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SUBMISSION FOOD LABELLING REVIEW DETAILS FOR PUBLICATION I have read and understood (Personal details deleted) submission and am in full agreement with all the points made therein. Rather than restate these same ideas in different words, I wish to put forward her submission on my behalf. Herein follows the submission. INTRODUCTION: Fact: 50% of Australians will get cancer and this number continues to shows an increasing trend 60% of our population is obese or overweight Australians are dying of lifestyle induced diseases, many of which can be traced back to our eating patterns. Australian’s might have a longer average lifespan but we are getting sicker and sicker and we are suffering the effects of ill health earlier in life. This is largely due to our increasingly sedentary lifestyle and the quality of the food that we are consuming. Not only does this impose a huge burden on our medical system but it also detracts from our quality of life. Every single thing that goes into our mouth or is applied on our skin has the potential to enter our bloodstream and affect our health either positively or negatively. Unfortunately our food supply has been allowed to deteriorate to the point where most of the products in our supermarkets are having a negative affect on our health. It is no surprise that so many Australians are sick with cancer, diabetes, heart disease, arthritis, hormonal disorders and a myriad of other ails. If toxic additives and questionable farming practices and production processes cannnot be banned or more tightly regulated, at the very least we have the right to know what we is contained in our food, cosmetics and toiletries so that we can make informed choices. Ideally there would be a massive overhaul of the entire food industry. We have moved so far away from food as the way nature provides it, that you have to wonder whether it still qualifies as food. Certainly it is edible. But is it safe? Thank you for this opportunity to contribute to this Review of Food Labeling Law and Policy. I call on you to protect public health and consumer choice by introducing and strictly enforcing legislation that enables us to make better choices. I hope that you will exercise your common sense and good judgement and do what is right for the people of this country as well as the people you love and your own self. Please consider the following in your review. LABELING IS THE ONLY BASIS FOR INFORMED CONSUMER CHOICE Food has the potential to harm or heal. Until it can be proven beyond reasonable doubt that pesticides, genetic modification and nano technology is 100% safe then we should have the right to make an informed choice. Labeling is our only basis for informed choice and current laws make this impossible. We have the right to knowledge about the products we are supporting when we exercise our purchasing power. This requires us to have easy access to adequate information. CURRENT LAWS FOR GENETIC MODIFICATION ARE SEVERELY FLAWED & MISLEADING The European Union has set an excellent example by requiring the full labeling of all food ingredients produced by a process involving genetic modification. Identification of genetic modification should extend to processed oils, refined sugars and starches, enzymes, additives, as well as fresh produce, livestock products and foods containing GM fed animal products such as dairy. GM soybean, corn, canola and cottonseed are engineered to make their own insect toxins to repel pests or engineered to withstand heavy and frequent spraying with herbicides like Roundup. These potent toxins may end up in these foods which are widespread in our supermarkets. They also end up in animal feed. Either way, they are unlabeled, are potentially dangerous and have been found to provoke severe allergic reactions, particularly in children. Consumers want to know, and also have a right to know, whether genetic engineering has been used anywhere within the production process - from the feedstock used through to genetic modification of the ingredients themselves. Anything that has been genetically modified or derived from a genetically modified crop should be properly identified. Under the current laws: - Only those foods with “detectable” levels of genetically modified proteins or DNA need to be labelled. This presents a problem in highly refined products were GM proteins become undetectable even though there is increasing evidence that these GM components remain in the final product. - Food from animals fed GM feedstock are not labeled as GM - GM enzymes and additives are not labeled. Since most GM ingredients enter our foods supply in the above mentioned ways, most remain unlabeled and appear to the consumer to be GM free. This is very misleading. Please put an end to the deception that is allowable under the current regulations. All foods and personal use products including fresh produce, animal products and pet foods should be properly labeled if GM technology has been used. Much uncertainty remains as to the safety of genetic modification. We still do not know all the short and long term effects of consuming GM ingredients and there is increasing evidence that these products are actually unsafe: “The American Academy of Environmental Medicine has warned that the public should avoid genetically modified (GM) foods, stating, "There is more than a casual association between GM foods and adverse health effects. There is causation”. A large number of studies and incidents have implicated GM foods in a wide variety of health problems, including accelerated aging, immune dysfunction, insulin disorders, organ damage and reproductive disruption." - Natural News, February 25, 2010 by David Gutierrez http://www.naturalnews.com/028245_GM_food_side_effects.html MANDATORY LABELING FOR ALL FOOD, FOOD PACKAGING INGREDIENTS AND COSMETIC INGREDIENTS PRODUCING USING NANOTECHNOLOGY Anything produced using nanotechnology or manufactured in nanoparticle form should be labelled. There is currently no requirement for this under preexisting laws. Like genetic modification, this technology is relatively new and untested. The long term implications remain unknown. We should err on the side of caution and allow consumers to make informed choices. STANDARDISED LABELS COVERING SET CRITERIA AND DESIGNED FOR EASE OF USE All labels should be printed with black lettering on a white background. With an ageing population, many consumers find it difficult to read some food labels, especially when they are printed on a dark or coloured background. Use by dates and country of origin can also be hard to locate. This information should all be contained on the food label. All labels should follow a preset format so that there is consistency across all brands and products. Use of icons or diagrammatic representations would also assist those who are visually impaired. The nutrition panel could incorporate a graph to visually depict the macronutrient breakdown. Poorly designed labels do more to confuse than inform and this is why a standard format would work well. Chemical additives should be identified by name and number. example: Monosodium Glutamate (621) SUSTAINABILITY, ETHICS AND PUBLIC CONSCIENCE It should be possible to determine at a glance whether the product meets our personal requirements for safety and ethics. Standardised labels covering certain criteria would enable this. Consumers are increasingly concerned about nutrition, health, sustainability, animal welfare and environmental impact and it is anticipated that demand for this kind of information will only increase further. It would be worthwhile exploring issues relating to sustainability labeling and observing what is being done overseas by those corporations who are already setting the precedent. Free range eggs is a good example of a product where consumers think they are doing the right thing but little do they know that they are supporting unethical farmers who do not adequately care for the safety and wellbeing of their hens. Similarly, dolphin friendly tuna may not be friendly to other marine life. Ingredients should be identified with specificity. Palm oil should be identified as palm oil and not vegetable oil or sodium laureth sulfate. Many people are trying to avoid products containing palm oil because of the destruction to the orang utan habitat and threat to their population but this is impossible with vague descriptors. Similarly, products containing rennet should be labeled as either “animal rennet” or “non animal rennet” so that vegetarians and vegans can select products with confidence. People are becoming increasingly concerned about the welfare of animals that are used to make food. The American Human Association (AHA) has developed a “Human Certification Program” which sets guidelines for animal husbandry standards. We have a similar certification program for eggs, with the RSPCA giving their “paws” stamp of approval to particular products. Perhaps we can learn from the AHA’s American Humane Certified Program (AHC) or expand the “paws” program to other products like meats, milk and other dairy. The AHC program is voluntary and the use of growth hormones, antibiotics and other artificial technique to boost production are prohibited. It is designed to find a balance between practicality and profitability so that both animals and the farmers can benefit. FLUORIDE IN FOOD AND PERSONAL USE PRODUCTS Many food and personal use products contain water. The European Court of Justice last year declared that fluoridated water be treated as medicine and disallowed its use in the preparation of foods. In Australia, there is presently no way of knowing whether the water in our products has been treated to remove chemicals and other contaminants. Labeling laws should be tightened to incorporate disclosure on the source of water, especially in products like milk where water makes up a large component of the ingredients. Water could be labelled using the following format: contains water (tap/mains), water (distilled), water (reverse osmosis), water (deionised). We are already being medicated with fluoride through our public water supply. We should have the right to know if we are also being medicated through our food. MSG AND FREED GLUTAMATES ARE DANGEROUSLY AND DECEPTIVELY DISGUISED UNDER A LOOPHOLE IN CURRENT REGULATIONS There is growing concern and awareness of the dangers of excitotoxins such as monosodium glutamate and aspartame. There is increasing evidence that these ingredients affect the central nervous system and contribute to obesity, dementia, food addictions and other health problems . At present, MSG is labelled under a myriad of names including yeast extract, hydrolysed wheat/soy/protein, natural flavour, vegetable protein extract, to name just a few. Most consumers are unaware of this and innocently pick up foods like stock and soups that are boldly labelled as “MSG free” or “No added MSG”. Although MSG may not have been directly added as additive number 621 because this is off putting to consumers, it is in there in another way - as a freed glutamate or hydrolysed protein which for all intents and purposes is still MSG. Using harsh processing to free up the glutamate from a protein such as vegetable, soy or wheat has the same affect as adding MSG directly and this is a convenient work around solution for food manufacturers. Anything that contains MSG or creates MSG during processing should be labelled accordingly. For example: Hydrolyzed soy protein (MSG), yeast extract (MSG), natural flavours (MSG). Alternatively the word Glutamate could be used eg Hydrolyzed vegetable protein (Free Glutamate), Calcium caseinate (Free Glutamate), Gelatin (Free Glutamate), Malt extract (Free Glutamate) BETTER LABELING OF ANIMAL PRODUCTS There is a need for better labeling on meats, especially those prepacked in supermarkets. Some meats have nutrition panels and some don’t. As consumers we also have a right to know more about how the animals are reared, whether they are grain, grass or corn fed. We need to know whether these animals have been reared on a diet of Genetically modified food. We need to know whether fish is farmed or ocean caught or river caught. THE ROLE FOR GOVERNMENT AND COSTS OF INCREASED REGULATION Concern about costs of complying with a new regulatory standard and enforcing this standard are not sufficient reasons to reject these proposals. At the end of the day, our most precious asset is at stake - our health. Cost should not be a reason for continuing on with the current regime which is severely lacking and putting our health at risk. In reality, full labeling does not impose unreasonable burdens on the Australian food industry and certain measures could be introduced to reduce the costs of implementing a new regulatory standard such as uniform requirements between states. Increased production costs are nearly always passed onto consumers anyway and it is my belief that most consumers would be willing to pay a fraction more for food that was satisfactorily labeled. Ideally the federal government would fund part of the costs of regulation as part of it’s health reform package since these laws will have an impact on public health. The Commonwealth has funded the Gene and Nano Technology and Information Services (GNITS) and National Enabling Technologies Strategy (NETS) information programs and yet our labeling laws do not require the disclosure of these potentially hazardous technologies. If taxpayer funds are being used to disseminate information then it is only fair that funds also be used to disclose their presence in foods and personal use products. Everyone should be entitled to make fully informed choices about what they eat and what they dish up to family, friends, pets and clientele. If it proved too costly to implement a new set of Australian food standards then we would do well to adopt the standards set by the European Union. Since around 80% of our food industry is already foreign owned and many are already complying with the EU rules, it would not impose unreasonable burdens for corporations to comply with the European system here too. It is vital that the Government impose comprehensive regulation for the public’s safety and right to information. Food labels need to be factual, comprehensive and accurate. This is especially important for novel processes such as genetic manipulation and nano materials. Ideally these foods would not be allowed at all, but at the very minimum there should be clear labeling especially when there is no history of safe use. Food labeling is one area where self regulation should not be allowed. LEARNING FROM THE EUROPEAN UNION (EU) The EU system is presently the best in the world with it’s more conservative approach to new technology and potentially unsafe ingredients. Surely our food supply is one area where it makes sense to exercise precaution by following the EU’s lead. The EU has clear labelling of nano materials, and additives that are not proven safe. Irradiated foods are also clearly labelled. Europe has also prohibited the use of hormones and non therapeutic antibodies in livestock production and is phasing out many synthetic herbicides and pesticides. They have also reduced the risk of a “Mad Cow” development by disallowing animal waste to be recycled into animal feed. Although the European system is not perfect (and they could improve it by furthering the regulations on locally produced GM animal feed) it is by far the best in the world and we would do well to follow their lead or further improve on it. DANGERS OF IMPORTED FOODS In some countries there are hazards that do not currently exist here in Australia. One such example is meat imported from countries where Bovine Spongiform Encephalopathy (BSE) exists in cattle and other animals. Ideally this meat would not be allowed into Australia since the Red Cross does not even allow blood donations from people who have been overseas and potentially contaminated with BSE. However, at the very least the potential for BSE should be disclosed through proper labelling of imported foods. ADVERTISING AND MISINFORMATION Labels are for the provision of factual information and should not be used for marketing. Boasting that the product is 99% fat free when it is laden with sugar does little to help the consumer make an informed decision. There is also the problem of foods touting possible health benefits when there is no substantiated evidence to support their claims. This is often done through subtle manipulation of words. Whilst they cannot say “prevents risk of osteoporosis” they can say “strengthens bones”. Marketers have also become very good at stretching the truth like boasting that the product contains real fruit when there is minimal fruit in the product or only a fruit derived concentrate or fructose. Products should only be branded as wholemeal if they contain whole meal or whole grain wheat or flour. White flour or rice products that have been colored brown with caramel or artificial colours are not wholemeal and should not be allowed to be labelled as wholemeal or brown. The same should apply to wholemeal products that have had the whole grains removed and then added back as wheat bran. Similarly, unnatural fibres like maltodextrin and inulin are being added to ice creams, biscuits and juices so that the manufacturer can claim that the product is high in fibre. These isolated, unnatural fibres are not likely to have the same health benefits as naturally occurring fibre. In reality these ingredients are little more than cheap filling agents. Boasting that a product is trans fat free implies that the product is safe or healthy. Replacing the trans fat with saturated fat does not mean it is any better for heart health. Trans fats should be banned but to use their absence for marketing purposes is just lame. CONCERNS OVER COUNTRY OF ORIGIN “Made in Australia from local and imported ingredients” This is a vague but all too common product description that tells us nothing about where the ingredients are from and what proportion are from offshore. If products contain ingredients sourced offshore then the country of origin should be listed for those ingredients. Where the country is not disclosed, it can be assumed that the country of origin is Australia. Example: Soy (China), wheat, maltodextrin (India), iodised salt. Alternatively the percentage of Australian sourced and foreign sourced ingredients could be displayed. There is confusion as to terms like “made in Australia”, “packaged in Australia” and “Australian owned” and the various symbols that are used - Australian flag, map of Australia, pictures of Australian icons. CONCLUSION At the very least, Australia and New Zealand should adopt the same standards as the European Union. Better yet, we would improve upon their model and become the world leaders in food labeling. Food labels are the most convenient and easily accessible place for information. Websites, consumer hotlines and other information services are not a substitute for sound labeling. Thank you again for this opportunity to contribute. In summary, here are the key points that I feel need to be considered: Consumers depend on labels as their main source of information when making purchasing decisions. Ease of use should not be at the expense of proper disclosure and good information. We have a right to know how the product is manufactured - whether it been genetically modified or engineered, whether nanotechnology been used, and whether it has been processed in such as way as to free up proteins (glutamates). Ingredients need to be disclosed with specificity. Vague terms like “natural flavour”, “vegetable oil”, “skim milk powder” and “water/aqua” do not provide enough information to make an informed choice. Palm oil should be labelled as palm oil. Full labeling of all food ingredients that have been produced using genetic modification, regardless of whether the levels of GM proteins and DNA are detectable or not. GM should extend to animal feed, processed oils, refined sugars and starches, enzymes, additives and pet food. Anything that contains MSG or creates MSG during processing should be labelled accordingly. At present MSG is only identified when it is added as a separate ingredient but savvy manufacturers create MSG from protein structures during the processing of the food. This obviates the need to add MSG separately and therefore it’s presence is well hidden. Food labels should follow a set layout for ease of use and consistency. Improvements are needed in labeling the country of origin and the source of ingredients Please consider your own health and that of your family and loved ones when forming your decisions. If we cannot ban questionable ingredients or practices, then it is essential that food labels provide enough information for us to make a well informed decision. As paying customers, this should be a right, not a privilege.
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