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Food Standards Authority New Zealand
Monday, July 31, 2006
The Soil & Health Association of New Zealand Inc is 65 years old, and is the largest membership organisation supporting organic food and farming in New Zealand, and as such advocates for a healthy natural diet derived from food produced organically and free from additives.
This submission will look at the issue of fortification in terms of the Policy Guideline and the original discussion options.
Policy Guideline, Fortification of Food, Vitamins & Minerals.
The FSANZ Act 1991 (the Act) Section 10 contains ‘High Order’ Principles
1. (a) – the protection of public health and safety
(b) - provision of adequate information relating to food to enable consumers to make informed choices.
2. (a) - the need for standards to be based on risk analysis using the best available scientific evidence
(c) - the desirability of an efficient internationally competitive food industry.
(d) - the promotion of fair-trading in food.
Options Considering Fortification with Folic Acid as in the Initial Assessment Report 2004
1. Maintenance of the Status quo
2. Extension of Permissions For Voluntary Folate Fortification
3. Mandatory Folate Fortification
4. Increased Health Promotion and Education strategies to increase folate intakes.
The Soil & Health Association supports the education of consumers on healthy diet and nutritional needs. Soil & Health believes that a healthy diet negates the need for fortification and in the absence of quality national education campaigns promoting healthy diet (option 4), The Act Section 10 Objective 1 (a) is not met.
Objective 1 (a) is also not met considering the risks associated with mandatory fortification as outlined in the submission of the ADHD Association and GE Free NZ in food and environment.
Soil & Health shares the concerns outlined in these submissions. Adequate science has not been researched by FSANZ and NZFSA, and interpretation of the science researched does not appear to be impartial or precautionary. Our members do not share the approach of the authorities.
Soil & Health is conscious of the links between environmental toxins and Neural Tube Defect, for example with dioxin, as in the submission of ADHD Association and others, and Objective 2 (a) should ensure that other causal effects on NTD occurrence are taken into account when or before considering a dietary solution.
FSANZ’s Publication; "Mandatory Folic Acid Fortification - A short guide to the development of a food standard for Australia and New Zealand" includes as a question-answer the following;
Are there any potential adverse effects from taking folic acid?
High doses of folic acid are not known to have any adverse effects on healthy individuals. The US and Canada have had mandatory fortification of flour with folic acid since 1998 and have found this to be a successful and effective means of reducing the rate of NTDs.
This answer does not seriously answer the question and shows a bias towards a mandatory fortification outcome. It is known that high doses of folic acid can have adverse effects, and certainly unhealthy individuals appear not to have been considered. The second part of the answer is not an answer to the question. This type of question-answer PR spin does not meet Objective 1 (a) or (b).
The reduction of options to 1) Status quo & 3) Mandatory Fortification also does not meet Objectives 1 (a) (b), & 2 (a).
There has been no comprehensive promotion and education strategies to increase folate intakes (option 4) in New Zealand, and consequently an appropriate NZ study base on which to use or discount that option, the one preferred by several original submitters and Soil & Health.
Soil & Health is conscious of the need for good nutritional education and supports strategies that explain the necessity and sources of folate in diet. (Option 4)
Fortification with any synthetic additive is contrary to the ideals of the consumer base of Soil & Health’s membership, and mandatory fortification will reduce choice for those wanting to avoid additives.
The Act Section 10 Objective 1 (b) will not be met if any particular food or sub group has mandatory fortification.
For example if white bread or whole grain bread or trim milk were used as a vehicle for fortification, then that food group is no longer a choice for those wanting to avoid fortification.
Informed choice may allow a decision away from that food group, but real informed choice would allow a consumer to have fortified white bread or non-fortified white bread for example. This would favour options 1 or 2 and 4. Certainly not 3. However if option 3 was pursued, an exemption for organic foods would allow consumer choice.
The growth in farm based flourmills and Farmers Markets has not been taken into account in the recommendation to use bread flour as a vehicle for folic acid fortification. Small mills will have difficulty in equipping for fortification and this would be a barrier to fair trade as promoted in Objective 2 (d).
With environmental pressure by primary production intensification, being in part driven by downward pricing mechanisms as identified by The Parliamentary Commissioner for the Environment, in the Growing for Good Report, smaller value added, more direct sales based production is to be encouraged. Objective 2 (d) would encourage such.
These mills invariably are involved with whole grains which have not had the natural folate removed as in the more refined flours, meeting Objectives 1 (a), 2 (d), and fit well into Option 4.
Organic processing standards restrict additives in bread and do not permit the addition of synthetic vitamins. BioGro for example would have to change its standard to something less than consumer expectations if mandatory fortification was introduced.
The current voluntary fortification regime (Option 1) allows consumer choice and fair trade, which could largely remain with Option 2 as long as clear labelling was present.
Organic production and processing is based on minimum alteration or addition to food composition. Pre-mixes for bread have been suggested as an alternative vehicle for fortification, by which some organic bread may be excluded, increasing choice, depending on the bread type/s chosen. However this still is contrary to the expectation of organic consumers, as represented by Soil & Health, that organic food does not have synthetic additives.
With significant growth in organic trade internationally and the New Zealand Organic sectors aim at $1 billion value by 2013, it can be expected that growth in exports of organic flour and baked products from ‘Clean Green NZ’ will increase. There are international variations to acceptance of additives such as folate in organic products, generally based on the domestic market in the importing country, and of course as a trade barrier.
An exemption for organic products from any mandatory folic acid fortification will give New Zealand and Australia’s value added growth industry greater options for trade. The point of difference marketing benefit meets Objective 2 (c & d).
* The Soil and Health Association of New Zealand does not support Mandatory Folic Acid Fortification.
* Soil & Health supports an Option 4 educative approach to health and nutrition.
* Soil & Health shares the concerns expressed in the submissions of ADHD Association, and GE Free NZ in food and environment.
* Soil & Health supports the submission of Organics Aotearoa New Zealand to which it is a party.
* In the event of FSANZ choosing to pursue a Mandatory Fortification regime, Soil & Health requests that an exemption be made for Certified Organic producers and processors.