website: www.fedupwithfoodadditives.info

15 September 2003

Ms Debra Fletcher

FOI Cordinator

Food Standards Australia New Zealand

PO Box 7186

CANBERRA ACT 2610

Dear Ms Fletcher

Your letter of 4 September, received on 9 September, leaves us uncertain whether FSANZ is being deliberately arch or just inefficient in waiting until 30 days after our original request to advise that the statutory period of 30 days will not commence until FSANZ has made a decision to process our request. On the face of it, FSANZ appears to be playing with the public interest in this matter, let alone statutory FOI timeframes.

The public interest of the Food Intolerance Network can be attested by the fact that over 175,000 people have visited our website since September 1999, that more than 1500 people have registered for the bimonthly Failsafe Newsletter, that there are now 10 email support and discussion groups with a total membership of over 500 people and that the weekly email traffic to Sue Dengate and Howard Dengate separately exceeds 300 messages. These numbers grow by the month as more and more people become aware of the deleterious effects of some food chemicals on their health, behaviour and learning. No public or industry funding has ever been either sought or received by the Food Intolerance Network to provide this public interest service.

The approval process for agricultural and veterinary chemicals includes a full publication of the evidence that was assessed in granting or otherwise approval for the particular chemical, crop and pest combination. This transparency is in marked contrast to that displayed by FSANZ, where requests made in writing for such evidence since 1999, both directly and through State and Federal Ministers, have been fobbed off with assurances that extensive government and industry toxicological studies have been undertaken.

The ANZFA Act 1991 requires ANZFA, and presumably its successor FSANZ, to conduct scientific, risk analysis-based assessments of any regulatory measures. However, only limited studies, where they exist at all, appear to be in the public domain.

As we said in our original request on 1 August 2003, for propionic acid and its salts (280-283), for instance, all we can find is a World Health Organisation report which tested the additives internally on cats, dogs, rats, rabbits and one man, and concluded they were safe at all levels. There were no tests on children or for behavioural and learning toxicity. For 282 in particular, the only public scientific evidence with children is of harm.

With flavour enhancer ribonucleotides (627, 631, 635) we can find no public scientific evidence of a safety assessment, while we receive continuing reports of serious public harm, detailed on www.fedupwithfoodadditives.info and provided to you several times without effect.

How could it not be in the public interest to provide the assessment information publicly? Why should assessments be conducted in secret?

Please note that the two-way correspondence regarding the Food Intolerance Network's FOI request will be available to the public and media on www.fedupwithfoodadditives.info from now on, as will the requested information when you finally provide it to us.

We look forward to a speedy and favourable decision regarding the public interest in this request.

Yours truly

Mrs Sue Dengate Dr Howard Dengate