Official Letter available here
The Malta Association of Public Health Medicine (MAPHM) is in broad agreement
with the proposed agricultural policy and strongly believes that sustainable
agriculture has a key role to play in the maintenance and promotion of human
health, particularly through the promotion of consumption of local fruit, vegetables,
legumes, nuts, seeds and other plant produce. However, the policy focuses on
economic profitability of farming rather than placing people and the population’s
health and dietary needs at the centre of the policy.
While MAPHM understands that the farming sector in Malta is fragile and needs to
be supported in order to thrive, the excessive focus on meat and dairy products
apparent throughout the policy is discouraging, given the clear scientific evidence
favouring a reduction in meat intake at population level in order to maximise health
gains, and the shift away from meat consumption in developed countries for
environmental reasons. This is especially the case in Malta where industrial farming
is not only too intensive for the limited area of land available for agricultural
pursuits, but is also generally harmful to health in general (due to various hormone
disruptors and antibiotic practices prevalent in the industry) – and thus should not
Policy should not be driven by farmer’s needs but by people’s needs.
The lack of acknowledgement that animal husbandry is primarily responsible for
antimicrobial resistance (AMR) is a glaring omission in the policy document. There is
worldwide alarm at the rising rate of antimicrobial resistance and how this threatens
human health, hence strong disincentives that discourage or ban antibiotic use
should be a cornerstone of the agriculture policy. Given the importance given to
AMR during the Malta’s presidency of the EU, this gap is puzzling and should be
Food derived from plants (i.e. vegetables and fruits, cereals and grains, legumes,
nuts and seeds)
MAPHM noted with concern the report that local vegetable production is
decreasing, despite the concerted effort worldwide to shift away from a meat-based
diet towards a nutritionally balanced diet high in vegetables, cereal grains, legumes
and fruit in order to promote human health. Maltese national dietary guidelines
recommend that the bulk of one’s diet should consist of food derived from plants.
Increased vegetable and legume production is urgently required to reduce prices and
increase their consumption – this is particularly important given the current
sociocultural context where healthy food is perceived to be expensive. Priority
support should be given to plant production, rather than animal husbandry, and this
should be made clear in the policy document.
Meat and dairy production
Statements such as “the market could easily sustain a much greater production of
local fresh beef if this were competitive in price and in quality. Thus, it is imperative
to research this issue properly and establish which constraints have so far tethered
beef production to a status of by-product.” run counter to the worldwide drive to
shift away from energy-and water-intensive animal husbandry and towards
production of plant-based food. While recognising that a balance needs to be
reached between promoting human health through vegetable and fruit production
in order to lower prices and increase their consumption, and supporting existing
animal husbandry businesses in Malta, economic gain and profitability cannot and
should not justify increased investment in the latter sector. Animal husbandry in
general also increases local carbon and methane emissions, which runs counter to
our COP21 (Paris Agreement) climate obligations.
As outlined above, there is an overall impression of excessive support proposed for
energy-and-water-intensive animal husbandry, including cattle/swine meat
production and dairy production. This is problematic, given current and future
forecast water scarcity in Malta. The promotion of Hydroponics could go a long way
towards encouraging water conservation, since it uses 50% – 90% less water for crop
production compared to more traditional methods.
Environmental and climate change measures
The MAPHM agrees with concerns around environmental degradation and climate
change, and strongly supports the measures being proposed, particularly the
creation of a circular economy.
Beekeeping initiatives, wild thyme propagation efforts and, most importantly,
measures to control pesticide use that collectively promote a strong and healthy bee
population should be supported.
Given Malta’s urban sprawl and ever-decreasing land area available for cultivation,
initiatives such as insect protein farming and hydro/aquaponics in urban settings
should be more actively supported. In addition to promoting diversification of
produce, such initiatives are also much less water-intensive than traditional farming
method. The comment that such initiatives may have been submitted with the intent
to bypass the policy in order to gain structures for recreational purposes can be
easily countered by ensuring that only brownfield space in disturbed urban settings
is used for such initiatives.