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.
Submissions Against GE Brassicas
/in SubmissionsDec 8, 2006
Dear Members
Re: GE Brassica Field Trial
Crop & Food Research has applied to ERMA (Environmental Risk Management Authority) to spend taxpayers’ money on a 10-year field trial of genetically engineered brassicas: specifically cabbage, broccoli, cauliflower and forage kale. Plants would have genes spliced from bacteria and viruses, including ‘Bt’ (Bacillus thuringiensis), in order to kill cabbage white butterfly and diamond backed moth.
Soil and Health is supporting Organic Aotearoa New Zealand’s substantive submission opposing the trial, and putting in our own submission. We encourage members to write submissions to ERMA opposing the field trial.
SUBMISSIONS ARE DUE BY TUES 12 DECEMBER 2006
You should quote Crop and Food Research’s application GMF06001. Submit in writing to ERMA NZ, PO Box 131, Wellington, 6140, by fax to ERMA NZ, 04 914 0433, or online at www.ermanz.govt.nz. Include name, contact details, signature, the date, reasons for your submission, and the decision you seek.
As follows are some points you may wish to use, and websites for further information.
www.gefree.org.nz
www.giantexperiment.co.nz
www.GEinfo.org.nz
www.i-sis.org.uk
www.gmwatch.org
Thanks for considering this! We hope our submissions will lead to a rejection of the trial and protection of organic and GE-free crops and food. Let’s work together towards an Organic 2020.
Mike Palmers, Co-Chair
——-
I/We strongly urge ERMA to decline this application for the following reasons:
Environmental Risks and Lack of Long-term Sustainability
* There is no point approving this field trial for genetically engineered brassicas unless they are to eventually be grown commercially. However, if grown commercially, these GE brassicas will cause GE contamination of other brassica crops and honey, and destroy New Zealand’s clean, green image.
* Target insect pests will become resistant to crops genetically engineered with Bacillus thuringiensis (Bt), as has happened overseas.
* Insect resistance could result in more use of toxic sprays to control pests.
* Brassica pollen is readilty spread by insects, and GE brassicas would cross easily with dozens of wild and cultivated cousins.
* Any short-lived benefits before white cabbage butterfly and diamond backed moth are resistant comes at the cost of irreversible GE contamination.
Removal of Farmer Choice
* Insect resistance to Bt-engineered plants will result in the loss of a safe and important tool (natural Bt) for organic and conventional farmers.
* Contamination will remove farmer choice to grow GE-free food.
* If commercially grown, GE brassicas will contaminate GE-free crops, potentially making farmers liable for having illegal GE plants.
Removal of Consumer Choice
* Contamination will remove people’s right to buy and grow GE-free food. New Zealanders have stated clearly and often that they want to protect the availability of safe, natural and organic food.
Loss of Markets
* GE contamination – even trace levels – threatens our economy because of loss of exports to overseas markets, which have rejected GE foods.
* This field trial would tarnish New Zealand’s clean green image and reputation for producing safe and natural foods.
Liability
* Current liability laws are not strict enough to hold GE experimenters financially accountable for unintended or unforseen adverse impacts on farmers, consumers or the environment.
* Communities face paying (through rates, taxes or indirectly) the costs of clean-up, compensation and dealing with insect pests that have become resistant.
Use of Public Money
* Public money should not be spent on GE products, which the majority of New Zealanders (67% in recent surveys) do not want.
* GE-free methods of pest control in brassicas are already being practiced in organic systems. Public funds should be used for further research into sustainable, organic spest reduction methods.
Potential Negative Health Impacts
* Evidence of health impacts from Bt crops on people and animals must be fully investigated before the application is even considered.
* GE plants containing antibiotic-resistant marker genes can add to existing problems in controlling disease.
* Some forms of Bt toxins have been identified as potential allergens in humans.
Lack of Information from Applicant
* ERMA should not approve this field trial because the precise combination of plant, bacteria, virus and other genes is not known.
* Blanket approval cannot be justified, as different re-combinations may present different risks and therefore should be considered on a case-by-case basis.
* Independent scientists cannot provide expert advice on proper risk-management without knowing the gene-profile of the GE plants created.
Decision Sought
The risks of this field trial far outweigh any potential benefits. For all the above reasons, this field trial application must be rejected.
NZ doesn’t need dirty sweet corn
/in GE, Media Releases, Organic Community, OrganicsFollowing the latest GE seed border incursion, the Soil and Health Association of New Zealand is once again calling for a stop to imports of sweet corn and maize seed, until absolute certainty of nil GE contamination is achieved.
‘Clean green New Zealand farmers deserve better protection by Biosecurity NZ, and those affected by dirty seed need fast assurance of fair compensation, just as the wider community needs assurance that the contaminated seed and young plants will be destroyed,’ said Soil & Health spokesperson Steffan Browning,
‘It is increasingly frustrating and disturbing having repeated border incursions of dirty seed. If some in MAF Biosecurity are letting their team and the rest of New Zealand down, and zero tolerance cannot be assured, then MAF must encourage further development of New Zealand’s own clean seed industry’.
‘Self sufficiency in clean seed can protect New Zealand’s clean green reputation as a GE Free producer’.
Prime Minister Helen Clark’s call for New Zealand to be the world’s first truly sustainable nation included the statement: “I want sustainability to be central to New Zealand’s unique national identity….”
‘Our unique national identity includes Nuclear Free and GE Free for most kiwis, and these repeated incursions tarnish that identity’, said Mr Browning.
‘Contrary to Dr William Rolleston of Life Sciences Network, who doesn’t mind a little contamination, the large majority of New Zealanders have consistently indicated they don’t want GE contaminated food or have GE crops grown.’
‘Organic growers and consumers who have sights on an Organic 2020 don’t need Life Sciences contaminated thinking. We want food and crops that our consumers and markets appreciate, not dirty low value commodities’.
Soil & Health is also concerned that possible dilution of contaminated parent lines of seed may be allowing intentional contamination into New Zealand.
Such concerns, according to Mr Browning, further fuel the need to develop New Zealand’s seed industry as part of a Clean Green, GE Free, Nuclear Free national identity.
Organic Farming Offsets Food Miles
/in Food, GE, Media Releases, OrganicsOrganic farming offers solutions to the current food miles debate. Not only that, but it leads the way in low energy farming, and will help New Zealand reach its carbon neutral targets, according to the Soil & Health Association.
“Consumers are rightly becoming concerned about ‘food miles’, because the fossil fuel used in transporting food contributes to climate change through CO2 emissions,” says Soil and Health spokesperson, Steffan Browning. “However, New Zealand and overseas reports all show that organic production uses much less energy than conventional farming.”
Other bonuses are that organic production is the preferred consumer choice, it increases carbon sequestration and has much lower externalised environmental costs.
The Lincoln University report, Food Miles – Comparative Energy/Emissions Performance of New Zealand’s Agriculture Industry, by Saunders, Barber and Taylor, argues that with food miles, it is not just the distance that should be assessed but the total energy used, from production to plate, including transport.
The report, released in July, shows that New Zealand products use less energy, and have lower emissions per tonne of product delivered to the UK, than UK products do. It quotes a report by Defra (UK Department of Environment, Food and Rural Affairs): “…it can be more sustainable to import organic food into the UK than to grow non-organic food in the UK.”
The Lincoln report quotes Swedish research over 23 dairy farms, “…. these tests showed that the total energy use of organic dairy farms per unit of production was significantly less than each of the two conventional types of farms, …. A similar picture emerged for CO2 emissions.”
Soil & Health noted from the Lincoln report, that environmental costs of current farming systems when added to consumer prices are about 4 times that of the organic equivalent cost.
The Lincoln report also quoted a list of strategies for the consumer to avoid food miles when making purchases, provided by the UK Women’s Environmental Network. Their top five most ethical choices are (in order):
1. Organic, local and seasonal
2. Local
3. Fairtrade and organic
4. Organic
5. Fairtrade
The Soil & Health Association of NZ shares these principles as part of its Organic 2020 vision, but can see a place for sustainably produced organic goods from New Zealand being efficiently shipped to complement shortfalls in local British product.
While the Lincoln study did not consider carbon sequestration, American studies show that organic methods are far more effective than conventional methods at taking CO2 from the atmosphere and fixing it as beneficial organic matter in the soil. The 23-year Rodale Institute study calculated that if 10,000 mid sized U.S. farms converted to organic production, it would be equivalent to taking 1,174,400 cars off the road, or not driving 14.62 billion miles.
Former British Environment Minister Michael Meacher told a 2004 Soil Association conference in Edinburgh, that the government must boost organics to help Britain meet its Kyoto targets. He also highlighted the Rodale Institute research, which also found that soluble nitrogen fertilisers in conventional farming destroyed soil biota that trap greenhouse gases.
The Soil & Health Association of NZ sees continued government support for the organic sector as an important solution to food miles arguments, and to the Prime Minister’s aim of a truly sustainable New Zealand.
Brassica trial crazy
/in GM, Health, Media Releases, OrganicsCrop & Food’s intended GE Brassica field trial is even crazier than their existing GE onion trial, according to Soil & Health, and move in the opposite direction to the Prime Ministers sustainability vision.
Potential key drawbacks are:
1. Early resistance by pests
2. Fast spread of GE brassicas and interbreeding contamination
3. Contamination of GMO free crops
4. Loss of markets through contamination
5. Loss of markets through NZ’s Clean Green image loss
6. Human and animal health risks
The use of Bacillus thuringiensis (Bt) in genetically engineered crops has shown an early build of resistance in pest insects, resulting in the loss of a safe and important tool for many farmers.
Organic producers are able to use Bt and careful use has maintained its benefit without pest resistance. Organic and GMO free producers markets demand products free of GMO contamination.
The current use of Bt poses little risk to humans or stock as the toxin only occurs in the pest caterpillar’s gut.
GMO Bt poses risks as the toxin is in every cell of the GM crop including that eaten by consumers and also the pollen and roots.
Brassica pollen travels large distances, the seeds are small and brassicas cross easily, with hundreds of variants in existence. GMO brassicas will be one of the riskiest and dirtiest GMO crops possible.
The use of GMO crops flies in the face of Prime Minister Helen Clark’s vision of New Zealand being in the vanguard of sustainability, with New Zealand being the first truly sustainable nation, said Soil & Health spokesperson Steffan Browning.
A truly sustainable nation will have no part in GM crops or stock.
Crop & Food’s is a State Owned Enterprise whose persistence with experimenting with many vegetable and flower crops that are creeping into field trial applications is contrary to New Zealand’s Clean Green image.
Crop & Food are experimenting with a number of brassicas and also tomatoes, cucurbits, onions, asparagus, orchids, cyclamen, snapdragons, pelargoniums, violas and others in their laboratories. A lot more than most are aware of, according to Browning.
“It is time to stop these experiments if there is no serious expectation to grow in New Zealand. New Zealanders have clearly stated that GM crops are not wanted.”
PMs Sustainability Vision most important statement for some time
/in Media Releases, Organic Community, OrganicsThe Soil & Health Association congratulates Prime Minister Helen Clark for the vision of New Zealand being the world’s first truly sustainable nation.
Yesterday at the Labour Party Conference the Prime Minister asked, “Why shouldn’t New Zealand aim to be the first country which is truly sustainable… I believe that sustainability will be a core value in 21st century social democracy…
* I want New Zealand to be in the vanguard of making it happen – for our own sakes, and for the sake of our planet.
* I want sustainability to be central to New Zealand’s unique national identity….”
“This is the most important and exciting statement for New Zealand’s future for some time from that level,” said Steffan Browning, Soil & Health spokesperson, “New Zealanders will welcome a vision of a truly clean green country.”
This significant vision fits with the Soil & Health vision of an Organic 2020, where by the year 2020 most of New Zealand’s production is certified organic and the remainder is in conversion to organic.
With milestones towards an Organic 2020 being difficult to achieve until recently, such vision from the Prime Minister is encouraging. It comes on the back of last year’s Government funding support for sector group Organics Aotearoa New Zealand, and the Green Party initiated funding for an Organics Advisory Service.
“Organic milestones will be more easily attained with a sustainability vision coming from the Prime Minister,” said Mr Browning.
“Organic production leads the way in sustainable methods of primary production, and a visionary Prime Minister will hopefully do all in her power to ensure the organic sector, as a vanguard of sustainability, can maintain its development into the future.”
Prime Minister Helen Clark finished, “Our country is special, and our people are special.” Soil & Health would add its motto ‘Healthy Soil, Healthy Food, Healthy People.”
An organic exemption from folic? Could be.
/in Food, Health, Media Releases, Organic CommunityThe Soil & Health Association is thrilled that there is to be a review of the decision to mandatorily fortify bread with folic acid.
The review allows further opportunity for an exemption from the fortification proposal for organic breads to be considered.
“Soil & Health is grateful that New Zealand Food Safety Minister Annette King has allowed this further opportunity”, said Soil & Health spokesperson Steffan Browning.
Soil & Health and other organic organisations on both sides of the Tasman have called for their Food Standards Ministers to allow consumer choice through an organic exemption.
“Such an exemption would allow for organic bread to be as organic consumers expect,” said Mr Browning, “that is, bread without any artificial additives.”
The Australia and New Zealand Food Regulation Ministerial Council meeting held in Sydney, where NZ’s Food Safety Minister met with 9 Australian ministers yesterday, reinforced its commitment to mandatory fortification, with the review over 6 months.
The Ministers’ joint communiqué included,
“Food Standards Australia New Zealand have been asked to review the proposed standard due to technical considerations with the implementation of the standard, and compliance issues, within six months.”
Soil & Health is aware of many letters to NZ Minister Annette King from organic consumers. Australian organic consumers and organisations recently also called on Australian Ministers to consider an exemption.
Members of Parliament from a range of parties also supported the Soil & Health position, as did New Zealand Consumers Institute, with Organics Aotearoa New Zealand leading an organic sector delegation to a recent meeting with Annette King.
“An organic exemption from mandatory fortification with folic acid would show acknowledgement of the rights of organic consumers to continue selecting their food according to their needs, and for organic millers and bakers to remain in business”, said Mr Browning.
An exemption for organic bread will give all consumers a choice of a fortification free product while still accessing a healthy option.
Let Us Spray
/in Food, Health, Media Releases, Organic CommunityAs further exposed in Monday’s TV3 Let Us Spray documentary, the clear links between 2-4 5 T and 2-4-D manufacture and use, and spina bifida and other tragic deformities, show a need for a quick conversion by mainstream agriculture to organic production.
Tomorrow Food Safety Minister Annette King considers, with her Australian counterparts, another chemical approach to a minimal solution for spina bifidas often resulting from widespread toxins in food and environment and New Zealand’s deteriorating nutritional health status.
For many decades a persistent head in the sand approach to the chemical tools of the day has been taken, and those standing up for the environment and health have been ridiculed.
Soil & Health can recall Dows PR magazine, with then Prime Minister Keith Holyoake parading through Dow Chemicals New Plymouth factory extolling its virtues. Elsewhere in the magazine was a parody of Silent Spring author Rachel Carson.
Rachel Carson, an early advocate against agrichemical use and its effects on the environment was ridiculed at the time, but her particular focus and that of Dows, DDT, was soon to be proven as a persistent deadly pollutant.
“Now with dioxin laced 2-4-5-T and 2-4D clearly identified as a mutagen, other chemicals such as the fungicide benlate, also identified as a mutagen, should be withdrawn from use and cover ups surrounding adverse effects need to stop”, said Soil & Health spokesperson Steffan Browning.
Embracing a vision of truly sustainable primary production and more natural health care solutions will reduce such tragedies as experienced throughout New Zealand through the use of 2-4-5-T, 2-4D, DDT, benlate and other current agrichemicals.
Soil & Health calls for urgent assistance for primary producers to find alternatives to the widespread use of agrichemicals. Current agrichemicals include many with known mutagenic, endocrine disrupting and carcinogenic properties.
“This is not sustainable when the health effects, often carried by future generations, are taken into account. Nor is it sustainable as our markets look for cleaner and cleaner products”, said Steffan Browning
The Soil & Health Association sees a cruel link between intended mass medication of 4 million people with folic acid (synthetic folate) to reduce the effects of only 8 spina bifida pregnancies and the plight of those others exposed to dioxin contaminated herbicides.
Synthetic folic acid is intended to be added to all bread as a partial remedy to New Zealand’s Neural Tube Defect (NTD) plight. NTDs mostly present as spina bifida as shown on TV3’s documentary.
Spina bifida occurrence is greatly reduced by adequate folate levels around conception and early pregnancy.
The use of the chemical folic acid as an alternative to good diet with good natural folate levels is a poor sop to the advocates for spina bifida sufferers who have for many years called for Government intervention to the spina bifida scourge.
Rather than educate of the risks of agrichemical exposure and how to get spina bifida limiting natural folate, through a good diet, the market sensitive producers, agrichemical suppliers and Government have decided on a keep it quiet approach and instead the whole population is to be consuming another synthetic compound, folic acid.
This government, that has been complicit with cover-ups of the link between the widespread use of toxins in Godzone and human health, is now considering mass medication with synthetic folic acid, as some form of sop to those affected by previous widespread agrichemical use.
An average of only 8 out of ~70 NTD pregnancies will benefit from the mass medication of 4 million, and yet an educational program in Western Australia that included nutritional information and voluntary supplements achieved a 30% reduction in NTDs.
A program similar to that tried in Western Australia would mean 21 NTD pregnancies benefiting here in New Zealand, and would have widespread other health benefits, as such a program could also cover broader nutritional issues, and allow personal responsibility and consumer choice.
Synthetic folic acid is not likely to be on the same health scale as dioxin contaminated herbicides, yet, as with the supposed benefit and repeated assurances of safety of those earlier herbicides, a mass medication is now intended without even the more obvious health uncertainties of high folic acid intakes being deeply explored.
This economic decision to only benefit 8 pregnancies, while protecting bad industrial and agricultural practice and in turn using mass medication with synthetics, shows more of the same approach. A blind faith in chemical solutions to environmental and human health. It is time for a better vision for New Zealand, according to Soil & Health.
Soil & Health has long campaigned against toxins in the environment and food chain and is seeking an exemption for organic producers and consumers from any mass chemical fortification.
“Clean Green New Zealand needs an urgent vision of an Organic 2020, not the current chemical patches to chemical misadventure approach”, said Steffan Browning.
Consumer Choice with Folic Acid
/in Food, Media Releases, Organic Community, OrganicsNever before have New Zealanders’ been subject to mandatory fortification of their food. Never before have New Zealand’s organic bakers been faced with having to add synthetic additives to their bread. Organic products must have an exemption from mandatory fortification.
Food Standards Australia New Zealand (FSANZ) have decided to mandatorily fortify bread with folic acid and are expected to make a similar decision for iodine. Both are outside organic consumer expectations.
Food Safety Minister Annette King, meeting with fellow Australian Ministers, can either agree with the decision at the Food Standards Ministerial Council meeting in Canberra, October 25, or seek a review of the decision.
Soil & Health, and the organic bakers and flour millers listed below, call on the Hon. Annette King to allow New Zealand consumers an organic choice.
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.
Organic bakers, farmers and millers using natural growing, and baking techniques and ingredients seek an exemption from mandatory fortification of bread with folic acid and iodine.
Organic bakers do not use synthetic additives, and such additives are completely against the principles of organic production.
Small mills will have difficulty in equipping for fortification and this would be a barrier to fair trade. Some mills may have to close down.
Organic bakers take pride in the natural quality of their products.
Organic consumers seek out organic products because of the way they are produced and the absence of synthetic ingredients. Many organic breads are whole grain, maintaining natural folate.
Organic consumers are most often health conscious and many use specific dietary items to address known nutritional gaps.
The Food Standards Australia New Zealand (FSANZ) decision for mandatory fortification with folic acid and the proposal to fortify with either potassium/sodium iodate/iodide is without precedent in New Zealand. No other fortification of food has ever been mandatory in New Zealand.
Consumers have indicated in surveys that they do not want mandatory fortification. In a New Zealand Food Safety Authority (NZFSA) 2005 study, 84% thought mandatory fortification should not apply. Over 75% of the study group emphasised consumer choice is very important.
The only consumer choice granted by FSANZ is unleavened breads and unfortified flour. This is not really choice for most consumers.
An exemption for organic bread will give all consumers a choice of a fortification free product while still accessing a healthy option.
Organic Bakers
* Purebread – Robert Glensor Ph 04 902 9686, 0274 575 964
* Breadman – Steffen Klink Ph 03 365 0990
* Venerdi – Phil Ph 09 813 5481
* Helios Bakery – Matthias Kroeger Ph 09 372 8382
* Dovedale – Greg Ph 03 539 1167
* Essene Bread – Colin Thomson Ph 09 835 1223
* Watermill Bakery – Bolli Bolliger Ph 06 370 1129
* Quake Bake – Robert Hass Ph 06 833 6446
Organic Millers
* Millmore Downs – Ian & Gita Henderson Ph 03 314 3712
* Terrace Farm – Geoff & Ira Wilson Ph 03 302 8663
* NZ BioGrains – Harry & Mary Lowe Ph 03 308 7349
Above are examples of the options left for consumers who want to avoid mandatory fortification of all other bread with folic acid and iodine. The other alternative is to bake your own bread.
Mandatory fortification of iodine in bread
/in SubmissionsBelow 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.
Government call for Consumer Choice ignored by FSANZ
/in Food, Health, Media Releases, Organic CommunitySoil & Health is appalled at the lack of consumer choice from Food Standards Australia New Zealand’s (FSANZ) mandatory folic acid fortification of bread proposal released on Friday evening. The proposal is for effectively all bread to have synthetic folic acid added.
With no meaningful exceptions in the proposal, Soil & Health is calling on the Minister of Food Safety Annette King to use her influence for at least organic breads to be exempt to allow consumers choice.
“At the recent Baking Industry Association of New Zealand conference the Minister expressed the need for choice and the difficulty for bakers with the all bread proposal and I know she has heard consumers” said Soil & Health spokesperson Steffan Browning.
“Mass medication is not wanted by New Zealanders and New Zealand Government submissions to FSANZ were clear about that, but that message has been effectively ignored. New Zealand studies mentioned found the majority of participants were opposed to mandatory fortification with folic acid.”
The FSANZ Board has effectively rejected a strong submission* supporting the need for consumer choice from the New Zealand Food Safety Authority (NZFSA). Ministry of Foreign Affairs and Trade (MFAT), Ministry of Economic Development (MED), and the Ministry of Consumer Affairs supported the wide-ranging submission. The Ministry of Health (MoH) supported the submission in principle.
“While varying from the Soil & Health submission, which called for a full exemption for organic products from the synthetic folic acid, NZFSA has certainly listened to consumer concerns and looked for a middle way through” said Mr Browning. “Soil & Health remains committed to helping organic consumers and small bakers find a solution to this draconian proposal.”
There have yet to be any publicly funded campaigns in New Zealand promoting naturally folate-rich foods or folic acid supplements to address the incidence of neural tube defects. Foods naturally high in folate are green leafy vegetables (such as broccoli and spinach), nuts, orange juice, some fruits and dried beans and peas. Cereals are moderate sources of folate. With children to be the more likely victims of excessive folate levels and health issues around excessive folate levels unresolved, choice and education are a better solution.
This FSANZ proposal leaves consumers baking their own bread as the only real option if wanting a choice. This is not acceptable to most organic consumers who, like other consumers. rely on commercial bakers for their synthetic free daily bread.
“My baker of choice uses no additives at all,” said Mr Browning “ and this decision takes no account of the natural folate already existing above average in the wholesome organic loaves.”
The FSANZ proposal says
“Mandatory folic acid fortification may be an issue for bakeries producing artisan breads using only ‘natural ingredients’, and for organic bread manufacturers. Artisan bakers may consider the fortification of their products will not fit with their niche market, and could be seen as detrimental to sales. Folic acid may not be considered a ‘natural ingredient’ as it is a synthetic form of folate, and may also conflict with organic industry standards.”
“FSANZ’ could use Standards New Zealand’s Organic Standard for a definition of organic to allow an exception” according to Soil & Health’s Steffan Browning, “Consumer choice would be the better for it.”
Soil & Health calls on Minister of Food Safety Annette King, New Zealand’s representative on the Australia and New Zealand Food Regulation Ministerial Council, to insist on real consumer choice by way of a review of this proposal at the Council’s next meeting on 25th October 2006.
Steffan Browning
Spokesperson
The Soil & Health Association of New Zealand Inc
021 72 5655
* Excerpts from the FSANZ decision analysis of NZFSA Submission
Consumer Choice
Refers to NZFSA (2005) and NZ Association of Bakers (2004) research on consumer attitudes to mandatory fortification that found the majority of respondents did not support mandatory fortification.
Considers that given the level of resistance to fortification in the New
Zealand population, consumers must have choice between fortified and unfortified bread products. Notes the current proposal would not provide consumer choice.
Health risks
Australian consumption data may not be accurate for NZ populations. Only appropriate to use Australian consumption data for NZ children if no suitable New Zealand data and modelling.
The percent of NZ children exceeding the UL could be far greater than 6% because all flour in NZ may be fortified with folic acid in NZ due to the inability of NZ flour mills to segregate bread making flour.
Children will be exposed to much higher levels of folic acid than previous generations. It may be in future generations of children that adverse effects become apparent.
No monitoring of young children has been undertaken in North America. Both of these countries provide some consumer choice between fortified and unfortified bread.
Removing bread from the diet of young children as an option for avoiding fortified bread would not be consistent with the New Zealand National Nutrition Guidelines.
New Zealand Commerce Commission (NZCC) considers there may be implications in the proposal standard regarding fair trade and labelling issues. The NZCC requests the opportunity to discuss these issues further before any decision to adopt the preferred option.