Why is a mandatory food and drink policy required for SA Health settings?

    Healthy eating contributes significantly to positive health outcomes at an individual and population level; conversely unhealthy eating is the third highest contributing risk factor to the burden of disease in Australia (1). Easy access to nutritious foods and drinks supports the adoption of healthy food choices which play a key role in preventing diet-related diseases and obesity, which costs the Australian health system 27 billion dollars a year.

    In line with the Health Council’s Standards, the Policy reinforces the South Australian public healthcare sector’s leadership role to the community and settings beyond healthcare that healthy food and drink provision is the expected standard in Australian public sector healthcare settings,  and that unhealthy food and drink choices are to be limited. The Policy will ensure that the availability and promotion of food and drink to staff and visitors of South Australian public sector healthcare settings is consistent with the Australian Dietary Guidelines.

     (1) Australian Institute of Health and Welfare (AIHW 2021). Australian Burden of Disease Study 2015: Interactive data on risk factor burden. AIHW, Australian Government. https://www.aihw.gov.au/reports/burden-of-disease/interactive-data-risk-factor-burden/contents/overview, accessed 2 November 2021.


    What are the key differences between the revised Policy and its previous iteration?

    The Policy sets revised standards for food and drink provision in SA Health agencies and Attached Offices in line with the Health Council Standards. These are detailed in Section 5 of The Policy (Policy Requirements). As per the original Policy, RED foods and drinks should be no more than 20% of the foods and drinks displayed.

    Under the revised Policy, noteworthy changes include:

    • a new target requiring the provision of at least 50% GREEN foods and drinks;
    • diet drinks to comprise of no more than 25% of drinks available for sale or provided by any outlet;
    • sugar sweetened beverages are not to be supplied for sale or provision to staff or visitors in healthcare facilities, this is a recommendation of the National Standards and is currently being implemented in other jurisdictions (New South Wales, Queensland, Victoria and Western Australia). See FAQ: What drinks are considered ‘sugar-sweetened beverages’?

    New foods and drinks not permitted for sale or provision to staff and visitors (in addition to alcohol) include:

    • kombucha and other brewed soft drinks (e.g. ginger beer, kefir): these contain small amounts of alcohol up to 1.15% by volume;
    • formulated supplementary sports foods, formulated meal replacements and supplementary foods/drinks (see FAQ What are formulated supplementary sports foods, formulated meal replacements and supplementary foods/drinks?)

    Please refer to Healthy Choices: Food and Drink Classification Guide for South Australia: Updates, differences and rationale for selected categories for more information.

    How are food and drinks classified in the Policy?

    Developed by public health nutrition experts within Wellbeing SA, the revised Food and Drink Classification Guide for South Australia (the Guide) has adopted the Victorian Government’s Healthy Choices: Food and Drink Classification Guide nutrient criteria, with a few modifications. The Policy and Guide applies a traffic light approach to food and drink classification, and classifies foods into three groups based on their nutritional value:

    • GREEN (best choices) - These foods and drinks reflect the five food groups in the Australian Guide to Healthy Eating and are the healthiest choices. Ensure they are always available and displayed prominently. Actively promote and encourage GREEN foods and drinks.
    • AMBER (choose carefully) - These foods and drinks should be selected carefully and consumed in moderation. Do not let AMBER items dominate the menu or options displayed. Do not promote or advertise AMBER items at the expense of GREEN options. Offer healthier options within the AMBER category and avoid large serving sizes.
    • RED (limit) - These foods and drinks reflect discretionary foods and drinks in the Australian Guide to Healthy Eating and should be consumed rarely and in small amounts. Availability and display of RED options should be limited. RED food and drinks should not be promoted or advertised, displayed in prominent areas, supplied at functions or meetings, or used for fundraising purposes

    Why are sugar-sweetened beverages not permitted for sale or provision under the Policy?

    In line with the Healthy food and drink choices in public sector healthcare settings for staff and visitors: goals, principles and recommended nutritional standardssugar-sweetened beverages  are not recommended for sale or provision to staff or visitors in healthcare facilities. This recommendation is currently being successfully implemented in other jurisdictions: New South Wales, Queensland, Western Australia and Victoria, and is now proposed for SA Health.  

    Sugar-sweetened beverages are of low nutritional value and are typically consumed in high quantities. Examples of sugar-sweetened beverages include (by are not limited to): carbonated soft drinks, flavoured mineral waters, ice teas, cordials, energy drinks and sports drinks, and fruit and vegetable drinks with added sugars (flavoured milk drinks are not considered sugar-sweetened beverages as they contain valuable nutrients such as calcium and protein).

    Sugar-sweetened beverages are high in energy (kilojoules or calories) but are low in other nutritional value. Over consumption of sugar-sweetened beverages is common and is associated with increased energy intake and consequently increased risk of unhealthy weight gain and chronic disease (2). 

     Additionally, there is also moderate evidence supporting the relationship between increased consumption of sugars and dental caries (tooth decay) (3).     

    (2) World Health Organization. 2016. ‘Reducing consumption of sugar-sweetened beverages to reduce the risk of childhood overweight and obesity’. Available at: World Health Organisation e-Library (accessed 6 February 2019).

    (3) World Health Organization, 2015. ‘Guideline: Sugars intake for adults and children’. Available at: World Health Organisation - Guideline: Sugars intake for adults and children.


    What drinks are considered ‘sugar-sweetened beverages’?

    Sugar-sweetened beverages include:

    • soft drinks
    • flavoured mineral waters
    • cordials
    • energy drinks (these also contain caffeine)
    • sports drinks
    • fruit and vegetable drinks with added sugar
    • coconut water containing added sugar
    • iced teas containing added sugar

    Note the following products are not included in the sugar-sweetened beverage category:

    • 99% juice with no added sugar (products up to 250ml are AMBER; however, products >250ml are RED)
    • Flavoured milk drinks, as whilst they may contain added sugar, they provide valuable nutrients such as protein and calcium. 
      • Low or reduced-fat flavoured milk (or 2g or less total fat per 100mL), and calcium fortified (at least 100mg per 100mL) flavoured milk alternatives that are equal to or less than 900kJ per serving as sold are GREEN.
      • Low or reduced-fat flavoured milk and flavoured milk alternatives that are between 900-1,600kJ per serving as sold are AMBER.
      • Regular-fat flavoured milk (or more than 2g total fat per 100mL), and flavoured milk alternatives that have less than 100mg calcium per 100mL, and equal to or less than 1,600kJ per serving as sold are AMBER.
      • Flavoured milk and flavoured milk alternatives that are more than 1,600kJ per serving as sold are RED.

    Can healthier foodservices be profitable?

    Yes. Evidence gathered in Victorian health care facilities and other public settings demonstrates that healthier food and retail outlets can be profitable:

    • Central Gippsland Health has implemented the Victorian Government’s Healthy Choices guidelines across its retail sites, vending machines and catering menus. The changes made have resulted in a reduction in food waste, positive feedback and acceptance from staff and visitors, and an increase in retail and vending revenue.
    • Western District Health Service in Victoria was the first health service in Australia to
      1. remove sugary drinks in 2015;
      2. provide a 100% GREEN menu in 2018;
      3. provide 100% GREEN vending machines.
    • In 2020, YMCA Victoria’s ‘everyday pricing change’ initiative demonstrated that decreasing the price of GREEN foods and increasing the price of RED foods can encourage customers to make healthier choices without impacting on sales. These pricing strategies can potentially be applied in health care settings.

    Further examples of successful case studies (including short videos) from Victorian Hospitals and health services and other settings can be found here.

    What are the benefits for the public health care sector in supplying healthier food and drink for staff and visitors?

    The South Australian Government is committed to improving workplace health, safety and wellbeing across South Australia (4). In 2017-18, almost half (49.5%) of all South Australians had at least one chronic condition. Furthermore, in 2019, 97% of working South Australians report at least one chronic disease risk factor with 83% reporting multiple risk factors. In 2018, overweight (including obesity) and all dietary risk factors (combined) were the second and third leading risk factors respectively contributing to total disease burden in Australia (5).  In addition to benefits for the physical and mental health for staff, there are multiple benefits for the public health care sector. Healthier workforce are:

    • three time times more productive;
    • have 50% less injuries; and
    • staff are five times more engaged (6)

    Reviews in some healthcare services demonstrate that consumers in these settings are increasingly demanding healthier food and drink options. Evidence also shows that healthy changes are not adversely impacting sales of food businesses (7). (See FAQ:  Can healthier foodservices still be profitable?)

    (4) The Collaborative Partnership for Workplace Health and Wellbeing in South Australia was established in 2020 to build a more comprehensive and proactive state-wide strategy for workplace health, safety and wellbeing in South Australia. South Australian Government members include Wellbeing SA, SafeWork SA, Office of the Commissioner for Public Sector Employment, and the Department for Innovation and Skills.

    (5) Australian Institute of Health and Welfare 2021. Australian Burden of Disease Study 2018 – Key findings. Cat. no. BOD 30. Canberra: AIHW. Viewed 29 September 2021, https://www.aihw.gov.au/reports/burden-of-disease/burden-of-disease-study-2018-key-findings

    (6) Business Case for Investing in the Health of Workers.

    (7) v Huse O, Blake MR, Brooks R, Corben K and Peeters A. The effect on drink sales of removal of unhealthy drinks from display in a self-service café. Public health nutrition 2016; vol. 19, no. 17, pp. 3142-3145, doi:10.1017/S1368980016002482



    Will the Policy continue as mandatory?

    The Policy will continue as mandatory as it is an existing policy directive, and (as required by the new SA Health Policy Framework) supports the legislative and strategic context within which SA Health operates, namely the Health Care Act (2008), and the South Australian Health and Wellbeing Strategy (2020 – 2025).   

    Where does the Policy apply?

    The Policy applies to all government run food outlets and in all situations where food and drinks are provided to staff, visitors and the general public in SA Health facilities, including: government run cafeterias, cafes, kiosks, canteens, shops and mobile food trolleys, vending machines, event and meeting catering, fundraising initiatives and events, catering for patient or client education programs, and external groups providing catering.

    The Policy does not apply to 

    • food prepared by SA Health facilities for the aged care sector client groups, such as Meals on Wheels or Nursing home recipients or clients attending day activity centres for the frail aged;
    • contracted/privately operated cafes, cafeterias, cafes, kiosks, canteens, and shops.

    Does the Policy apply to food and drinks I bring from home to consume at work?

    No. The Policy does not apply to food or drinks that staff or visitors bring from home for personal consumption.

    Does the Policy apply to inpatient meals?

    No. The Policy does not apply to food and drinks supplied to inpatients, irrespective of whether they are on a special diet or not. Inpatient menus are guided by separate nutritional standards and guidelines.

    What are formulated supplementary sports foods, formulated meal replacements and supplementary foods/drinks?

    Under the Food Standards Code, these products are defined as ‘Special purpose foods’, and are not necessary for the general population.

    • Formulated supplementary sports foods are products that are specifically formulated to assist sports people in achieving specific nutritional or performance goals. These products include high carbohydrate supplements, protein energy supplements, and energy supplements. These products should only be used under medical or dietetic supervision, and are not suitable for children under 15 years of age or pregnant women.
    • Formulated meal replacements and supplementary foods/drinks: These include Formulated meal replacements, formulated supplementary foods, and formulated supplementary food for young children. These are not necessary for the general population.

     A formulated meal replacement means a food for sale that has been specifically formulated as a replacement for one or more meals of the day, but not as a total diet replacement; and is represented as a formulated meal replacement.

    A formulated supplementary food means a food specifically formulated as, and sold on the basis that it is, a supplement to a normal diet to address situations where intakes of energy and nutrients may not be adequate to meet an individual’s requirements.

    A formulated supplementary food for young children means a formulated supplementary food for children aged 1 to 3 years.

    How will the Policy be implemented and monitored?

    As articulated in the draft Policy, Wellbeing SA’s Healthy Food Environments Hub will engage with SA Health sites to provide guidance, support and auditing to facilitate Policy implementation and monitoring.

    Staff responsible for Policy implementation and compliance will need to:

    • Check all food and drink for sale to staff and visitors complies with the Policy by using the digital FoodChecker tool, and/or the Food and Drink Classification Guide.
    • Monitor the Policy compliance indicators outlined in Section 9 of the Policy using the FoodChecker digital tool to assess the percentage of RED and GREEN foods and drinks, and diet drinks on display and menus in retail outlets, and in vending machines, and submit the FoodChecker reports to the Wellbeing SA Healthy Food Environments Hub.
      • There will be a transition period to enable SA Health agencies and attached offices adequate time to make changes to meet the Policy requirements and indicators.

    The Wellbeing SA Healthy Food Environments Hub (the Hub) will engage with SA Health services/agencies to provide guidance and support to ensure that staff responsible for compliance and monitoring know how to use FoodChecker to assess menus and vending machines and conduct their own assessments. The Hub will commence by June 2022.

    The Healthy Food Environments Hub will coordinate and communicate the Policy compliance reporting schedule and summarise the compliance results for SA Health overall. The Healthy Food Environments Hub may also undertake random audits to assist and facilitate Policy monitoring and compliance.

    Who is leading the revision of the Policy?

    Public Health Nutrition experts within Wellbeing SA’s Health Promotion Branch (Prevention and Population Health Directorate) are leading the revision of the Policy. A Healthy Food and Drink Policy Steering Group has also been convened to provide advice to Wellbeing SA on matters relating to the update of the Policy, consisting of nominated LHN stakeholders via SA Health’s Chief Executive’s Council.

    Who can I contact for further information or advice?

    For further information on the consultation process or general questions about the revised draft of the Policy please contact James.Bayliss@sa.gov.au with Healthy Food and Drink Policy Review in the subject matter box.