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

C29	Australian Consumers’ Association (ACA) Ms Clare Hughes	Supports Option 1 Cannot support Option 2 for the reasons below (although is not theoretically opposed to mandatory fortification). ACA does not believe the devastating impact of NTDs is sufficient justification for short consultation and a quick decision. Also disappointed only two options were proposed. ACA’s preferred approach is to delay fortification decisions until more data is obtained, along with increased education. Considers the proposal is a population wide solution for a small number of women. Considers there is insufficient evidence that mandatory folate fortification of bread making four will reach the target group. Notes most women will not achieve the 400 ug daily recommendation through food so will need supplements. Suggests the proposal will still disadvantage low socio economic women and women with unplanned pregnancies. Health risks Believes there is still sufficient scientific uncertainty about the risks associated with increased consumption of folic acid to postpone mandatory fortification. ACA is concerned bread making flour will increase unmetabolised folic acid levels of some young children. Food Vehicle Considers there is no evidence FSANZ has considered alternatives to bread making flour or conducted dietary modelling of other potential food vehicles. Therefore stakeholders are unable to make an informed decision. They request dietary modelling of other vehicles e.g. certain breakfast cereals (excluding children’s cereals), other cereal products, low fat milk or dairy products. Voluntary fortification Concerned FSANZ does not plan to reconsider voluntary permissions for folate as this makes it more difficult to ensure non target groups do not consume excessive amounts, especially young children. ACA believes FSANZ must reconsider current voluntary permissions e.g. for children’s breakfasts cereals. Consumer choice Concerned the proposal limits choice. Mandatory fortification is supported in principle as long as it does not place others at risk. ACA is not confident evidence in the Draft Assessment Report (DAR) provides adequate assurance against negative effects of increased levels of unmetabolised folic acid. Labelling If mandatory fortification is introduced ACA supports the inclusion of folate on the Nutrition Information Panel (NIP). Monitoring Dietary modelling has been based on National Nutrition Survey (NNS) data now 11 years old, and permission of voluntary folate fortification has been introduced. There appears to be no funding committed go extensive and ongoing monitoring. ACA is unable to support mandatory fortification without a commitment to extensive monitoring being established (lists the surveillance required). Education Mandatory fortification will require accompanying education. Proposal does not clarify whether extra funding is available for education or whether agencies / organisations will be expected to take this on. Considers resources and funding for education should be allocated prior to a decision. Requests FSANZ further consider new research since the Initial Assessment Report (IAR) and conduct dietary modelling of alternative foods.
C30	Crippled Children’s Society (CCS), New Zealand Mr Lyall Thurston	Supports Option 2 CCS has been leading NZ Folate Awareness campaign seeking mandatory fortification of flour with folic acid since 1990s. Considers fortifying flour with folic acid is consistent with international experience and research to reduce NTDs. Considers this proposal is a long overdue public health opportunity. Joins ASBHA in urging FSANZ to implement this proposal.
C31	Coeliac Society of Australia Mr Graham Price	The Society does not have a view on the benefits or other wise of folic acid fortification. Food vehicle Considers the proposal does not define bread making flour so assumes this will include gluten free bread making flour. If folic acid fortification of flour is mandated, the Society requests that this be clarified and made clear if gluten free flour is included.
C32	Coeliac Society of Western Australia Ms Necole Rowe	Supports Option 2 Food vehicle Notes individuals with coeliac disease will not benefit if this is restricted to wheat based bread making flour. The Society requests that specific consideration be given to this group. Alternatively specific targeted promotional activities should be considered for individuals with celiac disease.
C33	Consumers’ Institute of New Zealand Ms Belinda Allan	Supports Option 1 Acknowledge mandatory fortification will reduce the incidence of Neural Tube Defects. Consumer Choice Concerned mandatory fortification of bread making flour will limit choice as it will be difficult to buy unfortified products. Notes a New Zealand Food Safety Authority (NZFSA) study in 2005 where 84% thought mandatory fortification should not apply. Over 75% of the study group emphasised consumer choice is very important. Suggests FSANZ investigates alternative food vehicles e.g. bread improvers are used in fewer products than bread making flour. Alternatively, suggests exemptions such as organic flour, as if this is not exempt this would affect the organic certification. Health risks Concerned the nutrient imbalances and excesses may result. Notes the DAR refers to uncertainties associated with mandatory fortification such as elevated blood folate levels in young children and masking of B12 deficiency in elderly. Monitoring Any fortification strategy must be accompanied by monitoring of nutrient levels in the population, including comprehensive baseline data. Monitoring must be well funded based on these uncertainties. Education / Communication Notes the lack of publicly funded awareness campaign in NZ. Believes education should commence before mandatory fortification is considered. Education must be clear supplementation is still needed to reach recommended levels.
C34	Diabetes United Kingdom Ms Cathy Moulton	Supports Option 2 Provides similar comment on the draft report to that provided to the proposal by the Scientific Committee on Nutrition in the UK. Notes that many women do not start taking folic acid supplements early enough because of unplanned pregnancies or lack of knowledge. Notes that women with diabetes have a much higher risk (3-4 fold) of giving birth to a child with an NTD than women without diabetes. Diabetes UK therefore recommends that women with diabetes should have the higher dose of 5 mg folic acid per day, and asks that this issue be addressed. References provided.
C35	GE Free New Zealand Ms Claire Bleakley	Supports Option 1 with full labelling of fortified breads required Cannot support mandatory fortification on the basis of : Consumer choice Considers the proposal limits consumer choice, all consumers will have to bare the associated costs and increased costs may decrease consumption. Organic breads could not be sold under organic standards if fortified (this also creates a barrier to free trading). Health Risks Considers the merits and health benefits of mandatory fortification are uncertain, would be of little benefit and could give a false sense of security. Drug-nutrient interactions: considers folate supplementation could increase seizure/bipolar/pain episodes due to interaction with anticonvulsant medication. Considers folic acid taken concomitantly with other specified drugs can reduce folic acid absorption. Refers to drug / nutrient interactions when high doses of folic acid (amount not quantified) are taken concomitantly with both phenytoin and pyrimethamine. Considers supplemental folic acid can adversely affect absorption of zinc. The possibility that a genetic engineering process could be used to produce folic acid causes serious concerns. Requests clarification on the source of the synthetic folic acid to be used. Supplements/education Believes an education programme re diet and the use of folic acid supplements is the best option. Provides references
C36	Genetic Support Council WA Inc. Ms Sharon Van der Laan	Supports Option 2 Considers voluntary fortification has not been successful in improving folate intake so far. Considers mandatory fortification of bread making flour would provide protection against NTDs for all women regardless of social factors, indigenous status, and whether pregnancies are planned or unplanned. Considers in countries where folate fortification is mandatory no adverse effects have been reported and a decline in NTDs has been reported. Monitoring Monitoring of effectiveness and safety is needed. Education Not all NTDS will be avoided; must ensure appropriate resources are available for education.
C37	Green Party Aotearoa New Zealand Ms Sue Kedgley MP