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Proposal P1002 – Hydrocyanic Acid in Ready to eat Cassava Chips – Assessment Report

1 April 2008

Dear Sir/Madam

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

Regulatory Measure

In light of the recent issues NZFSA agrees that a maximum level for hydrocyanic acid in ready-to-eat cassava chips should be added to the Australia New Zealand Food Standards Code (FSC). NZFSA supports that the maximum level should be set at 10 mg/kg hydrocyanic acid, which is as low as reasonably achievable.

However we would like to propose that the scope be expanded from “in ready-to-eat cassava chips” to “in ready-to eat foods that contain cassava, including cassava chips”. Cassava chips are a relatively new product in the Australia / New Zealand marketplace and the number of products in this sector is growing. The proposed standard only captures products currently in the marketplace. Product innovation by industry could lead to the marketing of other ready to eat products containing cassava. Expansion of the scope of the proposed regulatory measure would negate the need to revisit the standard if other ready-to-eat products containing cassava were marketed.

Nomenclature

A maximum level of 10 mg/kg total hydrocyanic acid is consistent with the international standard for edible cassava flour and the nomenclature is consistent with existing provisions for hydrocyanic acid within the FSC. However NZFSA considers the term “hydrocyanic acid, total” as used in the FSC is misleading because the substance that is present in cassava is not what is usually termed hydrocyanic acid, but the cyanogenic glycoside linamarin. Hydrocyanic acid is a chemical term referring to a specific substance and that substance does not include any cyanogenic glycoside.

In the P1002 Assessment Report, FSANZ states that a maximum level of 10 mg/kg for hydrocyanic acid in ready-to-eat cassava chips in Standard 1.4.1 is proposed as an appropriate risk management measure while additional information is gathered about other cassava based foods and other foods containing cyanogenic substances. As noted above, while NZFSA proposes a broader scope for the standard pending further review, NZFSA would also like to propose that a nomenclature review should also be included in this additional work to ensure that the standard covers free hydrocyanic acid and substances which can release hydrocyanic acid.

Codex

We note that Codex Committee on Contaminants in Foods (CCCF) meets in the Hague in the week commencing 31 March 2008. Under Agenda Item 2 (Matters Referred to the Committee by the Codex Alimentarius Commission and/or other Codex Committees/Task Forces) the Proposed Draft Standard for Bitter Cassava will be discussed. Any relevant discussion on cassava/ hydrocyanic acid levels at CCCF should be taken into account when FSANZ prepares its approval report.

Yours sincerely