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Application A565 – Nisin Use in Processed Meat Products – Draft Assessment Report

14 September 2007

Dear Sir/Madam

Thank you for the opportunity to comment on this application. The New Zealand Food Safety Authority (NZFSA) has the following comments to make.

NZFSA Supports Option 2: vary Standard 1.3.1 to approve a broader use of nisin to include a limit of 12.5mg/kg in processed meat products.

NZFSA is satisfied that the estimated dietary exposures results do not raise any public health and safety concerns with nisin at the proposed levels of use. It is noted that a separate dietary exposure assessment was not conducted for New Zealand children under 15 years old. However we accept the rationale given by FSANZ for the assumption that the dietary exposures to nisin for New Zealand children are well below the ADI. This rationale is quoted below:

Based on the estimated 95^th percentile dietary exposures for Australian children aged 2-6 years (10% of the ADI), it can be assumed that 95^th percentile dietary exposures to nisin for New Zealand children are also well below the ADI.

Even if there was a difference in food consumption patterns between Australian and New Zealand children, it would need to be appreciably higher for New Zealand children in order to make dietary exposures approach the ADI. Such a large difference in consumption between Australian and New Zealand children is considered unlikely.

Draft Variation to the Australia New Zealand Food Standards Code

As the drafting stands nisin would only be permitted in sub category commercially sterile canned cured meat under item 8.2. The drafting in the DAR does not appear to permit nisin to be added to the other subcategories under item 8.2 i.e. cured meat, dried meat and slow dried cured meat. The Applicant sought to amend Schedule 1 of Standard 1.3.1 to include limits for nisin for the whole category 8.2 Processed meat, poultry and game products in whole cuts or pieces not just the sub category commercially sterile canned cured meat. FSANZ’s preferred approach is in line with the amendments sought by the Applicant. However this has not been carried through in the Draft Variation presented in the DAR. This could be remedied by removing the words "commercially sterile canned cured meat" as shown below:

[1] Standard 1.3.1 of the Australia New Zealand Food Standards Code is varied by –

[1.1] inserting in Schedule 1, under item 8.2 Processed meat, poultry and game products in whole cuts or pieces commercially sterile canned cured meat –

[1.2] inserting in Schedule 1, under item 8.3 Processed comminuted meat, poultry and game products –

Yours sincerely