07 Jul 2019

This is a summary of the response - the detailed response can be downloaded in pdf form below. 


  • The BDA welcomes the creation of Public Health Scotland, which is an opportunity to bring together the currently fragmented public health sector in Scotland, provide sector leadership and ensure that public health Including prevention and early detection become higher priorities within local and national government, the NHS and the health and social care system more generally.
  • The BDA believes dietitians and the wider AHP workforce, as a key part of the public health workforce, have a crucial role to play in the functioning of PHS and the delivery of its responsibilities and objectives. This has been outlined most recently in the UK-wide AHP public health strategy, and we expect the new PHS body to reflect this key part of the workforce in its strategies, its leadership and its engagement.
  • The plans outlined within the consultation are positive overall, and we can appreciate the effort that has been made to consider all aspects of the creation of this body. It will not be a quick or simple process, and it is clear that a great more detail is yet to be decided, including remit, organisational structure and leadership. We hope that Scottish Government will continue to engage with all partners beyond this consultation as it takes these ideas forward.
  • We would encourage PHS to be an open, respectful and participatory organisation, which sets a strong culture of openness and inclusivity from the outset and from the top down. It must be a listening and learning organisation and all these aspects should be clearly articulated in its central purpose and remit.
  • We would encourage Scottish Government to consider and apply lessons learned from the creation of similar bodies in other parts of the UK, such as Public Health England and Public Health Wales.
  • We would encourage the creation of a clearer set of outcome-focused responsibilities for PHS, perhaps drawing on those used by Public Health England as an example. Articulating responsibilities in a clear and concise manner improves the accountability of the organisation as a whole.


  • The BDA believes it is vital that PHS has the scope to comment on and drive change in areas much broader than just health and care. It is well established that there are a great many wider determinants of health, from education to poverty, housing to environment. PHS has to be ambitious in its scope and give the remit to intervene in all these areas. It must promote equality and social justice in the widest sense if it is to be successful in its aims of improving the health of the Scottish public.
  • We would encourage Scottish Government to more clearly articulate how it intends to reflect the views of and maintain close ties with local NHS and local government public health teams. We would also urge PHS and Scottish Government to engage closely with all professional bodies with involvement in public health to ensure wide professional input. 
  • While we appreciate the desire to ensure continuity and reduce costs by making use of existing buildings, we hope in the long term that PHS can reflect a Scotland-wide footprint, truly representative of the population served by the new organisation. This should include considerations of how technology can be used to bring PHS staff, partners and the public closer together.
  • Bringing together the functions of Health Protection Scotland, NHS Health Scotland, and Information Services Division will require significant upheaval, and every effort needs to be made to minimise disruption and prevent a loss of expertise or experience from any of those organisations in the transition. This process should not be rushed, and we believe the intention of having the new body functioning by April 2020 is ambitious. We would hope to see a great deal more information about the proposed transition process soon.
  • We are disappointed that there is not more detail regarding funding for the new body. It is encouraging that Scottish government will meet start-up costs, and we agree that funding should follow function. However, we believe Scottish government should commit to additional funding if required, rather than simply relying on transitioning existing pools of funding. We hope a more advanced business case will have been made by the time the organisation comes into being.
  • We would urge Scottish Government to ensure that process of appointment/recruitment for senior executive posts and the PHS board should be open and transparent, and seek to attract as broad a range of candidates as possible. PHS should make every effort to ensure its senior executives and board represent the diversity of people and professions that work in the public health sector, including all health care professions (such as Allied Health Professions).
Consultation Document