Submission to the Food Labelling Review Panel May 2010

SUBMISSION TO THE FOOD LABELLING REVIEW PANEL MAY 2010

BY LINLEY GRANT OAM, BA Hons.

PREAMBLE

I am no expert, but I am a member of a number of voluntary organisations whose primary concern is not primarily nutrition and food labelling, but whose members are however, vitally interested and concerned in the issues surrounding food labelling. I am currently an Adviser for Health for the National Council of Women of Tasmania Inc.; a community representative on the Tasmanian Government’s Health Plan, a member of the Tasmanian Women’s Council, and a Consumer Representative on the GP’s Association Community Forum. I also worked part-time, as a Level 2 RN in the Burns Unit of the Royal Hobart Hospital for 24 of my 47 years of paid employment. I taught nutrition, in particular the nutrition of patients with burns injuries, for over 10 years to nursing and medical undergraduates and graduates.

For the last 30 years I have had a severe reaction to milk proteins (probably tyrosine) and a grandson who also reacts to artificial colourings. This has involved me in many hours of reading food labels, because so many foods have milk products added to them.

SUBMISSION

POLICY DRIVERS

1.  FOOD LABELS MUST BE EASY TO READ –

There is a CRITICAL NEED FOR THOSE WITH ALLERGIES AND OTHER REACTIONS TO FOODS AND FOOD ADDITIVES TO BE ABLE TO READ ALL FOOD LABELS. THIS IS OFTEN DIFFICULT.

There are thousands of Australians who react to food products and additives. It is considered by some medicos that constant exposure to small quantities of unrecognised allergens and irritants results in the eventual violent reactions many people experience.

If you react to, e.g., milk proteins you need to be able to read every label – biscuits, salami, soups, breakfast cereals, chocolate and sweets containing milk products and condensed milk, margarines, etc., apart from obvious products which contain milk, cheese, yoghurt, whey, milk products, etc.

Also, if a recipe is changed, e.g. as the established Australian biscuit recipes were changed when Arnotts was sold to Americans, and milk products added, the change should be well advertised and clearly visible on the labels. I was quite ill for several months because I did not realize that this change had occurred.

So often the labels on the contents of processed products are in such tiny print they are quite difficult to read; in the case of sweets and chocolates the names of the contents are often hidden under the edge of a wrapper and you have to lift the wrapper edge to find them. Then the font size is so small it is difficult to read, or the sealing process has crept onto the names of the contents, again making labels difficult to read.

2.  INDEPENDENT LABELLING RE HYGIENIC FOOD SOURCES

THERE IS A GREAT NEED FOR ALL AUSTRALIANS TO KNOW THAT THE FOOD THEY EAT COMES FROM HYGIENIC SOURCES. THERE IS A GREAT NEED FOR SUFFICIENT INDEPENDENT INSPECTORS TO BE ABLE TO VISIT ALL SOURCES OF FOOD PRODUCTION AT VERY SHORT NOTICE AND INTERMITTENT INTERVALS TO ENSURE ADEQUATE HYGIENE AT ALL LEVELS OF THE FOOD INDUSTRY. FOOD LABELLING CONCERNING HYGIENE BY AN INDEPENDENT SOURCE SHOULD BE MANDATORY.

There were always problems where milk for example, was collected from farms where hygiene was less than adequate. The advent of battery hen and intensive pig farming has increased the problems. Over the past 20 years there have been many cases cited in the media and in the courts where the multi-national food chains have certified a farm and the food source has been contaminated. Recently a farmer was found guilty in the courts but the multi-national re-certified the farm soon after, yet conditions were and are, still below standard. In a country like Australia there is no need for battery or intensive farming of any livestock.

Consumers should be able to easily select the source from which their food comes and know that it comes from a certified, hygienic farm and processor.

3. PLACE OF ORIGIN

AUSTRALIAN CONSUMERS SHOULD LEGALLY BE ABLE TO KNOW THAT THE FOOD THEY BUY IS EITHER 100% AUSTRALIAN PRODUCED, OR IT IS NOT.

For example, concentrated orange juice from another country which is recons- tituted with water when it arrives in Australia is labelled “Australian” This is dishonest. If a product is not wholly Australian it should NOT carry the Australian label.

4. STATE OF ORIGIN

As Australia is such a vast country, it is important to know where, e.g., “fresh” vegetables and fruit come from. Stores should be required to place a state of origin label on all displays of fresh produce, fruit, fish and meat. We should know whether we are selecting Northern Territory tomatoes or Tasmanian.

Consumers should know the state of origin for all produce, particularly fresh produce and goods. Consumers should have the right to choose. Clear signage should be placed on the display area for each product. Consumers should know if we are eating fruit from another country. There is an obvious need for more regular inspection of labelling concerning point of origin.

5. CONTENT ACCURACY

AUSTRALIANS SHOULD KNOW THAT CONTENTS OF FRESH, PROCESSED OR PACKAGED PRODUCTS ARE ACCURATELY LABELLED AND BE ABLE TO MAKE AN INFORMED CHOICE. For example, now that certain species of fish stocks have declined, it should be illegal for a species to be labelled by the name of other species, e.g. - where Trevally is labelled Blue-eye Trevalla. This happens. In other cases, some products, including fresh vegetables, cheese, honey, etc. are grown in Tasmania, then transported to the mainland (Victoria), processed and packaged and sent back to Tasmania and state of origin is not labelled.

FOODS CONTAINING TRACES OF ANTIBIOTICS SHOULD BE LABELLED.

Consumers have a right to know if the food they are selecting was produced from plants or animals which were given antibiotics. Some people build up intense allergies from such products. Other patients are insensitive to their curative effects when they most need them. However, some farmers are still using these substances , to give better yields, without declaring them.

FOODS CONTAINING GENETICALLY MODIFIED PRODUCTS SHOULD BE LABELLED.

Consumers have the right to know if a product contains genetically modified ingredients, so they can make their own decision concerning their use. Scientists do not yet know the long- term results on human health of genetic modification of every food product, or whether people are building up allergies towards these products. Until the outcome is clear, it is only right that such products are clearly labelled, so that those with concerns can choose.

ROLE OF GOVERNMENT

There appear to be three main roles and several principles for the Government –

(a)  The regulatory and legislative role for creating legal standards;

(b)  A ‘policing’ role via the provision of adequate numbers of inspectors with adequate powers to commence and follow-through on legal action against offenders

(c)  The creation of adequate sanctions which are sufficient to cause possible offenders to re-consider their decision.

(d) 

The principles of safety, integrity, fairness and the right of the consumer to adequate knowledge and the right to choose, should underlie all government action.

NEEDED POLICIES AND MECHANISMS

Most members of the public would agree that in many respects labelling in Australia is very good; however any change to down-grade or reduce it, to suit the producers and processors, will bring great hardship on those who are dependent upon clear and adequate labelling.

RECOMMENDATIONS

1.  That labelling should continue at least as it is currently; if anything, there should be stricter labelling to give consumers more accurate information than is currently available. It should be mandatory that lists of contents are easy to read and clearly visible on every processed product.

2.  That there should be sufficient, independent inspectors to ensure that from the producer to the point of sale, adequate safety and hygiene standards are upheld and maintained and that products are clearly labelled as such.

3.  That the right to choose is maintained, e.g. local versus non-local goods, goods containing certain additives or genetically modified products are well labelled.

4.  That if a long-established recipe is changed, the change should be well advertised and the changed contents clearly labelled.

5.  That sanctions for inaccurate labelling should remain quite severe.

Linley Grant OAM

(Contact details deleted)