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Agreed Outline and Content

Response to proposal:

On 30 June 2008 NZFSA circulated a proposal for the 2009 NZTDS to interested parties and also posted the proposal on the NZTDS website. Ten responses to the proposal were received. All were supportive of the proposal in general.

Some respondents made suggestions for inclusion of specific foods on the food list, in many instances however the food suggested was already included within a food type on the list, e.g. powered fruit drinks included within ‘fruit drink’. One respondent suggested the inclusion of breast milk, using information on the presence of contaminants or residues that are available from other studies to calculate the dietary exposure for a 6-12 month breast fed infant (as a new population group). However, breast milk will not be collected as part of the NZTDS). Changes made to the food list are discussed below.

Several respondents commented on the compounds or elements for which the foods would be tested, especially with respect to folic acid, fluoride, and bisphenol A. The reasons for not including analysis for folic acid were addressed in the proposal and this compound will not be tested for in the 2009 NZTDS. NZFSA did include fluoride analysis in the request for tender for the laboratory analytical services, however no tender was offered for this element. We also note that the Ministry of Health is currently completing analytical research on fluoride content of infant formula. Given the apparent unavailability in New Zealand of a test for fluoride, the current work being undertaken by the Ministry of Health, and budget constraints preventing going overseas for any analysis, NZFSA will not include any analysis for fluoride in the 2009 NZTDS.

In respect of the possible inclusion of bisphenol A, this compound is associated with either the packaging in which food is processed or sold (e.g. plastic or plastic lined), or the container in which food is prepared (e.g. micro waved / heated in plastic). Analysis for bisphenol A would therefore involve preparation of the food in such a way as to allow the compound to enter the food – this is contrary to the purpose of a TDS which is to identify what is in the food. TDS food samples are prepared ready for consumption with particular care to ensure that the sample is not contaminated by the preparation method. Further, those foods used in normal preparation, such as cooking oil or water, are analysed separately so that the contribution they make to dietary exposure can be accurately estimated. Identifying compounds that can be introduced through the utensils or containers used in cooking/heating a food, or by the particular process (e.g. microwave, stove top, BBQ/open fire) would involve separate preparation and analysis for each potential food/container/preparation method combination and would have significant resource/cost implications given the number of foods involved in a TDS. Analysis for bisphenol A is therefore considered to be more appropriate for a separate study if exposure to this compound is to be investigated.

Several respondents commented on the question NZFSA asked in respect of using the data from the 1997/98 Adult Nutrition Survey when estimating dietary exposures, rather than wait for the data from the 2008 Adult Nutrition Survey to become available. Of those who commented, only one suggested that the 2009 NZTDS be delayed; all others supported using the 1997/98 data and revising the dietary exposure estimates when the updated data becomes available. NZFSA will proceed with the 2009 NZTDS on the current timeline (as set out above).

Other matters raised by respondents were the inclusion of: a vegetarian and an older age group in the dietary exposure estimates, traditional Maori foods, and more ethnic foods. A vegetarian female was included in the 1997/98 NZTDS and no significant variation of dietary exposure from that of a female eating a mixed diet was identified. Information relating to changing dietary intakes, be it for a vegetarian or an older age group, will need to come from a national nutrition survey, unfortunately no such national information is currently available. The inclusion of traditional Maori foods was discussed in the proposal. It was noted that currently available information indicates that, for the average consumer, traditional Maori foods are eaten irregularly or only on special occasions.