Mandatory fortification of iodine in bread

/in
Submission to: Food Standards Authority New Zealand
Submission Author: Steffan Browning, Soil & Health Association
Tuesday, September 19, 2006

Below is the Soil & Health NZ submission to FSANZ’ Proposal for Mandatory Fortification of Iodine in bread.

Bar influence by Food Safety Minister Annette King at the October 25 Ministerial Council meeting, folic acid which has already been recommended by FSANZ, will be likely joined by iodine to be included in NZ bread including organic bread.

Annette King can either press her Australian equivalents, state and federal, to call for a review of the FSANZ decision to allow, for example, an exemption for organics from any mandatory fortification, or the Minister can take New Zealand down a different path than the Australians as happened with Country of Origin Labelling. The Minister has the power. Or of course Australian ministers can call for an organic exemption.

Mandatory fortification of any NZ foods has not occured before. All fortification has been voluntary, including the high uptake of iodised salt in the past. This is a serious intrusion into free choice of all consumers and the integrity of NZ organics.

We have been given support by MPs from two parties so far and given opportunity it would be useful to put our concerns to any MPs that you come in contact with, particularly those close to the Labour Government. This is not new legislation it is over to the Minister.

Remember FREE CHOICE and an ORGANIC EXEMPTION.

Thanks
Steffan
Spokes
person

———

Submission to Food Standards Australia New Zealand

Re: PROPOSAL FOR MANDATORY FORTIFICATION WITH IODINE (Proposal P230)

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.

In the event of mandatory fortification of either or both, iodine and folic acid, Soil & Health recommends an exemption for organic foods.

Soil & Health is conscious of the need for good nutritional education and supports strategies that explain the necessity and sources of iodine in diet, and those factors which suppress adequate iodine uptake.

Soil & Health is concerned that other components such as some soy products and fluoride in the contemporary diet may be factors in the rise in iodine deficiency. Organic consumers prefer a solution to the cause, rather than focus on treatment of symptoms.

In the event of need for supplementation, natural products as ingredients are preferred.

Seaweeds are used by some organic consumers with an awareness of the added need for minerals such as iodine, and certified organic kelp – seaweed products exist with that market in mind.

Acknowledging the high level of nutritional and health awareness of organic consumers, in the event of an exemption for organic foods from fortification, monitoring will show any need for increased education or recommendations to that consumer sector.

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.

That said, many pregnant and breastfeeding women in Australia and New Zealand, in the absence of adequate iodine intake or subject to goitrogenic factors, may require daily iodine supplements.

FSANZ states in the draft assessment report that fortification will not be enough to address iodine status shortfalls.

Soil & Health agrees that an education program through the health system, including information on iodine sources and inhibitors is required, with optional supplementation a possibility.

This does not necessitate mass medication and in that event, broader consumer choice than unleavened bread and a few cereals is appropriate. Considering typical diets, the unfortified choices suggested in the Proposal assessment report are not really choice at all.

Soil & Health is aware of small domestic market focused bakeries that would have difficulty complying with the proposed standard for mandatory fortification with iodine. Those bakeries, and also access to markets requiring no added iodine, need to be allowed for in the interests of fair trade. Regulation as recommended so far disadvantages small commercial operations. An exemption for organic foods would reduce the level of commercial disadvantage.

Organic production and processing is based on minimum alteration or addition to food composition. Organic processing standards restrict additives in bread. 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 allows consumer choice and fair trade as long as clear labelling is present.

FSANZ’ Proposal states, ‘Food labeling or promotional claims must be factually correct and not misleading or deceptive under the fair trading legislation of Australia and New Zealand. FSANZ intends to discuss the use of descriptors such as ‘natural food’, and ‘organic foods’ with the

Australian Competition and Consumer Commission and the New Zealand Commerce Commission, to clarify the status of foods using iodised salt with regards to fair trading”

An appropriate descriptor or definition of ‘organic’ produce or goods is likely and appropriately that which has been produced according to either a ‘National’ organic standard, or is organically certified. The 12 month transition period for implementation allows more than sufficient time for that mechanism to be established.

At least three organic certification organisations in New Zealand:
1. Organic Farm NZ Incorporated
2. BioGro Producers and Consumers Council owners of BioGro NZ Certification and BioGro Domestic Organic Certification
3. The Biodynamic Farming and Gardening Association, Demeter certifier in New Zealand, do not agree with mandatory fortification of organic food and in principle agree with an exemption for organic food.

The Soil & Health motto is Healthy Soil , Healthy Food , Healthy People.

Below a paragraph that expresses the principle as presented by one of our prolific members.

“Under genuine organic management the inherent expectation and principle is that the produce grown takes up and produces enough iodine and folic acid to satisfy a person’s need when consuming a balanced organic diet.

While this is not yet necessarily always the case it is the aim of the organic production system to produce ‘whole foods’ in the true sense of the word. We are better off exploring what is required to get acceptable levels in our food crops again and pay the true and fair price for producing quality food.

Giving in to external pressure to fortify foods takes away the only natural option to explore what is required to grow ‘quality’ food and gives producers and wholesalers a cheap and easy way out. It encourages a commodity/quantitative approach (factory farming vs organic farming) and prevents a focus on quality food production. A regulation that encourages fortification encourages poor food production systems!

An exemption would allow the organic producers to continue exploring genetic material and growing methods that deliver ‘genuine’ organic whole foods and will also give consumers a choice”.

Summary

* The Soil and Health Association of New Zealand does not support Mandatory Iodine Fortification.
* Soil & Health supports public education of the need for iodine, sources of iodine and factors that inhibit the uptake of iodine.
* Soil & Health supports informed and fair consumer choice.
* 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.
* Soil & Health and other organic organisations in New Zealand and Australia wish to explore with FSANZ, options for an organic foods exemption from mandatory fortification.

Folic Acid

/in
Submission to: 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

Objectives
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).

Summary

* 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.

GE lucerne / alfalfa

/in
Submission to: Biosecurity New Zealand
Submission Author: Steffan Browning, Soil & Health Association
Sunday, July 30, 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 GE Free environment and diet.

Soil & Health is concerned at the risks of GE contamination to organic production from seed imported into New Zealand and requests that Biosecurity NZ maintains a strong stance to negate that risk. Soil & Health supports the setting up of an effective protocol that will ensure New Zealand gardeners and primary producers do not have to deal with issues of GE contamination.

Organic producers operate with a consumer expectation of 0% GE contamination in their products, and so Soil & Health is in full support of the submission by GE Free in Food and Environment. Organic producers and consumers share many of the issues their conventional counterparts do concerning possible GE contamination, eg market access, liability in the event of contamination, ability to save seed, new weeds, possible health effects, loss of choice.

While supporting GE Free NZ’s position, the Soil & Health Association of NZ also wishes to speak to its position and of the issues significant to organic producers.

 

Sent to:
Arun Siva
Plant Imports
Biosecurity New Zealand
PO Box 2526
Wellington