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 the three options outlined in the document. As with others in the baking industry our preferred option is 5.3 Revocation of the New Zealand Folic Acid Standard under the proviso that voluntaryfortification be included. However, should the Government reject this option we support the Government's "preferred option" 5.2 Amendment to Commencement date as a practical means of addressing the major concerns we have with the folic acid standard Particular comments on the points raised in the discussion paper are included below. At the outset though we would like to stress our continued willingness to work with NZFSA to identify the best approach to address the issue related to NTDs whilst providing our consumers with choices so they can be purchase bread without fear of unknown health risks. 5.1: STATUS Quo DISADVANTAGES NTD reductions: 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. Research commissioned for FSANZ by Monash University seriously questioned whether the objectives of mandatory fortification would be achieved through mandatory fortification of bread and Prof Segal identified this would not be the best option for NZ. In her report Professor Segal stated she could not conclude that mandatory fortification of bread was the optimal strategy to adopt. Furthermore she stated mandatory fortification of folate (MFF) in New Zealand was not a cost effective option with an estimated cost of over $500,000 per NTD prevented. She identified that a Health Promotion Campaign would be required to provide supplementary use in addition to MFF and even this would only prevent an 8 per cent reduction of NTDs which in New Zealand represents between 6 7 NTD conceptions and 1 live birth. While one could argue on the exact level of bread required to prevent a significant number of neural tube defects, it is clear that supplements would still be needed to minimise the number that may occur. The sad fact is that there will be still be more NTDs occurring than are prevented under any strategy but it is clear that increased use of supplements would be more potent in delivering a desirable outcome.
i In light of this, it is our view that extending the range of fortified breads, coupled with an education programme and greater promotion of supplements would be a much more effective vehicle. 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 take account of this. Mandatory fortification is Not supported by consumers We are aware that 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 an earlier independent research commissioned by the NZ Association of Bakers. Recent debate through various forms of the media has confirmed consumers' opposition to the measure. Reduces consumer choice We have long argued that consumers have the right to purchase breads that meet their requirements in terms of additives. 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. The only real alternative under the regulations is to buy "Organic". Organic flour and therefore organic bread in the NZ market place is a luxury and is likely to be too costly for many New Zealand families. Whilst there are some exclusions to this requirement, they do not offer realistic alternatives to the bulk of consumers. Organic flour and therefore bread is extremely limited in the NZ market place 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 It would appear from the Wald model used in the standard, that given the number of NTD conceptions in NZ is approximately 72 per year (14 live births) applying the planned fortification levels (approx. 135ug 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 approx 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 (approx. 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 is therefore identified as a better approach for New Zealand. Imposes costs on industry It is yet to be determined the costs to us in terms of compliance measures and as a result it is not clear what would need to be passed onto costs for the consumer. l would like though to take the opportunity to point out, while we have recognised there are costs, we are not primarily requesting an end to mandatory fortification on a cost basis; instead the focus has been on providing choice, minimising risk and good science. May be difficult to comply with due to difficulties associated with getting an even spread of folic acid to the required level l have had a lead role in working with NZFSA in terms of finding a method of accurately applying the required levels of folic acid and believe we have come some way towards achieving this through application at the "input" stage. I believe though this is still an area that requires more work by the industry and its technicians especially for grain breads. Until this work is finalised, it will not be possible to gauge with full confidence actual folic acid intake by New Zealanders. Further disadvantages It is a real possibility that New Zealand children may regularly consume more folic acid than their recommended daily intake as a result of this initiative. We therefore believe that parents will naturally be worried about the long term effects (either real or perceived) on their children's health. Potential risks associated with colon and prostate cancer as well as anaemia in the elderly has been highlighted in the media and to date there is no way to substantially refute this risk. There is a large amount of conflicting information in the media and until some study is undertaken or uncovered that is held out by our government to refute these risks, we would be negligent in dosing our customers with folate. Officials acknowledge that there are significant unknowns and that this is a "rapidly growing" area of research shouldn't we wait until the public can face this risk with greater certainty?
5.2 AMENDMENT TO COMMENCEMENT DATE Advantages Allows voluntary fortification to continue As bakers, we are willing to work with the wider industry to expand the range of fortified breads so we can go some way towards offering options for those consumers who want folic acid in their bread. This will give consumers a real choice. Provides greater choice to consumers over the next two years 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. 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 leaves 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 enriched breads. 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 25thto 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 million a year estimated costs resulting from application 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 has delayed implementation of mandatory fortification until concern about cancer links has been fully investigated and Ireland has also advised against this approach. We believe it is prudent for the Government to postpone the standard while research positions are clarified. 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. Disadvantages Would reduce the impact on addressing the folate deficiency in New Zealand diet, and reducing the number of NTD affected pregnancies We believe the proposals outline above would more effectively address this concern. 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; 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 also would not allay the concerns of consumers in relation to their confirmed opposition to mandatory fortification of bread Implementation no longer aligned between Australia and New Zealand As a domestic based bakery we do believe this is an issue of relevance. 5.3 REVOCATION OF NEW ZEALAND FOLIC ACID STANDARD Advantages Provides certainty for industry and consurners This is true and would confirm that Government has taken onboard the concerns of industry and consumers. The issues, real or perceived, by consumers over the "goodness" of their bread would be removed. Ensures maintenance of consumer choice over the longer term Agreed
Disadvantage 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 should be revisited. 6. COST IMPLICATIONS As a result of the continued introduction of iodised salt, we have already incurred several thousand dollars worth of packaging costs associated with plate charges/bag runs for meeting this standard. At this stage we have had to hold off on the folic acid compliance in a number of our bags but will have some products that will be fortified. Should the status quo go through then we would have several thousand dollars worth of additional cost. We have already completed the work on dosage levels to meet the required range. Should the status quo option be pursued then we believe we could 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 would be the use of funds to determine appropriate levels to use under a voluntary regime. We are prepared to pursue this approach. 7. OTHER COMMENTS We support the view of the Bakers Association and 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. (Bread is a product not widely consumed by women of childbearing age but it is by children, men and older women)
It is consistent with the nutrition policies 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 of a small target population results 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 Thank you for the opportunity to comment on the Discussion Document, please do not hesitate to contact me if you require further information. Annette Campbell CEO Couplands Bakeries Ltd