The following is a copy of Gillian Blair's submission to the Food Labelling Review :

Att: Food Labelling Review Secretariat
Department of Health and Ageing
MDP 150
GPO Box 9848
Canberra ACT 2601 Australia

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cc: Parliamentary Secretary for Health, Mark Butler
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Drivers for Upgrading Labelling Requirements:

There are many drivers for much more stringent labelling requirements. Factors include:

The right of the public to know which foods contain genetically engineered foods, irradiated foods, or foods in nanotech wrappings or containing nanotech products, as none of the foregoing have been proven safe for consumption or use.

The dramatic rise in food intolerances, allergic reactions, and anaphylactic shock in people, and ill-health in animals, in the years since the introduction of genetically engineered food to the food chain;
 
The urgent requirement for people to be able to avoid foods to which they have negative or life-threatening reactions (or to seek out foods they desire to eat for health purposes);

The need for food processors, restaurants, school canteens, hospitals, etc, to be able to select or avoid certain foods or food constituents;
 
The need to be able to track down long-term and short-term sources of ill health and other reactions to foods, both for public health emergencies and for research purposes;
 
The Role of Government in Regulation of Foods:

It is one of the responsibilities of government to set up systems to safeguard the health of the population.

With the certainty of yet more changes in the genetics, food constituents, and processing of food, due to recent developments and new methods in food technology and farming, Government should therefore be setting in place legislation to prevent novel new food-borne health problems;
 
Although foods that are derived from new technologies or have been subjected to new processing methods (such as irradiation) are presently seen as bio-identical in Australia, scientists in other countries have discovered novel new constituents in some of these foods, and may discover more. An example of how something that was considered safe and healthy is now being removed because of new evidence showing harm is the removal of fluoride from water supplies in many towns and states in the USA.

It is necessary for scientific and health purposes to record food constituents in order to keep track of any health developments that may develop and may be related to foods. Epidemiological studies of food constituents are made more difficult without labelling.
 
Whilst FSANZ is responsible for ensuring that the food supply is safe, the assumption by FSANZ that genetically engineered or irradiated foods, or wrappings containing nanotechnology metals are safe has not been proven.

Until rigorous testing over a period of years has proven the safety or otherwise of genetically engineered or irradiated foods, or foods containing or wrapped in nanotech products, the government has an obligation to give the public a means of avoiding these products.  

 
Policies on Labelling:
 
Products under the category of Foods Requiring Pre-Market Clearance such as irradiated foods, genetically engineered food, plus foods containing nanotech products or packaged in nanotech wraps or containers lined with nanotech products (new metallic and other chemical substances less than 300 nanometres in size) should be fully labelled as such. These products have no history or proof of being safe for use, and the testing regimen is not fail-safe.    
 
The uncertainty principle must be allowed for in labelling of Foods requiring pre-market clearance. We do not know what we do not know, and scientists therefore do not know what to test, where to look or what to look for.

For example it took years to pinpoint Thalidomide as a teratogen, and chlorofluorocarbons were not identified as the cause of damage to the ozone layer until years after their release.

An additional factor is that FSANZ does none of its own testing, but relies on the word of manufacturers and licence holders.

Government and the public cannot allow food safety matters to be reliant on the word of vested interests: full labelling is essential.

Nanomaterials should be fully labelled, and subject to greater testing. It is insufficient for nanomaterials to be regulated only by Standards Australia. Where there is the possibility of consumption of these new products, either by intent or accidentally, then they should also fall under the jurisdiction of FSANZ and the NHMRC, with responsibility for testing to be conducted by the CSIRO and/or independent scientists.

Special Note re Fluorides:

Fluorides are known toxic substances never proven safe. They are presently banned from food and drink in most of the world. Many people have allergic reactions to fluoride even when in what government presently perceives as small doses. Like lead a few years ago, fluoride has now been scientifically recognised as poisonous in very low amounts.

The fluoride added to water supplies contains lead, mercury, cadmium, and other harmful substances that are poisonous at extremely low levels.

Products made with fluoridated water, or which have been fumigated with sulfuryl fluoride, should also be labelled, as levels of fluoride in some foods can reach as high as 90 parts per million.

Studies from China show neurological damage to babies and children at as low as .5 (point five) parts per million. Products made with or containing fluoride should also be labelled, showing content and amount.


Gillian Blair,
Public Officer / Secretary,
Sustainable Agriculture and Communities Alliance  (A0047711V)
Western District