One of the leaders of the Australian flour milling industry, Mark Laucke of Laucke Flour, has written an open letter to the Australian Food Industry expressing serious reservations about the mandatory fortification of flour with folic acid.

On 13 September 2009 it became compulsory in Australia for all bread-making flour to be fortified with folic acid as a consequence of an amendment to the Food Standards Code passed two years ago that took effect on that date.

Laucke’s concerns are expressed in an open letter addressed to the food industry dated 6 December 2009 which was released publicly today (14 December, 2009). The letter is published below:

“Letter to the Food Industry regarding Mandatory Folic Acid Fortification

Standard 2.1.1 – Cereals and Cereal Products (The Standard) was implemented on the 13th September 2009 and requires the mandatory fortification of wheat flour (MFF) for making bread with folic acid.

To view The Standard, inspect:

http://www.foodstandards.gov.au/_srcfiles/Standard_2_1_1_Cereals_v112.pdf

I have in the past several years opposed the implementation of The Standard for MFF because I believe that

• The process of developing and instituting The Standard has been fundamentally flawed

• Enforced consumption of folic acid introduces adverse health risks to a wider population

• Millers are not reliably able to achieve and prove compliance with The Standard

• Flour millers and even Bakers may be legally liable for health claims resulting from mandatory folic acid fortification

• Mandatory fortification restricts consumer freedom of choice, and consumers are practically unable to avoid folic acid

• Mandatory folic acid fortification still does not provide enough Folate for the target population

• Australia must heed increasing international concern for mandatory folic acid fortification

I have focussed all of my best efforts (by letter, e-mail and personal representation) toward convincing the members of the Ministerial Council for Food Regulation (Ministerial Council) that the adoption of MFF should be postponed and The Standard for MFF should be immediately reviewed in light of emerging scientific evidence regarding the human health risks associated with folic acid fortification.

Until now I have purposefully identified myself and my business as being non-compliant with The Standard so as to highlight my concern for consumer safety. However, Ministerial Council and the Honourable Mark Butler, Parliamentary Secretary for Health and Chair of the Ministerial Council, remain adamant in their support for MFF.

On the 16th of November, Food Standards Surveillance Officers from the Food Policy and Programs Branch of the South Australian Department of Health visited my office. The officers represented that the intention of their visit was to open dialogue for the purpose of seeking my compliance with The Standard.

Based on these discussions and all considerations, I reluctantly accept that The Standard is the law, and that I must inevitably comply with the law. I acknowledge that I must comply, in spite of my abiding concern for the health implications for individual consumers and the wider Australian Population.

I advised the Officers that I would, as required by law and their direction, move to implement MFF according to the recommendations of the Implementation Sub-Committee (ISC) and the Compliance and Enforcement Model. Mark Butler has advised: “I remain confident and satisfied with the expert scientific advice from FSANZ that based on all the scientific evidence, there is no apparent risk to public health and safety.”

I accept that he has represented as a public position that there is no health risk associated with MFF, and that he has been encouraged to do this so as to maintain the belief that bread is a safe food. It is in no-one’s interest if the public stop eating bread and associated bakery products.

However, I am aware of a considerable number of recent research reports that represent a high degree of risk associated with MFF, so I could never express such a level of confidence as Mark Butler. Indeed, I am very fearful that MFF will cause harm to very many individuals in our community, now and to succeeding generations. Mark Butler has advised: “Health Authorities will be monitoring the effectiveness of the increased levels of folic acid in the food supply. The Australian Institute of Health and Welfare has been given overall responsibility for the monitoring program and reporting on its progress. In addition, the Standard will be reviewed two years after implementation to assess the effectiveness of, and continuing need for this public health initiative.”

However, based on personal experience, I have no confidence that the above will be effective unless the food industry becomes actively involved. I will continue to do what I can as an individual and as a leader to ensure that the risks associated with MFF are made known to the appropriate authorities.

Unfortunately, it is apparent that they are not interested in my representations as an individual. It appears that MFF is here to stay in Australia for a period of at least 2 years, unlike in New Zealand where agitation by Bakers caused the Government to defer the implementation of MFF. Once entrenched, it is likely that MFF will stay due to inertia, and due to disinterest in further assessment and change. At the moment, it seems that MFF is accepted and represented as safe because it is politic to so do. However, while its safety is accepted and represented by Government, such safety is NOT proven. In this, MFF is aberrant because:

• The process of assessing and instituting MFF was flawed

• MFF food is not aligned with normal Health and Food Safety protocols regarding presumed safety

• Bread fortified with Folic Acid is in reality a Novel Food that has not followed the required assessment for public health and safety considerations

MFF must either be proven safe according to appropriate due process, or discontinued. The ultimate protection for Consumers is to ensure that a Review of MFF and The Standard does in fact occur, and that it is objective and reasonable. Such a Review must ensure:

• That all the risks associated with MFF are properly and factually established

• That there is no bias in reports and recommendations to Ministerial Council

• That Ministerial Council acts in accordance with such recommendations.

The Food Industry must become involved with MFF issues, and take ownership and a high degree of control. I encourage you as an individual to seek out more information, and to discuss MFF and its implications widely throughout the industry and community.

I encourage you to work together with and through the most appropriate industry association so as to ensure that the people of Australia are provided the quality and safety of food that is appropriate to their needs and expectations.

Please feel free to contact me if you would like any further information or to discuss any issue above.

Mark Laucke

Laucke Flour Mills

Appendix A: The difference between Folic Acid and Folate

Appendix B: Australian Representations of Safety

Appendix C: Extracts from research papers regarding the metabolism of Folic Acid by humans

Appendix D: Adverse Health Risks Referenced research papers regarding the risks associated with MFF “