May 16, 2008

Food Standards Australia New Zealand
PO Box 7186
Canberrra, BC ACT 2610
AUSTRALIA

RE:  Proposal P1003 Mandatory Iodine Fortification for Australia Assessment Report

On behalf of the children of Australia and New Zealand and the salt producers of these countries, the Salt Institute again extends our congratulations to FSANZ for devising a rational, measured response to an emerging problem of iodine deficiency.  The Salt Institute fully supports the efforts of the ICCIDD, WHO and UNICEF who have led the international effort for the last generation; the Institute is a leading member of the Network for the Sustained Elimination of Iodine Deficiency and representing the Institute I serve on the ICCIDD Board of Directors.  While these organisations endorse universal salt iodisation, they also recognise the unique circumstances in which Iodine Deficiency Disorders are manifest in different areas.  Therefore, choosing iodised salt as the vehicle and extending its use in measured steps is a strategy consistent with the experience of the worldwide campaign to virtually eradicate the scourge of IDD.  Most importantly, mandating use of iodized salt in a limited universe of foods (e.g. bread) offers FSANZ an opportunity to monitor and adjust its strategy as consumer behaviour becomes manifest. 

Thus, we continue to believe the proposal would be strengthened by including a strong statement that the government is committed to protecting and enhancing the mental development of the next generation through the iodisation of salt and that this proposal is merely the first step to carry that policy into effect.  That will put the public and the food industry on notice that an extension of the use of iodised salt would be in order should the current intervention fall short of its expected achievement of adequate iodine intakes for the population.   

We would emphasize the basis for our support of Proposal P1003: 

• Replacing plain salt with iodised salt in bread is technologically feasible and well-tested.  The assessment report is incontrovertible.   Some of the public comments on P230 for New Zealand noted this is the initial step and judged it part of the solution of overcoming population iodine deficiency.  We agree P1003 is an initial step and more may be required, but would remind FSANZ of the importance of iodised salt as the entire solution with regard to fortifying a food.  Salt is consumed in predictable amounts which is a major reason why iodised salt is not only the preferred vehicle to deliver iodine supplementation, but an important reason to confine authorization of iodine fortification to this ingredient alone.
   

• The use of iodised salt is the international standard.  WHO, UNICEF, ICCIDD all endorse salt iodisation.  Some comments to P230 expressed concern with salt.  Not only is there evidence that iodizing salt is the most cost-effective strategy, but that salt intake levels are not impacted by use of iodised salt.  And FSANZ is probably tracking the emerging medical literature examining the health outcomes of diets with regard to salt intake levels  The latest study, of the U.S. population, confirms the earlier studies that document no improvement in CVD mortality or all-cause mortality among those who reduce dietary salt (see http://www.springerlink.com/content/51x08lvvv76v9204/fulltext.pdf). 
   
• The proposed strategy of P1003 is likely to be highly effective.  FSANZ estimates that 40% of Australians currently have inadequate iodine intakes and that P1003 would lower that to less than 10%.  Even more significantly is that women in childbearing ages will be even better protected and that additional public education can increase further improve that number.
   
• P1003 preserves the opportunity to fine-tune in the future.  A key element to the strategy must be to maintain continuing monitoring of Australian and New Zealander iodine intakes.  Perhaps P1003 will be the entire solution.  More likely, additional foods may need to be produced using iodised salt.
   
• The proposed level is proven safe and achievable.  Australia and New Zealand are the home of sophisticated and modern salt manufacturers.  While today they may be able to promise quality control consistency of iodine concentrations of 25 – 65 mg/kg, FSANZ should work with these committed stakeholders towards enhancing salt producer capabilities and tightening that compliance window as technology/management allow.  The U.S., for example, uses potassium iodide in regulated concentrations of 60 to 100 mg/kg.

 We salute FSANZ for its careful analysis and responsible leadership in mandating use of iodised salt.  Requiring one segment of food processors to use iodised salt will result in the salt industry equipping itself to iodise bulk salt and, thus, prepare against the day when it may be necessary to expand the universe of food processors mandated to use iodised salt.

Sincerely,

Richard L. Hanneman
President

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