Charities Commission Registration CC22512

Submission to Food Standards Australia New Zealand on the proposal for mandatory fortification of food with folic acid - July 2006.

Food Standards Australia New Zealand is a joint agency that advises both governments, through a Ministers' Council, of recommended food standards for Australia and New Zealand. In 2004 they produced an assessment report on folic acid fortification of food, and in July 2006 they sought further submissions on a proposal they will soon put ot the Ministers' Council. This is what we said:

This submission is from NZORD, the New Zealand Organisation for Rare Disorders. NZORD is an umbrella network of 125 rare disease support groups. We work to assist them to be better informed and more efficient in their work, and to help their voices be heard in matters of health and disability service planning and delivery, and in policy matters of interest to them. We also have significant links to 71 groups for common disorders in New Zealand.

From our extensive networking and discussion with these groups over the six years of NZORD’s existence, we are aware of keen interest in technologies and systems that can improve the detection, prevention and treatment of disease and disability, coupled with a strong interest in the safety of any systems or technologies used. This submission is based on that experience within our networks, and in particular on a close liaison we have had with CCS New Zealand, the Paediatric Society of New Zealand, and the Genetic Services in New Zealand, in monitoring the evidence, risks and policy options for reducing Neural Tube Defects by folate fortification.

We strongly support the proposal to fortify the food supply with folate. This support includes the proposed delivery mechanism and fortification levels. We believe the evidence of benefit is very strong and any risk of harm is minimal to negligible. The proposal is clearly a significant public health initiative to benefit the health of babies in Australia and New Zealand.

Food Standards Australia New Zealand is urged to adopt the proposed regime as quickly as possible. We are concerned that the proposal to fortify food with folate has taken so long to get to this stage. Every week of delay results in several preventable NTDs in Australia and New Zealand, leading to much grief and loss for many families. We ask that no further delays are permitted.

NZORD further submits that there is at least a moral duty, and by extension, arguably also a legal duty, on both the Australian and New Zealand governments to implement folate fortification through FSANZ, as soon as possible. Now that the evidence of effectiveness is clearly established, and the safety/risk issues are adequately assessed as they are here, the significance of the positive impact on mortality and morbidity avoided puts a clear duty on our two governments to act to protect the health of our communities. Put another way, it would be morally indefensible, and arguably legally indefensible too, for this proposal not to proceed. Comparisons can be made with other important public health measures such as pasteurisation of milk and treatment of public drinking water supplies, to demonstrate that a failure to implement this proposal would be negligent, as well as unacceptable politically and unacceptable in terms of good public health practice.

NZORD submitted on the 2004 consultation on this topic and refers you to that submission for more detail of our support for this proposal.