New Zealand Association of Bakers Inc

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1 New Zealand Association of Bakers Inc Microsoft House, 3 11 Hunter Street, Wellington. RO. Box 1925 Tel: (04) Fax: (04) August 2009 Policy Group New Zealand Food Safety Authority PO Box 2835, Wellington Dear Sir/Madam, Re PROPOSED AMENDMENT TO THE NZ FOLIC ACID STANDARD Attached are three copies of a submission prepared by this Association in response to the NZFSA Public Discussion Paper; no 10/09, 22 July Please do not hesitate to contact the undersigned if you require any additional information. Yours sincerely, Marcia Dunnett Executive Officer

2 Submission by NZ Association of Bakers to New Zealand Food Safety Authority Oil Proposed Amendment to the New Zealand Folic Acid Standard NZFSA Public Discussion Paper; no.10/09 10 August 2009 PO Box 1925 Wellington Ph: Fax:

3 This submission has been prepared by the NZ Association of Bakers (NZAB) representing: Goodman Fielder NZ Ltd George Weston Foods NZ Ltd Couplands Bakeries Breadcraft (Wairarapa) Ltd Yarrows (The Bakers) Ltd Walter Findlay Ltd Quality Foods Southland Old Fashioned Foods Group The Association also endorses the submission lodged by of our counterpart organisation, the NZ Food & Grocery Council The Association is pleased to have the opportunity to comment on Public Discussion Paper; No 10/09 Proposed Amendment to the New Zealand Folic Acid Standard and the three options outlined in the document. This industry's preferred option is 5.3 Revocation of the New Zealand Folic Acid Standard however, should the Government reject this option the NZAB supports Government's "preferred option" 5.2 Amendment to Commencement date as a practical means of addressing the major concerns of the industry with the folic acid standard 5.1 Status Quo. We deal with each of these options under the relevant document headings which address also the problems identified by Government under 3 Problem ldentification. We wish at the outset to register our concern that there is no mention in the document of health concerns in the document which we consider to be a serious omission and we cover this under several sections of this submission. f 5. STATUS QUO Advantages Maximises the opportunity to reduce NTDs We do not agree that mandatory fortification of bread "maximises the opportunities to reduce NTDs because there are other strategies the Government could employ to reduce NTDs such as the target group consuming supplements at the correct time. The evidence is debatable that adding folic acid to bread will make any difference to the current status of NTDs.

4 Research commissioned for FSANZ in 2007 by Professor Leonie Segal of Monash University seriously questioned whether the objectives of mandatory fortification would be achieved through mandatory fortification of bread. Officials advise that women would have to eat up to 11 slices of bread a day to reach the optimum amount of folate to optimally reduce neural tube defects and admit that even with the amount of recommended folate added to bread, supplements would still be needed to prevent some neural tube defects. There will still be significantly more NTD conceptions NOT prevented than are prevented. It would appear from the Wald model used in the FSANZ standard, that given that the number of NTD conceptions in New Zealand is approximately 72 per year (14 live births), applying the planned fortification levels (approximately 135 for every 100g of bread 3 to 4 slices) between 3 to 18 NTDs (1 to 2 live births) would be prevented. With supplements this level can be lifted to 600mg/day (equivalent of approximately 11 slices of bread) and preventions would increase to between 11 and 28 NTD conceptions prevented (4 live births). Even then at optimum levels there would still be at least 44 NTDs (approximately 8 live births) per year that are NOT prevented BUT widespread supplement use would have a much more significant impact. Education and use of supplements were identified by Professor Segal as a better approach for New Zealand. C It is also unknown what the long term effect of increasing the consumption of folic acid, which is a synthetic form of naturally occurring folate, would be and officials warned the former government of this fact and stressed the importance of the monitoring framework taking account of this. We have always maintained that extending the range of fortified breads, coupled with an education programme and greater promotion of supplements would be a much more effective vehicle. Is consistent with the intention of the standard as developed By FSANZ under the join system Whilst this may be consistent with the treaty, as there is no trade trans Tasman in fresh bread and only a small amount in frozen product, there is no practical benefit to New Zealanders for this but many disadvantages. There is no shared standard in any case. Both countries developed separate standards, one flour and the other for bread.

5 Maintains maximum alignment with Australia Refer to above points Disadvantages Not Supported by consumers Research conducted by NZFSA in 2005 confirmed 84% of consumers interviewed, even after providing information on the reasons for fortification, did not support mandatory fortification of bread, one of their favourite staples. In place of mandatory fortification consumers preferred public education campaigns and labelling that provided consumer choice. The NZFSA results were in line with those resulting from independent research by Elizabeth Brown BDR Ltd commissioned by the NZAB in Recent debate through various forms of the media have confirmed consumers' opposition to the measure. Reduces consumer choice ī' The mandatory nature of the standard removes choice for consumers. Whilst there are some exclusions to this requirement, they do not offer realistic alternatives to the bulk of consumers e.g. organic bread sales amount to around 1% of the total market and is too costly for many New Zealand families. Baking their own bread is not a realistic option for many, especially working women. Uncertainty that the mandatory fortification would deliver the desired outcome The levels of fortification have been set too low to achieve the stated objective and women in the target group will still require supplements. Imposes costs on industry Whilst the industry will incur additional costs associated with the measures which could translate into costs for the consumer. This has never been the primary objection by the industry to the measures. May be difficult to comply with due to difficulties associated with getting an even spread of folic acid to the required level

6 = The industry is not confident that it can achieve folic acid levels within the gazetted minimum and maximum range in individual loaves and has advised both NZFSA and FSANZ of this repeatedly. Other disadvantages Some New Zealand children will regularly consume more folic acid than their recommended daily intake as a result of this initiative. Potential risks associated with colon and prostrate cancer as well as anaemia in the elderly. Officials acknowledge that there are significant unknowns and that this is a "rapidly growing" area of research. 5.2 AMENDMENT TO COMMENCEMENT DATE Advantages Allows voluntary fortification to continue Bakers are willing to expand the range of fortified breads. It will be important for this to continue if realistic alternatives such as increased levels within a higher range of breads are to be considered. Provides greater choice to consumers over the next two years C_. Consumers have made it clear that they want choice. There have been a number of polls conducted on this subject over the years and all of them have concluded that New Zealanders do not want mandatory fortification of bread (even when the reason for intervention was explained). A delay will provide for the continuation of voluntary fortification and the opportunity to consider broadening the range of breads containing folic acid. It will provide the opportunity to undertake research on increased folic acid levels. The actual folate levels will need to be agreed with dietary modelling experts to avoid placing the.wider population at risk. It is believed that by fortifying a targeted range of for example, grain breads, will reduce the risk to young children/families and leave the bulk of bread free of folic acid. It will also provide the opportunity to do further work on ensuring an even distribution of folate in fortified breads.

7 The industry is also prepared to consider ways in which it might be able to support a government funded education programme promoting the benefits of these breads to the target group (e.g. through point of sale material and on pack labelling). A Baking Industry Folic Acid Summit is planned for August 25th to commence this process. Less costly to the industry over the next two years The savings are difficult to ascertain at this time but the starting point will be from the $10.4 million a year estimated costs resulting from application and compliance requirements of the mandatory standard. Allows new evidence to be considered As NZFSA has noted, research into the health effects, both positive and negative is a "rapidly developing area". The United Kingdom have delayed implementation of mandatory fortification until concern about cancer links have been fully investigated and Ireland have advised against this as there was not a strong public health argument for its introduction. We believe it is prudent for the Government to postpone the standard while research positions are clarified. f Other advantages Deferral of implementation confirms that Government has taken onboard the concerns of consumers with respect to their lack of support for mandatory fortification of bread, potential cancer risks and the unknown effects of children consuming too much folic acid, by providing more time to fully consider and research these. Provides the opportunity for industry to deliver expanded choices to consumers. Disadvantages Would reduce the impact on addressing the folate deficiency in New Zealand diet, and reducing the number of NTD affected pregnancies The proposals outline above would more effectively address this concern.

8 o It is important to note also that due to folic acid awareness and work by health professions, the rate of NTDs in New Zealand has reduced significantly to the extent that New Zealand has a very low birth prevalence of neural tube defects and even with mandatory fortification, the gains in NZ are likely to be very small. There will be no benefit to all men, children and the elderly in terms of reducing NTDs, even some women of childbearing years will gain no benefit from the measures. Would not remove uncertainty that mandatory fortification may still occur Whilst this is true it would allay some of the concerns of consumers in relation to their confirmed opposition to mandatory fortification of bread Implementation no longer aligned between Australia and New Zealand There is already a separate standard for New Zealand. Australia and New Zealand do not trade bread and the benefits from alignment of this standard are minute in terms of the total relationship with Australia. 5.3 REVOCATION OF NEW ZEALAND FOLIC ACID STANDARD Advantages Provides certainty for industry and consumers This is true and would confirm that Government has taken onboard the concerns of industry and consumers. Would provide encouragement to the baking industry to voluntarily expand the voluntary range of enriched breads on the basis this option being revisited. Ensures maintenance of consumer choice over the longer term Agreed Other advantages Allays concerns about increased rates of prostrate and colon cancer as a result of mandatory fortification Allays concerns with respect to the unknown effects on New Zealand children from consuming too much folic acid.

9 Disadvantages Would reduce the impact of addressing the folate deficiency In the New Zealand diet and reducing the number of NTD affected pregnancies Officials admit that even with the specified amount of folate added to bread, supplements will still be needed to prevent some neural tube defects. The industry has always maintained that a safer and more effective approach to this would be more targeted fortification through a range of breads coupled with a focused public health campaign. Would be inconsistent with the joint standards as developed with Australia The impact would be negligible given that so little bread is exchanged across the Tasman and that NZ already has a separate standard different to Australia. Would not provide for voluntary fortification This would be true in terms of the current standard but if this is the agreed option, provision for voluntary fortification would have to be revisited. 6. COST IMPLICATIONS F The work done by the industry on dosage levels to meet the required range and user guide has already been completed in anticipation of the standard coming into effect. There is therefore no material change to the industry in the short term regardless of the option implemented. Should the status quo option be pursued, however, the industry would incur substantial cost to ensure compliance with the standard actual cost is yet to be clarified but could be significant dependent on the level of legal surety required. Key savings to the industry, should the preferred option or the revocation of the standard be accepted, would be due to the removal of testing required to guarantee compliance. Ongoing costs in this instance to the industry will be in use of funds to determine appropriate levels to use under a voluntary regime. The industry has indicated that they are prepared to pursue this approach.

10 The industry has never argued against implementation on the basis of cost to the industry as it would attempt to recover from the marketplace but recognise that this would be a cost to consumers. 7. OTHER COMMENTS We take issue with the comments in the document under "Background" paragraph 6 which identifies the policy principles for the development of the standard that mandatory fortification of the food supply should only be introduced in response to a demonstrated significant population health need, and where: o o o o it is the most effective public health strategy to address the problem it is consistent with the nutrition policies of Australia and New Zealand it will not result in detrimental excesses or imbalances; and it will deliver effective vitamins to the target population to meet the health objectives We argue that mandatory fortification of folic acid in bread does not meet all of FSANZ's own guidelines: It is the most effective public health strategy to address the problem Mandatory fortification of bread will not provide sufficient folate levels in women of childbearing age to be effective. The ineffective targeting will result in inadequate intake of folate amongst the target population and excess intake in non target groups including young children. It is consistent with the nutrition polīcies of Australia & New Zealand Given the unknown effects on some sections of the New Zealand population from artificially increasing folic acid intakes, it is difficult to see how this policy can be consistent with nutrition policies. It will not result in detrimental excesses or imbalances Mass medication for a small target group will result in health risks to non target population, especially children and the elderly. Delivery of vitamins to target group Mandatory fortification does not guarantee that the target population will actually receive the levels of folic acid needed to make a difference to their folate status. The delivery of the vitamin through bread is not an appropriate vehicle as women statistically are not big bread consumers and some do not eat bread at all

11 o Thank you for the opportunity to comment on the Discussion Document, please do not hesitate to contact either of the undersigned if you require further information. Laune Powell President NZ Association of Bakers Marcia Dunnett Executive Officer NZ Association of Bakers I"

This submission is lodged on behalf of Couplands Bakeries Ltd.

This submission is lodged on behalf of Couplands Bakeries Ltd. Thank you for the opportunity to comment on Public Discussion Paper; No 10/09 Proposed Amendment to the New Zealand Folic Acid Standard and