August 25, 2006
Food Standards Australia New Zealand
PO Box 7186
Canberrra, BC ACT 2610
AUSTRALIA
RE: Proposal P230 Considerations of Mandatory Fortification with Iodine
On behalf of the children of Australia and New Zealand and the salt producers of these countries, the Salt Institute 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.
We 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 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. As noted below, there is reasonable expectation that there may be further decline in the use of iodised salt as Australians and New Zealanders take advantage of the convenience of meals prepared outside the home.
The declining iodine nutrition status of Australians and New Zealanders parallels that of Americans and Canadians (it is different than the serious re-emergence of IDD in Europe). Since the critical supplemental iodine in all these countries comes from iodised salt, the explanation for the decline is straightforward: consumers are preparing less food at home now than a half century ago; a greater portion of their food intake comes from foods processed commercially or cooked in restaurants for dine-in or take-away consumption. Customarily, salt provided to food processors and food service customers is not fortified with potassium iodate. This shift to foods prepared outside the home has led to a decline in packaged table salt sales and the resultant erosion of iodine intake.
Consumers in Australia and New Zealand, unlike the situation in North America, have also been neglectful in choosing iodised salt. This suggests that part of the solution for declining iodine status should be a renewed public education campaign, perhaps in public schools. We also support the proposed education campaign targeted at advising pregnant women of the critical importance of their iodine intake for the mental development of their developing child.
The proposed mandate for use of iodised salt in processed cereal based foods at 30 mg iodine per kg salt is a good first step to reverse the decline in iodine nutrition status. The experience of using iodised salt in bread in Tasmania suggests this intervention can be implemented without significant disruption to food processing operations. Further extending the Tasmanian experiment to breakfast cereals and biscuits should be a simple matter. Adjusting the fortification level in table salt poses no technical challenge for salt producers.
Continuation of population iodine monitoring will enable FSANZ to track and determine whether requiring iodine-fortified salt in other foods may be required should the initial mandate prove insufficient. In addition, the salt industry would find it a simple matter to increase the proposed 20 mg iodine per kg salt to a higher level should that become necessary. In short, this is a measured response with as much supportive evidence as could be amassed for any option.
We note that the cost benefit analysis discusses possible implications of iodising Australian/New Zealand salt for trading with Japan. We see this as an imaginary concern. Since domestic producers will continue to provide plain salt to most of the food processing industry, obviously they will have sufficient inventories of non-iodised salt for export to Japan. We are advised that unscrupulous marketers in Japan have made unwarranted charges that imported Australian salt is iodised in contravention to Japanese regulations, but have seen no evidence to substantiate those charges.
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
 |
| [About Salt Institute] [About salt] [About the salt industry] [News] [SI Member Business (password required] [E-Mail Salt Institute] |