ANZFA Annual Report 2000 - 2001
Contents, Chairman's Foreword, Managing Director's Foreword, The Right Balance, Corporate Overview, Portfolio Outcome
Part B - [ pdf ] Appendices 1, 3 -9
Appendix 1- Food Standards Report; Appendix 3 - Staffing; Appendix 4 -Functions and powers of ANZFA; Appendix 5 - current publications; Appendix 6 - Categories of documents; Appendix 7 - Consultants; Appendix 8 - ANZFA Representation; Appendix 9 - ANZFA Board
Part C - [ pdf ] Appendix 2 - Financials
Managing Director's Foreword
In my foreword to last year' s annual report, I said that 1999-2000 was in many ways a year of review with much of our efforts being devoted to the review of the Food Standards Code, a major internal review of ANZFA' s administrative arrangements and a number of external reviews which had the potential for considerable impact on our work. In the wake of that ' year of review' , 2000-2001 has been a ' year of implementation' - largely devoted to supporting the implementation of decisions taken the previous year.
New Food Standards Code
We are delighted that our work in developing a new Food Standards Code for Australia and New Zealand has come to fruition and that, in November 2000, the ministerial council adopted a very high proportion of all our recommendations while seeking modification of a small number. The council adopted 18 recommendations on Applications and 68 recommendations on Proposals during the year. They required major additional work on one which related to genetically modified food, and made minor changes to three applications relating to maximum residue limits and one relating to the labelling of alcoholic essences. The rest were adopted as recommended by ANZFA. Several aspects of the new Food Standards Code were varied but the overwhelming majority of these recommendations were also adopted.
This has been the culmination of a huge and ambitious task. It represents a major benefit to industry in removing a large amount of pointless red tape that had accumulated over past decades - removing this should reduce production costs and facilitate innovation and competition. Consumers, too, should benefit as the new code requires more information on labels to help them make informed, healthy choices about their food and maintains a high level of food safety protection. It also brings our standards much more in line with those of major trading partners and embodies current scientific knowledge about food safety.
We recognise how important it is for us to give guidance, particularly to small food businesses, to help them interpret and apply the new regulations. The larger companies are much more accustomed to dealing with regulation and have greater resources to help them do so, but they too will benefit at least from having a uniform approach to interpretation and implementation.
We devoted a great deal of effort this year to producing user guides, explaining the intention of key new standards and guiding companies on how to implement them. This process took longer than we anticipated, largely due to the fact that it wasn' t good enough for ANZFA just to draft and issue these guides, we needed to consult closely with industry and other users to ensure that the language and content was suitable for the intended audience. We also had to ensure that State, Territory and New Zealand enforcement agencies were confident that the guides were sufficiently clear, unambiguous and reasonable to maximise consistency in their implementation. Uniform implementation is critical given that it would be confusing and costly if there were different interpretations of the regulatory requirements placed on the compliance for a particular food as that food moved from one State to another or between Australia and New Zealand.
The Regulatory Process
ANZFA' s processes for reviewing and developing food regulation are highly transparent and participative. We are not permitted to review and develop food standards without publishing our intention to do so in respect of any particular matter. We are also required to provide, in almost all cases, two opportunities for stakeholder groups and the public at large to contribute evidence, ideas and opinion to guide and influence the review of the matter. In addition at the conclusion of the ANZFA review process we are required to publish our advice to the Ministerial Council as soon as practicable after that advice is tendered.
Community involvement strategy
As an organisation, we recognise that the involvement of the community in setting food standards is vital if we are to have realistic, workable food regulation.
During this year, we developed and released a community involvement policy and protocol. The protocol identifies around 20 steps we will take to improve community involvement. To begin this process we talked to about 40 stakeholder organisations. We asked them what we do well and what we don' t. From the information we received, we developed a draft strategy which was then circulated to stakeholder groups for comment. The strategy was amended accordingly and was then approved by the Board. The protocol was developed from this strategy and was again circulated to the stakeholder groups whose comments were built into the final version.
This protocol is intended to be used as a practical document by both community members and ANZFA staff to guide them and help them understand the processes which we will use in seeking community involvement in reviewing and developing food standards.
Genetically modified (GM) foods
The decision of the ministerial council in relation to GM food labelling brought about a standard which, when it comes into effect in December 2001, will provide for the identification of the overwhelming majority of all food produced containing genetically modified materials. The sharp reduction in our mail on this topic suggests the decision has made a very significant contribution towards alleviating consumers' concerns.
I also believe that public discourse on the issue has become considerably better informed in recent times with debate much more based on robust evidence and logic.
We also participated in the New Zealand Royal Commission on Genetic Modification. We provided submissions and background material and appeared as witnesses. ANZFA was very impressed by the thorough and balanced approach of the Commissioners which was reflected in a highly professional, objective, evidence-based report.
BSE
The spread of the BSE epidemic from Britain to Europe and the indicators that there may well be a spread of infected material far beyond Europe, presented a major challenge to us. Great credit is due to Australian and New Zealand quarantine, health and other authorities for their work towards excluding this menace from our countries to date.
Unlike other threats to food safety, the presence of viable BSE-infective material in processed food cannot be identified directly - no tests are yet available. We have, therefore, put a lot of effort into developing a new regulatory approach to safeguarding our food supply. This is a system based on assessing the rigour and comprehensiveness of BSE safety measures in the countries in which the beef and beef products are produced, as well as their known BSE exposure to date. These regulations will come into effect in the first part of the new financial year.
These are not, of course, the first steps taken to protect Australia' s food supply from BSE. As early as 1996, imports of bovine products from the UK were halted. An import suspension on bovine products from 30 European countries and Oman took effect early in January 2001. The new arrangements will replace this temporary import suspension and apply to all countries exporting bovine products to Australia. New Zealand has decided to develop its own arrangements.
I greatly appreciate the cooperation we received from other Australian government agencies in developing a mechanism which we think will be effective in keeping the risk to the Australian consumer to an absolute minimum without being unnecessarily trade-restrictive.
Novel Foods
A new standard on novel foods came into effect on 16 June 2001. In 1999, Ministers had agreed to our recommendation that companies should be given 18 months to prepare and lodge applications and provide data for approval of any novel foods they had in the market place or were proposing to develop for sale.
Applications were lodged covering only two classes of novel foods. One involved foods already on sale. Unfortunately some foods in one of those two groups did not meet the standard and had to be removed from shelves. On the basis of data subsequently provided to ANZFA, we decided that the other class of food for which we received an application was not a novel food in view of its extensive period of use in Australia and New Zealand under close medical supervision.
Manufacturers or importers considering new forms of food or using new technologies should take account of the novel food standard. They should discuss the product with ANZFA and, where necessary, lodge an application, along with the appropriate data, to ensure that the food is lawful before putting it on the market.
Irradiation
On 13 September 2001, Ministers agreed to the limited use of irradiation for herbs, spices and herbal infusions. This was the first irradiation application we had received. The scientific community around the world is becoming increasingly concerned about the toxic effects of some of the chemicals currently used for decontamination and disinfestation of food, and the environmental effects of some of the others. Irradiation is seen as a safer alternative to these. At the same time, we recognise that the transition from one technology to another cannot occur overnight.
Health claims
We have made a recommendation to the ministerial council which, if approved, will allow manufacturers in Australia to make promotional claims for certain foods, linking them with beneficial health outcomes. While the recommendation continues the current general prohibition on health claims, the new system would permit some claims on a claim-by-claim basis.
Food composition is widely accepted as being an important factor, positive or negative, in the health of our population. A regime which makes a positive contribution to public awareness of these links and which can positively influence consumer behaviour to help them make healthy food choices is, therefore, of huge potential benefit to the health of the community.
At the same time, manufacturers see the capacity to make claims about health benefits from food as an important element in allowing them to sell new and better products.
This would seem to be a win-win situation for both manufacturers and consumers, so long as claims are true - and this means giving high priority to robust substantiation. If consumers don' t have this assurance in relation to health claims, international evidence is that it is likely to weaken public confidence in other information on food labels such as the nutrition and other compositional information required under the new Food Standards Code.
Country of Origin
Late in 2000-2001, ANZFA commenced its review of the existing country of origin standards of Australia and New Zealand. We regard this as a difficult issue, and one that can not be readily be determined on the basis of a scientific assessment.
While some people believe that knowing the country of origin is important to allow them to avoid foods from countries whose foods do not have a history of being safe, in fact other food standards and the quarantine measures implemented by AQIS provide that protection. Country of Origin labelling is not, therefore, necessary for the protection of public health and safety. It may, however, be germane to other aspects of people' s values.
The existing standards in Australia and New Zealand differ markedly on this issue and we need to recognise that there are two different cultures in this matter.
International issues
We are in an environment where all major regulatory decisions need to be looked at from an international perspective as well as a domestic one. In both Australia and New Zealand, food sold abroad accounts for a large share of our employment and export earnings. We are very dependent on being able to trade in a relatively open world market. We continue to be conscious of new direct and indirect threats to free trade. ANZFA continues to participate actively in Codex Alimentarius and other international bodies that are involved with food regulation, not only to contribute our expertise, but also to be able, as far as possible, to ensure that our national food regulatory interests are fully taken into account and that we align with international standards.
We are making considerable efforts to collaborate and exchange scientific information and regulatory best practice with other advanced regulatory agencies. This year, we signed an Memorandum of Understanding with Health Canada in relation to GM foods. Canada has similar regulations to Australia on these foods and this agreement will allow us to share assessments and discuss problems. We have drawn upon the assessments undertaken in a number of other jurisdictions in the northern hemisphere to provide us with guidance on many of the major issues we have been dealing with during 2000/2001.
Within our limited resources, we continue to put considerable effort into programs in the Asia Pacific region. This is mainly capacity-building work, assisting neighbouring countries to draw upon standards and regulatory approaches which we have developed and found effective. This year we began a strategic review of this work to ensure our focus is on those projects where we can have the greatest beneficial impact. I appreciate the encouragement and financial support we have received from AusAID and from foreign affairs and trade agencies in both countries. Without their funding, we would be unable to perform this work.
We are also developing closer links with the World Health Organisation (WHO) in this work. One of our senior officers has recently completed a five-month placement with the WHO, where she has been assisting in the development of the Global Strategy on Food Safety. We will also be providing support to WHO in the planning and conduct of the World Food Safety Forum scheduled for October 2001.
We will also be working with the food regulatory area of the European Union (EU) in the latter part of this year on a number of current issues including the development of a new European food standards agency and on a number of other major new developments in the EU.
Consumer concerns
We are aware of growing consumer concern over the safety of food in the light of recent scares over dioxin, BSE and foot and mouth disease. In many cases, the apprehension is out of proportion with the actual danger. We have provided information directly to individuals and through the internet and the media, to help ensure that consumers had a realistic understanding of these risks.
We have recently been concerned at the results of analyses of soy and oyster sauces which revealed that a proportion of these contain dangerous contaminants, chloropropanols, believed to be a by-product of the of acid hydrolysis process when applied to soy protein. We have had to institute temporary measures to severely curb this threat while not restricting the availability of the majority of soy and oyster sauces which meet demanding safety requirements.
To protect consumers and to maintain public confidence in food safety, we must give close attention to new food processing technologies which are emerging. These include ultra high pressure, ultrasound, multiple hurdle and other decontamination and disinfestation technologies. Early indications are that these can add to the weapons available against food borne illness. However, we do not yet have enough knowledge of these to know how effective they are in different foods and what negative impacts they may have, if any.
My hope is that the regulatory system can be on the front foot in regard to major new technologies to ensure that we know enough about them to establish their safety before they come into general use. We must bring forward proposals for regulation where there is justified cause for concern and provide the necessary reassurance where there is none. At this early stage, we have no specific reasons for concern other than that some of these technologies might not be as effective with some classes of food, or with some classes of threat, as they were initially perceived to be. It is important that they are not regarded as a panacea and used to do things that they are not capable of doing.
Streamlining
Over the past year we have looked for ways of eliminating unnecessary aspects of our processes while improving the opportunity for interested groups to make submissions in an effective way. We are also improving the transparency and openness of our processes. The streamlining project has been directed towards improving the way in which we handle applications and proposals from start to finish and to avoid unnecessary duplication. It is also intended to make it clearer at the outset to our stakeholder groups what the issues are that we are considering, in order to give them a greater capacity to make effective contributions.
The results are now beginning to be reflected in new style documentation on our standards review and development processes. These should prove to be more intelligible to our stakeholders and briefer to read, through eliminating much of the past duplication. At the same time, they will meet the various statutory, treaty and other obligations which must be met through our documentation.
Food Standards Australia New Zealand
The change to the ANZFA Act has many implications for us in that we will no longer be directly servicing the ministerial council - we will still have direct links to the council, but the Commonwealth Department of Health and Aged Care will provide its secretariat. Nevertheless, as a very substantial proportion of matters considered by the council will be reports provided by ANZFA, we do not anticipate a major change to our work-load. We will also be providing papers in future for the new Food Regulation Standing Committee to help them understand the scientific basis for our conclusions to allow them to then generate their advice to the ministerial council.
In addition, we will have a major job of work to inform the public about the disappearance of ANZFA and its re-emergence as the new Food Standards Australia New Zealand at a time when ANZFA has become reasonably well known. Our challenge will be to minimise any confusion during the changeover period as to who should be approached in relation to food regulatory matters.
Thank you to staff and colleagues
This foreword would be seriously deficient without a tribute to the quality and quantity of effort from the staff and the Board of ANZFA. For all, there have been huge challenges, not only in the sheer volume of work, but also in the need to find fair and scientifically robust solutions to many complex problems - often in an environment where there were strongly held and widely divergent views across our various stakeholder groups.
To their credit, the staff and the Board stuck to their jobs throughout the year. They did not lose sight of the need to keep public health and safety as their first priority. They also gave due attention to the other statutory obligations they must satisfy. They went to great lengths to gather, listen to and weigh up the opinions of all interested groups. They gave high priority to ensuring that conclusions were based on robust evidence and sound science, and they put in the effort needed to meet all major deadlines.
The end result was the successful completion of a vast job of revision and updating of the food standards for the two nations. It stands to bring considerable benefits to the public and the food industry.
Thank you all for a job well done.
Ian Lindenmayer
Managing Director
ANZFA Annual Report 2000-2001
Part A - [ pdf ]
Contents, Chairman's Foreword, Managing Director's Foreword, The Right Balance, Corporate Overview, Portfolio Outcome
Part B - [ pdf ] Appendices 1, 3 - 9
Appendix 1- Food Standards Report; Appendix 3 - Staffing; Appendix 4 -Functions and powers of ANZFA; Appendix 5 - current publications; Appendix 6 - Categories of documents; Appendix 7 - Consultants; Appendix 8 - ANZFA Representation; Appendix 9 - ANZFA Board
Part C - [ pdf ]
Appendix 2 - Financials