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Application P230 – Consideration of Mandatory Fortification with Iodine – Issues Paper

6 June 2007

Dear Sir/Madam

Thank you for the opportunity to comment on the Issues Paper for this Proposal.

The following sets out the views of the New Zealand Food Safety Authority (NZFSA), the Ministry of Health (MoH), the Ministry of Foreign Affairs and Trade (MFAT), the Ministry of Economic Development (MED) and the Ministry of Consumer Affairs (MCA).

Key points of this submission:

• Support the mandatory replacement of salt with iodised salt in bread, with a salt iodisation range from 35-55 mg of iodine per kg of salt.

• Support retaining the voluntary permission for iodine in iodised salt and reduced sodium salt at the new range of 35-55 mg per kg to make it consistent with the mandatory requirement.

• Acknowledge that the proposed new approach to iodine fortification will not deliver enough iodine to fully meet the needs of pregnant and breast-feeding women, and some children.

• Seek a direct comparison of projected increase in average daily iodine intake of adults in the Issues Paper with the modelling done for the Draft Assessment Report (DAR). This should be presented in the Final Assessment Report (FAR).

• Recognise that iodised table salt will continue to play a role in meeting the iodine needs of some individuals and that careful consideration will need to be given to how best to communicate health messages associated with the consumption of salt.

• Acknowledge that the voluntary use of iodised salt in manufactured foods may also be an important contributor of iodine to the diet of New Zealanders.

• Acknowledge that industry may undertake programs to reduce the salt content of their bread. NZFSA and MoH are interested in the impact that salt reduction strategies may have on the iodine intake and status of the population.

• Acknowledge the potential role of iodine content claims in the promotion of iodine containing foods through voluntary fortification, but would be disappointed to see iodine content claims on foods inconsistent with Food and Nutrition Guidelines.

• Recognise the need for on-going monitoring and the need for a review of the effectiveness of the Standard.

• Acknowledge a FSANZ role for some components of an overall monitoring system, including the contribution to updating Australian national food composition databases. Suggest that work be undertaken to share food composition data between the two countries, particularly for foods that are the same, to avoid duplication.

• Seek clarification from FSANZ as to whether the strategy to guide communication and education initiatives to raise awareness and understanding of the proposed standard is a trans-Tasman strategy. If so, we recommend that New Zealand be involved in the development of the strategy to ensure that the New Zealand situation is adequately addressed and sufficient time and resource are available to implement the communication strategy.

Food Vehicle Selection

This submission supports the mandatory replacement of salt with iodised salt in bread with a salt iodisation range from 35-55 mg of iodine per kg of salt. We also support retaining the voluntary permission for iodine in iodised salt and sodium reduced salt at the new range of 35-55 mg per kg.

We support the proposal that breads represented as organic be exempted from mandatory iodine fortification. This will provide consumers with a greater level of choice if they do not wish to consume iodine fortified bread. However, we would like FSANZ to be more specific in the provision to exempt breads made under or aligned with an organic certification agency or a recognised agency (recognised by the relevant competent authority). This would accommodate the range of certified standards available for organic produce in New Zealand and assist with compliance and enforcement issues. MCA strongly supports the exemption for organic breads, to provide consumer choice for those consumers who wish to avoid iodine.

A targeted information programme will need to be developed for consumers of organic bread to ensure they are aware that the product does not contain iodine and what the implications of this might be for them.

The proposed Standard does not prevent the voluntary use of iodised salt in foods other than those mandated. Foods containing iodised salt will be identifiable by ingredient lists or from the provision of information on request if the foods are not required to bear a label. The potential for the uptake of voluntary permissions in the Food Standards Code permitting the addition of iodised salt to any food may make a valuable contribution of iodine to the diet, but will need to be carefully monitored. This sector of the market could increase significantly, especially if there is a perceived marketing advantage through use of iodine content claims.

Change in Adequacy of Intake

The Issues Paper reports that the proposed mandatory fortification would increase the average daily iodine intake of adults by around 30-70 mcg. It has been difficult to compare this projected increase in iodine intake with that presented in the DAR due to differences in the way intake data has been presented in the two reports. Given that the proposed food vehicle selection has been narrowed down to bread, it is essential to know what the impact is on the average daily iodine intake of adults. We consider that the FAR should contain a direct comparison with the modelling done for the DAR. We are also interested in knowing what percentage of adults at the lower end of the range of increase in average daily iodine intake (i.e. 30 mcg / day) will meet the Recommended Dietary Intake (RDI) for iodine of 150 mcg per day, especially in New Zealand.

As indicated in our introductory comments, the proposed iodine fortification approach will not deliver enough iodine for pregnant and breastfeeding women, whose current intakes fall well below the RDIs (220 and 270 mcg, respectively). This is evidenced from the results of the Thyromobile and Iodine in Pregnancy (TRIP) study (Porter et al 2006), which reported a mean UIC (Urinary Iodine Concentration) of 38 mcg/l and an estimated iodine intake of 48 mcg per day. Therefore, even if these women increased iodine intakes at the upper end of the 30-70 mcg range they would still be well below their respective RDIs.

Monitoring and review

As mentioned in our DAR submission, the responsibility for monitoring mandatory iodine fortification in New Zealand will lie predominantly with NZFSA and MoH. The NZFSA and MoH accept responsibility and recognise the need for on-going monitoring of the impact and safety of the proposed Standard. This is to ensure that iodine levels are sufficient to bring about a significant improvement in health status and to identify adverse affects from mandatory fortification. The NZFSA and MoH await confirmation of the proposed monitoring framework for iodine to determine if additional data collections will be necessary to meet monitoring requirements.

The need for a review of the effectiveness of the Standard is essential and a suggested time frame for this would be helpful. As this review will need to draw on health status data, a suggested time frame for a review of the Standard would greatly assist programming this work.

Costs

We note that the cost to Government of monitoring and communication were not included in the cost benefit analysis information presented by Access Economics Pty Limited for New Zealand, so this analysis is not a true reflection of the full costs of mandatory fortification. We would like to see these costs included in the FAR.

Salt Reduction Strategies

The Issues Paper refers to work undertaken by FSANZ to determine the impact of salt reduction strategies on the ability of bread makers to make claims about the presence of iodine in bread. As part of this work, NZFSA and MoH assume that FSANZ considered the impact that such strategies would have on the iodine intake and status of the New Zealand population; however, this has not been reported in the issues paper. Salt reduction strategies, which will include breads with a large market share, are already underway in New Zealand. We strongly recommend that FSANZ reflect the impact of such salt reduction programmes in their dietary modelling because the review process is unlikely to detect the impact of such strategies on iodine status quickly enough.

Changes in the fortification level, reconsideration of additional food vehicles or direct addition of iodine to bread, may need to be investigated in the future if reductions in the salt content of bread mean that the population does not reach expected intakes of iodine. This would need to be part of any review process.

Nutrition, Health and Related Claims for Foods Containing Iodised Salt

We acknowledge the potential role for nutrient content claims to play an important role in the promotion of iodine containing foods through voluntary fortification. However, such messages will need to be carefully managed through education and communication strategies as we would be disappointed to see the promotion and increased consumption of foods inconsistent with the Food and Nutrition Guidelines, because of their increased iodine content.

Food Composition Databases

New Zealand acknowledges FSANZ’s role for some components of an overall monitoring system, including the FSANZ contribution to updating Australian national food composition databases. We would be keen to work towards sharing food composition data between the two countries, particularly for foods that are the same, to avoid duplication.

Implementation

We are supportive of the proposal to implement iodine fortification over the same timeframe as folic acid fortification. This would result in a cost saving for bread manufacturers (and ultimately consumers) through having to only make one change to packaging. It also seems that there would be consumer education advantages to making the two changes simultaneously, in that the resources for the two campaigns could be combined and targeted with dual messages. This is strongly supported by MCA.

It will be important for industry to keep the MoH and NZFSA informed as to the timing of the change to iodised salt in bread making because any overlap with the 2008 NZ Adult Nutrition Survey will have implications for estimating iodine intake and interpreting urinary iodine results.

Communication and Education Strategies

The Issues Paper reports that FSANZ has prepared a strategy to guide communication and education initiatives to raise awareness and understanding of the proposed Standard. We assume this is a trans-Tasman strategy and, therefore, request that New Zealand be involved in the on-going development and review of the strategy to ensure the New Zealand situation is adequately reflected. NZFSA, MoH, and MCA are keen to be consulted on, and would like input into, the communication and education strategy.

While we recognise that iodised table salt will continue to play an integral role in meeting the iodine needs of some individuals, careful consideration will need to be given on how best to communicate health messages associated with the consumption of salt to avoid consumer confusion as this may be seen as a contradictory health message. In addition, as mentioned above, the voluntary use of iodised salt in manufactured foods may also be an important contributor of iodine to the diet of New Zealanders. Health messages about the importance of iodine in the diet will need to be carefully managed to ensure there is not an increase in the consumption of foods inconsistent with the New Zealand Food and Nutrition Guidelines.

It is of concern that the proposed new approach to iodine fortification is unlikely to deliver enough iodine to fully meet the needs of pregnant and breastfeeding women. In the absence of a suitable iodine supplement for pregnant and breastfeeding women in New Zealand, thought will need to be given to how best to assist these women in achieving their RDI for iodine.

References:

Porter AP, Skeaff SA, Thomson CD, et al. 2006. The Thyromobile and Iodine in Pregnancy (TRIP) Survey: Assessing the iodine status of New Zealand Pregnant women. NZDA Conference Proceedings. New Zealand Dietetic Association: Wellington.