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Response to the Otago Daily Times article ‘Proposed food law as tough to swallow’ (January 10 ’05)

19 January ‘05

Sir,

As your Editorial Food and sense (12 January) rightly pointed out, common sense should prevail in the outcomes of our current Domestic Food review project. An earlier article (Proposed food law as tough to swallow, 10 January) made a number of incorrect points and I would like to reassure your readers on these points, as a read of the five discussion papers makes clear (all available online at www.nzfsa.govt.nz or in hardcopy from us, call free 0800 693 721):

The proposals have been designed to ensure the programme is as cost effective as possible.

The charts that are in the public discussion documents reflect the best information available on diseases often associated with foodborne illness. The text accompanying them identifies the changing social patterns and data issues that help understand the charts and their limitations.

While it is admirable that food businesses in the Clutha district have not been shown to have yet been the cause of cases of foodborne illness, the rapid change and expansion in the range of things we eat and ways of preparing, handling and storing food, and the emergence of new foodborne pathogens does not mean that what was 'future-proof' 30 years ago is now still so. And it certainly does not mean that the rest of New Zealand is as lucky as Clutha has been.

Detailed and prescriptive control documents are not one of the preferred proposals and, even if adopted, would not necessarily result in businesses that are following good hygienic and food handling practice (much of which is easily learned and is common-sense).

Costs associated with food businesses vary widely across New Zealand at local government level depending, for example, on the level of funding either provided to food businesses by local government from local government revenues (cross-subsidisation from rate payers) or from food businesses to other local government activities (cross-subsidisation from food businesses). Overall operational costs across New Zealand are not expected to change but it is expected that greater transparency will result and some changes may be made as a result of this transparency.

NZFSA will not provide 'telephone directory-sized' templates. The proposals intend that plans are appropriate for the business. However, instead of expecting businesses to reinvent the wheel, or imposing consulting costs on businesses that do not want to, or cannot, develop a risk-based management plan, NZFSA is proposing to work with the relevant industries or sectors to develop simple and easy-to-follow templates and guidelines. This is merely good practice and will aim to ensure that any employee (not just the business owner) can access the proper information and procedures to deliver safe food preparation and provision.

It is difficult to understand why a 'small army' of verifiers will be required when all 30,000 of New Zealand's food businesses are already supposed to be regularly inspected. Some increase may result where gaps in the system are identified. Survey information provided by local government and public health units (published by NZFSA and available on the NZFSA website) suggests that the entire New Zealand local food industry is currently regulated at the ‘shop front’ by around 135 people spending some of their time in the area. A number of options in the Domestic Food Review papers provide for local authorities to deliver 'verification' instead of inspection services. Everything that a good local authority officer should be currently looking for will also be covered in the new system... the difference is that there will be national consistency.

We agree that all those involved in the food industry should have their say, and we encourage them to do so.

I would also like to stress that the proposals currently out for public consultation in the Domestic Food Review were developed after a great deal of discussion and input from many people and organisations - among them environmental health professionals from 15 local authorities around New Zealand.

Carole Inkster

Director (Policy)

New Zealand Food Safety Authority