website: www.fedupwithfoodadditives.info

18 November 2003

Ms Claire Pontin

General Manager

Strategy and Operations

Food Standards Australia New Zealand

PO Box 7186

CANBERRA ACT 2610

Dear Ms Pontin

Thank you for the first batch of FOI information, consisting of some 300 pages sent on 28 October 2003. While it was interesting and frustrating to revisit 1995-2000 processes to which the Food Intolerance Network has already attempted to contribute, the specific information that we have requested has yet to be provided.

The key point is that Proposal P150 (March 1997) (pages1,8), and your various Ministers at various times, have promised that "At full assessment, ANZFA will review the existing toxicological evaluations of the additives in the draft proposed standard …to ensure that the public safety has been maintained." However in P150 (undated, presume 2000)(page1) "the standard was developed by applying risk analysis to ensure the dietary exposure to food additives to the food supply did not present an unacceptable risk to public health and safety…".

In other words, consumers have been dudded yet again, because ANZFA/FSANZ has done the easy bit, dietary intake assessment, but not, despite promises, the hard bit about toxicological evaluation.

While we continue to have grave doubts about your toxicological assessment process, because it is based on classical animal dose experiments without any behaviour or learning dimensions, we are seeking in the public interest to examine the scientific basis for approval of the specific food additives propionic acid and its salts (280-283) and flavour enhancer ribonucleotides (627, 631, 635).

In the papers which you have provided, CODEX STAN 192-1995 Rev3-2001 reports in Annex C List B page 45ff that 280-283 propionates were last reviewed in 1973 at JECFA Meeting 17, while page 43 reports that 635 ribonucleotides was last reviewed in 1974 (JECFA 18) and 627 and 631 in 1993 (JECFA 41).

It is hard to believe that science has not advanced in the 10-30 years since these various reviews were done, particularly as we are aware of dozens of papers, for instance regarding propionic acidaemia, that need to be considered if this is to have any pretensions to a scientific process.

A second important issue is that we have been informed by the FOI Coordinator in the Department of Health and Aging that our FOI request has not been formally transferred to them and that they are under no obligation to process it. If the required information is not within FSANZ, then we request that you make a formal transfer of our FOI request or inform us if you do not so intend, so that we might continue the bureaucratic paper trail.

We continue to request the scientific evidence upon which the approval and use of these additives was agreed in the Review of the Food Standards Code and look forward to a speedy provision of information as requested.

Yours truly

Mrs Sue Dengate Dr Howard Dengate