I15
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New Zealand Association of Bakers Inc. (NZAB)
Ms Marcia Dunnett
| Supports a modified Option 2
Alternative proposal is provided.
Concerns with current proposal
Data
Considers it is unlikely the outcomes predicted will be achieved based on current bread consumption patterns. Using data from 1990s does not reflect more recent reductions in bread consumption.
The food consumption model assumes a daily intake of 3 – 4 slices of bread per day to achieve the 131 ug folic acid intake projected for the target group.
Current estimates of bread consumption for the target group from industry research (GWF and Goodman Fielder formal and informal research) show the target group consume 1 – 2 slices of bread a day rather than the 3 – 4 slices used in the model. Therefore the impact on the target groups is under the threshold of the Wald model, and the number of NTDs live births saved is likely to reduce significantly from that estimated.
The mean intake of the target group as projected is less than 200 ug/day, the median is lower than this, and only 2% of target group will meet the maximum effectiveness level of 400 ug folic acid.
Notes the anticipated NTDs prevented is 1 live birth and 8 NTD conceptions per year based on the Wald model.
Ministerial Council Policy Guidelines
Considers the proposal is inconsistent with policy principles for mandatory fortification
Preferred regulatory option has not been demonstrated to be without risk. The effects of continually exceeding the UL particularly in the very young have yet to be determined.
Increased folic acid can mask vitamin B12 deficiencies in older people.
The UK Scientific Advisory Committee on Nutrition (SCAN) has yet to promote fortification as it wishes to consider further evidence.
Considers the proposal is not the most effective public health strategy as supplementation is still required, and a government funded education campaign has not yet been trialled.
No clear evidence that the current proposal will deliver effective amounts of folic acid to meet the health objective.
A programme that encourages women to consume grain breads is more consistent with nutrition guidelines than an approach that encourages consumption of all breads.
Impact on Industry Export risk
The proposed approach will jeopardise the export of flour based products manufactured in NZ.
NZ government has been encouraging flour based companies to move into export markets, as demonstrated by a current government research investment in excess of $18 million.
Product for current and future export markets, including frozen pastry and doughs will be affected. These products are produced using bread flour, and may also be affected by the risk of cross contamination at the flour mill. The possible presence of folic acid on the label will be problematic for companies affected.
Export crumb products will be affected e.g. fish fillets and meats.
Export products destined for Japan and the wider Asia area will be affected.
NZ exporters may face a potential loss of export business worth in excess of $67million per annum.
Many of the products sold into Asia use NZ’s ‘green’ image for their marketing and the products are sold on the basis that they are ‘natural’ and contain no additives.
Introduction of folic acid into flour will mean that the companies can no longer use this natural marketing approach, with possible loss of sales.
This issue is more to meet consumer requirements rather than legislative requirements of the export market country.
The choice of flour products will be much more limited than FSANZ proposal suggests as most pastry flour produced in NZ originates from bread flour; a number of cakes are made from bread flour and retail high grade flour is made form bread flour.
A number of NZ based flour mills will be unable to treat bread flour in isolation from other flour, therefore all flour will be fortified.
There is strong consumer opposition to mandatory fortification as demonstrated by research in 2003 (Brown), and 2005 (Hawthorne).
The strong New Zealand response is likely to be driven by the following factors: NZ food regulations until recently did not allow bread to contain artificial additives; NZ has no mandatory fortification, and the NZ public appears to have much stronger views regarding their right to control their food and beverage consumption as demonstrated by the fluoridation of water debates.
There are sufficient differences between NZ and Australian consumers to warrant the alternative approach outlined in this submission.
Cost benefit analysis
The cost benefit analysis does not cost:
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an education campaign that will be necessary with mandatory fortification;
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the cost of monitoring;
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the cost of labelling changes including products other than bread.
Goodman Fielder indicates that for NZ the labelling costs will be double those estimated. The cost of labelling incurred by the baking industry will be in excess of $1 million.
Other concerns include:
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lack of clarity around the nature of the educational campaign
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who will pay the costs incurred by the baking industry in implementing mandatory fortification
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what scientific data is available to show that the folic acid from fortified flour will be bio-available in the bread.
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how will the levels of folic acid in the flour be monitored in NZ? It is currently very difficult to have the test performed.
Alternative proposal
Recommendation includes:
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