How useful is our food regulator FSANZ?

For those who are affected by food additives, the efforts of the food regulator Food Standards Australia New Zealand (FSANZ) are largely irrelevant as presently conducted, and increasingly so with changes in food industry practice in response to consumer concerns.

There are two reasons. One is that FSANZ’s assessments for approval operate within a deliberately narrow range of what constitutes ‘safety’ and the second is their inability to address food industry ‘gaming’ of the Food Standards Code.


The first of these issues is discussed here.


Scope of additive safety assessments


The top priority Objective in the Food Standards Act is “the protection of public health and safety” yet safety assessments carried out by FSANZ do not include or prioritise many issues which concern consumers, leading to a loss of confidence in their processes.


Taking just one example, asthma. We have known since Roman times that sulphites can cause asthma. Australian research which used an effective baseline diet found that 65% of young asthmatic children reacted to sulphites. Even the conservative World Health Organisation (WHO) revised upward their estimate of the number of sulphite-sensitive asthmatic children, from 4% to 20-30% in 1999. Yet FSANZ permits levels of sulphites far higher than anywhere else in the world (as high as 3000mg/kg, cf maximum of 2000mg/kg elsewhere). Given that Australia has one of the highest rates of childhood asthma in the world, this should be a priority issue for FSANZ yet it is not, nor do they accept any public education role on the issue.


Here is an abridged list of problems linked to particular additives by consumers (see full list under references below). None of these are within the current scope of ‘safety’ when FSANZ approves additives, yet they are all of major concern to consumers. Behaviour, learning and mood dimensions are always ignored despite sound scientific evidence to the contrary:


Asthma, Frequent nose bleeds, Sinusitis, Frequent ear infections, Eczema, Urticaria (hives), Angioedema, Pruritis (itching), Rosaceae, Flushing, Excessive sweating, Sore vagina in children, Alopecia (patchy baldness), Irritable bowel symptoms (IBS), Recurrent mouth ulcers, Stomach ache, Bloating, Reflux in babies, adults, Constipation, Colic in babies, adults, Encopresis, Soiling (sneaky poos), Eating disorders, Bedwetting, Urinary urgency, Cystitis, Arthritis, Nystagmus (involuntary eye movement), Myalgia (muscle pain), Tics, Tremor, Rapid heartbeat, Heart palpitations, Tachycardia (fast heart beat), Headaches or migraines, Tinnitus (noises in ear), Hyperacusis, Auditory sensory processing disorder (ASPD), Paraesthesia (pins and needles), Dysaesthesia (numbness), Hypoglycemia, Anxiety, Panic attacks, Depression, Obsessive ruminations,  Self harm, Suicidal thoughts,  Teeth grinding (bruxism), Impaired memory, Unable to concentrate, Disorganised, Easily distracted, Difficulty reading and writing, Loud voice, Speech delay, Selective mutism, Stuttering, Repetitive noises, Poor coordination, Difficulty falling asleep, Restless legs syndrome (RLS), Persistent night waking, Insomnia, Nightmares/night terrors/sleepwalking, Sleep apnoea, Mood swings, Premenstrual tension, Grizzly or unhappy, Cries easily or often, Irritable, Uncooperative Oppositional defiance: ODD, Loses temper, Argumentative, Touchy, easily annoyed, Angry, ADHD, ADD, Autism, Aspergers, Inattentive, Restless, Head banging, Hyperactivity, Tantrums.


What this means is that consumers do not trust FSANZ, even in their own surveys.


·         61% of Australians lacked confidence in organisations providing regulation and monitoring of the food supply (FSANZ Consumer Attitudes Survey 2008)

·         96% believe that food additives should be better tested before they are approved, the focus being on including evidence of behavioural, learning and other health effects before approval (648 people, Food Intolerance Network 2008)


This mistrust extends, with good reason, to the processes which FSANZ uses for assessment. Two brief examples must suffice. Between 1999 and 2003 the Food Intolerance Network asked FSANZ for the scientific evidence upon which the original approval for propionates 280-283 was based and FSANZ was unwilling to produce such evidence if in fact it exists. The Network started a formal Freedom of Information (FOI) process in 2003 with a final response from FSANZ saying "that these documents do not exist" and then, later in the letter "currently available toxicological data supports the safe use of propionic acid ….”. At the time it was considered extraordinary that the "currently available toxicological data" exists in a state of superposition, both existing and not existing to support the safe use of these additives!


The same FOI process gave the same nil response concerning the approval of the flavour enhancers 627, 631 & 635 ribonucleotides, for which the Network had received many reports of severe itchy rashes. This additive family were approved without any scientific evidence, in contravention of the Act.


These brief points show that there is an arms race underway between FSANZ as a regulator and the billion dollar food industry, and that the first Objective under the Act, “the protection of public health and safety”, is losing. Evidence has been presented that FSANZ is also failing on the second and third Objectives which are the provision of adequate information relating to food to enable consumers to make informed choices and the prevention of misleading or deceptive conduct.


A referenced version of this section may be seen at 

There are further scientific references at