TO ALL <Australian and
Dear Minister
LACK OF SCIENTIFIC EVIDENCE FOR
CERTAIN FOOD ADDITIVES
Over the past several years we have written to you and your predecessors regarding the effects of certain food additives on the health, behaviour and learning of a growing proportion of the Australian and New Zealand population. In these letters we have requested your assistance to see the scientific evidence upon which the approval of certain food additives is based, since such evidence is a requirement under the Food Standards Australia New Zealand Act 1991 yet the evidence was neither in the scientific literature nor being made available by FSANZ. As we are sure you are aware, the Act says that FSANZ, in "developing or reviewing food regulatory measures and variations of food regulatory measures",…must have regard to…"the need for standards to be based on risk analysis using the best available scientific evidence".
In addition we were promised, in responses to our letters during the review of the Food Standards Code, 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."
Since no scientific evidence has ever been forthcoming from these requests, we commenced a Freedom of Information (FOI) process on 1 August 2003 to seek just this information for two key additives that have become ubiquitous in our diets:
* propionates (280-283), the common bread preservative recently extended to several other food classes, which has been proven to cause learning and behaviour problems in children; and
* ribonucleotides (627, 631, 635), a new flavour enhancer in many savoury products and even butter, which has been reported to cause severe itchy skin rashes in many people. This is emerging as a particular issue for old people who are tormented by rashes caused by ribonucleotides in the cheap food provided in nursing homes, to the extent that people are starting to call it Meals-on-wheels disease.
The results of this FOI process are publicly available on our website.
We are now writing to warn you that there is no scientific evidence,
either in the scientific literature or in the information provided through the
FOI process, to justify the use and extension of use of these additives.
While this disturbing lack of evidence has been confirmed for these two
problem additives, we are certain that the FOI process would reveal the same
lack of evidence for many other additives. This is a serious issue that leaves
you exposed to public attack on a failure of the food regulatory regime and in
breach of the Food Standards
In response, your bureaucrats may blandly inform you that "currently available toxicological data supports the safe use of propionic acid and its salts as food additives and the safe use of ribonucleotides as flavour enhancers for the vast majority of the population", as they have on past occasions. If they do, please ask to see the "currently available toxicological data", since even the FOI process hasn't found one shred of it.
Your bureaucrats may also reassure you that they are "not aware that
the safety of propionic acid or ribonucleotides
has been raised as an issue in any other country." You might ask them how
could FSANZ or any other food regulatory agency be aware of effects from these
food additives if there is no system in place to record such occurrences?
For instance, over more than five years we have provided FSANZ and its
predecessor with hundreds of case studies of the effects of these additives,
yet we are certain that FSANZ would report in international circles that these
additives are not an issue. Further,
We believe that this issue should be discussed by Ministers together and seek your support for an improved and rigorous scientific assessment of all food additives before people are exposed to them.
Yours truly
Dr Howard Dengate FAICD