lobbying

How can you help? By writing for change.

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

Letter to FSANZ (formerly ANZFA) regarding food intolerance priorities in April 2003 (no response by July 2003)
FORMAL COMPLAINTS REGARDING COLONIAL FARMS GLUCOSE SYRUP, LOWAN WHOLE FOODS KIDS BYTES, AND SANITARIUM SO GOOD SOYMILK (February 2003)
Dismissive and bureaucratic responses from most States on the bread preservative and 635 are available if you want to contact me.
Letter to ANZFA with further reports of reactions to Additive 635 (see letters and responses here)
Response from ANZFA to two previous letters, saying that anecdotal evidence on 635 is not considered useful and that maybe housewives should do the research that is ANZFA's responsibility. Agricultural and veterinary chemicals have an adverse experience reporting scheme, but we humans don't rate, it would appear. An outrageous letter!! Please contact me if you want to have a copy faxed to you.
Letter to ANZFA 21/5/00 re new Food Standards Code
Letter to ANZFA 2/5/00 re Additive 635
Response from ANZA, saying "don't you worry about that"! Please contact me if you want a copy faxed to you.
Letter to ANZFA 2/5/00
Letter to Ministers 16/4/00
ANZFA's response 31/3/00
Letter to ANZFA 21/3/00
Letter to Ministers by a reader
MEDIA RELEASE 22/8/99
Letter to MINISTERS 15/8/99. I can fax responses from the Federal Minister and Opposition and Tasmania to you - please email sdengate@ozemail.com.au
Letter to MINISTERS 3/3/99. Their varying responses can be faxed to you for all States/Territories - please email. Most of them and/or their advisers cannot distinguish food intolerance from food allergy.

24 November 2003

The Project Officer

Publications Review

Health Advisory Section

National Health and Medical Research Council

GPO Box 9848

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.

The first report of an association between food additives and asthma appeared in 1958, when six cases of asthma in children were attributed to artificial colour² and in 1967, a case of severe intractable asthma was attributed to tartrazine (102) in the patient's medication and a yellow-coated vitamin tablet³. Since then, additives in food, vitamins and medications have been associated with asthma exacerbation frequently and in many countries including Australia^4,5, Canada⁶, France⁷, Papua New Guinea⁸, South Africa⁹, Spain¹⁰ and Japan¹¹. Although 'primary exposure in children is through foods', additives in drugs are a source of serious reactions¹². Salicylates are also associated with asthma¹³. By 1976, routine testing of asthmatics for sensitivity to food additives and salicylates was recommended¹⁴.
Consumption of food additives in Westernised countries has been steadily increasing since the 1960s. According to FDA data, daily per capita production of food dyes in the USA increased from 12 mg in 1955, to 32 mg in 1975, to 47 mg in 1998, a fourfold increase over 4 decades. Increasing intake of food additives makes awareness of the effects of food chemical sensitivity more difficult because in Westernised countries today 'exposure to [food chemicals] is sufficiently frequent to mask any relationship between ingestion and symptoms in susceptible people'¹⁵.
It is easier to see the effects of diet in a society in transition than in one in which the dietary change to highly processed foods has become firmly established. In Saudi Arabia, a comparison between village children who ate a traditional Arab diet and city children who ate more Western style processed foods showed that eating at fast food restaurants was associated with a 2-3 fold risk of developing asthmatic symptoms¹⁶.
Evidence shows that standard challenge testing¹⁷ for food chemical sensitivity is likely to miss the majority of responders^15,18. In a study which compared challenge testing with and without a comprehensive four-week elimination diet to obtain a low and stable baseline, the use of the Royal Prince Alfred Hospital elimination diet was associated with a threefold increase in the number of sulphite sensitive asthmatics identified by challenge¹⁸.
Sulphite preservatives are the additives most likely to affect asthmatics. The World Health Organisation recently upwardly revised its estimate of the number of asthmatic children affected by sulphite preservatives from less than 4% to 20-30% of asthmatic children¹⁹. These figures are probably a significant underestimate since they are derived mainly from studies using standard challenge testing^9,20 which are likely to miss the majority of responders (see point above).
The only study ever to use a comprehensive additive-free low salicylate elimination diet with asthmatic children found that over 65% of the children were affected by sulphites²¹. Such a significant effect cannot be ignored in the management of childhood asthma.
In Australia, young children are frequent consumers of acknowledged sulphite vectors such as sausages, dried fruit snacks including muesli bars, fruit flavoured drinks and french fries. Total dietary intake figures showed that Australian two-year-olds consumed approximately twice as many sulphites as 12 year olds and nearly four times as many sulphites as adults per kg bodyweight²².
As well as sulphites, benzoate preservatives (210-213) in drinks and medications have been associated with asthma. In France a child who took benzoate-preserved asthma medication continuously for six years remained asthma-free when avoiding benzoates in medication, drinks and food²³.
Other food chemicals which have been associated with asthma in the Food Intolerance Network and with asthma or similar intolerance reactions in medical journals include annatto (E160b) natural colour²⁴, sorbates (200-213)²⁵, MSG (621),⁷ antioxidants BHA (E320) and BHT (321)^26,27 and dietary salicylates¹⁸.

Effectiveness of dietary intervention

Improvements in asthma symptoms have been reported with additive-free, low salicylate diets for adult asthmatics^18,28, 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.

sulphites - World Health Organisation guidelines recommend that when a suitable alternative method of preservation to sulphites exists, its use should be encouraged¹⁹. Italian researchers suggest that sulphites are not always essential from a technological point of view and MPLs (maximum permitted levels) could be reduced³³. For example, although permitted, Italians in general do not use sulphites in meats and in the USA, the use of sulphites in meat was banned in 1959 whereas in Australia, sulphites are permitted in sausages and processed meats, and although sulphites in mince were banned many years ago, there are still a number of butchers who disregard this regulation²².
artificial colours - following an extensive review in 1999, independent scientists from the Centre for Science in the Public Interest recommended that the FDA should consider banning the use of artificial colours³⁴. There are natural alternatives.
annatto natural colour (160b) - there is a safe natural alternative for this additive, betacarotene 160a, which is used widely throughout Europe although the use of betacarotene is discouraged in Australia by representatives of Food Standards Australia New Zealand who claim it is 'too difficult and expensive'.
antioxidants BHA, BHT and TBHQ - can be replaced by safe antioxidants ascorbates and mixed tocopherols from the range 300-309.
benzoates - For many years, 7UP lemonade has been a colour-free, preservative-free, low salicylate soft drink available in cans and bottles. As of this month, 7UP contains benzoates in the name of 'longer shelf life'. Is a longer shelf life strictly necessary?

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 diet^35,15.

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:

Screening for food chemical sensitivity should be recommended as the first course of treatment for children with asthma before turning to medication. Children should be referred to a qualified dietitian, with experience in this area, for a three week trial of the Royal Prince Alfred Hospital Elimination Diet.
Health organisations and medical experts should work with the food industry to reduce the use of asthmagenic additives, especially sulphites, in the foods that children eat.

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. American Academy of Pediatrics. 'Inactive' ingredients in pharmaceutical products, Pediatrics 1997;99(2):268-78.

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 3^rd. 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;1:53-59.

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 1^st congress of the Asian Pacific Society of Respirology. Tokyo, Japan, 1988:69, reported in Hodge L et al, cited above.

24 November 2003

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

"Government, private agencies and health professionals concerned about children with ADHD and other behavioural problems should acknowledge the potential for diet to affect behaviour and should advise parents to consider modifying their children's diet as a first means of treatment" and
"Parents should consider dietary changes (along with behavioural therapy) as the first course of treatment for children with behavioural problems before turning to stimulant drugs."

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

"that significant changes in children's hyperactive behaviour could be produced by the removal of artificial colourings and sodium benzoate from the diet" and
they estimated that "the impact [of removing additives] on the proportion of children with elevated hyperactivity score (above the 85 percentile) would be to reduce the prevalence from 15% to 6%".

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:

100% of those who completed 2-3 weeks of the diet improved in behaviour rating by more than 25% (see below, abstract and graph based on data in the paper attached).

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

"Government require schools to minimise the sale and use of food containing..artificial colours, flavours and preservatives from ACT school canteens…" and
"put in place a policy that when children are identified with behavioural problems, dietary management should be investigated and offered as a management option" and "offer dietary management as part of the rehabilitation process for juvenile offenders."

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; New York:Plenum.

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. London: John Libbey, 1986;169-177.

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 Wakefield JA. The impact of a low food additive and sucrose diet on academic performance in 803 New York City Public Schools. International J Biosocial Res 1986;8(2):185-195.

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;1:41-46.

Swain AR, Dutton SP and Truswell AS. Salicylates in foods. J Am Diet Assoc 1985; 85:950-60.

Swain AR, Soutter VL, Loblay RH and Truswell AS. Salicylates, oligoantigenic diets and behaviour. Lancet 1985; ii:41-2.

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:

Dietary changes (along with behavioural therapy) should be recommended as the first course of treatment for children with behavioural problems before trialling medication. Children should be referred to a qualified dietitian, preferably with experience in this area, for a three week trial of the Royal Prince Alfred Hospital Elimination Diet.
Health organisations, medical experts, pediatric hospitals and schools should minimise the use of food additives that may contribute to behavioural disorders.

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 AUSTRALIA

phone +61 8 8981 2099 fax +61 8 8942 3099

email: sdengate@ozemail.com.au

website: www.fedupwithfoodadditives.info

_____________________________________________________________________________________

15 April 2003

Mr Graham Peachey

CEO FSANZ

PO Box 7186

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:

Propionates (280-283), used as a bread preservative and found in an increasingly wide range of other foods. This is, in our view, an insidious additive proven to cause problems by Royal Prince Alfred Hospital among others. We have asked for years for regulators to provide evidence that this additive is safe, but the only scientific evidence is that it is not safe, including a recent paper in the Journal of Paediatrics by Sue Dengate and Dr Alan Ruben. This additive is unnecessary.
Ribonucleotides (635, also 627, 631), newly introduced as a flavour enhancer. We have twice provided FSANZ multiple observations of severe rashes and respiratory symptoms from this additive and believe that people may already have died from it. Following recent publicity on "A Current Affair", we have received hundreds more reports, which will be forwarded to you shortly. This additive should be withdrawn immediately.
Sulphites (220-228), widely used in foods and frequently not labelled or slipping through the 5% loophole. Sulphites have long been known to trigger asthma in susceptible people. Safe alternatives exist. As the prevalence of childhood asthma in Australia is one of the highest in the world, has reached 50% of preschoolers in the latest survey and continues to increase, we agree with independent scientists from the Centre for Science in the Public Interest: the use of sulphites (except in wine) should be banned.

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

Food Intolerance Network

Coordinator: Sue Dengate

PO Box 85 Parap NT 0804 AUSTRALIA

phone +61 8 8981 2099 fax +61 8 8942 3099

email: sdengate@ozemail.com.au

website: www.fedupwithfoodadditives.info

______________________________________________________________________________________

4 February 2003

Principal Health Inspector

NT Department of Health and Community Services

GPO Box 40596

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, 2 Tarlington Place, Smithfield NSW 2164

cc Managing Director, FSANZ, PO Box 7186, CANBERRA MC ACT 2610

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 AUSTRALIA

phone +61 8 8981 2099 fax +61 8 8942 3099

email: sdengate@ozemail.com.au

website: www.fedupwithfoodadditives.info

______________________________________________________________________________________

4 February 2003

Principal Health Inspector

NT Department of Health and Community Services

GPO Box 40596

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.

Yours truly

Ms Sue Dengate

cc The General Manager, Lowan Whole Foods, 11 Bollard Place, PICTON NSW 2571

cc Managing Director, FSANZ, PO Box 7186, CANBERRA MC ACT 2610

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 AUSTRALIA

phone +61 8 8981 2099 fax +61 8 8942 3099

email: sdengate@ozemail.com.au

website: www.fedupwithfoodadditives.info

______________________________________________________________________________________

4 February 2003

Principal Health Inspector

NT Department of Health and Community Services

GPO Box 40596

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.

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