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This is an
historical file of letters to and from food regulators and Ministers. Scroll
down to see them. Current letters are here

The Project Officer
Publications Review
Health Advisory Section
National Health and Medical
Research Council
GPO
CANBERRA ACT 2601
ASTHMA: MANAGEMENT, EDUCATION AND RESEARCH 1995
The Food Intolerance
Network, which now consists of over 1500 members including more than 700 in a
range of specialised support groups, wishes to make a submission to the review
of the above publication.
The Food Intolerance
Network remains concerned that the present document focuses almost entirely on
improving drug treatment of symptoms for asthma without any recommendations
that address the causes of asthma. The ultimate goal of asthma research is to
prevent asthma, not just relieve its symptoms1. The Network believes
that there is now a considerable body of scientific evidence that food
chemicals contribute significantly to asthma especially in children, supporting
the proposed new recommendation given below.
Effectiveness of dietary
intervention
Improvements in asthma
symptoms have been reported with additive-free, low salicylate diets for adult
asthmatics18,28, an additive-free low salicylate elemental formula29
and an additive-free very low calorie meal replacement program30
following obesity surgery. Dietary management is most effective when all
provoking food chemicals are avoided31.
In a three month study of
19 asthmatic children, the only child of five to comply well with an
additive-free, low salicylate diet was a formerly severe asthmatic who achieved
normal lung function and freedom from all medication. There were no significant
improvements in 14 sulphite sensitive children who were asked to avoid
sulphites. Sensitivities to other food additives such as benzoates were not
tested and researchers commented that the sulphite free diet 'did not involve
radical changes in food consumption, and alternative foods and beverages not
containing [sulphites] could be substituted with ease'21. This was
not the experience of Corder and Buckley who after studying hundreds of
asthmatics commented on the 'prevalence and abundance of doses of unlabeled
sulfite in many foods … in the USA'15. Members of the Food
Intolerance Network can confirm that avoiding sulphites in Australian foods and
medications is extremely difficult as the use of sulphites, including
unlabelled sulphites, is so widespread.
Food labelling
It is considered that
appropriate food labelling will help in alerting individuals who cannot
tolerate sulphites19, but such labelling is of little use to
children who are unaware of their sensitivities; to children whose parents or
carers are not prepared to make the effort to restrict the child's diet; and in
countries such as Australia where there is an abundance of unlabelled
sulphite-containing foods, especially in unpackaged foods and takeaways.
The Food Intolerance
Network has observed that families of asthmatic children are less motivated to
restrict their diet unless there are other problems such as difficult
behaviour. As one mother said, 'She's no trouble when she has asthma. She just
sits there and tries to breathe.' When Sweden removed azo dyes from all food
except caviar, cocktail cherries, fruit cocktails and some alcoholic drinks,
the number of patients presenting with intolerance to azo dyes, benzoates and
aspirin intolerance decreased32.
To protect
food-sensitive asthmatic children - possibly the majority of asthmatic children
- the appropriate public health response is to reduce the use of asthmagenic
additives in the foods that children eat.
Fed Up with Asthma by Sue Dengate
This book, published by
Random House in 2003, provides an up-to-date and comprehensive science-based
review of the effects of food chemicals on asthma and how modification of diet
can reduce or eliminate asthma in many people.
The work arose from observations
of Food Intolerance Network members over many years. We noticed that when
families embarked on the Royal Prince Alfred Hospital elimination diet for a
child's difficult behaviour, any asthmatics in the family would improve. This
was despite the fact that mothers usually said 'but his asthma isn't related to
foods. He only gets it when he has a virus' or some other trigger. In the same
way that asthmatics are unaware of their sensitivity to aspirin unless
reactions occur within 20 minutes of ingestion14, most asthmatics
think that unless they experience an immediate asthma attack after eating, they
are not sensitive to foods.
Yet we noticed that in
every case while the child or adult remained on the diet their asthma would
improve and exposure to former triggers would fail to result in asthma. A
review of the literature suggested that chronic exposure to certain food
chemicals may cause continued inflammation of the airways with no obvious
symptoms. These inflamed airways are more likely to result in asthma when
exposed to environmental factors such as viruses or exercise. Findings so far
suggest that bronchial responsiveness reduces when food chemicals to which a
sensitivity has been demonstrated are removed from the diet35,15.
This mechanism accounts for
the hundreds of reports we have received of improvements in asthma while on the
elimination diet; of recurrences of asthma when failsafers break their diets;
and of numerous anecdotes such as: a 35 year old woman who developed
adult-onset asthma within three months of switching from regular Coke (which is
benzoate-free) to Diet Coke (which is preserved with benzoates) and became
asthma-free when she reverted to regular Coke; a woman who developed
adult-onset asthma when she followed a weight loss diet which involved snacking
on a trail mix of sulphited fruit and nuts; a 5 year old failsafer with
previously severe asthma who remained asthma-free while avoiding sulphites and
benzoates until she missed nearly a term of schooling with asthma due to sorbate
preservatives added unnoticed to the family's regular brand of margarine; a 12
year old who was kept wheat-free for eight years because her family had noticed
her asthma occurred after sandwiches - the elimination diet showed the child's
asthma was related to BHA (320) in bread and margarine rather than wheat
itself; a woman who realised a commercial soup contained MSG because it
exacerbated her asthma - the puzzled company eventually found unlabelled MSG
added by the supplier of their soup stock; health authorities in three regions
who discovered excessive use of artificial food colouring in meat and rice
dishes when English curry house patrons complained of asthma following curries;
and elite athletes who have outgrown their childhood asthma but develop
exercise asthma years later when they start eating large numbers of
sulphite-containing muesli bars during training.
Fed Up with Asthma contains extensive scientific
references and provides more detail than the above summary. It is helping thousands
of Australian families.
Conclusion
From the above it is
clear that there is sound scientific evidence for a change in stance by the
NHMRC and that in fact community action is outrunning the NHMRC.
The NHMRC may be
interested to know that our website has had nearly 200,000 visits since
establishment in September 1999 and that we receive continual reports of the
effectiveness of the Failsafe diet for asthma. Many families report that asthma
is just not an issue if the Failsafe diet is used.
It is also a concern to
the Food Intolerance Network that Australia leads the world in this area, in
the work with tens of thousands of children and adults at the Royal Prince
Alfred Hospital Allergy Unit, but that much of their excellent work has not
been written up and exposed to peer review. NHMRC could consider ways to assist
this Unit to bring the work of Drs Loblay, Swain and Soutter the prominence
that they deserve.
Based on the above
detailed scientific studies, the Food Intolerance Network proposes that the
NHMRC makes the following recommendations:
We look forward to
inclusion of these recommendations in the review of the publication.
Yours truly
Mrs Sue Dengate Dr
Howard Dengate
References
1. Haby MM, Peat JK, Marks
GB, Woolcock AJ, Leeder SR. Asthma in preschool children: prevalence and risk
factors, Thorax 2001;56:p589.
2. Speer S, Management
of childhood asthma. Charles C Thomas, Springfield, 1958, cited in Feingold
BF, Recognition of food additives as a cause of symptoms of allergy, Ann
Allergy 1968;26:309-13.
3. Chaffee FH, Settipane
GA. Asthma caused by FD&C approved dyes. J Allergy 1967;40:65-72.
4. Baker GJ, Collett P,
Allen DH. Bronchospasm induced by metabisulphite-containing foods and drugs. Med
J Aust 1981; 2:614-6.
5. Allen DH Allen DH, Van
Nunen S, Loblay R, Clarke L, Swain A. Adverse reactions to food. Med J Aust
1984; 141 (Suppl) 37-42.
6. Yang WH, Purchase ECR.
Adverse reactions to sulfites, Can Med Assoc J 1985;133:865-880.
7. Moneret-Vautrin DA.
Monosodium-glutamate-induced asthma, Allerg immunol 1987;19(1):29-35.
8. Timberlake CM, Toun AK,
Hudson BJ. Precipitation of asthma attacks in Melanesian adults by sodium
metabisulphite. PNG Med J 1992;35:186-190.
9. Steinman HA, Le Roux M,
Potter PC. Sulphur dioxide sensitivity in South African asthmatic children, S
Afr Med J 1993;83:387-390.
10. Gastaminza G, Quirce S,
Torres M, Tabar A, Echechipia S, Munoz Fernandex de Corres L. Pickled
onion-induced asthma: a model of sulfite-sensitive asthma? Clin Exp Allergy
1996;25(8):698-703.
11. Arai Y, Muto H, Sano Y,
Ito K. Food and food additives hypersensitivity in adult asthmatics. III
Adverse reactions to sulfites in adult asthmatics. Arerugi 1998;47(11):1163-7.
12.
13. McDonald JR, Mathison
DA and Stevenson DD. Aspirin intolerance in asthma, J Allergy Clin Immunol
1972;50(4):198-207.
14. Stenius BS, Lemola M.
Hypersensitivity to acetylsalicylic acid (ASA) and tartrazine in patients with
asthma. Clin Allergy 1976;6(2):119-29.
15. Corder EH, Buckley CE 3rd.
Aspirin, salicylates, sulfite and tartrazine induced bronchoconstruction. Safe
doses and case definition in epidemiological studies. J Clin Epidemiol
1995;48(10):1269-75.
16. Hijazi N, Abalkhail B,
Seaton A. Diet and childhood asthma in a society in transition: a study in
urban and rural Saudi Arabia. Thorax 2000; 55:775-779.
17. Bush RK, Taylor SL,
Holdren K, Nordlee JA, Busse WW. Prevalence of sensitivity to sulfiting agents
in asthmatic patients, Am J Med 1986;81(5):816-20.
18. Hodge L, Yan KY, Loblay
RL. Assessment of food chemical intolerance in adult asthmatic subjects. Thorax
1996;51(8):805-9.
19. Fifty-first meeting of
the Joint FAO/WHO Expert Committee on Food Additives, Safety Evaluation of
Certain Food Additives: Sulfur Dioxide and Sulfites, World Health Organisation,
Geneva, 1999.
20. Friedman ME, Easton JG.
Prevalence of positive metabisulfite challenges in children with asthma. Pediatr
Asthma Aller Immunol 1987;
21. Towns SJ, Mellis CM.
Role of acetyl salicylic acid and sodium metabisulfite in chronic childhood
asthma. Pediatrics 1984;73(5):631-7.
22. Australia New Zealand
Food Authority. The 1994 Australian Market Basket Survey, Australian
Government Publishing Service, 1996, Canberra, p42.
23. Petrus M, Bonaz S,
Causse E, Rhabbour M, Moulie N, Netter JC, Bildstein G. Asthme et intolérance
aux benzoates. Arch Pédiatr 1996;3:984-987.
24. Mikkelsen H, Larsen JC,
Tarding F. Hypersensitivity reactions to food colours with special reference to
the natural colour annatto extract (butter colour). Arch Toxicol Suppl
1978;(1):141-3.
25. Soschin D, Leyden JJ.
Sorbic acid-induced erythema and edema. J Am Acad Dermatol 1986;14(2 Pt
1):234-41.
26. Fisherman EW, Cohen G.
Chemical intolerance to butylated-hydroxyanisole (BHA) and
butylated-hydroxytoluene (BHT) and vascular response as an indicator and
monitor of drug intolerance. Ann Allergy 1973;31(3):126-33.
27. Bauer AK, Dwyer-Nield
LD, Keil K, Koski K, Malkinson AM. Butylated hydroxytoluene (BHT) induction of
pulmonary inflammation. Exp Lung Res 2001;27(3):197-216.
28. Genton C, Frei PC,
Pecoud A. Value of oral provocation tests to aspirin and food additives in the
routine investigation of asthma and chronic urticaria. J Allergy Clin
Immunol 1985;76(1):40-5.
29. Hoj L, Osterballe O,
Bundgaard A, Weeke B, Weiss M. A double-blind controlled trial of elemental
diet in severe, perennial asthma. Allergy 1981;36(4):257-62.
30. Stenius-Aarniala B,
Poussa T, Kvarnstrom J, Gronlund EL, Ylikahri M, Mustajoki P. Immediate and
long term effects of weight reduction in obese people with asthma: randomised
controlled study. BMJ 2000;320(7238):827-32.
31. Clarke L, McQueen J,
Samild A and Swain A. The dietary management of food allergy and food
intolerance in children and adults. Australian Journal of Nutrition and
Dietetics 1996;53(3):89-94.
32. Juhlin L. Recurrent
urticaria: clinical investigation of 330 patients. Br J Dermatol
1981;104(4):369-81.
33. Leclercq C, Molinaro
MG, Piccinelli R, Baldini M, Arcella D, Stacchini P.Dietary intake exposure to
sulphites in Italy - analytical determination of sulphite-containing foods and
their combination into standard meals for adults and children. Food Addit
Contam 2000;17(12):979-89.
34. Jacobson FJ, Schardt D.
Diet, ADHD and behaviour: a quarter-century review. Centre for Science
in the Public Interest, 1999 Washington DC. www.cspinet.org
35. Yan KY, Nicholas NR,
Salome C. Effect of diet on bronchial hyperresponsiveness in asthma.
Proceedings of 1st congress of the Asian Pacific Society of
Respirology. Tokyo, Japan, 1988:69, reported in Hodge L et al, cited
above.
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The Project Officer
Publications Review
Health Advisory Section
National Health and Medical
Research Council
GPO Box 9848
CANBERRA ACT 2601
ATTENTION DEFICIT HYPERACTIVITY DISORDER 1996
The Food Intolerance
Network, which now consists of over 1500 members including over 700 in a range
of specialised support groups, wishes to make a submission to the review of the
above publication.
The Food Intolerance
Network continues to disagree with the current recommendation 19 ("While
some studies have suggested that food and food additives influence some
behaviours in some children, dietary manipulation is not recommended in the
routine management of ADHD. If a special diet is instituted, it should be under
the careful supervision of a qualified dietitian, preferably with experience in
this area.") and believes that considerable research since the date of
this recommendation supports the proposed new recommendation given below.
Significant research worthy
of NHMRC review includes:
1. Center for Science in
the Public Interest Review
Center for Science in the
Public Interest "Diet, ADHD and Behavior - A Quarter Century Review "
by MF Jacobson and D Schardt 1999 (Executive Summary attached). This major
review strongly recommended, inter alia, that
2. Isle of Wight Study
This $700,000 UK Ministry
of Agriculture, Fisheries and Food Research and Development Report "Do
food additives cause hyperactivity and behaviour problems in a geographically
defined population of 3 year olds?" (FS3015 30/06/00) (Executive Summary
attached) found that 16.4% of 1873 children were hyperactive and 23.4% had
behaviour problems and
3. Bread preservative
study
This study provided
evidence of behavioural effects from a ubiquitous bread preservative and
provided a significant measure of how effective the Royal Prince Alfred Hospital
elimination diet, popularly known as the Failsafe Diet, can be in helping
children:
Abstract from Journal of Paediatrics and Child Health (2002) 38(4), 373-376.
Controlled trial of cumulative
behavioural effects of a common bread preservative
S DENGATE and A RUBEN
Darwin, Northern Territory,
Australia
Objective: Many
anecdotes and one scientific report describe cumulative behavioural effects of
bread preservative on children.
Methodology: Twenty-seven
children, whose behaviour improved significantly on the Royal Prince Alfred
diet, which excludes food additives, natural salicylates, amines and
glutamates, were challenged with calcium propionate (preservative code 282) or
placebo through daily bread in a double-blind placebo-controlled crossover
trial.
Results: Due
to four placebo responders, there was no significant difference by ANOVA of weighted
placebo and challenge Rowe Behaviour Rating Inventory means, but a
statistically significant difference existed in the proportion of children
whose behaviours 'worsened' with challenge (52%), compared to the proportion
whose behaviour 'improved' with challenge (19%), relative to placebo (95%
confidence intervals 14-60%).
Conclusions: Irritability,
restlessness, inattention and sleep disturbance in some children may be caused
by a preservative in healthy foods consumed daily. Minimising the concentrations
added to processed foods would reduce adverse reactions. Testing for
behavioural toxicity should be included in food additive safety evaluation.

The Few Foods diet is
acknowledged to be far more effective than the Feingold diet but too difficult
for general use (see Arnold 1999 under section 5, below, and Carter CM, Urbanowicz M, Helmsley R,
Mantilla L, Strobel S, Graham PJ and Taylor E. Effects of a few food diet in
attention deficit disorder, Archives of Disease in Childhood
1993;69:564-568). However the RPAH or Failsafe diet achieves similar
effects to the Few Foods diet and is suitable for widespread use (Swain et al Lancet
1985, Dengate and Ruben 2003 under section 5 below).
4. ACT school-age children's health study
In April 2003 the ACT
Legislative Assembly Standing Committee on Health recommended (see attached), inter
alia, that
5. Recent research
bearing on diet and behaviour
The following references
were not considered in preparing the 1996 NHMRC advice on ADHD:
Arnold, LE. 'Treatment alternatives for Attention-deficit/hyperactivity
disorder' Journal of Attention Disorders 1999;3(1):30-48.
Bennett, CPW and others. 'The Shipley Project: treating food allergy to
prevent criminal behaviour in community settings', Journal of Nutritional
and Environmental Medicine 1998;8, 77-83.
Boris, M. and Mandel, F. 'Food additives are common causes of Attention
Deficit Hyperactivity Disorder in children'. Annals of Allergy
1994;(72:5),462-468.
Breakey J. The role of diet and behaviour in childhood. J Paediatr.
Child Health 1997; 33:190-194.
Breakey JM, Hill M, Reilly C. and Connell H. A report on a trial of the
low additive, low salicylate diet in the treatment of behaviour and learning
problems in children. Aust J Nutr Diet 1991;48(3):89-94.
Clarke L, McQueen J, Samild A and Swain A. The dietary management of
food allergy and food intolerance in children and adults, Australian Journal
of Nutrition and Dietetics 1996;53(3):89-94.
Conners, CK. Feeding the brain: how foods affect children 1989;
Dengate, S. Dietary management of Attention Deficit Hyperactivity
Disorder, Aust J Early Childhood 1997;(22:4),29-33
Dengate S and Ruben A. Controlled trial of cumulative behavioural
effects of a common bread preservative, J Paediatr Child Health 2002;38(4):373-6.
Dengate, S and Ruben A. Letters to the editor. J Paediatr Child
Health 2003;39(7):569-70.
Feingold, BF. Dietary management of nystagmus, J Neural Transmission,
1979;45:107-115.
Loblay RH and Swain, AR. 'Food intolerance'. In: Wahlqvist M.L.,
Truswell A.S., editors. Recent Advances in Clinical Nutrition.
Parker G and Watkins T. Treatment-resistant depression: when
antidepressant drug intolerance may indicate food intolerance, Aust N Z J
Psychiatry 2002:36(2):263-5.
Rowe, KS. 'Synthetic food colourings and hyperactivity: a double-blind
cross-over study.' Australian Paediatric Journal; 1988;24:143-147.
Schettler E. and others. In harm's way: toxic threats to child
development, Greater Boston Physicians for Social Responsibility (GBPSR),
2000. http://www.igc.org/psr/
Schoenthaler, SJ. 'Diet and delinquency: empirical testing of seven
theories', International Journal of Biosocial Research 1985;7(2);
108-131.
Schoenthaler, SJ, Doraz WE and
Schulte-Korne G, Deimel W, Gutenbrunner C, et al. Effect of an
oligoantigenic diet on the behaviour of hyperactive children. Z. Kinder
Jugendpsychiatr. Psychother. 1996;24(3): 176-183.
Shaywitz BA and others. Effects of chronic administration of food
colouring on activity levels and cognitive performance in developing rat pups
treated with 6-hydroxydopamine. Neurobehavioural toxicology 1971;
Swain AR, Dutton SP and
Swain AR, Soutter VL, Loblay RH and
Uhlig T and others. Topographic mapping of brain electrical activity in
children with food-induced attention deficit hyperkinetic disorder, Eur J
Pediatr, 1997;156:557-61.
Weiss, B. Food additives as a source of behavioural disturbances in
children. Neurotoxicology 1986;7:197-208
Weiss, B. The behavioural toxicity of food additives. In: Weininger J,
Briggs GM, editors. Nutrition Update. Vol 1. New York: John Wiley &
Sons; 1983. p.21-37.
From the above it is
clear that there is sound scientific evidence for a change in stance by the
NHMRC and that in fact community action is outrunning the NHMRC.
The NHMRC may be
interested to know that our website has had nearly 200,000 visits since establishment
in September 1999 and that we continue to receive thousands of reports of the
effectiveness of the Failsafe diet for ADHD and food intolerances. The
application of this diet is made more difficult if children are already on
medication.
It is also a concern to
the Food Intolerance Network that Australia leads the world in this area, in
the work with tens of thousands of children and adults at the Royal Prince
Alfred Hospital Allergy Unit, but that their excellent work has not been
written up and exposed to peer review. NHMRC could consider ways to assist this
Unit to bring the work of Drs Loblay, Swain and Soutter the prominence that
they deserve.
Based on the above
detailed scientific studies, the Food Intolerance Network proposes that NHMRC makes
the following recommendations:
The Food Intolerance
Network continues to support the current recommendation 11 ("Further research, including
comparative studies, should be undertaken to establish the cost-effectiveness
of the various components of management of ADHD").
We look forward to
inclusion of these recommendations in the review of the publication.
Yours truly
Mrs Sue Dengate Dr
Howard Dengate
![]()
Food
Intolerance Network
Coordinator:
Sue Dengate
PO Box 85 Parap NT
0804
phone +61 8 8981 2099
fax +61 8 8942 3099
email:
sdengate@ozemail.com.au
website: www.fedupwithfoodadditives.info
_____________________________________________________________________________________
Mr Graham Peachey
CEO FSANZ
CANBERRA ACT 2610
Dear Mr Peachey
We are writing to congratulate
you on becoming CEO of FSANZ at a time of rapid changes in the nature of food
and the regulatory environment.
As one of your key
stakeholder groups, we look forward to working with you over the next five
years and take this opportunity to introduce ourselves.
The Food Intolerance
Network provides information world-wide about the effects of food on behaviour,
health and learning in both children and adults, and support for families using
the low chemical elimination diet recommended by the Australian Royal Prince
Alfred Hospital - free of additives, low in salicylates, amines and flavour
enhancers (FAILSAFE).
We have been in existence
for over ten years and in that time have been instrumental in helping tens of
thousands of people deal with their problems, through Sue's four best-selling
books, through a free bimonthly e-newsletter that goes to over 1,500 people and
through eight current email support groups with up to 200 members in each. The
Network is run by Sue and Howard Dengate from Darwin.
Sue Dengate is a psychology
graduate, former teacher and food intolerance counsellor. Her interest in the
effects of foods on children's health, behaviour and learning began with her
own children's experiences. Sue established and coordinates the world-wide Food
Intolerance Network. In 2001 she completed a 'supermarket tour' around the
world, checking food additive use in 15 countries. Random House Australia has
published "Different Kids", "Fed Up", "The Failsafe
Cookbook" and her latest, "Fed Up with Asthma".
Dr Howard Dengate is
currently Executive Director Policy & Coordination with the Northern
Territory Department of Business, Industry and Resource Development. He studied
food technology at the University of NSW and worked for 10 years in wheat
research in New Zealand before becoming Director of the Agricultural Research
Institute, Wagga Wagga, NSW and then moving to the Territory 14 years ago as
Deputy Secretary in the Department of Primary Industry and Fisheries.
Our objective is to work
with the food industry and regulators to substitute safer additives than the 50
known to cause problems (see attached) and to ensure that labelling and
point-of-sale information allow people to avoid food components that trigger
their problems.
A particular target is removal
of the 5% labelling loophole, which allows food manufacturers to choose not to
declare additives, as having "no technological effect", even when
food-sensitive people suffer chronic ill-health or behavioural problems from
the cumulative effects of additives at such levels.
After surveying Network
members, we have three current campaigns on food additives:
We note that FSANZ's recent
Fellows Symposium gave FSANZ the key message that it must establish effective
partnerships with key stakeholder groups, and overcome the communication
challenges that arise if scientific information is incomplete and/or challenges
conventional thinking.
This communication is
two-way. We look forward to being engaged with FSANZ to challenge conventional
thinking and to provide a consumer viewpoint. We encourage you and your staff
to remain current with our complete and active website www.fedupwithfoodadditives.info.
Yours truly
Mrs Sue Dengate Dr
Howard Dengate
![]()
Coordinator:
Sue Dengate
PO Box 85 Parap NT
0804
phone +61 8 8981 2099
fax +61 8 8942 3099
email:
sdengate@ozemail.com.au
website: www.fedupwithfoodadditives.info
______________________________________________________________________________________
Principal Health Inspector
NT Department of Health and
Community Services
GPO
CASUARINA NT 0811
Dear Sir or Madam
FORMAL COMPLAINT REGARDING COLONIAL FARMS GLUCOSE SYRUP
I wish to lodge a formal
complaint regarding misinformation in the labelling of the Colonial Farms Fine
Foods glucose syrup sold in the NT, as elsewhere in Australia.
The substance of my
complaint is that the label implies that the only ingredient is glucose syrup.
However glucose suppliers and manufacturers advise that the product contains
sulphur dioxide (additive 220) at up to 450 ppm. This amount is sufficient to
cause serious reactions in asthmatics sensitive to sulphites, as many are. This
issue has been raised by phone twice with the company over the last two years -
they admitted that there was sulphur dioxide in the product but they were using
up old labelling. Two years later there is no change in the labelling.
Enquiries were made because
members of Food Intolerance Network have been reporting health, behavioural and
learning reactions to this product, which should not be the case if the label
was accurate.
A letter from your Minister
recently advised that if people react to food additives, then they need only
read the label and avoid those foods. However this is only one example of many
where people do not know what is in their food unless they ring the
manufacturer and the manufacturer is willing to be honest, since regulatory
monitoring and surveillance is virtually non-existent.
In the Food Standards Code,
it is a criminal offence in Australia to supply food which does not comply with
relevant food standards, not a civil offence. Therefore I look forward to you
treating this complaint with the vigour that a criminal offence requires. The
letter will be posted on my website, as will your replies.
Yours truly
Ms Sue Dengate
cc The General Manager,
Colonial Farms Fine Foods,
cc Managing Director,
FSANZ,
cc Ms Louise Sylvan,
Australian Consumers Association, 57 Carrington Rd, MARRICKVILLE NSW 2204
![]()
Food
Intolerance Network
Coordinator:
Sue Dengate
PO Box 85 Parap NT
0804
phone +61 8 8981 2099
fax +61 8 8942 3099
email:
sdengate@ozemail.com.au
website: www.fedupwithfoodadditives.info
______________________________________________________________________________________
Principal Health Inspector
NT Department of Health and
Community Services
GPO
CASUARINA NT 0811
Dear Sir or Madam
FORMAL COMPLAINT REGARDING LOWAN WHOLE FOODS KIDS BYTES
I wish to lodge a formal
complaint regarding misinformation in the labelling of Lowan Whole Foods Kids
Bytes Real Apple Fruit Filling with Yoghurt Ribbons sold in the NT, as elsewhere
in Australia.
The substance of my
complaint is that the label says clearly that, among other ingredients, it
contains "natural colour". However enquiries of the company resulted
in advice that this "natural colour" is in fact the artificial colour
tartrazine (102) AND artifical colour sunset yellow (110).
Enquiries were made because
members of the Food Intolerance Network had earlier been reporting health,
behavioural and learning reactions to this product, which should not be the
case if the label was accurate.
A letter from your Minister
recently advised that if people react to food additives, then they need only
read the label and avoid those foods. However this is only one example of many
where people do not know what is in their food unless they ring the
manufacturer and the manufacturer is willing to be honest, since regulatory
monitoring and surveillance is virtually non-existent.
In the Food Standards Code,
it is a criminal offence in Australia to supply food which does not comply with
relevant food standards, not a civil offence. Therefore I look forward to you
treating this complaint with the vigour that a criminal offence requires. The
letter will be posted on my website, as will your replies.
Yours truly
Ms Sue Dengate
cc The General Manager, Lowan
Whole Foods,
cc Managing Director,
FSANZ,
cc Ms Louise Sylvan,
Australian Consumers Association, 57 Carrington Rd, MARRICKVILLE NSW 2204
![]()
Food
Intolerance Network
Coordinator:
Sue Dengate
PO Box 85 Parap NT
0804
phone +61 8 8981 2099
fax +61 8 8942 3099
email:
sdengate@ozemail.com.au
website: www.fedupwithfoodadditives.info
______________________________________________________________________________________
Principal Health Inspector
NT Department of Health and
Community Services
GPO
CASUARINA NT 0811
Dear Sir or Madam
FORMAL COMPLAINT REGARDING SANITARIUM SO GOOD SOYMILK
I wish to lodge a formal
complaint regarding misinformation in the labelling of Sanitarium So Good
Soymilk, sold in the NT, as elsewhere in Australia.
The substance of my
complaint is that the label makes no mention of any antioxidants being used in
the oil used in formulating the soymilk. However enquiries of the company
resulted in advice that the oil has in the past contained antioxidant TBHQ
(319) and currently, following representations from the Food Intolerance
Network, is believed to contain a mixture of tocopherols (306-309). The Food
Intolerance Network asserts that scientific evidence is that TBHQ should not be
used in any food, while it accepts that tocopherols are safe. Enquiries were
made because members of the Food Intolerance Network had earlier been reporting
health, behavioural and learning reactions to this product, which should not be
the case if the label was accurate.
The Food Standards Code
1.2.3 requires declaration of all food additives in a compound ingredient where
the food additive is performing a technological function in the final food. The
Food Intolerance Network believes that the antioxidant is clearly performing a
technological function, otherwise why is it added, and so it should be
declared.
A letter from your Minister
recently advised that if people react to food additives, then they need only
read the label and avoid those foods. However this is only one example of many where
people do not know what is in their food unless they ring the manufacturer and
the manufacturer is willing to be honest, since regulatory monitoring and
surveillance is virtually non-existent.
In the Food Standards Code,
it is a criminal offence in Australia to supply food which does not comply with
relevant food standards, not a civil offence. Therefore I look forward to you
treating this complaint with the vigour that a criminal offence requires. The
letter will be posted on my website, as will your replies.
Yours truly
Ms Sue Dengate
cc The General Manager,
Sanitarium,
cc Managing Director,
FSANZ,
cc Ms Louise Sylvan,
Australian Consumers Association, 57 Carrington Rd, MARRICKVILLE NSW 2204
![]()
(March 2002)
Food
Intolerance Network
Coordinator:
Sue Dengate
PO Box 85 Parap NT
0804
phone 08 8981 2099
fax 08 8942 3099
email:
sdengate@ozemail.com.au
website:
www.ozemail.com.au/~sdengate
______________________________________________________________________________________
Dr Ian Lindenmeyer
Managing Director
ANZFA
CANBERRA MC ACT 2610
Dear Dr Lindenmayer
FURTHER ADVERSE EXPERIENCES WITH
ADDITIVE 635 (SODIUM 5’ RIBONUCLEOTIDES)
In May 2000 the Food
Intolerance Network provided you with twelve detailed reports of serious
reactions to Food Additive 635. The response from ANZFA was patronizing at best,
suggesting that we should provide clinical evidence, which is clearly beyond
the resources of this Network. The response left unanswered the serious issues
raised, which are that you appear to have no system where adverse experiences
can be reported and heard nor any publicly available evidence of safety of this
additive.
The situation remains the
same today. There are still people being seriously affected every day by this
additive. It is being found in an increasing range of foods, including takeaways
where it is impossible to obtain information about its presence in the food.
We provide below some more
recent reports concerning this additive:
Above we have provided more
evidence of serious reactions to an additive that ANZFA has officially approved
for everyday use in Australian and New Zealand food. We seek your answers to
the following questions:
We believe that some
Australians and New Zealanders have probably already died from the effects of
Additive 635. They would be recorded as death from asthma or anaphylactic
shock, but nobody is looking for the cause in the increasing use of a dangerous
food additive. It is time ANZFA took it seriously.
Yours truly
Mrs Sue Dengate Dr
Howard Dengate
cc Ms Louise Sylvan,
Australian Consumers’ Association.
![]()
Food
Intolerance Network of Australia (FINA)
Coordinator:
Sue Dengate
PO Box 85 Parap NT
0804
phone 08 8981 2099
fax 08 8942 3099
email: sdengate@ozemail.com.au
website:
www.ozemail.com.au/~sdengate
21 May 2000
Project
Manager, Draft Joint Code
Australia
New Zealand Food Authority
Canberra
Mail Centre ACT 2610
AUSTRALIA
SUBMISSION ON THE DRAFT
JOINT AUSTRALIA NEW ZEALAND FOOD STANDARDS CODE
This submission is made by
the above national body representing those one to two million people in
Australia and New Zealand who are, knowingly or not, affected on a daily basis
by food intolerance. It is provided after the official closing date for
submissions of 17 May because consultation in Darwin occurred on 16 May and the
ANZFA official present agreed to a late submission for that reason.
FINA continues to object to
the wider use of 50 additives and will continue to campaign for their presence
to be reduced or eliminated. However, addressing the Draft Food Standards Code
as a whole and its overall effectiveness and clarity, as amended for issues in
the addendum provided, FINA supports the draft except for two issues upon which
we request serious consideration from ANZFA.
First, we seek specific
notice within the Food Standards Code for food manufacturers and consumers of
those 50 additives that are recognised as causing problems for the food
intolerant people in Australia and New Zealand. The Food and Grocery Council of
Australia now recognise in their publications that 5-10% of the population is
food intolerant. Your advisers at the Royal Prince Alfred Hospital can confirm
that, out of the myriad of food additives, only 50 are known to contribute to
food intolerance reactions at present levels of use.
It would be clearly in the
interests of both food manufacturers and consumers if the peak food regulatory
body provided sound information and guidance as to which additives cause problems
and which are of no concern. This is essentially an education task, with
several food manufacturers already approached by FINA expressing gratitude for
the guidance that this information could provide. As was evident at the
briefing in Darwin, food manufacturers don't yet understand which additives
cause problems and which don't. At present, consumers too are bewildered by the
myriad names and numbers of additives and may well be avoiding foods that
present no risk to anyone. At the same time, there are various public lists of
"harmful" additives with no references or rational basis that either
exaggerate or confuse consumers.
We understand that
alteration of Schedule 1 of Standard 1.3.1 provides a difficulty in that this
Schedule is the only part that has presently been through the entire
Ministerial process. If this is correct, the suggested notice will either have
to be put through the whole process again, or it might better be included in
Standard 1.3.1 as a new Clause 13. Additives which may affect food
intolerant people. We attach a list that could then form the basis for a
Table to Clause 13.
We believe that the
proposal given above would take considerable heat from the present debate,
would be welcomed by food manufacturers and consumers alike, and would be taken
as evidence of leadership by both ANZFA and Health Ministers if it were
implemented within the new Food Standards Code.
Second, we have strong
concerns that, according to the Draft, there will be additives in compound
foods that will not have to be declared on labels if a manufacturer, without
having to provide evidence, decides that they are not performing a
technological function. Since you already require that ALL food additives must
perform a technological function (Standard 1.3.1 Food Additives says under
Purpose that "A food additive may only be added to food where expressly
permitted in this standard. Additives can only be added to food in order to
achieve an identified technological function according to Good Manufacturing
Practice."), surely this restriction is superfluous.
As
consumers, we want to know what additives are in the food, not whether they
continue to perform a technological function. Even small amounts affect some
people, and the effects of additives are both dose-related and cumulative,
facts that your approvals process has yet to digest.
We do
understand that additive levels will be low in the compound ingredient and
appreciate that the new standard is a considerable improvement on the old 25%
compound ingredient level. But we don't understand why it is still necessary to
insist on the additive being declared ONLY if there remains a technological
function in the final food. Why not simplify Clause 7 in 1.2.4 by deleting the
superfluous reference to technological function, vis:
1.2.4 Labelling of
Ingredients allows
that:
7 Declaration of compound ingredients…(at less than 5% by weight)…"subject to
clause 4 of Standard 1.2.2, all food additives in the compound
ingredient."
And then
you can also drop the long and tortuous Editorial Note following, which is akin
to determining how many angels can dance on a pin and leaves consumers
suspicious of food manufacturers' motives in failing to declare additives that
are known to be present.
This change would also ensure
the complete accuracy of Clause 4 of Standard 1.2.2 Mandatory
Information Requirements, which states that:
4 (1) The
label on a package of food must include a declaration of the presence in the
food of the substances listed in the Table to this clause, when present as -
(a) an
ingredient;
(b) an
ingredient of a compound ingredient;
(c) a food
additive or component of a food additive; or
(d) a
processing aid or component of a processing aid.
Otherwise, if we understand
the complexities of the drafting, the above clause will need to be modified to
add to 4(1) (c) "…except in the case of compound ingredients.", which
is untidy.
Thank you for the
opportunity to comment. We trust that the above can be considered
constructively and stand ready to support ANZFA publicly over the above
changes.
Yours truly
Mrs Sue Dengate Dr
Howard Dengate
|
FOOD ADDITIVES WHICH MAY CAUSE
PROBLEMS FOR FOOD INTOLERANT PEOPLE |
|||
|
COLOURS |
|||
|
Artificial colours |
102 Tartrazine 107 Yellow 2G 110 Sunset yellow FCF 122 Azorubine 123 Amaranth 124 Ponceau 4R 127 Erythrosine 129 Allura red AC 133 Brilliant Blue FCF 142 Green S 151 Brilliant Black BN 155 Brown HT |
Natural colour |
Annatto natural colour 160b |
|
PRESERVATIVES |
|||
|
Sorbic acids |
200 Sorbic acid 201 Sodium sorbate 202 Potassium sorbate 203 Calcium sorbate |
Benzoic acids |
210 Benzoic acid 211 Sodium benzoate 212 Potassium benzoate 213 Calcium benzoate |
|
Sulphites |
220 Sulphur dioxide 221 Sodium sulphite 222 Sodium bisulphite 223 Sodium metabisulphite 224 Potassium metabisulphite 225 Potassium sulphite 228 Potassium bisulphite |
Antioxidants |
310 Propyl gallate 311 Octyl gallate 317 Erythorbic acid 318 Sodium erythorbate 319 tert-Butylhydroquinone 320 Butylated hydoxyanisole (BHA) 321 Butylated hydroxytoluene (BHT) 312 Dodecyl gallate |
|
Propionic acids |
280 Propionic acid 281 Sodium propionate 282 Calcium propionate 283 Potassium propionate |
Nitrates & nitrites |
249 Potassium nitrite 250 Sodium nitrite 251 Sodium nitrate 252 Potassium nitrate |
|
FLAVOUR ENHANCERS AND ADDED FLAVOURS |
|||
|
Glutamates |
620 L-Glutamic acid 621 Monosodium glutamate (MSG) 622 Monopotassium glutamate 623 Calcium dihydrogen diLglutamate 624 Monoammonium L-glutamate 625 Magnesium di-L-glutamate 627 Disodium guanylate* 631 Disodium inosinate* 635 Sodium 5' ribonucleotide* |
Added flavours |
many |
from Clarke, L and others, Dietitians
Association of Australia review paper: 'The dietary management of allergy and
food intolerance in adults and children', Aust J Nutr & Diet (1996) 53:3;
Royal Prince Alfred Hospital Allergy Unit, 'The Simplified Elimination Diet',
available from dietitians; Dengate, S 'Fed Up', Random House, 1998; and Swain A
and others, 'Friendly Food', Murdoch Books, 1991 *Not yet proven.
![]()
Food
Intolerance Network of Australia (FINA)
Coordinator:
Sue Dengate
PO
Box 85 Parap NT 0804
phone
08 8981 2099 fax 08 8942 3099
email:
sdengate@ozemail.com.au
website:
www.ozemail.com.au/~sdengate
1 May 2000
Dr Ian Lindenmeyer
Managing Director
ANZFA
PO Box 7186
CANBERRA MC ACT 2610
Dear Dr Lindenmeyer
FORMAL REQUEST FOR INVESTIGATION OF ADDITIVE 635
FINA has received numerous
complaints concerning the food additive 635 (sodium 5' ribonucleotide), which
is found in tasty snack foods - pies, party pies, flavoured chips, flavoured
noodles, dried soups. The effects reported are serious and in one case to date
were life threatening.
Here is a typical response:
"I ate just a few CC's at a staff function.
Within an hour I had a red rash and itch like that from a caterpillar inside my
right elbow. By the time I went to bed I was scratching myself all over the
armpit and upper body. Having a shower really made it go, across my chest and
up my neck on the right. The next morning at an aerobics class I had a red rash
over my entire right body from the waist up to my neck, where it formed an
unsightly and extremely itchy vivid red high-water mark around my neck.
"Three days later I still have lumps and itches
in my right armpit and up to my face. I seem to have become hyper-sensitised to
other allergens that rarely affect me, sneezing, scratching and itching. If I
hadn't seen this all happen to my son I wouldn't believe that it was caused by
such a small amount of an additive. And I know that it will last a week, based
on his experience.
And here's one that appears
to be anaphylactoid:
"I have a story regarding flavour enhancer 635
from the eight-year old boy next door.
"Last year he ate a pie bought from a bakery shop
near his mother's workplace. Not only did he get the skin reaction he also
suffered a life-threatening anaphylactic-type reaction with swelling of mouth,
tongue and throat. The doctor (fortunately a doctor's surgery was just around
the corner) who treated him said that he was probably a matter of minutes away
from death. He remained on antihistamines for weeks and missed a lot of school.
For days his lips protruded four inches or so! The family was unable to find
out what was in the pie and so the cause of the reaction remained a mystery.
"A little over a month ago this child was given
two or three CC's by a friend at school. Within a short time his arms were
itching and his chest was covered in red and white wheals. This reaction was
not as severe as the pie incident (the dose was no doubt much lower). I think
that reaction took a week to subside.
"His mother has commented that this boy has had
no problems of this kind until last year, although he does have a history of
mild asthma.
"It wasn't until I was looking through your web
site that I found the more-than-likely culprit. The family is very grateful. Once
again
"THANK YOU! Surely 635 cannot go on being legal -
if it was a drug it would be taken off the market or used, if deemed necessary,
with extreme caution under hospital conditions, I'm sure!
These detailed anecdotes
are backed up by e-mails to FINA from all over
As a result of the above
reports, FINA formally requests that ANZFA investigate additive 635 for its
health effects and requests to be informed in detail of the process that ANZFA
will follow in investigating this adverse experience report.
Yours truly,
Sue Dengate
cc Dr Heather Yeatman,
ANZFA Board
cc Nicola Ballenden,
Australian Consumers' Association
cc Dr Dick Copeman,
Consumer Food Network
![]()
Food
Intolerance Network of
Coordinator:
Sue Dengate
phone 08 8981 2099
fax 08 8942 3099
email:
sdengate@ozemail.com.au
website:
www.ozemail.com.au/~sdengate
1 May 2000
Dr Ian Lindenmeyer
Managing Director
ANZFA
CANBERRA MC ACT 2610
Dear Dr Lindenmeyer
I thank your Acting
Managing Director, Peter Liehne, for his rapid response on 31 March to my
Network's letter of
At the risk of appearing
repetitious, the issues I raised were, in order:
ANZFA's
responses:
"…ANZFA…generated considerable confusion for [its] stakeholders
during the review process…[and so will]…generate more user friendly reports in
the future."
Friendly towards whom, your clients the food industry? My Network is not
looking for user-friendly reports but consumer-friendly action!
"..the review resulted in more general permissions for a large
number of food additives…[and]…is expected to lead to decreased levels of usage
in many foods."
The expectations and experience of my group about levels of usage is exactly
the opposite - you may recall a claim in my last letter that it has become
virtually impossible to buy bread without propionate 282 just in the last five
years. Every day there are less foods available without the Big 50 Additives,
as FINA attests on a daily basis. Unless you can provide some evidence of
reduced additive usage, this statement from ANZFA is wishful rubbish - do you
have evidence that I can peruse?
"ANZFA has reduced
levels of permissions in some cases." Thank you for the two additives where this has
occurred. On the other hand, the majority of additives have now been permitted
to be used in a wider variety of foods, so that the total dose will increase.
As Dr Weiss has shown, in references earlier supplied to you, it is the total
dose that is important in affecting food intolerant people. Where is the
scientific evidence of safety on total additive dose?
Positive suggestion: FINA suggests that you improve your understanding of consumers' views
and knowledge through improved consultative processes and will be pleased to
contribute to that end.
ANZFA's responses:
"…safety
assessment…is based on exhaustive laboratory testing…" There are two matters to criticise
here. On is that, despite the excellent nutritionists which you employ, there
is no testing for safety of total additive load, for mixed additives or for
interactions between them. Second, and more seriously, the basis of risk
assessment is never the so-called minor health problems, learning or behaviour.
Working from the medical model, ANZFA uses classical laboratory-based toxicology
and has yet to recognise the wider social implications of the use of these
chemicals.
Where is the assessment in
health terms of itchy skin rash, irritable bowel, asthma, tinnitus, 'restless
legs', headache, migraine, lethargy, irritability, restlessness, sleep
disturbance, anxiety, depression, impairment of memory and concentration and
hyperactivity?
"additives …are
considered to be safe for the vast majority of the population…there may be a
small number of individuals who are particularly sensitive to some food
additives.."
ANZFA remains unwilling,
probably for legal rather than scientific reasons, to publicly acknowledge the
fact that the Big 50 food additives daily affect 1-2 million Australians and
New Zealanders. Scientifically, "the prevalence of pharmacological food
intolerance is unknown but it is estimated to occur in 10% of the population.
It occurs much more commonly than food allergy" (Australian Journal of
Nutrition and Dietetics,1996 53:3 p91). Even the Australian Food and Grocery
Council, in their "Facts on Foods" information sheet provided by Mr
Liehne, explicitly recognise food intolerance as affecting 5-10% of the
population - in my view, 10% is a vast minority which ANZFA is failing badly
and they are belittled by your statement.
Positive suggestion: I suggest that you acknowledge that a significant part of your
constituency is affected by food additives and work towards including broader
health, behaviour and learning parameters in your testing of additives so as to
obtain better outcomes for consumers.
ANZFA's response:
"..avoid eating
these substances…food additives are generally required to be identified when
used in foods." For
some reason, it is that word 'generally' that strikes fear into my heart. There
are two issues here. One is labelling. FINA is pleased that there has been an
extension of "mandatory labelling requirements for all food
additives" and in particular that the pernicious practice of allowing
25% of a food ingredient to contain undeclared additives will be reduced to 5%
over the next 18 months. The reality for FINA members is that labelling is
often wrong and that there are no effective sanctions for mislabelling or
exceeding regulatory limits. The shift to Good Manufacturing Practice will
exacerbate this situation.
The second issue is that
ANZFA claim to require "more informative labelling of substances that
may cause adverse reactions in foods" but in fact there will be no
warning that the Big 50 cause adverse reactions. Their presence will be shown,
but not their possible effects on 1-2 million Australians and New Zealanders.
FINA receives hundred of
e-mails a week now about these two issues, but hard data is lacking.
Positive suggestion: ANZFA undertake market research into changes in the range of foods and
the total daily intake of food additives following implementation of P150 and
reveal the results publicly.
Positive suggestion: ANZFA could fund the writing up of the important research performed by
the
Finally, I take certain
pleasure in attaching a bread wrapper from a Goodman Fielder "Vogel"
loaf showing propionate 282 as an ingredient, contrary to their advice to you.
Take a look on the bread shelves when next you're shopping - five years ago
there was virtually no propionate used, today you can scarcely buy one without
it.
Please spend some ten
minutes personally browsing my website at http://www.ozemail.com.au/~sdengate
and you will see that the effects of these additives is an issue of growing
political importance that will not go away.
Yours truly,
Sue Dengate
cc Dr Heather Yeatman,
ANZFA Board
cc Nicola Ballenden,
Australian Consumers' Association
cc Dr Dick Copeman,
Consumer Food Network
![]()
Food
Intolerance Network of
Coordinator:
Sue Dengate
phone
08 8981 2099
email:
sdengate@ozemail.com.au
The Hon Dr Michael
Wooldridge
Minister for Health &
Aged Care
Parliament House
Dear Minister
Thank you for your response
to my earlier letter raising concerns about food additives and food labelling
and their effects on the probably 1.8 million Australians who are affected on a
daily basis by food intolerance.
I understand that Health
Ministers are shortly to vote on Proposal P150 which, if passed, will
considerably increase the range of foods in which food additives known to have
ill-effects will be found.
If you intend to vote in
favour of the this proposal, you may wish to consider not just the daily human
cost and difficulty your decision will inflict on many people, but also the
real political difficulty you will face in reversing this decision when the
time to restrict many food additives inevitably arrives. The scientific
evidence is clear and has been presented several times to ANZFA, but their
response is bureaucratic and process-driven, as you will see from their latest
letter (attached).ANZFA1.pdf
I attach for you a poster
that is being distributed to schools, dieticians, support groups and the media
throughout
This issue has also been
recently filmed by A Current Affair (Channel 9) and will be screened in the
next two weeks.
The increasing daily number
of visitors to my website (http://www.ozemail.com.au/~sdengate)
is also evidence of a growing body of concern that will inevitably involve you
politically. Please take a look at the human stories there.
My Network hopes that you
will closely question the officials who are recommending this course of action
in P150 and arrive at a precautionary scientific approach.
Yours truly,
Mrs Sue Dengate
![]()
(March 2000)
For ANZFA's response, click here (requires Acrobat
Reader). A full response is being prepared, but note that, contrary to ANZFA's
advice relayed from Goodman Fielder, I hold a bread label from
"Vogels" that does contain added propionate (282).
![]()
Food
Intolerance Network of
Coordinator:
Sue Dengate
phone
08 8981 2099
email:
sdengate@ozemail.com.au
Dr Ian Lindenmeyer
Managing Director ANZFA
Dear Dr Lindenmeyer
I really must take
exception to your statement in the most recent ANZFA News No17 where you claim
that "we take these consultations very seriously and often change proposed
regulatory measures in response to external comment."
This statement is totally
at odds with the actual practice that I have observed in dealing with ANZFA
over the last three years. The most recent was ANZFA's progress report on
Proposal P150 "A Joint General Standard for Food Additives".
The detailed concerns of my
Network, backed up by considerable scientific references, and those of a
further 30 groups and individuals who made similar submissions, were uniformly
dismissed in one easy sentence: "all issues have been dealt with
previously either in the Policy paper or in the full assessment report of
P150".
In contrast, the action
taken by ANZFA with respect to, for instance, the Australian Food and Grocery
Council, was almost uniformly to roll over and say "changes made".
Reading through the changes resulting from the inquiry, the columns are full of
extensions of uses of additives. Any restrictions are trivial and requested by
food manufacturers. The changes requested by manufacturers and approved by
ANZFA will considerably extend the use of food additives in the food of
Australians and New Zealanders, to the daily detriment of those people who
react to additives.
Why can't ANZFA follow the
logic of the following statements and respond to them in a responsible manner?
While
My family and I recently
drove 10,000km return from
By the way, please don't
try to tell me that this bread preservative is safe. I know you don't have any
scientific evidence of its safety on health, behaviour and learning, because I
have asked for it from your Minister before without ever receiving a response.
Dr Loblay, of course, can confirm that preservative 282 calcium propionate is a
known problem for many people. My own research, to be published this year, will
place the matter on the scientific record.
I think that it is time that
ANZFA took seriously the evidence of the effects of the fifty food additives
listed in the attachment and applies the precautionary principle in more than
rhetoric. Please spend some ten minutes browsing my website at http://www.ozemail.com.au/~sdengate
and you might see that the effects of these additives is an issue of
considerable and direct importance that will not go away.
Yours truly,
Sue Dengate
cc Dr Heather Yeatman,
ANZFA Board, cc Nicola Ballenden, Australian Consumers' Association cc Dr Dick
Copeman, Consumer Food Network
![]()
(November 1999) A letter to health ministers
Sydney, 8 November 1999
Dear Minister,
We want to express our sheer
anger against the Australian New Zealand Food Authority proposal " P150: A
Joint General Standard for Food Additives " allowing food additives in
higher doses in already contaminated food and increasingly in others, which
previously escaped manipulation.
Daily we try to keep my son
away from drinks and sweets rigged with artificial colours, humble breads full
of 282 preservative, sausages filled with sulfites to look falsely fresh and
jumpy, vanilla ice creams with colour !!! 160(b) etc. The list is long and we
don't want it to be longer.
After my son has a soft
drink, few sweets or goes to certain food outlets, we know that shortly we will
be unwillingly cast in that horror movie with Linda Blair " The Exorcist
". We see these foods with additives affect the health and behaviour of
our family. Reactions to food additives are definitely dose related and
cumulative. We know from other parents of their behaviour related family
problems. What about the increased proportion of hyperactivity in our children?
Do you think it is just a myth or a trendy fad? Can you explain the road rage
incidents, especially those involving young woman? (Apparently, woman are twice
as likely to be affected as men are). Can you explain that when we buy Italian
wafers, the content information states "flavours added for Australia, USA
and Canada"? You create a monster wanting more and more, throwing many on
the already over stretched Medicare system.
In our opinion this is
institutionalised crime of Federal and State Governments and big business
slowly poisoning the public, and most importantly, our children and our family.
What are we going to do
about that? We are going to ignore food with harmful additives and we are going
to be vocal about it. When P 150 is passed, we shall be more vocal and act
within our community to bring awareness of yours and big business actions.
Take firm path now and
prevent the long, bumpy road ahead by refusing the Food Industry their
additives.
Yours sincerely
Jane and Richard van Hagen
NSW
![]()
(August
1999)
Food Intolerance Network of Australia (FINA)
MEDIA RELEASE - 23rd August 1999
_____________________________________________________________________
"The use of food
additives known to affect health, behaviour and learning is about to be
considerably extended with the approval of the Australian New Zealand Food
Authority ANZFA, the body that is meant to protect consumers" claims Sue
Dengate, popular author and coordinator for the Food Intolerance Network of
Australia FINA.
Over the last year there
has been a review of Australian Standards for Food Additives, run by ANZFA.
Their recent report considerably widens the range of foods in which Australians
will consume additives.
"Of over 300 permitted
additives, there are nearly 60 which are known to have effects on people on a
daily basis, especially on children. These include some natural and artificial
colours, a range of preservatives like benzoates, sorbates and propionates,
some antioxidants and flavour enhancers. Safe alternatives exist for most of
them, either in the form of other additives or improved technology."
"Most people don't
realise they are affected by food additives. If you eat them every day, how can
you notice the difference? The main effect is a short fuse, like over-reacting
when things go wrong, and restlessness, as when children go to bed like
jack-in-boxes. Other daily symptoms that can affect the 5-10% of the population
who are food intolerant include itchy skin rash, irritable bowel, asthma,
tinnitus, 'restless legs', headache, migraine, lethargy, irritability,
restlessness, sleep disturbance, anxiety, depression, impairment of memory and
concentration, and hyperactivity " warns Sue Dengate.
A key example is the
additive number 282, calcium propionate, which is now used widely as a mould
inhibitor in bread. Its known effects on children's learning and behaviour are
not obvious because it is eaten every day by nearly everybody. Now ANZFA is
proposing to allow it to be used in "preparation of food additives, cheese
and cheese products, fat emulsions (>80% oil), dried fruits and vegetables,
fruit and vegetable spreads including jams, chutneys and related products,
fruit and vegetable preparations including pulp, fruit and vegetable juices and
fruit and vegetable products, water based flavoured drinks, alcoholic beverages
(including low and no alcohol), mixed alcoholic drinks not elsewhere
standardised, and mixed foods".
"Genetically
engineered foods might someday possibly affect people, but these additives are
seriously affecting many people now. Tell your Health Minister that you don't
want any extension of the use of harmful food additives," urges Sue
Dengate.
________________________________________________________________________
Further information from
Sue Dengate, Food Intolerance Network of
![]()
(September
1999)
Food
Intolerance Network of Australia (FINA)
Coordinator:
Sue Dengate
PO
Box 85 Parap NT 0804
email:
sdengate@ozemail.com.au
15th August 1999
Dear Minister
Thank you for your response
to my earlier letter raising concerns about food additives and food labelling
and their effects on the probably 1.8 million Australians who are affected on a
daily basis by food intolerance (Your reference ).
The fear that I expressed
to you at the time was that the Australia and New Zealand Food Authority
(ANZFA) would continue their policy of polite non-engagement on this issue so
critical for the health, behaviour and learning of so many people. And this is
indeed what has happened. This week I received from ANZFA a progress report on
Proposal P150 "A Joint General Standard for Food Additives".
The detailed concerns of my
Network, backed up by considerable scientific references, and those of a
further 30 groups and individuals who made similar submissions, were uniformly
dismissed in one easy sentence: "all issues have been dealt with
previously either in the Policy paper or in the full assessment report of
P150".
In contrast, the action
taken by ANZFA with respect to, for instance, the Australian Food and Grocery
Council, was almost uniformly to roll over and say "changes made".
Reading through the changes resulting from the inquiry, the columns are full of
extensions of uses of additives. Any restrictions are trivial and requested by
food manufacturers. The changes requested by manufacturers and approved by
ANZFA will considerably extend the use of food additives in the food of
Australians and New Zealanders, to the daily detriment of those people who
react to additives.
Let me give just two
examples. The additive number 282 calcium propionate is now used widely in
bread as a mould inhibitor and is particularly iniquitous because it is eaten
every day by nearly everybody, meaning that its known effects on children's
learning and behaviour are not obvious since people are rarely free of its
effects. If you want a second opinion on this effect, it can be provided by the
Royal Prince Alfred Hospital Allergy Clinic in Sydney, whose researchers lead
the world in this area and who have treated over 15,000 people over the past
years.
Calcium propionate is now
to be used in "preparation of food additives, cheese and cheese products,
fat emulsions (>80% oil), dried fruits and vegetables, fruit and vegetable
spreads including jams, chutneys and related products, fruit and vegetable
preparations including pulp, fruit and vegetable juices and fruit and vegetable
products, water based flavoured drinks, alcoholic beverages (including low and
no alcohol), mixed alcoholic drinks not elsewhere standardised, mixed
foods".
Please ask your scientists
to provide you with a published paper that shows that calcium propionate is
safe. Please don't just ask your bureaucrats to provide a suitably anodyne
response: ask for specific evidence that this additive has been tested for its
affects on health, behaviour and learning, particularly in small children. I
venture to suggest that there is no positive evidence, since my searches have
found none. There are papers that talk about acute toxicology in rats, but here
we have a massive experiment on Australians, a dramatic extension of use of
just one additive that is known to cause problems. I have provided to you
before, and now attach again (ATTACHMENT A), my core group of scientific
references that prove that food additives affect people at levels currently
used: where are the counter-arguments?
By the way, lest you be
persuaded that 282 calcium propionate is essential for supplying bread to
Australians and New Zealanders, please be advised that it is not in fact used
to stop moulds from the air growing on bread, whose surfaces are free of mould
on exiting the ovens. It is added because it is easier for manufacturers of use
an additive than to keep their factories clean. If their bread slicers and
machines were wiped over probably once a week with vinegar, there would be no
need for the additive. Poor hygiene and a cheap technological fix are behind
this additive, which is rarely used in many countries but which is now almost
ubiquitous in
The second example is that
of 321 butylated hydroxy toluene (BHT) and its cousin 320 butylated hydroxy
anisole (BHA), used as antioxidants. The respected "Additive Code
Breaker" (Lothian Books, Melbourne 1996) has this to say: "BHA is not
permitted in foods intended specifically for infants and young children…. there
is a mass of evidence to support the safety of BHA…there are also many
scientific reports which cast doubt on its safety. At high levels there are
frequent reports of toxicity…children who eat foods containing BHA are
particularly likely to consume more than average…Some people are allergic to
BHA…". And of BHT: "Some people are sensitive to the presence of BHT
and develop rashes…there is a recent report in the Lancet of BHT causing
a violent skin rash in a young French woman…".
ANZFA's action on BHT?
Edible oils & oil emulsions - P150 level: NOT PERMITTED Now: 100mg/kg. Yet
this is an additive where a safe alternative exists (306-309 tocopherols) and
where modern packaging renders the necessity unlikely. Did you know that it is
not possible to buy refined vegetable oil in cold
Please note that my Network
is NOT asking for all additives to be banned. Many are useful or at
least harmless. But the 60 additives listed in ATTACHMENT B are known to affect
people from scientific literature. Safe alternatives exist for most of them,
either in the form of other additives or improved technology.
I went to the trouble of
obtaining a copy of the Policy referred to, entitled "Framework for the
assessment and management of food-related health risks (September 1996)."
This document identifies in some 30 pages assessment and management for
chemical risks, microbiological risks and nutritional risks, yet suffers from a
glaring deficiency which is that nowhere is there definition of what is meant
by "adverse effects" or "health risks". There are rather
circular statements: "probability of an adverse health outcome" (page
1) and "those aspects of the diet which could adversely affect human
health either in the short or long term" (page 3). For most people, it
would be regarded as an adverse outcome if a food that one ate every day
contributed towards the following symptoms, as they do in 10% of the
population:
A
family history of related symptoms is very common, and women are affected about
twice as frequently as men. In some allergic individuals with eczema, asthma or
rhinitis, food chemicals many aggravate their pre-existing symptoms."
(Australian Journal of
Nutrition and Dietetics (1996 53:3 p91))
Let me put these into
layman's terms as daily symptoms: itchy skin rash, irritable bowel, asthma,
tinnitus, 'restless legs', headache, migraine, lethargy, irritability,
restlessness, sleep disturbance, anxiety, depression, impairment of memory and
concentration and hyperactivity.
But, please note: there is
no assessment of food additives for effects on health in these terms, or on
behaviour or learning, particularly with children. Again, please ask your
scientists this direct question. I hope that the answer will surprise you.
The Policy does admit that
there are other dimensions to risk, including "psychological, social,
ethical and economic", then admits that they will not be explored. Too
hard. It also claims, without providing evidence and against known evidence
given above, that "food intolerance is restricted to small sub-populations
or individuals". Ten percent is a small sub-population, of sub-humans
perhaps?
The Policy says, "For
food additives…the Authority has the responsibility to establish and maintain
food standards where necessary to protect public health and safety" (page
4). Nobody reading the detail of the Inquiry Report on P150 would believe for a
minute that it was done for the public, when all members of the public were so
blatantly fobbed off and industry so clearly favoured. This objective for ANZFA
cannot be met until they address the mounting evidence that:
Therefore the methodology
used to assess intake and safety is seriously flawed and requires change. If
adequate and appropriate methodology were applied, then what would appear in
the approved Standard would be very different from that which is presently
proposed.
You should also be shaken
by the statement in the Policy, to which you have presumably acceded, that
"In general, food allergenicity and intolerance reactions cannot be
predicted from present animal models." Then how are they detected or
predicted? There is no adverse reaction reporting mechanism coordinated at the
Commonwealth level, and my members report State/Territory post-approval
monitoring as non-existent. As an example of adverse reactions known to the
public, here are two specific additives upon which I have received many reports
of problems. These are the propionates (280-283) now widely used in bread and
eaten every day, causing irritability, aggression, headaches, stomach aches,
lethargy, bedwetting and urinary urgency. I am presently writing up results of
research into the effects of 282 on children. The second is the flavour
enhancer 635 approved in 1994, which from many reports to me may be associated
with itchy skin rashes up to 30 hours after ingestion. Rashes may vary from
mild to dramatic. Reports include school children suffering itchy rashes after
eating chips and party pies at class parties, some children requiring emergency
treatment in the middle of the night and up to two weeks of antihistamine
treatment after eating foods containing additive 635. Others develop a chronic
mild rash. Typical foods include flavoured chips, instant noodles and party
pies. The reaction is dose-related and cumulative. Some individuals are more
sensitive than others are. Adults may be affected too.
It appears that, in the
absence of "animal models", ANZFA with the food industry is carrying
out a massive uncontrolled experiment on the Australian population. Or is there
something that I've missed?
In summary, my Network does
not accept that the concerns, which I have raised repeatedly, have been
addressed in the Policy or in the full assessment report of P150, as alleged.
We have been fobbed off again.
I also reiterate that what
I seek from you, on behalf of the Food Intolerance Network of Australia is
clear public assurance that:
While the recent public
debate about genetically modified foods has largely been about future and
potential risks, the effects of food additives are present and real. The
effects are felt every day by the many people who lead twilight lives of chronic
ill health, poor school performance and poor social behaviour. I have
appreciated your leadership on the genetically modified food issue and look
forward to similar leadership on the issue of food intolerance and additives.
In conclusion, I attach a
thoughtful excerpt from "Living Downstream" by the ecologist Sandra
Steingraber, who is our modern Rachel Carson of "Silent Spring" fame.
It presents policy principles that need to be adopted for food in Australia:
the precautionary principle, the principle of reverse onus, and the principle
of least toxic alternative. I commend them to you.
Yours truly,
Mrs Sue Dengate
_____________________________________________________________________________________________________
ATTACHMENT A: KEY
REFERENCES
Bennett CPW and others,
(1998) 'The Shipley Project: treating food allergy to prevent criminal
behaviour in community settings', J Nutr & Environmental Med, 8,
77-83.
Bennett CPW and others
(1997) 'The health of criminals related to behaviour, food, allergy and
nutrition: a controlled study of 100 persistent young offenders', Journal of
Nutritional and Environmental Medicine, 7; 359-366
Boris, M. and Mandel, F.
(1994) 'Food additives are common causes of the Attention Deficit Hyperactive Disorder
in children'. Annals of Allergy (72:5),462-468.
Carter, C.M., Urbanowicz,
M., Helmsley, R., Mantilla, L., Strobel, S., Graham, P.J. and
Clarke, L., McQueen J.,
Samild, A. and Swain, A. (1996) 'The dietary management of food allergy and
food intolerance in children and adults'. Australian Journal of Nutrition
and Dietetics (53:3),89-94.
Conners, C.K. (1989) Feeding
the brain: how foods affect children.
Egger, J., Carter, C.M.,
Graham, P.J., Gumley, D. and Soothill, J.F. (1985) 'Controlled trial of
oligoantigenic treatment in the hyperkinetic syndrome'. Lancet
(1),540-45.
Harley, J.P., Ray, R.S.,
Tomasi, L., Eichman, P.L., Matthews, C.G., Chun, R., Cleeland, C.S., and
Traisman, E. (1978) 'Hyperkinesis and food additives: testing the Feingold
hypothesis'. Journal of Pediatrics (61),818-828.
Kaplan, B.J., McNichol,
R.D., Conte, R.A. and Moghadam, M.D. (1989) 'Dietary replacement in
preschool-aged hyperactive boys'. Journal of Pediatrics (83),7-17.
Loblay R.H. and Swain, A.R.
(1986) 'Food intolerance'. In: Wahlqvist M.L., Truswell A.S., editors. Recent
Advances in Clinical Nutrition. London: John Libbey, 169-177.
Rowe, KS (1988) 'Synthetic
food colourings and hyperactivity: a double-blind cross-over study.'Aust
Paediatr Journal; 24:143-147
Rowe, K.S. and Rowe K.L.
(1994) 'Synthetic food colouring and behaviour: a dose response effect in a
double-blind, placebo-controlled, repeated-measures study'. Journal of
Pediatrics (125),691-8.
Schaumberg, H. H. and
others (1969) 'Monosodium L-Glutamate:its pharmacology and role in the Chinese
Restaurant Syndrome', Science 163;826-828
Schoenthaler, S. J. (1985)
'Diet and delinquency: empirical testing of seven theories', International
Journal of Biosocial Research, 7(2); 108-131
Weiss, B. (1983) 'The
behavioural toxicity of food additives'. Nutrition Update (1), 21-37.
ATTACHMENT B:
FOOD ADDITIVES WHICH MAY CAUSE PROBLEMS
|
COLOURS |
|
|
Artificial colours |
102, 107, 110, 122-129, 133, 142, 151, 155 |
|
Natural colour |
160(b) annatto natural colour |
|
PRESERVATIVES |
|
|
Sorbic acids |
201-203 -widely used |
|
Benzoic acids |
210-213 - in soft drinks, cordials, juice drinks |
|
Sulphites |
220-228 - widely used |
|
Nitrates & nitrites |
249-252 - in processed meats like ham and devon |
|
Propionic acids |
280-283 - in bread, crumpets, hamburger buns |
|
Antioxidants |
310-321 - in oils, margarines, chips, french fries |
|
FLAVOUR ENHANCERS |
|
|
Glutamates |
621-625, 627, 631, 635 - in tasty foods |
|
ADDED FLAVOURS |
- in many processed foods |
from Clarke, L and others, Dietitians
Association of Australia review paper: 'The dietary management of allergy and food
intolerance in adults and children', Aust J Nutr & Diet (1996) 53:3;
Royal Prince Alfred
Hospital Allergy Unit, 'The Simplified Elimination Diet', available from
dietitians;
Dengate, S 'Fed Up', Random
House, 1998; and
Swain A and others,
'Friendly Food', Murdoch Books, 1991
ATTACHMENT
C:
excerpt
from "Living Downstream" by the ecologist Sandra Steingraber (Virago
Press 1998) page 270:
Three key principles can
assist us in this effort.
One is the idea that public
and private interests should act to prevent harm before it occurs. This is
known as the precautionary principle, and it dictates that
indication of harm, rather than proof of harm, should be the trigger for action
- especially if delay may cause irreparable damage. Central to the
precautionary principle is the recognition that we have an obligation to
protect human life. Our current methods of regulation, by contrast, appear
governed by what some frustrated policy-makers have called the dead body
approach: wait until damage is proven before action is taken. It is a system
tantamount to running an uncontrolled experiment using human subjects.
Closely related to the
precautionary principle is the principle of reverse onus. According
to this edict, it is safety, rather than harm, that should necessitate
demonstration. This reversal essentially shifts the burden of proof off the
shoulders of the public and onto those who produce, import, or use the
substance in question. The principle of reverse onus requires that those who
seek to introduce chemicals into our environment first show that what they
propose to do is almost certainly not going to hurt anyone. This is
already the standard we uphold for pharmaceuticals, and yet for most industrial
chemicals, no firm requirement for advance demonstration of safety exists. But
chemicals are not citizens. They should not be presumed innocent unless proven
guilty, especially when a verdict of guilt requires some of us to sicken and
die in order to demonstrate the necessary evidence.
Finally, all activities
with potential public health consequences should be guided by the principle
of the least toxic alternative, which presumes that toxic substances
will not be used as long as there is another way of accomplishing the task.
This means choosing the least harmful way of solving problems - whether it be
ridding fields of weeds, school cafeterias of cockroaches, dogs of fleas,
woollens of stains or drinking water of pathogens. Biologist Mary O'Brien
advocates a system of alternatives assessment in which facilities regularly
evaluate the availability of alternatives to the use and release of toxic
chemicals. Any departure from zero should be preceded by a finding of
necessity. These efforts, in turn, should be coordinated with active attempts
to develop and make available affordable, non-toxic alternatives for currently
toxic processes and with systems of support for those making the transition…
The principle of the least
toxic alternative would move us away from protracted, unwinnable debates over
how to quantify the cancer risks from each individual carcinogen released into
the environment and where to set legal maximum limits for their presence in
air, food, water, workplace, and consumer goods. As O'Brien observed, "Our
society proceeds on the assumption that toxic substances will be used
and the only question is how much. Under the current system, toxic chemicals
are used, discharged, incinerated, and buried without ever requiring a finding
that these activities are necessary."
![]()
(March
1999)
Food
Intolerance Network of Australia (FINA)
Coordinator:
Sue Dengate
PO
Box 85 Parap NT 0804
phone
08 8981 2099
email:
sdengate@ozemail.com.au
Dear Minister
I am the founder and
coordinator of the Food Intolerance Network of Australia (FINA), which seeks to
represent the views of the probably 1.8 million Australians who are affected on
a daily basis in health, behaviour and learning by reactions to food. Mine is a
fulltime voluntary task undertaken because of my family's problems and because
I am able to help so many people. My days are filled with emails and phone
calls from all over Australia from desperate people who are at their wit's end
with trying to buy safe food in world where labelling has become a lawyers'
game rather than a means of informing people what they are eating. I am glad to
say that I also receive many thanks from grateful people who can report that,
with a modified diet, their children "have turned into angels for the
first time in their lives." To carry out my task, I edit a national
newsletter called "Failsafe", maintain a webpage (www.ozemail.com.au/~sdengate),
speak at conferences and provide telephone and email support nationally.
Over the past year I have
made two major submissions to the Australia and New Zealand Food Authority as
it reviews the Food Standards Code and have received polite letters of
non-engagement back from them. Therefore I have decided to write to you and to
your colleagues to alert you to the serious issue of food intolerance that
leads many people to lead twilight lives of chronic ill health, poor school
performance and poor social behaviour. If you wonder where road rage is coming
from, and increasing asthma, and poor school behaviour, and the epidemic of
attention deficit disorder diagnosis, and many other social ills, you should look
at the effects of our modern food.
The particular matter which
has triggered this letter is that two sections of the latest ANZFA Proposal
P161 make an absolute mockery of labelling and will make it impossible for
those affected by food intolerance to control what they eat.
The first of these two sections says:
"The Authority considers that there is no need for an advisory
statement about various food additives, other than sulphur dioxide, that may
cause minor food intolerance reactions. The symptoms that these food
additives are reported to produce cannot always be reliably linked to these
additives. An advisory statement would not provide useful information to
consumers and may cause unnecessary avoidance of products. Such a statement
would be so widespread on food products that its intent may become meaningless.
It would also incur a significant labelling cost on manufacturers, which is not
warranted on public health and safety grounds. A requirement for such a
statement would also set up a trade barrier that cannot be justified under the
WTO."
"People who have food intolerances should be educated by their
medical or dietetic practitioner as to a suitable diet" (ANZFA P161 p6
16. Other foods - emphasis added)."
Let's take these statements
in order. First, minor food intolerance reactions. This is very
reassuring, but what is the reality of food intolerance? Here's a quote
concerning "reactions" from a review in the Australian Journal of
Nutrition and Dietetics (1996 53:3 p91):
"Prevalence
The
prevalence of pharmacological food intolerance is unknown but it is estimated
to occur in 10% of the population. It occurs much more commonly than food
allergy.
Symptomatology
Symptoms
can involve the skin, gastrointestinal tract (GIT), respiratory tract or
central nervous system: either individually or in combination.
A
family history of related symptoms is very common, and woman are affected about
twice as frequently as men. In some allergic individuals with eczema, asthma or
rhinitis, food chemicals many aggravate their pre-existing symptoms."
In other words, food
intolerance affects about 1.8 million Australians with a wide range of very
distressing symptoms. They are not "minor reactions" and this
is not a minor issue.
Next: The symptoms that
these food additives are reported to produce cannot always be reliably linked
to these additives. I provide attached a set of key references from
peer-reviewed journals that show conclusively that this statement is wrong.
Where is the evidence upon which ANZFA's statement is based? Where, indeed, is
the forum where this debate can be held, given that consumers are not empowered
or funded, unlike the various food industry associations and lobby groups? Let
me make it clear to you that there are only 60 additives that are known to
cause problems out of the more than 300 permitted. A list of those known to
cause problems is attached. Not all additives are harmful. But those which
cause problems for food intolerant people should be labelled as such.
I must also say that the
burden of proof as to which additives cause reactions should not be upon
volunteers such as myself, but upon the scientists who advise you. Ask them for
positive scientific evidence that, for instance, calcium propionate used in
bread is safe or that butylated hydroxy anisole (BHA) used as an antioxidant in
oil is safe. I think you will find that there is no such evidence beyond
testing for carcinogenicity and that there is no testing for effects on health,
behaviour and learning. In particular, there is no testing for such effects on
children, who are much more reactive and vulnerable.
Please go ahead and ask
your scientists. If you want a second opinion on this critical issue, please
approach the Royal Prince Alfred Hospital Allergy Clinic in Sydney, whose
researchers lead the world in this area and who have treated over 15,000 people
over the past years.
An advisory statement
would not provide useful information to consumers and may cause unnecessary
avoidance of products. This statement is the height of patronising arrogance. It would
provide essential information to tens of thousands of Australians who
are knowingly affected by food intolerance reactions and alert many others to a
presently unknown cause for their problems. It would lead to necessary
avoidance of products.
Such a statement
would be so widespread on food products that its intent may become meaningless. Another way of phrasing this is to
say: "food additives known to cause problems are now so widespread that
it's not worth warning people about them." Is this really a statement that
Health Ministers want to make? I believe that it would be possible to provide
appropriate warnings concerning the 60 additives known to cause problems
without bringing the food industry undone. The WTO reference is an unrealistic
but trendy catch-all, which is being used to justify all sorts of lowest common
denominator behaviour by food companies at present. It should not cloud
sensible thinking.
And last, the bit that
makes you laugh till you cry: people who have food intolerances should be
educated by their medical or dietetic practitioner as to a suitable diet. If
one cannot know what is in the food, or whether it can provoke symptoms, all
the "education" in the world won't help. If a person affected by food
intolerance can't buy food without those additives, which is an increasing real
problem, no practitioner can help. And ANZFA is talking about 10% of the
population of Australia and New Zealand. Again, this ANZFA comment is
insufferably ignorant and patronising.
The second section in P161 which makes my blood boil is
about the intended requirement not to show on the label some additives
that arrive in the final food as part of a compound ingredient. This has been a
favourite way for food manufacturers to avoid showing additives on labels and
must be addressed in these revisions to the Food Standard Code. Here is the
innocuous and bureaucratic text (ANZFA P161 p17 Standard 1.2.4 Labelling of
Ingredients, Table to subclause 6(2) - emphasis added):
|
Amount of compound ingredient in the food |
Ingredients of the compound ingredient to be included in the statement of ingredients |
|
250g/kg or more |
All ingredients |
|
Less than 250g/kg |
Subject to clause 4 of Standard 1.2.2, all food additives in the compound ingredient where the food additive is performing a technological function in the final food |
And in the Editorial Note following "…Some
food additives, added as part of the compound ingredients, may not be
performing a technological function in the final food because of some
processing. For example, a preservative in apple pulp or antioxidant in
vegetable oil will not necessarily be performing a technological function once
apple pulp has been added to pie and then backed (sic) or once the vegetable
oil has been added to mayonnaise. Manufacturers need to consider this when
designing labels.…".
What is being intended to
be allowed here is that up to 25% of the ingredients of the food on your table
may contain additives that are not on the label!
The practical effects of
this are already obvious in my daily work. The only way to find out whether a
particular compound food contains additives not on the label is to ring the
manufacturers and beg them to tell the truth about their product. Is this what
is intended by Health Ministers?
There is no requirement for
manufacturers to inform me. Sometimes I obtain leaked information from
scandalised employees. Members of FINA and the Royal Prince Alfred Hospital
share information about what food is safe and what is not. Is this the
situation that Health Ministers want? There is a food blacklist that grows as
rapidly as my phone bill from Darwin and my overall feeling is one of outrage
and complete lack of trust in regulatory mechanisms.
I hope that I have
convinced you that food intolerance is a real problem that requires a more
responsive and effective system of food regulation. If you want to know more
about this topic, Random House has recently published my second book "Fed
Up", which has sold over 10,000 copies in six months. What I now seek from
you, on behalf of the Food Intolerance Network of Australia is clear public
assurance that:
Yours truly
Sue Dengate
![]()
Bennett CPW and others,
(1998) 'The Shipley Project: treating food allergy to prevent criminal behaviour
in community settings', J Nutr & Environmental Med, 8, 77-83.
Bennett CPW and others
(1997) 'The health of criminals related to behaviour, food, allergy and
nutrition: a controlled study of 100 persistent young offenders', Journal of
Nutritional and Environmental Medicine, 7; 359-366
Boris, M. and Mandel, F.
(1994) 'Food additives are common causes of the Attention Deficit Hyperactive
Disorder in children'. Annals of Allergy (72:5),462-468.
Carter, C.M., Urbanowicz,
M., Helmsley, R., Mantilla, L., Strobel, S., Graham, P.J. and
Clarke, L., McQueen J.,
Samild, A. and Swain, A. (1996) 'The dietary management of food allergy and
food intolerance in children and adults'. Australian Journal of Nutrition
and Dietetics (53:3),89-94.
Conners, C.K. (1989) Feeding
the brain: how foods affect children.
Egger, J., Carter, C.M.,
Graham, P.J., Gumley, D. and Soothill, J.F. (1985) 'Controlled trial of
oligoantigenic treatment in the hyperkinetic syndrome'. Lancet
(1),540-45.
Harley, J.P., Ray, R.S.,
Tomasi, L., Eichman, P.L., Matthews, C.G., Chun, R., Cleeland, C.S., and
Traisman, E. (1978) 'Hyperkinesis and food additives: testing the Feingold
hypothesis'. Journal of Pediatrics (61),818-828.
Kaplan, B.J., McNichol,
R.D., Conte, R.A. and Moghadam, M.D. (1989) 'Dietary replacement in
preschool-aged hyperactive boys'. Journal of Pediatrics (83),7-17.
Loblay R.H. and Swain, A.R.
(1986) 'Food intolerance'. In: Wahlqvist M.L., Truswell A.S., editors. Recent
Advances in Clinical Nutrition. London: John Libbey, 169-177.
Rowe, KS (1988) 'Synthetic
food colourings and hyperactivity: a double-blind cross-over study.'Aust
Paediatr Journal; 24:143-147
Rowe, K.S. and Rowe K.L.
(1994) 'Synthetic food colouring and behaviour: a dose response effect in a
double-blind, placebo-controlled, repeated-measures study'. Journal of
Pediatrics (125),691-8.
Schaumberg, H. H. and others
(1969) 'Monosodium L-Glutamate:its pharmacology and role in the Chinese
Restaurant Syndrome', Science 163;826-828
Schoenthaler, S. J. (1985)
'Diet and delinquency: empirical testing of seven theories', International
Journal of Biosocial Research, 7(2); 108-131
Weiss, B. (1983) 'The
behavioural toxicity of food additives'. Nutrition Update (1), 21-37.
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FOOD ADDITIVES WHICH MAY CAUSE PROBLEMS
|
COLOURS |
|
|
Artificial colours |
102, 107, 110, 122-129, 133, 142, 151, 155 |
|
Natural colour |
160(b) annatto natural colour |
|
PRESERVATIVES |
|
|
Sorbic acids |
201-203 -widely used |
|
Benzoic acids |
210-213 - in soft drinks, cordials, juice drinks |
|
Sulphites |
220-228 - widely used |
|
Nitrates & nitrites |
249-252 - in porcessed meats like ham and devon |
|
Propionic acids |
280-283 - in bread, crumpets, hamburger buns |
|
Antioxidants |
310-321 - in oils, margarines, chips, french fries |
|
FLAVOUR ENHANCERS |
|
|
Glutamates |
621-625, 627, 631, 635 - in tasty foods |
|
ADDED FLAVOURS |
- in many processed foods |
from
Clarke, L
and others, Dietitians Association of Australia review paper: 'The dietary
management of allergy and food intolerance in adults and children', Aust J Nutr
& Diet (1996) 53:3;
Royal
Prince Alfred Hospital Allergy Unit, 'The Simplified Elimination Diet',
available from dietitians;
Dengate, S
'Fed Up', Random House, 1998; and
Swain A
and others, 'Friendly Food', Murdoch Books, 1991
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