11 December 2003

Ms Christine Coogan

FOI Coordinator

Department of Health and Ageing

PO Box 9848

CANBERRA ACT 2601

Dear Ms Coogan

We wish to make formal application under the Commonwealth Freedom of Information Act 1982 for the approval statement and scientific information upon which the approval was based for the following food additives: propionic acid and its salts (280-283) and ribonucleotides (627, 631, 635). This information has been sought unsuccessfully from FSANZ, as shown in the attached letter. The entire correspondence is on the above website under Features.

In the papers which FSANZ 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). NHMRC was the responsible agency at this time.

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. Therefore we also seek any later papers.

For propionic acid and its salts (280-283), for instance, the only public evidence to date 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 (see attached paper).

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 FSANZ several times without effect.

We seek remission of the FOI application fee on the basis of public interest, since we represent a large non-funded group working entirely in the public interest.

Yours truly

Mrs Sue Dengate Dr Howard Dengate