 25 years ECE health and design experience. I'm currently undertaking a PhD with University of Otago Wellington Department of Public Health. I support comments by Peter Reynolds (ECC) and Kathy Wolfe (NZCA) on the Food Act and would like to offer the following view:

The way that Early Childhood Education Services have been treated under the Food Act is a classic failure of Public Health risk assessment. During the past 25 years I have visited about 600 Early Childhood Education Services and investigated about 50 ECE Service gastroenteritis outbreaks. I have also investigated and analysed many food-borne outbreaks from restaurants and other sources. Of the 50 ECE outbreaks only one was related to food, and that was an iced birthday cake brought from home.

There is a very good reason for this. The biggest risk in ECE centres is from contaminated hands, not food. Risks with cooked food usually relate to holding times - keeping food warm too long. ECE centres normally prepare food fresh for each meal, so this is not usually a concern for them. The big risk in ECE centres, with children in nappies and learning toilet hygiene, as well as engaging in messy play with water and play dough, is infection from contaminated hands. These infections are usually viral, and cooking destroys the viruses. This means that it's the "simple snacks" referred to in the MPI online guide, the foods handled without cooking, that are the high risk foods. It's not freshly baked muffins or casseroles that are the risk, it's cut apples, cracker biscuits and food from home. The MPI risk allocation is precisely back to front.

Having said this, there is a big risk of gastroenteritis from ECE centres. As far back as 1998 I estimated the cost of NZ ECE related infections at $20M - $50M a year, and ECE originated outbreaks take down communities, not just ECE centres. The biggest risk relates to hand washing, yet the Ministry of Education (through Ministerial directive) has failed to act on this risk. The regulations for ECE services allocate only one wash hand basin to 15 children. We have known for decades, through experience, that this is completely inadequate for ECE environments, ignoring the logistics of hand washing before meals and the practicalities of other hand washing needs. In most ECE centres hand washing for children is located only in toilet areas, not in activity areas, or even in nappy change areas. Attempts to get this changed in the 2008 regulations were rejected by the Ministry of Education, as the regulatory review was required to be "cost-neutral" without regard to the cost of infections.

I absolutely agree that children's health needs should be respected, but it's so important to ensure that regulatory measures fit the context and actual risks. Inspections required by MPI will serve only to generate an expensive compliance market, but I doubt they will prevent a single infection. By contrast improving the regulations in relation to hand washing facilities is simple, cost-effective and desperately needed. As Kathy Wolfe has said The MPI approach also threatens children's nutrition and quality of life through onerous compliance cost. Food is not an optional add-on in full day childcare, it's essential nutrition and may constitute the major part of a child's diet. For well designed ECE services the kitchen is also the hub, as it might be at home. Fresh baking and hot food is part of the children's quality of life.

Mike Bedford

He Kainga Oranga, University of Otago

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