First published on substack 10/09/2024 : https://petrahooijenga.substack.com/p/food-regulator-proposes-loophole
Food Standards Australia New Zealand proposal P1055 Definitions for gene technology and new breeding techniques
Much the same with the definitions in the Food Act Australia New Zealand, and the new proposed changes to the definition for gene technology and new breeding techniques. Some definitions are very exact, and other definitions give the opportunity for very wide interpretation. For the critical thinker it’s an easy to spot, very clever game of semantics. Looking at the level of misdirection and wizardry involved, I suspect it comes straight out of the house of Slytherin.
All jokes aside, this is kind of an existential issue for humanity and if it didn’t worry me so much, I would not be sitting here writing about it. But I cannot longer sit on the sideline and watch companies, bureaucrats, politicians and regulators continue with the wrecking of human health and the health of the planet. Especially when this is done under the guise of sustainability and climate change. Hence, I’ve written to my elected state and federal representatives to share my concerns, but this is not enough.
Did you know we are all supposed to feel very happy about being able to eat these New Breeding Technique (NBT) foods? They are new shiny bio-tech answer to solving the world’s problems. NBT foods will save the world with essential proteins and other ingredients, so the cow farts won’t destroy the planet! What they don’t tell you is that most proposed NBT foods are synonymous with Ultra Processed Foods. Ultra Processed Foods (UPF) or Ultra Processed Food Ingredients (UPFI) on steroids, the Frankenstein version that is.
Just for a moment, visualise a refinery plant, the petroleum type, a bio reactor that contains genetically modified yeast. Scientist in hazmat suits go and feed the little yeasty beasts with a delicious chemical mix of carbon, hydrogen and oxygen (CHO). Of course, after they eat, the little yeasty beasts (do they glow in the dark?) need to poo. This is where the pooper-scooper scientists come in and collect the sceptic tank with yeasty beasty poo. I wonder if it stinks.
This poo contains the proteins, that will be sold to the food industry to be used as ingredient in food for human consumption. Now the poo protein is technically not a GM ingredient, it is simply the excrement of ultra processing using GM technology.
The gist of the FSANZ Proposal P1055 is that these types of new processes should not be included in the current Code with quite strict regulations around GM foods and GM ingredients, that include safety testing and labelling. So, in order to get the ambiguity out of the current interpretation of the Code, the change in definitions is proposed to effectively cut the red tape for industry and commercialise NBT foods faster, and without scrutiny. No safety testing or labelling required.
And what about the potential impact on human health you might wonder? The already detrimental impact of UPF and UPFI, and the ever worsening epidemic of chronic disease?
Not considered. Nope, not within the scope of this Proposal. And worse, as per the current definitions of ‘food’ and ‘safety’ in the Food Act, these aspects are not considered at all.
This is very strange, when the main purpose of the Food Act is to ensure a high standard of public health protection in Australia and New Zealand. The definition of public health in the minds of most citizens would include the impact of chronic disease. So again, a game of semantics. It is almost as if regulators have invented an entirely new language. They are using the same words, but are operating from a different definition and meaning of those words. To clarify, the state of Public Health, with regards to chronic health conditions in Australia in 2022 according to ABS report in 2023:
- Eight in ten (81.4%) people had at least one long-term health condition
- One in two (49.9%) people had at least one chronic condition
- Mental and behavioural conditions (26.1%), back problems (15.7%), and arthritis (14.5%) were the most common chronic conditions.
Overweight and obesity are key contributors to this chronic disease epidemic, which in all fairness started with the introduction of processed and mass-produced foods in the 20th century. The good news is that overweight and obesity are reversible, with a healthy diet, physical activity and other beneficial lifestyle activities. With regards to diet, the strongest scientific evidence to reduce the risk of chronic disease is for a Mediterranean style diet, rich in fresh vegetables, fruits, wholegrains, pulses, seeds, nuts, seafood, and some animal food and minimally processed foods like butter and cheese. Therefore, from a Public Health and food health and safety regulation perspective, would it not make sense to move regulation more towards supporting these types of food, good for individual and public health? Please note that the American Heart Association issued specific dietary guidance to improve cardiovascular health based on the latest scientific evidence.
See that word ‘definitions’ again? “There is no commonly accepted definition for ultra-processed foods, and some healthy foods may exist within the ultra-processed food category.” I wonder which ultra processed foods would be classified as healthy. I can’t think of any, you?
In independent scientific literature, Ultra Processed Foods are mostly associated with increased risk of disease and mortality and harm to human health.
- Comprehensive analysis of 45 meta-analyses found consistent evidence linking ultra-processed foods to increased risks of conditions like cancer, heart disease, diabetes, obesity, and early death. Here a news article that references this same study.
- A review of studies involving nearly 10 million people found strong links between UPF consumption and increased risk of cardiovascular disease mortality, anxiety, depression, and type 2 diabetes. More about it in this CNN article.
- A Harvard study identifies processed meats, sugary breakfast foods and sweetened beverages as the ultra-processed foods most strongly associated with mortality risk.
- Australian study finds significant association between consumption of ultra-processed foods and obesity, and findings support the potential role of UFP in contributing to obesity in Australia.
- Ultra-Processed Foods linked to 10% higher mortality risk in older adults.
It’s not a pretty picture, and one would think the Food Regulator would be right on top of this issue. Unfortunately things are not that simple and straight forward. There are many stakeholders and stakeholder interests FSANZ needs to consider in its proposals. Industry is an important stakeholder, that contributes to the overall economy, and benefits from regulation that protects the industry and its brands.
Australian citizen are represented by their elected representatives and ministers for health, who all have a seat at the table with FSANZ, in the Ministers meeting. What are these ministers doing? Surely they are aware of the chronic disease problems in the country? The financial impact of this alone is close to $30billion dollars per annum in direct Public Health costs and loss of productivity.
Yet it seems industry has a firm grip on the regulatory framework for food in Australia and New Zealand, and FSANZ itself is the ultimate Authority, as defined in the Food Act. So, even if a Minister complained about the lack of consideration of public health, the power would still be with the Authority (FSANZ). Even if legislation was proposed to change the definitions in the Food Act, FSANZ would again be the ultimate authority deciding if it were to be accepted or not. Why does a regulator have so much power?
There seems to be a pattern worldwide, of industry pretty much running the organisations and government, through disclosed and undisclosed lobbying using myriad networks of non-governmental organisations.
And now, it looks like the food industry and related new syn-bio-tech companies are keen to take over traditional foods supply systems. The future of food film by James Corbett, an investigative journalist, gives a good overview of the global context of what is happening to our food supply systems in the name of sustainability and technological advancement. Something to keep in mind when you consider what is happening here in Australia.
The Corbett Report – Episode 460 The future of food
In Australia I would like to see the government address the problem of chronic disease and conflict with the Food Act head on. Especially now at this critical time with this Proposal 1055 to change the definition of gene technology being considered by FSANZ.
If genetic engineering is deregulated as proposed in P1055, without safety testing or labelling requirements for this new generation of NBT ultra processed foods and ultra processed food ingredients, we will likely see the burden of chronic disease increase.
Some great submissions have been made to FSANZ in the second round of public consultation which concluded 10 September 2024. You can learn more about these submissions in the following articles, and in some cases the submissions are included.
Kate Mason, from Deconstructing4IRnarratives, has produced a comprehensive video and article discussing the concerns about the deregulation of genetic engineering in food as proposed in P1055.
GeneEthics is a non-profit educational network of citizens and kindred groups, envisaging a safer, more equitable and more sustainable GM free future. You can read the GeneEthics submission to FSANZ Proposal P1055 here.
Physicians and Scientist for Global Responsibility NZ have published their response to the FSANZ request for public consultation in the following submission.
GE free New Zealand provide a lot of background information on the wider topic of GM foods and the current biotech threat. You can read the submission from GE free New Zealand here.
HEART Party Australia, with key policies around health, environment, accountability, rights and transparency, submitted the this response to FSANZ.
Do you want to:
- be able to continue to eat REAL food?
- be able to make food choices based on informed consent, about ingredients as well as processes?
- want to know whether your food has been produced with new genetic engineering technologies?
- Australia to be healthy again, and reduce exposure to Ultra Processed Foods and ingredients?
Then it is even more important that you speak up about this as well. This is what you can do:
- Contact the local, state and federal representative in your electorate and let them know your concerns about this proposal P1055.
- Share your concerns on social media, and make this a topic of discussion with family and friends. Contact the legacy media, and share your concerns.
- Connect with other people who share concerns about this, like some of the groups listed above, who have made submissions to FSANZ.
Plus, let me know your thoughts and concerns about this in the comments below. I’m sure that if enough caring people put their minds and hearts together for something as existential as this, we can affect change. The loopholes for industry need to be closed, especially if the health of our people and future generations depends on it, as is the case with this proposal P1055.
New definitions are needed; definitions that distinguish real food from syn-bio-tech ultra processed fake food. A definition of public health that includes real public health issues such as the chronic disease epidemic. And safety defined in a much wider scope to consider real public health.
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