February
23, 2005
Food
Standards Australia New Zealand
PO Box 7186
Canberra BC ACT 2610
AUSTRALIA
RE: P230 – Iodine Fortification
The
salt industry, through its global trade association, the Salt Institute, congratulates
FSANZ for its leadership and for the excellent analysis of the challenge of maintaining
iodine sufficiency for the populations of Australia and New Zealand, particularly for
expectant mothers and small children.
The
salt industry is vitally concerned for the health and economic productivity of Australians
and New Zealanders and recognizes our special opportunity and responsibility to contribute
to their well-being by providing iodized salt. We
stand ready to iodize all food grade salt as needed and assure FSANZ that neither
adjusting the scope of distribution of iodized salt nor the fortification level represents
a difficult challenge from a technical or marketing perspective. We would caution, however, that food processors
are not currently using iodized salt and require some education. Provision for a staged adoption of iodized salt in
manufactured food would seem highly desirable.
We
present our comments from our extensive experience and involvement in iodine nutrition and
support for national salt iodization efforts. Personally,
I have served on the Board of Directors of the International Council for the Control of
Iodine Deficiency Disorders for the past decade and chair the ICCIDD committee on salt. These comments, however, represent the views of
the Salt Institute, not ICCIDD.
1. We
agree that FSANZ has an obligation to protect public health through monitoring and
intervention to ensure adequate iodine nutrition and, further, that the most vulnerable
population are unborn and young children.
2. We
find persuasive the evidence suggesting an erosion of iodine sufficiency. This also has been the pattern in other countries
such as the U.S. and Canada where the commitment of the salt industry is strong and
regulatory programs, effective; the slide in iodine intake represents, as well described
in your paper, shifts away from iodine disinfection in dairy production and diminished
home meal preparation.
3. We
believe that expanding the usage of iodized salt is appropriate and the best means of
improving the iodine sufficiency of the populations of Australia and New Zealand. The choice of salt is obvious as a vehicle since
salt is consumed in relatively consistent quantities and within a relatively predictable
range. No country in the world has
chosen another vehicle for iodine fortification in preference to salt. In certain local areas, iodizing oil or even water
has been done, but these are temporary, local responses to severe iodine deficiency and
inappropriate for Australia and New Zealand; they are also very expensive. Experts in every public health organization from
WHO and UNICEF to ICCIDD have reached the studied conclusion that iodizing salt is the
superior solution.
4. We
agree with your identification of four basic regulatory options and additional
non-regulatory options.
5. We
recommend a staged adoption of Option 4. We
recommend that all retail salt be iodized in the near term and that salt sold to food
processors be iodized using some phased-in timeframe that will permit education and
buy-in. It is entirely feasible,
technically, to use iodized salt in food manufacturing, and we expect food manufacturers
would welcome the opportunity to provide – and promote – their products as vital
components of a healthy diet.
6. Further,
we recommend against Option 2: extending additional permissions to other food categories. Such a course would undermine the controlled
nature of iodine supplementation. No other
food or food ingredient is consumed in such predictable amounts and no other vehicle is
likely to be as cost-effective.
7. And,
we further recommend consideration of a variant of Option 3. Option 3 envisions a voluntary program, but
memorandums of understanding might be a useful means of education and phasing-in the USI
requirement and should be evaluated for this purpose.
8. Finally,
we recommend a targeted non-regulatory promotion campaign aimed, at minimum, at the most
important group: expectant mothers. As you know, a generation ago, salt restriction
during pregnancy was common advice from obstetricians; today it would be malpractice. Ensuring this high value target population is
bombarded with messages about the critical importance of iodine nutrition to the health
– especially the mental capacity – of their gestating baby would be highly
effective and appropriate. We are confident
that no mother would knowingly impair the development of her child’s brain. The simple message would be: “If you use salt in preparing your meals, be
certain that the salt you use is iodized.” This
message would not be contradictory to any overall salt reduction efforts (though we would
note our strong view that advice for universal sodium reduction ignores the preponderance
of evidence that shows no reduction in the incidence of heart attacks or strokes among
individuals consuming lower-sodium diets – but that’s an issue for another day).
We
accept the paper’s findings that the iodine deficit is marginal. While it is critically important that action be
initiated to erase the deficit, it would be easy to over-react. Your paper properly warns:
Iodine intake can
also produce adverse health effects at high levels and particular care is required where
populations have had low intakes of iodine over time. Iodine induced hyperthyroidism is
considered a possible side effect of iodine supplementation and has been reported in
almost all supplementation programs. Any program to increase the iodine status of a
population has to be implemented in a controlled manner and monitored carefully.
Phasing-in
the adoption of USI will not only provide this control and allow FSANZ to monitor
carefully the population impacts.
If we can be of assistance to FSANZ as this process unfolds, please
know of our intense interest and desire to help the citizens of Australia and New Zealand
enjoy the cost-effective benefit of iodized salt and the brainpower boost that will
accompany erasure of the current mild iodine deficiency in both countries.
Sincerely,
Richard L. Hanneman
President
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