Ofsted Better Inspection for All consultation response

Children's Food Campaign's Submission to Ofsted's Better Inspection for All consultation

Submitted: 5 December 2014

Q1 Do you agree or disagree with the new common inspection framework for maintained schools, academies, further education and skills providers non-association independent schools and registered early year’s settings from September 2015?

We are pleased that from September 2015, the new common framework will look at standards across all schools in England.  Our campaign and research highlighted the anomaly in regulation whereby some academies and free schools are not required to meet the school food standards.  The School Food Plan addressed this issue by working with the Department for Education to make all new academies subject to the regulation, but this still leaves over 4000 schools that are exempt. The new common inspection framework will include these exempt schools so at least they will be assessed on how well they promote healthy eating (Point 22).

We also note there is a proportion of schools for which this new framework may not apply due to their status as “Outstanding”, which exempts them from inspection. Though a lower priority than other schools, which will understandably need more attention and resources from Ofsted, it is important to ensure all schools are reviewed under this new proposed framework.

We feel it is necessary that Ofsted is mindful of the need for expertise on wellness amongst HMIs, and for training to be offered to HMIs or appropriate expertise commissioned to address the lack thereof, and to support inspections in identifying best practice and areas of improvement in this area.

We believe that Ofsted should include the word ‘wellbeing’ in Section 12 and Section 16, Point 3 of the Four Grade Judgement, as we feel this is a glaring omission from the draft framework which risks side-lining the importance of children’s wellbeing in inspections. 

Q2 Do you agree or disagree with the proposed effectiveness of leadership and management Judgement?

From January 2015, school food standards will be mandatory in all local authority maintained schools and academies and free schools established before 2010 and after June 2014. School governors are responsible for ensuring that these standards are met and the Department for Education has produced guidance to support governors. Therefore we hope that under Point 19: make sure that arrangements to protect children, young people and learners meet all statutory requirements’ inspectors will receive guidance and training on how to check that governors have met statutory requirements on school food.

There are two further statutory requirements that must be met by schools that relate to school food. The Children’s & Families Act 2014[1] introduces a duty on schools to support children with medical conditions and EU Food Information for Consumers Regulation requires the labeling of 14 specific allergens.[2] These two statutory requirements are significant as they allow children with allergies to enjoy a school meal with confidence.

We believe that leadership measures should include those in non-teaching roles who work within the school setting, such as business managers, school cooks and school governors, thus placing significant value on the contribution of non-teaching staff to the education and wellbeing of children and young people within the school setting.

We feel that any written feedback provided on leadership should include feedback for those within non-teaching roles, especially school cooks, thereby supporting the whole school approach to good nutrition and wellbeing.  

We further believe that Ofsted should include the words ‘and wellbeing’ into Section 19, Point 8 - specifically the sentence which currently reads: “make sure that arrangements to protect children, young people and learners meet all statutory requirements and promote their welfare”.

Q4 Do you agree or disagree with the proposed personal development, behaviour and welfare judgement?

We are delighted to see that under Point 22 inspectors will be asked to make a judgement on whether schools are successfully promoting or supporting children’s “knowledge of how to keep themselves healthy, including through exercising and healthy eating”. We hope that within the guidance, inspectors will be given a definition of ‘healthy eating’ and include in this definition standards relating to sustainability such as lower greenhouse gas or higher welfare.  In schools, a healthy food is defined by the school food standards, therefore adherence to the standards would show that the school is promoting healthy eating.[3]

However, the School Food Plan (which had cross-party backing at its launch and is supported by the Department for Education and Public Health England) worked with Ofsted to agree wording on school food to be added to the subsidiary guidance for inspectors from September 2013.  Point 76 of the guidance stated:

Inspectors should consider the food on offer at the school and atmosphere of the school canteen. They should:

• consider how lunch time and the dining space contribute to good behaviour and the culture in the school, including by spending time in the lunch hall, and
• ask school leaders how they help to ensure a healthy lifestyle for their children and, specifically, whether their dietary needs have been considered.

This important wording was removed in August 2014 and should be reinstated.

Under the proposed new framework, inspectors are at no point required to spend time in the school dining hall. The School Food Plan highlighted the importance of taking a ‘whole school approach’ to good food and pupil health. By considering “how lunch time and the dining space contribute to good behaviour and the culture in the school, including by spending time in the lunch hall,” Ofsted inspectors would have been driving positive change and reinforcing the whole school approach suggested by the School Food Plan.

We therefore recommend that that in addition to inspectors making a judgement on children’s and learners’ “knowledge of how to keep themselves healthy, including through exercising and healthy eating”, the inspection framework should require that inspectors spend time in the school dining hall and consider how lunch time and the dining space contribute to the culture of the school. A healthy food culture in schools can support both health and educational attainment; it is therefore important that this criterion is included in the new framework for inspection.

We feel that the omission of “wellbeing”, as defined under the Children and Families Act (2014), should be included in this section, as previously mentioned above.

We believe that the following points should also be added to the inspection criteria:

• That the school has robust policies which support pupils in relation to good diet, physical exercise, mental and emotional wellbeing, and which can be observed in the practice of life skills, such as cookery.

• That pupils have access to healthy environments which promote good food and wellbeing practices, particularly in the communal school areas, such as the school dining room, where behaviour, relationships and ethos can be observed.

• That pupils are consulted on welfare and wellbeing provision alongside other matters which are important to them, such as school food and extracurricular activities, through their school councils etc. 

Q12 Do you have any other comments about this consultation?

We feel that there is a clear omission of school food and pupil wellbeing within this proposed framework, particularly given the current climate around this policy area, such as with the Government’s investment in pupil premium for the most disadvantaged, the roll-out of Universal Infant Free School Meals and the introduction of the School Food Plan, and believe both should be featured clearly within the new framework.

 

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[1] http://www.legislation.gov.uk/ukpga/2014/6/section/100/enacted

[2] http://ec.europa.eu/food/food/labellingnutrition/foodlabelling/proposed_legislation_en.htm

[3] www.schoolfoodplan.com/wp-content/uploads/2014/06/School-Food-Standards-Guidance-FINAL-V1c-140617.pdf