FOOD LABELS: A MATTER OF LIFE AND DEATH
A presentation by Ian Lindenmayer
Managing Director,
Food Standards Australia New Zealand
29th National Conference of the Australian Institute of Environmental Health
20-25 October 2002,
Manly Pacific Parkroyal, Sydney
Introduction
It's often said that the provision of potable drinking water in the late 19th century did more to reduce infant mortality in Australia than all the wonders of medicine to that date.
Since those days, State and Territory governments and local authorities have put in place a sophisticated network of regulations, controls and infrastructure to protect the health and safety of the community. We can take a pride in this accomplishment, except, perhaps, for our inability to extend this level of wellness to our indigenous citizens.
Just as clean drinking water was the trigger for a healthier population a century ago, food is poised to be the 21st century equivalent.
We have in place national food safety regulations and enforcement regimes that will reduce the current seven million cases of food poisoning a year. We have a system of pre-market safety assessments for novel foods and technologies prior to them entering the marketplace. We have limits for contaminants and chemical residues in food and a national food recall system for unsafe food products.
We also have the new Food Standards Code which, on the surface, deals with the compositional and labelling requirements of food, but which I suggest to you has the potential to revolutionise the eating habits of Australians to the extent that hundreds, if not thousands, of lives will be saved each year.
The new Code comes into full effect on 20 December this year and much of the burden of enforcing its provisions will fall on your profession. Traditionally, in their food regulatory role, environmental health officers have placed the highest priority on protecting public health and safety from microbiological hazards. This is entirely appropriate. Defects in the handling and preparation of food that compromise the immediate health of consumers deserve your attention.
However, there is a growing body of evidence indicating that the nutritional make-up of the food supply is crucial in determining long-term health and longevity. In other words, the advent of nutrition information panels on all packaged food labels, in conjunction with public debate on food issues such as obesity, could lead to significant changes to diet in the population - changes that could have a profound influence on morbidity and mortality.
I intend to develop this issue later in my presentation. I hope to be able to convince you that enforcement of the Food Standards Code is not simply a matter of ensuring compliance with black letter law. Rather, it is the means by which you can make a contribution to the long-term health of the nation through the reduction of diet-related disease.
During this presentation, I intend to say a word or two about my agency, Food Standards Australia New Zealand, which many of you will remember fondly as ANZFA.
I also want to talk about the important new provisions of the Code and about our concerns about compliance with it on 20 December. Associated with compliance is the matter of consumer confidence in food labels and our worry that deception in one area of the label could lead to total distrust of everything on it.
And, I will conclude with a discussion of over-the-horizon issues, such as emerging problems for the food supply, food packaging as a source of contamination and the vexed issue of functional foods.
Food Standards Australia New Zealand
As most of you will be aware, the Australia New Zealand Food Authority became Food Standards Australia New Zealand (FSANZ) on 1 July 2002. The major change to our role is a new responsibility for a paddock-to-plate for food safety.
I mention this because, although EHOs have not traditionally been involved in safety at the agricultural end of the food chain, I understand that New South Wales is looking to integrate enforcement functions more closely and other jurisdictions may follow.
FSANZ is an independent bi-national statutory authority that develops food standards for Australia and New Zealand. It also has additional responsibilities in Australia - for example, the coordination of food recalls and the monitoring and surveillance of food safety. The enforcement of food standards in Australia rests with State and Territory governments (and with the Australian Quarantine and Inspection Service for imported food), and with the New Zealand Food Safety Authority in New Zealand.
The prime objective of FSANZ is to protect the health and safety of people in Australia and New Zealand through a safe food supply. Historically, we have achieved this mainly by developing food standards that govern the manufacture and labelling of processed foods and, more recently, in developing the food safety standards which apply to Australia only.
Under the new arrangements, responsibility for the development of primary production and processing standards has been transferred from the Agriculture and Resource Management Council (ARMCANZ) to FSANZ. Australia now has a framework for setting food safety standards for the whole food supply, from primary production to processed foods.
This should help ensure that there is much greater consistency through the food chain in the regulatory standards applying to the various stages, from production of raw commodities to the meal on the plate.
FSANZ's risk-based approach to setting food standards will be brought to bear on primary industry, including the meat, dairy, seafood, horticulture, grains, eggs, poultry and honey sectors. Changes will be considered in consultation with industry and other stakeholders. Two rounds of public consultation will normally occur for proposed changes to standards. And every stage of the standards-setting process will be transparent and inclusive.
We have already begun work on a standard for the seafood industry and the FSANZ Board has recently appointed people to a Seafood Standard Development Committee that will contribute heavily to the process.
Our expertise, of course, lies in the development of product standards for processed foods. Our relationships with food manufacturers and the retail industry have been built up over many years. We have not had the same level of interaction with the primary production sector and so there is much work to be done to build those bridges that improve the sharing of knowledge between industry and regulators and help inspire confidence in each other.
As a food regulator, FSANZ has always taken, and will continue to take, a conservative approach to food safety. I make no apology for this. It is better to err on the side of caution than to risk serious injury to consumers and the inevitable loss of public confidence in the food supply.
This is why we regard novel foods entering the marketplace and new food production technologies, such as gene technology and food irradiation, as unsafe until their safety can be proved. We will continue with this approach as we develop the primary production and processing standards.
It is very important that we recognise that at all parts of the food regulatory system, we must apply evidence-based risk management principles to our work. Some members of the community demand that we ensure that all food is completely or perfectly safe. We simply can't guarantee that.
All foods have the potential to cause health problems if eaten to excess or if consumed by people who have sensitivities or allergies to them. All food is open to contamination with chemical or microbiological contaminants in production or storage or transport or manufacture or in preparation for consumption. However, we also know that the most dangerous approach toward food is to not eat or to unreasonably exclude a wide range of foods from one's diet - such approaches automatically lead to starvation or serious malnutrition or dangerous overexposure.
The regulatory system must also recognise that if it becomes excessively demanding it can unreasonably raise the price of food or at least make many foods unaffordable for the least affluent members of our community. It could also have the effect of driving important foods out of our food supply in general and thus reduce the availability of the wide diversity of vitamins and minerals and nutrients critically important to long term health.
We are very fortunate in Australia to have one of the safest food supplies in the world. This did not occur by accident. It is expressly the result of our not having taken food safety for granted.
We have achieved this through a high level of cooperation between government and industry to develop regulatory standards, and enforcement arrangements and safe food production and handling methodologies to achieve that end. We are also fortunate in having a growing public awareness of the vulnerability of food to contamination and awareness of means for controlling those hazards in the home.
Over recent years there have been many highly publicised food safety crises around the world. The BSE problems in Britain, Europe and a number of other countries are simply one example. These crises have had wide ranging effects throughout the societies in which they have occurred.
Not only have they caused death and injury to significant numbers of people, they have also brought about a major loss of trust in the safety of the food supply and the effectiveness of the food regulatory system. This has done great damage to customer confidence in both domestic and international markets.
Australia has long been heavily dependent upon maintaining its strong world position as an exporter of primary food commodities and we are currently developing our capacity also in the manufactured and processed food market. It is vitally important that our food safety mechanisms do not break down and damage the existing high standing we enjoy as a producer of safe food.
Environmental health officers in local councils and their State and Territory counterparts have an important role in maintaining this high level of public trust. Nowhere is this better illustrated than in the national approach to surveillance activities and food recalls. As a network, we are getting better all the time. The work of State and Territory food officers through the Technical Advisory Group (TAG) is especially valuable in this regard.
Food recalls are currently running at an all-time high. Some sections of the media see this as a sign of weakness in the food regulatory system instead of, as it is, a sign that the system is doing its job. Almost all the recalls are initiated by the companies that have manufactured or imported the food, demonstrating the willingness of food manufacturers to act as full partners in the regulatory process.
Labelling provisions of the new Code
Turning now to the new Food Standards Code: as I mentioned before, it comes into full effect two months from today, after a two-year transition period to allow manufacturers to re-label their products.
As with all good contemporary regulation, the Code seeks to impose the minimum requirements necessary to achieve its objectives. In many parts, it is less prescriptive than the previous regulations, relying instead on outcome-based solutions. Industry, especially, should welcome the new freedoms in the Code to innovate and keep up with consumer needs.
Concurrent with the removal of outdated prescriptive commodity standards for specific foods from the Code, there has been an increase in generic mandatory labelling requirements. The new labelling regulations have been designed to enable consumers to understand more about the content of products in order to make choices that are better informed, healthier and safer.
This information is necessary as consumers become more conscious of the nexus between food and health.
A major study by the Australian Institute of Health and Welfare [AIHW, 1999] of the burden of disease and injury in Australia has found that cardiovascular diseases (20%) were the leading cause of overall disease burden, followed by type-2 diabetes (3%) and colorectal cancer (3%). These are all diet-related conditions. While not the only contributor to obesity, inappropriate nutrition is a major causative factor and obesity is closely associated with many of these diseases.
The chairman of the World Health Organization-linked International Obesity Taskforce, Professor James Ring, warned Australian health ministers in late 2001 that the 'scourge' of obesity could consume our health budgets. He said the number of obese and overweight Australian adults has increased from 40% to 60% in the past 18 years. Some 30% of children are overweight, exposing themselves to early death.
The recent NSW Government Childhood Obesity Summit served to underline this warning by issuing a series of recommendations aimed at addressing the problem. I am delighted that other jurisdictions are also focussing on this issue.
Diet-related disease hospitalisations in New South Wales in 1991-92 comprised 13% of all hospitalisations. Another paper has put the total cost of diet-related disease in Australia a decade ago at $1.52 billion direct costs and $0.7 billion indirect - a total of just over $2.2 billion - and the problem has grown since then.
These data, I believe, make a strong case for our continuing to seek out means of achieving improvements in the healthiness of the national diet in the interests of relieving the already intense pressures upon public and private health spending and, of course, alleviating the personal pain and suffering associated with the many diet-related diseases.
Obviously, improved food labelling, by itself, will not direct people into healthy diets.
Labelling has the potential to provide people with information about the individual product. However, while having that information is a necessary condition for making healthier food choices, it is not sufficient just in itself.
People also need to know what they should be looking for and why and for whom various nutrients are important. They need to understand, for example, the importance of balance in their diet and individuals need to know about which food characteristics they need more of and which they should be consuming less of.
The extent to which labelling can contribute will be dependent on the extent to which manufacturers meet the requirements of the new Code, as well as on the growth of consumer awareness and understanding of the information on the labels.
But food labels are the only means by which consumers can gauge the nutrition content of a particular food product. Importantly, the label provides the means of equipping the consumer to make an informed choice between several products of the same type sitting side by side on the shelves. If the required information is not present or if it contains false or misleading information, the consumer may well be led into making a decision contrary to his or her intentions and best interests.
Nutrition information panels
Earlier this year, it was suggested that the implementation date for the new Code should be delayed for a further year to give industry three years, rather than two, to review products and labels.
FSANZ undertook a study of the health impacts of a further year's delay in regard to one part of the Code - the labelling. This was not a simple task. While we had information that nutrition information influences consumer choice in Australia, we did not have information on the extent of that effect. We were fortunate, however, in having some United States data based on a study of the impact of mandatory nutrition labelling on packaged foods in that country.
The study indicated that consumers principally respond to negative nutrition information - such as high fat, high sodium and high calories. The US study indicated the market share of products that were rated least healthy in nutritional terms declined by 4% in well-educated neighbourhoods and by 5.7% in the lesser-educated neighbourhoods following mandatory nutrition labelling.
We brought together these figures with the extensive work undertaken by the AIHW on diet-related diseases. These diseases are mainly related to three risk factors: obesity, hypertension and high blood cholesterol.
These factors are strongly associated with several forms of cardiovascular disease, stroke, several forms of cancers, diabetes, osteoarthritis and disease of kidneys and gall bladder and back problems. The AIHW analysis attributed to each of these diseases a measure of life years lost (known as DALYs, or Disability Adjusted Life Years).
For purposes of the study, it was assumed that the Australian market response to better nutrition information would be the same as that in the United States. This is not an unreasonable assumption, given that both are affluent countries with high standards of education and literacy, high rates of change in food products on the market and rising interest in health and diet.
On the basis of this assumption, we could expect that a delay in the nutrition labelling would lead to between 320 and 460 additional deaths from diet-related disease for each year of that delay.
It would also impose substantial additional costs on the health system and on private individuals, as well as the pain and suffering associated with the resultant disease and mortality.
My point is that food labels are not simply marketing tools. They are the means by which a population with an increasing concern about diet and health is trying to pick its way through 50,000 items in a supermarket in search of healthy diets for themselves and their families.
Special declarations and advisory statements, including allergen labelling
Foods, food ingredients or components of an ingredient that can cause severe adverse reactions in some people - for example, peanuts and other nuts, seafood, fish, milk, gluten, eggs and soybeans - must be declared on the label, however small the amount.
Most people with an intolerance to these food constituents experience relatively short-term discomfort. However, for a small group of consumers, exposure to these ingredients or their products does not result in just a rash or feeling of malaise. It can produce anaphylactic shock, sometimes leading to brain damage and death.
Mandatory declarationsfor these foods and their products are an important public health requirement.
Other foods that may cause problems for consumers or pose a possible health risk to vulnerable groups within the community must carry anadvisory statement. Perhaps the best known is for added caffeine in energy drinks or chocolate bars. The food must be labelled as 'containing caffeine'.
The Code also makes provision for a third class of statement -mandatory warning statements -where there is a serious possibility of loss of life or serious injury to a sub-set of consumers. A warning statement about the bee product royal jelly is currently being considered.
Date marking
Date marking, either as a 'use by' or 'best before' date, provides a guide to consumers on the shelf life of the food. The 'use by' date is a valuable piece of public health information. Foods that have a 'use by' date are prohibited from being sold after this date because the food may then pose a safety risk.
Other foods will be marked with a 'best before' date. Foods can continue to be sold past the date provided they are fit for human consumption. Foods sold after this date may suffer a loss in quality which may result in consumer disappointment (but not injury) and a consequent loss of future sales for that product.
Representation of foods
This issue came into public focus recently after a survey by the Australian Consumers' Association reported alleged deceptive practices by manufacturers on food labels.
An example of this would be the highlighting of a desirable ingredient in the name of the product, while the ingredients list shows it to be present in minor, if not negligible, proportions. A hypothetical illustration might be a product sold as apricot pie where small amounts of apricot are augmented by larger amounts of cheaper fruit, colouring and flavouring. It does, in fact, contain some apricot, but most of the content is other material dressed up as apricot - yet this is called an apricot pie!
Percentage labelling requirements in the new Code will, I hope, reduce the incidence of this type of practice. This is not a public health matter. However, the resources of the ACCC and State and Territory fair trading agencies are limited in dealing with blatantly misleading food labels and my concern is that such practices will reduce public confidence in food labels.
Consumers expect true and accurate information on food labels. If parts are perceived to be false, all information on the label will be treated with distrust. This will severely diminish the power of labels to guide the consumer towards healthier food choices.
Health and nutrition claims
However, claims linking a food product with a disease or with some nutritional benefit do lie within the realms of public health and safety. They have the capacity to severely distort people's diets. They can hold out the promise of a benefit without substantiation.
At present, health claims are prohibited in Australia and New Zealand. The matter is being examined by the Food Regulation Ministerial Council, but health claims are not lawful at this stage. An exception is the folate health claim that links increased folate consumption to a reduction in neural tube defects in babies, such as spina bifida.
Nutrition claims such as 'lite', 'low fat' and 'reduced salt' are lawful but, as indicated earlier, these claims are subject to an industry Code of Practice on Nutrition Claims (CoPoNC), administered in Australia by an industry committee, which is not enforced by EHOs, State or Territory governments or the government of New Zealand.
I believe these self-regulatory arrangements for the management of nutrition claims have been a failure. Despite a requirement to report publicly each year, the Food Code Management Committee administering CoPoNC has not produced an annual report for four years. This committee is required to review complaints each quarter, but has only met once since August 1999. And the one complaint dealt with by the committee in August 2001 remains unresolved.
The attitude to CoPoNC by some food businesses can be illustrated by a response last month by a smallgoods manufacturer to a notification by a State health department that its 'low fat' claims breached the CoPoNC guidelines:
'The Code of Practice that you refer to is a voluntary code to which our
company had no input nor were we requested to be a signatory to its
recommendations. Accordingly we do not see that we should be bound by it.'
With the growing community concerns about obesity and diet-related disease, it is becoming increasingly important that nutrition claims be both truthful and not misleading. We need not just a clear specification of the requirements, but also a means of ensuring that all food businesses making such claims comply strictly with the rules that are adopted. My hope is that this will be one of the key outcomes of the current review of nutrition claims.
Again, the heart of the matter is the honesty of the information on the food label and the public's ability to trust what the label says.
Compliance with the new Code
It is clear that some companies will not be fully compliant with the Food Standards Code by 20 December unless they begin to give high priority to this task without further delay.
Information received by FSANZ through contact with individual food companies and industry surveys tells us that some businesses have not regarded compliance with the new Code as a priority and did not start work on the new labelling and composition requirements until late in the piece.
A few businesses claimed that they were unaware that the food standards had been changed. Others said they had delayed action until after ANZFA had produced its user guides late last year or blamed difficulties in using the web-based Nutrition Panel Calculator to prepare nutrition information for food labels.
I acknowledge that some of our efforts to assist industry during the transition period may have been less than fully effective. In particular, I accept that the Nutrition Panel Calculator has not been able to keep up with the demands on it. Quite frankly we had not expected the extent of demands.
We have taken a number of steps to enhance its capacity, but each time growing demand overtook the expanded capacity. However, last Friday we acquired broadband capacity for our website that effectively provides a fifty-fold increase in access. While we are expecting a further surge in demand over the remaining two months, I am confident that our expanded capacity will largely overcome the past access problems.
We have also put in place other services and products to assist industry. These include not only the publication last year of User Guides covering the major areas of doubt in industry about the standards, but also the publication of the answers to industry's Frequently Asked Questions through our website. In addition, we have maintained an expert industry helpdesk throughout this period which has provided a full enquiry service to food companies.
We have also gone to considerable lengths to alert the public at large about the advent of the new Code, through FSANZ publications and the generous assistance of trade bulletins and other publications.
I do not underestimate the work involved in identifying the information required for new food labels and the physical task of redesigning and printing the labels for thousands of food products. Nevertheless, I must admit to being somewhat surprised that some businesses claim to be unaware of the compositional content of their food - that is, the recipe used for producing it.
But what of the awareness of environmental health officers to the new Code? Does your profession fully understand its provisions and the enforcement responsibilities that flow from them?
FSANZ commissioned NFO Donovan Research to carry out qualitative research on several stakeholder groups with an interest in the new Code. Its report was published in April 2002 and appears on the FSANZ website. EHOs were surveyed as a distinct stakeholder group.
Typically, the EHOs who participated in the research spend 60-80% of their time on food-related issues, of which 10-15% (or less) was spent on food labelling issues. Food safety, food handling and hygiene occupy most of the food-related time. In very small offices, as little as 20% of an EHO's time could be devoted to food-related issues.
At present, EHOs mostly respond to complaints from the public and food industry competitors about labelling, rather than proactively check local manufacturers' labels to ensure compliance.
Enforcement of most food labelling standards was considered a low priority by the majority of EHOs surveyed, particularly those aspects that were viewed as consumer information or fair-trading issues - for example, nutrition information panels and percentage labelling. Allergen labelling, date marking and ingredients list assumed the highest priority in the context of the low priority of labelling overall.
These results will not surprise you. The problems associated with food-borne illnesses are obviously immediate and deserving of attention and resources. I also understand why the prosecution of food-labelling non-compliance takes a very low priority compared to food safety breaches.
What is needed, I believe, is a change in the mindset of enforcement away from dead bodies to the saving of lives not yet lost. This paradigm shift is needed if we are going to reap the benefits of food labelling to guide consumers to healthy eating lifestyles.
I should stress that I am not suggesting a huge switch away from microbiological pathogens and other immediate threats to the health of the consumer. What I am encouraging is that enough attention be given to labelling breaches to get the message across that our enforcement network is not turning a blind eye to them and that manufacturers and importers can therefore not safely disregard this important aspect of food regulation.
With rising consumer expectations we can all expect brickbats from the community if there is cause to believe that food businesses are getting away with erroneous, misleading or absent key information on labels.
The theme of this conference is 'The Living Profession' and I note your conference convenor's comment that this theme 'recognises the constant growth and evolution of environmental health to meet ever-changing community needs'.
I am heartened by this willingness of your profession to embrace change. May I suggest that, in relation to food-related enforcement activities, the evolution of your role gives greater weight to the prevention of long-term, chronic disease burdens in addition to the acute and immediate?
For this to occur, you will need to be at your persuasive best in arguing your case with your council management, especially your CEO, because priorities are usually set in terms of the allocation of resources. Within the environmental health profession, I encourage you to debate the issue fully.
While this debate unfolds, 20 December 2002 looms large. Non compliance with the Food Standards Code by industry is not an option. The eyes of consumers and consumer organisations will be on the supermarket shelves to catch manufacturers and retailers who attempt to cheat on them.
It is probably not an overstatement to say that enforcement of food regulations will be in the spotlight as never before from early next year. The stock-in-trade provisions for food already manufactured and packaged prior to the transition date may muddy the waters a little, for there may be many items on the shelves, with old labels, that can lawfully remain for 12 months or 24 months (for long-life products). Nevertheless, consumers will want to know if manufacturers are breaking the law.
I therefore urge all EHOs to familiarise themselves with the provisions of the new Code and to take advantage of the information and training provided by FSANZ and by State and Territory agencies.
The food regulatory chain is only as strong as its weakest link. All of us involved in the system have an obligation to ensure that the public's trust in the food supply is not only maintained, but also enhanced. I have every expectation that the environmental health profession will rise to the challenge.
Future food issues with health implications
Part of this challenge will be to deal with food issues that may be unforseen or only partly understood. BSE is a case in point, but it is by no means unique nor is it the only problem resulting from the globalisation of the food supply.
New problems in food safety
The Swedish discovery of acrylamide in some foods earlier this year took national food regulators by surprise. We know that some forms of acrylamide are considered to be an occupational health and safety hazard. But we do not know about the safety of the acrylamide recently found in food. The World Health Organization has called for more data from member countries.
Similarly, the presence of chloropropanols in soy and oyster sauces at unacceptable levels led to the removal of fourteen products from supermarket shelves in Australia in 2000 and 2001. Other foods are now being tested in several countries for the presence of these potentially carcinogenic compounds.
No country has robust data on the levels of these chemicals in the food supply, the mechanisms for their formation or the nature and likely timing of their impact on human health. We can expect more, rather than less, of these discoveries as analytical procedures improve and detection of other chemicals becomes possible.
Consumers expect FSANZ to adopt a prudent, cautionary approach to such challenges to food safety - and we will respond accordingly as soon as we have a basis for doing so which avoids the hazards of both under-reaction and over-reaction.
Packaging
To date, packaging has had a clear run in Australia. Few concerns have emerged about the way food is presented for sale. However, new information suggests that there is a potential for chemicals to leach from the artificial packaging into foods.
Some classes of foods have properties, such as soluble fats and acids, which can assist the leaching of chemicals from the packaging materials. The use of recycled materials for packaging may break down the structure of some of the chemicals in the materials and facilitate the leaching process.
There is also the concern that recycled packaging may be less stable and that it may not be as effective at inhibiting the entry of human pathogens to the food as new packaging materials. We are also in the early stages of examining this issue.
Functional foods and nutraceuticals
The challenges posed by functional foods and nutraceuticals are large and varied. There has been a rapid growth of these foods in the market. They purport to bestow health benefits on consumers, often through the use of botanicals as ingredients and, no doubt, some do make a contribution.
These foods are proving difficult to regulate and, I would imagine, enforcement of the regulations would be even harder.
As I see it, some functional foods have the capacity to usefully complement the food supply for some population groups. But many are redundant for large parts of the population because they duplicate nutrients already in diets in ample quantities. The question is therefore: are functional foods a safe part of the food supply?
In many cases, the ingredients are active in complementary medicines. They are marketed as 'natural', as if the word is synonymous with 'safe'. Yet, some of the most deadly human toxins come from plants and animals.
While few people would contemplate sharing their heart medication with the rest of the family, the potential exists for functional foods to be regarded as a food to be eaten by all - children, pregnant women and the aged. Clearly, they are not safe for all. The question mark over their safety must remain.
We need to address these issues with the Therapeutic Goods Administration and other drug regulatory bodies. In doing so, we need to recognise that they are not a homogeneous class of products and that the optimal regulatory response will need to reflect their differing likely risks and benefits.
Concluding remarks
I gave this presentation the title 'Food labels: a matter of life and death'. Some of you may regard this as hyperbole - a gilding of the lily to achieve my objectives. But, the evidence shows that food regulation, including mandatory label requirements, does have the capacity to save lives and to increase the quality of life.
Strong enforcement is vital to the success of the Food Standards Code in protecting public health and safety. Weak enforcement, especially in the area of food labels, will undermine the capacity of the Code to provide consumers with the information necessary to design diets which confer optimum health benefits.
The pre-decimal proverb of 'penny wise, pound foolish' probably sums up the situation. A dollar spent today on preventing unhealthy eating may well save a hundred or a thousand dollars down the track in health bills, compensation payments and disability pensions. New hospitals may not be required and, above all, the human suffering from diet-related disease can be reduced.
EHOs have a vital role to play in this scenario.
It is my fervent hope that FSANZ will be able to develop its relationship with environmental health professionals so that we are full partners in the food regulatory process. We need to tap into your knowledge and expertise in the field to tell us to what extent the Code is being complied with and how it can be modified to achieve a safer food supply.
Australia has one of the safest food supplies in the world. Wouldn't it be a feather in our collective caps if we could claim that the regulatory system responsible for this level of safety had made a big contribution to slashing the incidence of diet-related disease?
December 20 is the first day of the rest of our regulatory lives. I wish you well.