Please refer to anzfa’s guide to applications and proposals for a more detailed explanation of the process on how to undertake

7. Data issues

7.1 Dietary modelling

Those against mandatory fortification considered that the data used to assess food intake was out of date and that dietary consumption patterns have changed.

7.2 Modelling of NTDs prevented

Those against considered that mandatory fortification would result in only a small number of NTDs prevented and that NTD rates were falling regardless of mandatory fortification.

Other data issues included:

• 
  the need for baseline data including NTD statistics, nutrient intake, folate status and folic acid supplement use;
  
• 
  the dietary folate intake was not included, but was considered significant by some researchers; and
  
• 
  the folic acid intake data did not include folic acid from general multivitamin supplement use.
  

8. Alternative strategies to increase folic acid intakes

Some submitters were disappointed at the absence of previous Option 2 (increased permissions for voluntary folate fortification) and Option 4 (increased health promotion and education strategies to increase folate intakes) in the Draft Assessment. These options were included in the Initial Assessment.

Those in favour of mandatory fortification acknowledged the limitations of education strategies and the promotion of supplements. The limited uptake of voluntary fortification by industry was also noted.
A range of submitters against mandatory fortification favoured more resources committed to the promotion of supplements in conjunction with targeted education campaigns. Some submitters favoured free or subsidised folic acid supplements for the target group funded by Government. Others believed mandatory fortification may reduce the emphasis placed on alternative strategies.
Food industry provided particular alternative proposals based on increasing voluntary permissions.

9. Folic acid supplements

Submitters noted that women may believe folic acid supplements are no longer necessary with mandatory fortification. Ongoing education and promotion will be needed particularly targeting low social-economic and Indigenous groups. The NZ Government stated that discussions were being held with the NZ Ministry of Health and Medsafe with regard to providing lower dosage folic acid supplements to a prescription medicine standard.

10. Cost benefit analysis (CBA)

A number of submitters from various groups identified issues with the CBA including:

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  the cost of monitoring, education and communications needs to be included;
  
• 
  the costs of fortifying all sources of bread-making flour is not reflected in the report e.g. non wheat based flours;
  
• 
  costs to industry for labelling and packing costs are inadequate;
  
• 
  costs to industry do not reflect the costs of providing the precision required with the required range. Costs for equipment and installation are underestimated;
  
• 
  costs to industry for folic acid analyses are inadequate – laboratories and on site analyses are necessary;
  
• 
  full export costs are not reflected in CBA; and
  
• 
  the cost to consumers will increase
  

One industry submitter stated that the information given to the consultant preparing the CBA was not used.

11. Monitoring

Monitoring was a key issue, both for those for and against mandatory fortification. Adequate long term funding for the wide range of monitoring activities was seen as essential, and many wanted a commitment before the implementation of mandatory fortification. Clarification of responsibilities and funding was needed.

Collection of baseline information was highlighted as extremely important before embarking on a mandatory fortification programme, including baseline data for children.
The need to ensure sustainability and robustness of monitoring was noted. It was recommended that monitoring include rates of NTDs, blood folate, other potential health risks and benefits (cancer, cardiovascular diseases, vitamin B12 deficiency and other birth defects) and changes in voluntary fortification practices.
Those against mandatory fortification noted that monitoring of thiamin and an evaluation of its effectiveness had not been undertaken in Australia.

12. Education and communication strategies

Submitters both for and against mandatory fortification recognised the need for ongoing education and communication and that the agencies responsible need to be clarified and well resourced.

Key messages need to include the ongoing need for folic acid supplements. Education and communications regarding mandatory fortification would be required for the various target audiences including health professionals, key agencies and the public. Many submitters recommended education be targeted particularly to Indigenous and lower socio economic groups and through schools. It was noted a publicly funded national campaign had not been undertaken in NZ.

13. Enforcement and compliance

Enforcement and compliance were not identified as a major issue. This may be because the food vehicle was bread-making flour rather than bread. Some jurisdictions did raise the issue of enforcement indicating:

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  that regular monitoring and analysis of flour and bread for folic acid would be an essential component of compliance and enforcement; and
  
• 
  the range of folic acid permitted to be added to flour may be difficult for industry to maintain and therefore create enforcement difficulties.
  

14. Implementation and transition period

Industry considered the 12-month transition period to be inadequate for labelling and packaging changes to be made. Several submitters also considered the establishment of a monitoring programme including collection of baseline data and a commitment to funding of monitoring and education needed to be addressed prior to implementation.