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FSANZ Work Plan

19 June 2009

Dear Sir/Madam

Thank you for the opportunity to comment on the draft FSANZ Work Plan dated 1 June 2009. The New Zealand Food Safety Authority has the following comments to make:

• P235, P236 and P242 are referred to on page 17 as having “unknown” timetables as they are respectively “awaiting policy guidance from (the) Ministerial Council”. In our view, it would be helpful to state which policy guidance is awaited as we understand that some of the required policy guidance has already been completed.

• We appreciate that section 20 of the FSANZ Act only strictly relates to applications and proposals. However, it may also be useful for the Work Plan to include reference to other relevant work, such as the status of reviews initiated under section 113 of the FSANZ Act, for example the allergen review. The objects of the Act include transparency, and we note that other work such as reviews may be relevant to listed work such as a particular application or proposal.

• We would welcome clarity concerning the review of the definition of “nutritive substances” that FSANZ has previously foreshadowed. While we note that the work plan describes A613 as on hold following gazettal of P306, it is not clear from the balance of the work plan as to how FSANZ is planning to progress its own review of the definition and its application in the Code, which it signalled in the P306 first review report. As previously stated, in light of the issues concerning P306, and the Nutricia decision in the NSW Supreme Court, NZFSA is concerned that this work needs to be accorded priority to ensure the integrity of the current infant formula standard, (pending the development of any revised standard, which may be some time away).

• The entry concerning PA 1002 needs updating to reflect the current status of the Proposal.

Yours sincerely