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.
Government call for Consumer Choice ignored by FSANZ
/in CampaignsSoil & 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
* 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.
Organics and natural
New Zealand Commerce Commission (NZCC) considers there may be implications in the proposal standard with regards to fair trade and labelling issues. The NZCC requests the opportunity to discuss these issues further before any decision to adopt the preferred option.
Mass Medication not on says Soil & Health
/in Food, Health, Media ReleasesThe Soil & Health Association is calling for certified organic foods to be exempt from any possible mandatory food fortification schemes.
Today Soil & Health presented a submission to Food Standards Australia New Zealand calling for consideration of consumer choice, particularly for those choosing a healthy diet free of additives.
FSANZ had called for submissions to its proposal to have Mandatory Folic Acid Fortification of bread flours throughout Australia and New Zealand.
“Soil & Health promotes organically produced foods that exclude synthetic additives in their production and an exemption for organic foods would give all consumers a choice”, said Soil & Health spokesperson Steffan Browning.
“Mass medication is not a suitable alternative to a strong healthy diet campaign by the Ministry of Health”
“The real concerns regarding the prevention of Neural Tube Defects need targeted attention that is as naturally healthy as possible. The effects of Dioxin and other environmental toxins also implicated in NTDs need addressing ahead of weak cross community medication in place of poor diet,” said Mr Browning.
“Our submission also pointed out the lack of consideration to small farm based flour millers if the suggested ‘all bread flours’ fortification regime was pursued.
These producers of nutritious local product would be unfairly disadvantaged if having to equip for fortification.”
Folic Acid
/in SubmissionsThe 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 SubmissionsThe 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