Update: the statement issued after the Council meeting has been added to the bottom of the post
Members of the Australia and New Zealand Food Regulation Ministerial Council are due to meet today.
Below is an open letter, dated December 7, from leading health and community professionals calling for the Ministers to support warnings about the risks of drinking while pregnant being placed on alcohol products and at point of sale.
(Wouldn’t it be useful if there was some mechanism to ensure industry lobbying on such matters was similarly disclosed – documentation of which companies said what and to whom, for example?)
Dear Ministerial Council member
We understand that the meeting of the Australia and New Zealand Food Regulation Ministerial Council on 9 December will consider food labelling issues, including pregnancy health warning labels on alcohol products sold in Australia.
As you will be aware the recent Review of Food Labelling Law and Policy (the Blewett report) made a number of alcohol-specific recommendations, including that ‘a suitably worded warning message about the risks of consuming alcohol while pregnant be mandated on containers of alcoholic beverages and at the point of sale for unpackaged alcoholic beverages, as support for ongoing broader community education’.
You will also be aware of medical and community concerns about the impacts of prenatal exposure to alcohol. It is well established that alcohol is a teratogen that travels freely across the placenta and can cause nervous system damage and brain abnormalities resulting in cognitive and behavioural disorders in the affected child as well as physical growth problems. These disorders and abnormalities are referred to as Fetal Alcohol Spectrum Disorders.
The NHMRC Australian Guidelines to Reduce Health Risks from Drinking Alcohol state that ‘for women who are pregnant or planning a pregnancy, not drinking is the safest option’.
Health warning labels, combined with public education, offer an important opportunity to prevent Fetal Alcohol Spectrum Disorders.
Alcohol companies oppose mandatory health warnings and instead propose adopting a voluntary system developed by the drinks industry-funded organisation DrinkWise, with weak warnings that are likely to have little if any impact. Survey results recently published showed that there is minimal public support for this voluntary approach in contrast to clear and explicit warnings.
There is sound evidence that labelling alcohol products with health warnings will make an important contribution to raising awareness about the risks of drinking during pregnancy. This measure is recommended by key health authorities such as the National Preventative Health Taskforce, the AMA, the Cancer Council, the Heart Foundation and the Public Health Association of Australia.
We are aware that there will be lobbying from the alcohol industry to delay effective action, or to adopt their preferred approach.
We urge you to take a leadership role in preventing Fetal Alcohol Spectrum Disorders in Australia by supporting the introduction of strong, research-based mandatory pregnancy warnings on alcohol products and at the point of sale. This is consistent with the recommendations of the Blewett review and health and medical authorities, and will have an important impact in reducing Fetal Alcohol Spectrum Disorders in Australia.
Yours sincerely
Signed by the following 64 leading health professionals and organisations
Ms Cheryl Bart, Chairman, Foundation for Alcohol Research and Education
Dr John Boffa, Peoples’ Alcohol Action Coalition, Alice Springs
Professor Carol Bower, Telethon Institute for Child Health Research
Ms Jody Broun, Co-chair, National Health Leadership Forum and Co-chair, National Congress of Australia’s First Peoples
Professor Freda Briggs, University of South Australia
Dr Tom Calma, Former Aboriginal and Torres Strait Islander Social Justice Commissioner and founding Chair of the Close the Gap for Indigenous Health Equality Campaign
Associate Professor Rosanna Capolingua, Chair, Healthway
Professor John Catford, Deakin University
Professor Simon Chapman, University of Sydney
Associate Professor Kate Conigrave, Royal Prince Alfred Hospital
Associate Professor Peter Coyle, University of Adelaide
Associate Professor Tim Crowe, Deakin University
Dr John Crozier, Royal Australasian College of Surgeons
Professor Peter D’Abbs, Menzies School of Health Research
Professor Mike Daube, McCusker Centre for Alcohol and Youth
Mr Michael Doery, Chairman, Australian Drug Foundation
Professor Chris Doran, Hunter Medical Research Institute
Professor Elizabeth Elliott, University of Sydney
Professor Michael Farrell, Director, National Drug and Alcohol Research Centre
Professor Kingsley Faulkner, University of Notre Dame
Professor Gary Geelhoed, Princess Margaret Hospital for Children
Ms Suzanne Gleeson, President, Australian Health Promotion Association
Mr Mick Gooda, Aboriginal and Torres Strait Islander Social Justice Commissioner
Professor Wayne Hall, University of Queensland
Dr Steve Hambleton, President, Australian Medical Association
Dr Janet Hammill, University of Queensland
Professor Sandra Jones, University of Wollongong
Professor Helen Keleher, President, Public Health Association of Australia
Associate Professor Kypros Kypri, University of Newcastle
Dr Erin Lalor, National Stroke Foundation
Dr Anne-Marie Laslett, Centre for Alcohol Policy Research
Associate Professor Jane Latimer, George Institute for Global Health
Professor Stephen Leeder, University of Sydney
Professor Dan Lubman, Director, Turning Point Alcohol and Drug Centre
The Hon Sheila McHale, Palmerston Association Inc
Professor Con Michael, St John of God Hospital
Ms Sue Miers, Chair, National Organisation for Fetal Alcohol Syndrome and Related Disorders
Dr Peter Miller, Deakin University
Mr Justin Mohamed, Co-chair, National Health leadership Forum (National Congress of Australia’s First Peoples) and Chair, National Aboriginal Community Controlled Health Organisation
Professor Rob Moodie, University of Melbourne
Mr Michael Moore, Chief Executive, Public Health Association of Australia
Professor Jake Najman, University of Queensland
Professor Kerin O’Dea, University of South Australia
Associate Professor Craig Olsson, Deakin University
Professor Ian Olver, Chief Executive Officer, Cancer Council of Australia
Ms June Oscar, Chief Executive, Marninwarntikura Women’s Resource Centre
Dr Lyn Roberts, Heart Foundation of Australia
Mr Michael Robinson, Chairman, Drug Education Network, Tasmania
Mr John Rogerson, Chief Executive, Australian Drug Foundation
Professor Robin Room, President, Alcohol and other Drugs Council of Australia
Ms Ann Russell, Russell Family Fetal Alcohol Disorders Association
Ms Vicki Russell, National Organisation for Fetal Alcohol Syndrome and Related Disorders
Dr Steven Skov, Policy and Advocacy Committee, Australasian Faculty of Public Health Medicine of the Royal Australasian College of Physicians
Associate Professor Petra Staiger, Deakin University
Professor Fiona Stanley, Telethon Institute for Child Health Research
Mr David Templeman, Chief Executive Officer, Alcohol and other Drugs Council of Australia
Mr Michael Thorn, Chief Executive, Foundation for Alcohol Research and Education
Professor John Toumbourou, Deakin University
Professor Melanie Wakefield, Centre for Behavioural Research on Cancer
Emeritus Professor Ian Webster, University of New South Wales
Professor Emma Whitelaw, Queensland Institute of Medical Research
Mrs Anne Wilson, Kidney Health Australia
Professor Fiona Wood, University of Western Australia
Who was sent the letter:
The Hon Ms Nicola Roxon MP Minister for Health and Ageing
The Hon Mr Joe Ludwig MP Minister for Agriculture, Fisheries and Forestry
The Hon Ms Jillian Skinner MP Minister for Health NSW
The Hon Mr Geoff Wilson MP Minister for Health
The Hon Mr John Hill MP Minister for Health
The Hon Mr David Davis MLC Minister for Health and Minister for Ageing
The Hon Dr Kim Hames MBBS JP MLA Minister for Health
The Hon Mr Bryan Green MP Minister for Primary Industries and Water
The Hon Mr Konstantine Vatskalis MLA Minister for Health
The Hon Ms Catherine King MP Parliamentary Secretary for Health and Ageing Parliament House
The Hon Ms Katy Gallagher MLA Chief Minister
The Hon Ms Katrina Hodgkinson MP Minister for Primary Industries
The Hon Mr Tim Mulherin MP Minister for Agriculture, Food and Regional Economics
The Hon Mr Michael O’Brien MP Minister for Agriculture, Food and Fisheries GPO Box 668
The Hon Mr Peter Walsh MP Minister for Agriculture and Food Security
The Hon Mr Terry Redman MLA Minister for Agriculture and Food
The Hon Ms Michelle O’Byrne MP Minister for Health
***
COMMUNIQUÉ – Legislative and Governance Forum on Food Regulation
9 December 2011
Australian and New Zealand ministers responsible for the regulation of food and beverages met in Melbourne today to consider their response to the recommendations in the Food Labelling Review Report, Labelling Logic.
Today’s meeting, chaired by the Commonwealth Parliamentary Secretary for Health and Ageing, Catherine King, was the first meeting of the Legislative and Governance Forum on Food Regulation (Forum). The Forum on Food Regulation replaces the Australia and New Zealand Food Regulation Ministerial Council.
In considering the 61 recommendations of the food labelling review to formulate an agreed, all of government response, Forum members acknowledged the challenge faced by the Review Panel as it considered issues which generated considerable debate during the Review.
“Many of the issues have been the subject of deliberation by governments in Australia and New Zealand and internationally for some time now, and it is acknowledged that some issues will continue to be a focus in the future as we strive to improve public health and maintain our food safety, security and sustainability,” Ms King said.
“In considering its response to the recommendations, the Forum proposed actions and implementation over the next five years that endeavour to balance improving the information on food labelling to meet consumers’ needs, against maintaining marketing flexibility and minimizing the regulatory burden on industry and barriers to trade.
The full response will be available on the Food Regulation website.
Some of the key initiatives agreed by the Forum on Food Regulation include:
•National Nutrition Policy: Ministers agreed to the development of a comprehensive National Nutrition Policy and the development of guidelines that will outline the expectations of Food Standards Australia New Zealand (FSANZ) in relation to the role of food standards in supporting public health objectives;
•Food Labelling: Ministers agreed to a framework that will guide decision making on food labelling matters using a three tiered hierarchy consisting of food safety, followed by preventative health and consumer values issues. It was agreed that any new technology would be considered on a case by case basis against this hierarchy.
•Front of Pack Labelling: Ministers agreed to the need for an easily understood, interpretive front-of-pack labeling system for packaged foods. The Forum on Food Regulation will lead a collaborative process with key industry, public health and consumer stakeholders to develop an agreed system within a year. Ministers have required officials to provide a substantial report on the development of a front of pack labelling (FoPL) scheme within six months, to be considered at the June meeting of the Forum, with a view to having a system by the end of next year. The aim is to avoid the proliferation of different FoPL systems and the potential for consumer confusion from conflicting or inconsistent nutrition messages.
•Pregnancy warning labels on alcohol: Ministers agreed that warnings about the risks of consuming alcohol while pregnant should be pursued. Industry is to be given the opportunity to introduce appropriate labelling on a voluntary basis for a period of two years before regulating for this change.
•Health claims: Ministers considered a presentation by Food Standards Australia New Zealand on its work to develop a new standard for Nutrition, Health and Related Claims to help inform their decision on the Labelling Review recommendation on nutrition and health claims. FSANZ have now been asked to undertake broad consultation on the draft standard before a final standard is presented to Ministers.
Other issues discussed included:
Changed food safety arrangement for the retail and food service sectors
The Forum on Food Regulation has completed a review of the 2003 Ministerial Policy Guideline on Food Safety Management in Australia – Food Safety Programs and has agreed to put in place a new food safety management Policy Guideline for the retail/food service sectors. The new guideline will provide a framework for development of effective, efficient and nationally consistent food safety management arrangements for these sectors. The implementation of the 2003 Policy Guideline as it applies to other food industry sectors has been completed and is not changing.
Review of the mandatory fortification of bread with folic acid
Ministers noted that mandatory fortification in Australia has been successfully implemented by industry. They agreed to a phased approach for the Review that will assess the effectiveness of mandatory fortification. The Review will need to be supported by adequate and comprehensive data to make an informed assessment of the effectiveness of mandatory fortification of bread with folic acid, and funding permitting, the mandatory fortification of bread with iodine. The findings of the data from the nutrition and biomedical components of the Australian Health Survey (the National Nutrition and Physical Activity Survey and the National Health Measures Survey), have been identified as necessary to inform the Review, however the full results from this Survey are not expected to be available until May 2013 and onwards into 2014.
While there are certainly reasons to support this initiative (including basic consumers’ rights), I wonder if there has been research to indicate how much of the alcohol consumed in Australia is consumed by the drinker straight from the bottle vs consumed from a glass or other container? Drinkers (both at social venues and at home) may often not drink directly from the original alcohol container. Many, who have drinks poured for them, would never even see the original container. Would this be presumed to have some effect on the ability of warning labels to increase awareness and convey information? When I looked into the issue of alcohol labelling 2008, I was unable to find evidence that warning labels on alcohol products were effective as a public health measure. Perhaps this has changed?
I appreciate the concerns expressed but I have a major concern with endorsing an inflexible “zero tolerance” approach to alcohol use during pregnancy. Of course I agree, and it goes without saying, that excess alcohol is probably the most teratogenic of all chemicals for pregnant women However, myself and many others in the obstetric area wrote to the NHMRC when they released their Interim Guidelines. Our concerns were that the zero approach inappropriately creates unnecessary anxiety, and indeed, may, tragically even lead to women inappropriately being advised, or seeking terminations because of wrong-headed professional advice after very occasional or inadvertent low-level exposure to alcohol in early pregnancy, rather than receiving the reassurance they require! Most importantly, as I noted in my correspondence to NHMRC, the studies on which the zero tolerance approach were based, are very poor, and fraught with methodological inconsistencies. Presumably in response to our concerns, some minor modification and thinly-veiled, rather equivocal reassurance was subsequently made in the final Guidelines regarding low-level exposure (“risk likely to be low”).
As I say, the tragedy of the fetal alcohol syndrome from excessive alcohol use during pregnancy and the abnormalities that it causes in newborn infants is well established and I wholeheartedly endorse the importance of highlighting the dangers of excessive alcohol use during pregnancy by pregnant women . However, perhaps the NHMRC Guidelines on alcohol and pregnancy would be more believable and better accepted by the community if they didn’t opt to use bad science to justify good social objectives!!
The reality is that occasional or inadvertent alcohol exposure to alcohol during pregnancy, ( and in breast-feeding by the way!), will not have lasting adverse effects on the developing fetus, ( or infant), and women need that reassurance, whilst advising them to minimise their alcohol intake during pregnancy and breast-feeding. So let’s be honest about the facts before we design the appropriate warning labels!!
Ron Batagol,
Pharmacy and Obstetric Drug Information Consultant,
Nunawading, Vic 3131
My Doctoral thesis is on the Foetal Alcohol Syndrome (6 years study). This was after following the research literature on the topic for over 20 years since working in the Alcohol Studies Centre in Glasgow, Scotland, in the early 1980s. I have interviewd the Minister of Narcotics in USSR (a United Nations rep) in the 1980s about the impact of pre-natal alcohol on the next generation in Russia. The argument that is being presented by previous writers, has been recycled many times in Scotland (Edinburgh v Glasgow) Europe, and Australia (Westmead Hospital v Mater Mothers). How many times have I heard it to retain teh status quo and do nothing but argue. Meanwhile people in our community (many of whom end up in prison) try to cope with brain damage and mental health problems. Most will have some “conduct disorders” and learning difficulties at school and may need special schools or special classes. The cost on the whole community is enormous (Education, Social Workers, Foster parents, Child and Adolescent Mental Health Services, Legal system, Prisons). Even “social drinking” results in a thinner corpus collosum or none at all (separates the two hemisphers in the brain). The damaging effect of alcohol has been known since classical times when alcohol on a couple’s wedding night was banned in case of producing “weak, feeble and distempered” children. We can not hide this information from the public any longer. Alcohol causes brain damage (amongst other serious malformations). Remember that this prenatal damage is a lifetime hangover. It does not go away. It can not be ‘cured’. I have been a psychologist for many decades and have been in the workforce as a professional working with young people for over 50 years.
In 1988 one of the three recommendations of the Australian College of Obstetrics and Gynaecologists was that labels on all alcoholic beverages should read that alcohol is a teratogen and will/may damage a foetus. All bottles of wine exported from Australia to USA have had such a label for over 20 years. This protected the American people. The wine consumed domestically from the same winery bore no such label.
Elizabeth, with respect, please re-read what I have written. I have absolutely NO CONCERNS WHATEVER and, indeed, THOROUGHLY ENDORSE your concerns about the effects of excessive alcohol use in pregnancy and the risks of fetal alcohol syndrome. Indeed, when I first published my medical Reference Guides on Drugs and Pregnancy in 1980, I noted that in terms of quantifying the risk of teratogenic effects on the developing infant, excess alcohol consumption during pregnancy is the most teratogenic of ALL commonly-used chemical substances, including all of other the drugs and medicines that may be taken! However, since we now know that teratogenicity is a threshold not a stochastic phenomenon, my concern is that some, quite frankly, very poorly-designed research studies (including some used in the NHMRC Interim Guidelines), are used to inappropriately extrapolate downwards and prosecute the socially desirable position that ANY alcohol taken during pregnancy can harm the infant. This then results in the proposition that even occasional, intermittent or inadvertent exposure to a small number or even a single episode of alcoholic beverage intake is a risk to the developing infant. When women are advised and counselled on such a situation, they need justifiable appropriate reassurance, so that they do not tragically contemplate inappropriate termination or develop unwarranted anxiety about their pregnancy and the health of their developing infant, just as they do in other situations, when appropriate, if they are intermittently or occasionally exposed to certain other drugs or chemicals that they may take occasionally or in very small doses during pregnancy. As I say, there are better ways to educate people than resorting to bad science to justify otherwise desirable social objectives!! So, yes I support publicising the dangers of excess alcohol consumption during pregnancy, and putting appropriate warnings on labels, but please rely on evidence supported by the facts!