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Proposal P1003 – Mandatory Iodine Fortification for Australia – Assessment Report

16 May 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 – firstly regarding the editorial notes, and secondly on the transition period.

NZFSA supports a joint standard for this important public health issue. NZFSA has been in discussions with FSANZ on two changes that we seek to the editorial notes, in relation to the New Zealand standard. We seek these changes for New Zealand, however if they are also applied to bread produced in Australia, we would support this.

The changes NZFSA seek to the editorial notes are as follows. These are the changes that have been dealt with in an administrative process, in discussions between the NZFSA and FSANZ legal teams.

Additions to the Editorial Notes:

1. New Zealand requests an addition to the first Editorial Note to clause 5 as follows. The additional text is shown as “bold text in square brackets”. Please note it is section 11L not 11C of the Food Act 1981.

The intention of clause 5 is to require the replacement of non-iodised salt with iodised salt where it is used as an ingredient in bread. [The New Zealand Standard issued under section 11L of the New Zealand Food Act 1981 that adopts clause 5 limits the application of this standard to bread produced for the domestic market only].

2. New Zealand requests an addition to the third Editorial Note to clause 5, as follows. The additional text is shown as “bold text in square brackets”:

Standard 2.10.2 sets out the compositional requirements for iodised salt. [The target level of iodine when manufacturing iodised salt for addition to bread ideally would be at least the mid point of the iodisation range, i.e. at least 45 mg iodine per kg of salt].

The reasons for seeking the above amendments are as follows

Exemption for Exported Bread

One issue that has arisen for New Zealand relates to the export of bread (in the form of frozen dough) to Japan, an overseas market that does not permit iodine fortification. Under the Food Act, standards applying in New Zealand also apply to products for export. In order to retain this export market, manufacturers would need to be able to produce and export bread and/ or frozen dough that did not contain iodised salt. The New Zealand Food Standard 2002, implementing the New Zealand only iodine standard, already provides an exemption for bread for export.

Salt iodisation range

NZFSA supported the wider range of 25-65 mg iodine per kg of salt in order to progress the proposal. However, NZFSA is of the view that a change to the editorial note in the Draft Variation is required, so that the target level of iodisation is at least the mid point of the range (45 mg iodine per kg of salt). The dietary modelling for New Zealanders was based on this level. Remaining silent on the target level may result in salt iodisation levels at the lower end of the fortification range (25 mg iodine per kg of salt) which would result in fewer individuals meeting their Recommended Dietary Intake (RDI)¹ for iodine.

Transitional Period:

The preferred approach for P1003 identified in the Assessment Report, is to amend the New Zealand only mandatory iodine fortification Standard so it becomes a joint Standard for both Australia and New Zealand. The proposed draft variations to the Code are expected to come into effect 12 months after gazettal of P1003. The commencement date for the New Zealand only Standard is 27 September 2009. This date allows industry to prepare for the changes necessary for fortification, and is also consistent with the implementation date for the New Zealand food standard on mandatory fortification of bread with folic acid. We therefore would not wish to see any change to the implementation date for New Zealand.

Yours sincerely

¹ Recommended Dietary Intake (RDI) is the average daily intake level that is sufficient to meet the nutrient requirements of nearly all (97-98 percent) healthy individuals in a particular life stage and gender group.