The Australian Consumers' Association has food safety issues high on its agenda. Thousands of consumers phone or write to ACA every year asking staff to answer questions about, or to investigate, the areas that they believe are the most important to them.

Over the past two years one issue came top of the list month after month. The overwhelming impression gained by those responding to the queries and the complaints was that consumers somehow feel that the food supply is out of their control and it should not be.

In the past we knew exactly what we were eating. We grew some of it in the back yard, we bought some from the greengrocer, some from the butcher and the butter, sugar and flour from the grocer. Today we are confronted by a vast array of brightly packaged designer foods offering us convenience, fun and happy families forever.

Consumers are not sure what is in the food they are offered. In the media they learn that their pork may be genetically modified, their spices irradiated, and their cheese contaminated with listeria. They believe that there are more food additives in the food than is good for them and that if overseas countries are rejecting our meat, then there must be something seriously wrong. Consumers are confused by conflicting nutrition messages and feel helpless in combating the pressures of children subjected to high fat/high sugar food advertising.

In spite of all this Australia does have a good record overseas as a "clean" producer of food. We have a national clearance system for agricultural and veterinary chemicals, a low level of acid rain, little risk of radioactive pollution and a closely monitored inspection system for export produce. Just over two weeks ago the Federal Government announced plans to capitalise on this record and implement legislative and structural changes in an attempt to increase our food exports to $7 billion over the next decade (joint statement by Senator John Button and the Hon Simon Crean, 15 July 1992).

Is the Australian consumer served as well as our overseas consumer? At present there are only seven inspectors examining imported foods at the point of entry, although the Government plans to address this, with the promise that "we will be extending the current program so that all imported foods are able to be examined and so that inspections cover all requirements in the Australian Food Standards Code, including labelling, additives, food composition, chemical residues and general cleanliness and safety".

At the point of sale, foods are inspected by health surveyors who in some States are employed by local Councils whilst in others they are employed by the State Government. In Victoria, the legislation requires a minimum number of food samples for testing, but beyond that it depends on the finances and the commitment of the local Council. When we hear of the US or Japan rejecting Australian produce due to residue levels above acceptable levels, we have to wonder what is being sold to us on the domestic market.

Are we eating food with residue levels above that accepted elsewhere? Has there been any culling process which allows the export of foods with lower residue levels and are we, in fact, eating the foods with higher levels? For certain chemicals, such as some antibacterial agents, Australia actually has higher maximum residue levels than other countries.

I would like to briefly consider the risks involved in the major types of chemical residues which may be found in our foods today.

1. Hormonal Growth Promotants

Much has been made of the effect of the European Community ban on HGPs and its effect on our meat trade with the EC. Little has been said on the current lack of knowledge of the long-term effects on humans, although at this stage there is no conclusive evidence of risk when used correctly. The HGP-free animals are separated for export, so why cannot we have the domestic market meat labelled as HGP treated? Let the market sort out whether consumers really want to eat this or are prepared to pay a premium for non-treated meat.

Doubts have also been raised over proposals for the use of Bovine Somatotropine (BST), a genetically engineered growth hormone claimed to boost milk production by 10 to 25 per cent. At this stage it has not been approved for use in Australia, but it is certainly used in some countries. If it is approved by Codex Alimentarius there is a danger that it will be introduced into this country given Australia's policy of adopting Codex Standards.

2. Antibiotics

The use of antibiotics to control infection and promote growth is widespread in livestock production. It would be fair to say that consumers have few problems in principle with using veterinary chemicals for prevention or treatment of disease, assuming, of course, that the correct drugs and dosages are being used and the withholding periods observed. There is, however, substantial consumer opposition to the use of these drugs as growth promotants. The National Academy of Sciences Institute of Medicine, which prepared a Risk Assessment Study for the USFDA, estimated that "the doses of antibiotics given to livestock to promote growth or prevent infection would account for less than two per cent of human deaths due to food-borne, antibiotic resistant Salmonella poisoning" (FDA Consumer, April 1989). Whilst I accept that we cannot just transfer this type of research to Australian conditions, the critical point for the consumer is that these antibiotics are being used to provide a higher return on investment. The primary producer takes the profit, but the consumer takes the risk.

In Australia, residues in food and produce are monitored through the National Residue Survey (NRS) administered by the Department of Primary Industries and Energy, and the Market Basket Surveys, now carried out by the National Food Authority. It was reassuring to note the improvement from 3.6% of samples with sulphonamides above the Maximum Residue Levels (MRLs) in the 1988/89 Victorian Produce Monitoring Report to nil detections for the same product in the 1989/90 report (Victorian Produce Monitoring Report, Department of Food and Agriculture, May, 1991). Conversely, it was of concern that some exported products have slipped through the net and have been picked up as a violation by the US authorities.

3. Heavy Metals

Not only do we have different levels of acceptable limits from other countries and from the Codex Alimentarius Commission for some heavy metals, but we have for many years had different levels between States in Australia. The human body appears to be twice as tolerant of mercury for fish eaters in South Australia. Concern has been expressed over levels of cadmium in offal, particularly in kidneys, with several requests by State governments to raise the level as the local product could not comply with the legislation. Because cadmium is so toxic (it accumulates in the body and has a half life of twenty years), I believe there would need to be extremely sound justification to raise the permitted levels. In fact, I suggest that, as we learn more about the toxicity of cadmium, the levels may be lowered.

4. Pesticides

"Despite the growing awareness of the problems associated with pesticide use, worldwide sales continue to grow each year, with much of this growth in 'developing' countries". "Sales of agricultural chemicals by members of the Agricultural and Veterinary Chemicals Association (AVCA), which represent about 90-95 per cent of the market in Australia, grew from $437 million in 1987 to $547 million in 1988, representing about two per cent of the total world market". (ACA, How Safe is Our Food? 1991).

Consumer surveys predictably show that consumers regard pesticide residues in food as an unacceptable risk. In 1990, the Australian Consumers' Association brought together a number of groups involved in the eating, producing and selling of food. The purpose was to work towards an agreement which would make all parties more confident about consumer acceptance of foods, particularly fresh foods.

The result, some eighteen months later, is a Pesticides Charter which has been accepted by some twenty organisations as the basis for further dialogue on pesticide reduction in food production.

It begins with the agreement of all parties that reducing the use of pesticides in food production is beneficial to consumers, growers and the environment.

The parties agree that definite and attainable targets for overall reduction of pesticide use should be established and a national program to implement such targets be developed at a local level with due allowance for regional and local variations.

As a starting point, all parties agree to explore the possibilities for achieving the following reductions in overall pesticide usage:

(i) a 25% reduction within three years

(ii) a 50% reduction within five years

(iii) a 75% reduction by the year 2000

Priorities for achieving the targets include:

(i) identification and review of pesticides currently unused or unnecessary for agricultural production with a view to deregistration, prohibition or restriction of use in Australia;

(ii) identification and review of pesticides for which better alternatives exist and a timetable for phasing out of these in Australia by prohibition, deregulation and/or restriction of use;

(iii) identification of chemicals whose effect is largely cosmetic and phasing out of these in tandem with efforts to promote a different image of quality to consumers;

(iv) identification of the various alternative approaches being practised and developed in Australia and a national discussion between all interested parties, governments, producers, consumers, environmentalists, workers and researchers about how to extend their use and the appropriateness of different approaches to local and regional situations;

(v) discussion among all interested parties about redundant stocks of pesticides to ensure safe disposal and prevent illicit use and marketing abroad;

(vi) creation of a national working group representing the above interests to develop forward plans including additional research, on-farm trials, public education and fiscal measures for achieving the target reduction by the year 2000.

Following major efforts by the organic farming lobby, with support from consumer organisations, the Federal Government established the Organic Produce Advisory Committee. This body developed the National Standard for Organic and Biodynamic Produce which was released earlier this year. This followed many years of consumer confusion and distrust in regard to the labelling and identification of organic produce. Consumer organisations still have some concerns over the reluctance to establish specific pesticide residue limits in the final products, but regard the standard as the first step in providing consumers with the knowledge to make an informed choice about organic produce at the point of sale.

A major expansion in organic food production has been forecast by agricultural consultant Hassall and Associates, who estimate that the current one per cent of all agricultural land in Australia presently devoted to organic farming could well increase to five per cent by the turn of the century (AQIS Bulletin, March 1992).

The organic fruit and vegetable growers have demonstrated that there is a market for organically grown produce. The challenge is now ready for producers of other commodities to move into this market.

Consumers have demonstrated that they are prepared to pay for safety and for quality in food. They need to be reassured that they are getting exactly that. Consumers must rely on the integrity of the voluntary labelling systems in identifying organic foods. While self-regulation by the industry itself is in force, all of those in the industry must ensure that there is constant monitoring of products in the market place, the enforcement of rigid standards and the threat of effective sanctions for those who do not comply.

It will only take one retailer or one processor to abuse the system and all the trust and goodwill will disappear, together with the organic food market.

References

1. AQIS Bulletin, Vol.5, No.1, February 1992

2. AQIS Bulletin, Vol.5, No.2, March 1992

3. AQIS Summary of the International Conference on Food Standards, Chemicals in Food and Food Trade, 1991

4. Australian Consumers' Association, Consuming Interest, June 1990

5. Australian Consumers' Association, How Safe is Our Food?, Random House 1991

6. Australian Consumers' Association, Pesticides Charter, 1991

7. Australian Consumers' Association, Proceedings of the "Towards A National Food Policy" Conference, 1991

8. Australian Food Foundation, Newsletter, April 1992

9. British Medical Association, Guide to Pesticides, Chemicals and Health, Edward Arnold, 1992

10. Button, J. and Crean, S. Joint Statement on Australian Agri-Food Industries, July 1992

11. Department of Food and Agriculture, Victorian Produce Monitoring, May 1991

12. Department of Primary Industries and Energy, Chemical Residues in Food, AGPS, 1989

13. Department of Primary Industries and Energy, Information Paper: Agricultural and Veterinary Chemicals, June 1990

14. Federal Bureau of Consumer Affairs, Pesticide Use in Australia, August 1990

15. Russell, S.M., Chemicals in Food - Are Consumers' Concerns Real? Science Shop Seminar, Melbourne, 1991

16. Russell, S.M., Organic Foods and the Consumer Interest, CAFTA Seminar, Melbourne, 1990.