A bulletin for the Australian Food Industry September 1997

ANZFA draft standard on food additives

It will be an obligation on the proprietor of a food business under proposed national food hygiene legislation to ensure that food handlers engaged in

The proposal for national food hygiene standards (Food safety and hygiene June 1997) has occupied considerable industry and media attention in recent weeks. Another major proposal to come from the Australia New Zealand Food Authority (ANZFA) which has received much less public comment is a draft general standard for food additives.

The proposal follows the publication in March 1996 by ANZFA of a policy paper titled 'The regulation of food additives.' This paper concluded that:

the principal intent of food additive standards is to ensure the intake of food additives does not present a risk to public health;
the levels of additives which may be added should be established on the basis of risk analysis;
a second intent of food additive standards is to ensure that consumers are not exposed unnecessarily to high levels of food additives; and
the standard should facilitate both the consumers' desire to exercise choice and innovation (sic) in food technology by applying the minimum restriction on use consistent with good manufacturing practice (GMP)

The paper noted that the use of a food additive should not be a substitute for GMP and acknowledged that the introduction of a reference to GMP in a food standard raises a new complexity for enforcement authorities.

Since 1956, the principles guiding authorities in Australia on the use of food additives have been those recommended by the first meeting of the Joint FAO/WHO Expert Committee on Food Additives.¹ The principles set down at that meeting are as follows:

A. Technical purposes for which food additives are used:

maintenance of the nutritional quality of a food;

enhancement of keeping quality or stability with reduction in food wastage;

making food attractive to the consumer.

B. Situations in which food additives should not be used:

to disguise faulty processing or handling;

to deceive the consumer;

when the result is a substantial reduction in the nutritive value of the food;

when the desired result can be achieved by good manufacturing practices which are economically feasible.

C. The safety in use of a food additive must be established.

D. When a new food additive is proposed for use, clear evidence must be available to show that benefits to the consumer will ensue.

These principles led to a system of prohibition in Australian food law where approved additives only could be legally added to specific foods.

For the purposes of the draft general standard, ANZFA has now arranged all currently permitted additives into five groupings. These are:

Miscellaneous additives permitted extensively in Australia or New Zealand for which a numerical acceptable daily intake (ADI) is considered not necessary because of a lack of observed toxicity; or which have a numerical ADI that is unlikely to be approached from all technically justified uses. These additives are to be permitted in accordance with GMP in foods except fresh and unprocessed foods or 'where the presence of food additives would not be reasonably expected'.
Colours (i.e. a specific class of additives) for which an ADI has been deemed unnecessary on account of their lack of observed toxicity or which have an ADI that is unlikely to be approached from all technically justified uses. These colours are to be permitted in accordance with GMP in specified processed foods.
Colours which have numerical ADIs which are sufficiently high to enable their inclusion at a technologically useful level in all processed foods when tested on a dietary budget model. These colours are to be permitted subject to defined limits in specified foods.
Additives which have specific uses for which they can be 'generally considered safe'. This includes some additives from groups 1 and 2 in specific foods such as some unprocessed foods which are not permitted to contain additives in general.
Additives with numerical ADIs which estimates of potential intake indicate could be exceeded by unrestricted use. These additives are permitted, subject to defined limits, under individual categories of food defined in the draft standard.

The closing date for comments on this proposal has passed. ANZFA notes that the document may undergo significant modification during assessment although the general approach to food additive standards will not.

This proposal represents a major change in the form of food additive legislation in this country and the food industry and other interested parties should take the necessary steps to be fully informed of its progress.

For further information contact:
Australia New Zealand Food Authority
PO Box 7186
Canberra MC ACT 2610
http://www.foodstandards.gov.au/
email: anzfa_internet@foodstandards.gov.au

¹ FAO/WHO Joint Expert Committee on Food Additives (1957). 1st Rep. General principles covering the use of food additives. FAO Nutr. Meet. Rep. Ser. No.15

Food Safety and Hygiene

Prepared by Keith Richardson and Beverley George
Food Science Australia
PO Box 52, North Ryde 1670. Tel +61 2 9490 8397 Fax +61 2 9490 8499
Email enquiries@csiro.au