Katherine Rich: Imagine a world without food standards
1 July 2016
A presentation by Katherine Rich to a seminar celebrating 20 years of the Food Treaty between New Zealand and Australia.
Today, on the occasion of the celebration of the Food Treaty, I aim to give you a whistle-stop tour of food processing and food standards history to emphasise the importance of having a strong evidence base for food regulation, and to pay tribute to all officials who have made our food treaty such a success for both countries.
Some might think that food standards are a recent development of the 20th and 21st century’s explosion of processed foods. They would be wrong. Not only is there an amazing history of ‘processing’ food, but an equally wondrous journey in the world of food standards. Neither are new.
There was an excellent and fascinating article in 2015 in Scientific American by Evelyn Kim, a writer and educator from Copenhagen, describing the evolution of processed foods, starting from cavemen enjoying their first BBQ. She references the views of anthropologist Richard Wrangham of Harvard University, who believes that “cooking was THE essential step that allowed early humans to develop the big brains characteristic of Homo sapiens.”
So where has processed food developments come from apart from the first, roasted meat – 1.8 million years ago? Here’s a selection of food processing milestones, which I hope you find interesting: Bread – 30,000 years ago; Beer – 7000-3000 BC; Wine – 5400 BC; Cheese – 5000 BC: Olive oil – 4500 BC
But as the Bible says, “Man shall not live by bread alone” (Mathew 4:4). And we add: Pickles – 2400 BC; Noodles – 2000 BC; Chocolate – 1900 BC; Bacon – 1500 BC; Coffee – 1000 BC to 500 AD; Sugar – 500 BC
Now you can see that many of the demonised foods topical today are between 2500 and 9000 years old.
In the past couple of thousand years we have added these: Mustard – 400 AD; Peanut butter – 1400s; Carbonated water – 1767; Corn flakes – 1894; Spam – developed in 1926 but probably known to Monty Python fans for different reasons; Chicken nuggets – 1950s; High fructose corn syrup – 1957; Tang – 1959 (does anyone here remember what an innovation Tang was? – it’s probably a sign of your age!). And Lab-grown meat – 2013.
But with each development came concerns – about food safety and the impact of food on society. I’d say food politics is probably as old as food processing itself.
Take my favourite, coffee. Arabic writers noted its ‘powers of sociability’ (Kim 2015) prompting the Governor of Mecca to ban it in 1511. It’s been suggested that his 13-year caffeine headache resulted in the reversal of the ban in 1524. And around 1600, advisers (probably policy advisers) to Pope Clement VIII described coffee as “the bitter invention of Satan” because it was a drink favoured by the infidel Turks. However, the Pope did give papal authority making coffee acceptable for Roman Catholics.
Here we have prohibitions, policy advice, and promotion, all in the space of 90 years in the 1500s. Just a bit longer than our health claims standard took to develop (just kidding) and not unlike the criticism of coffee we have seen in the past decade.
Long before this, the writings from archaeological sites around the world and in documents such as the Bible provide guidelines and recommendations for food processing. There are extensive references to food in the Bible, about the dangers of ‘broth of tainted meat’ (Isaiah 65: 3-6) and multiple references to the animals, products and plants that might be eaten or might not.
These were standards for life and focused more on clean or unclean foods and on the adulteration of the body with such foods. But we now have Standard 1.4.4 which codifies prohibited foods and the likes of Standard 1.2.6 which manages cassava preparation.
These requirements have moved from the power of authority in religion to New Zealand and Australian law.
More explicit in history from a standards perspective, however, was the emergence of ‘food guilds’, which were cadres of professionals that was somewhat methodical and which drew on evidence to the extent of protecting their businesses. As a result, many guilds were established as protectionist organisations for trade purposes, but the good to come from them was the emergence of universities (such as Oxford) and, for food, safe preparation approaches and practices. Trade guilds, on the whole, set high standards and self-regulation of the winemakers, bakers, and butchers guilds with self-regulated fines for those who deviated from guild standards. Their fall was inevitable, however, since economically they were a deadweight on the competitiveness of industry by creating monopolies.
This is why regulatory impact analyses are vital to the process of protecting economic equality, and ensuring the impact of standards on innovation and technology is not unnecessarily constrained.
These processes are recent responses to limitations of the past. Constraints such as those that surrounded margarine manufacture competing against dairy products. The prohibitions on colouring margarine to make it more palatable to the eye and pale yellow more like butter, sounds so silly today, but such prohibitions used to exist.
Trans-Tasman food issues are not just about how we process foods but how we mix them and what ingredients we use.
Our standards on vitamins and minerals, food additives and processing aids (Standards 1.3.1 to 1.3.3) have origins in the food fortification and supplementation that has been carried out for centuries.
According to Peter Ottaway, a fascinating example of fortification in central Europe during the middle ages was mothers pushing iron nails into apples, leaving them for a while then feeding the apples to their ailing daughters.
Other fortifications from history are the natural iodines in salt featuring in South American Indian cultures, vitamin A in margarine in Denmark last century, and lime in flour for calcium uptake in Mexico.
All are reflected in our standards but with minimums for efficacy and maximums or upper limits to ensure we do not overdose on the ingredients.
And the next frontier in the evolution of fortification is bio-fortification, a topic currently working its way through Codex.
Over the years we’ve learnt a lot about food safety too. We might think that lessons from the past are those from previous centuries, and our friend Google delivers up banquet of food related disasters such as the London Beer Flood - 8 people killed when the corroded hoops of a giant vat gave way, flooding Tottenham Court.
The Great Mill Disaster, when the stones in the largest mill in the US in 1878 gave off sparks, ignited particles of flour dust in the air and caused a massive explosion started other fires that destroyed six nearby mills and killed 18 people.
The Boston Molasses disaster in 1915 when the largest molasses vat exploded creating a 15-foot-high wave of molasses that crashed through the streets at 35 miles per hour, leaving parts of Boston in 2-3 feet of molasses and 21 dead and 150 injured
And while these are more about equipment, there was most recently the Basra mass poisoning. This is a sad example but one which shows that food disasters can happen in any century. Many will recall stories about a shipment of grain in Basra, Iraq, that was treated with a methylmercury fungicide and was intended only for use on seed. The bags were marked poison—but only in English and Spanish—and the grains were dyed bright pink to indicate they were not for consumption. However, a huge number of bags were stolen, the dye washed off and the grain sold. The result was over 6500 people were hospitalized and 459 died.
Just goes to show even the best warning labels can only do so much to avoid harm.
The first chapter of the book containing that description is titled “The richness of our ignorance” which seems to me to reflect the Readers’ Digest article on the four most harmful ingredients in the food supply – trans fat, refined grains, salt and high fructose corn syrup.
There are worse but, as with all contaminants, it’s the dose that counts. This highlights another feature of the food standards we share – the evidence. For example, trans fats are not a significant problem for the New Zealand or Australian populations, so FSANZ has held a position of not developing a trans fat standard against some strong activism for such a standard.
Codifying standards as we know them today derive from the 17th century through to the ‘Lusk’ energy standard (Shrimpton 2008) and its promotion by the British Medical Association (key nutrients and vitamins and minerals). But it is only 150 years since the first pure food law in the English-speaking world was passed in the UK in 1860: An Act for Preventing Adulteration of Articles of Food and Drink.
As I have shown, many of the checks and balances in the FSANZ standards-setting process draw from the lessons of history. Removing uncertainty in labelling, providing certainty for a level playing field for manufacturers, is hard earned but essential to the system we have underpinned with international commitments through the Food Treaty.
It is sometimes difficult to ‘hold the line’ on evidence in the trans-Tasman arrangements when a country that is smaller than Sydney argues the toss or, looking to Australia, a territory smaller than Wellington has a contra view.
These are challenges that the Food Treaty addresses from a policy perspective while ensuring that the arrangements for standards development rests with experts and takes account of science, evidence and risk management.
Which leads me to the significance of international standards and their influence in our local standards. All those here today already understand how critical food is to the functioning of society, but some might be surprised to know what role it’s had during times of chaos and war.
Wars have been won and lost on food – the American Civil War was won, in part, by ‘starving the south’; Uruguay won a naval battle against Brazil by firing stale balls of cheese when the ammunition ran out (Wears A 2012); the Romans were defeated by a small Turkish tribe that left bowls of spiked honey out for their enemy, the Romans, containing mega doses of an LSD-like substance; exploding baked goods in WWII (used for smuggling explosives to Chinese rebels); and the Japanese submarine sunk by potatoes (the USS O’Bannon crippled a Japanese submarine, pulled alongside and pelted it with potatoes, distracted the submariners who got busy throwing them away thinking they were grenades, allowing the O’Bannon to re-position to fire a deadly salvo that sunk the submarine) (Wears A 2012).
I love this picture of this gifted plaque to commemorate this battle. As you’d expect food companies can never resist a public relations opportunity and here’s the plaque from the Maine Potato Growers who were clearly chuffed their potatoes were the ones used to win the battle.
History, as always, has a lot to teach us. We can take lessons for our food standards in economics, innovation, technology, additions to food, extractions from food and all the steps in between.
So what of the differences between our two countries that need to be accommodated by an international treaty to give it longevity.
Let’s start with sovereignty. This is accommodated through representation on the Ministerial Forum and the FSANZ Board, in Board appointments (New Zealand selects its three), New Zealand or Australian variations and the opt-out provision.
Then there is sport on which you will be pleased to know the Food Treaty is silent but perhaps explains why the sports food standard (Standard 2.9.4) remains un-reviewed since commencement of the Food Standards Code.
And that’s about it. Science and robust process does the rest to accommodate differences in population deficiencies, different foods and food practices, economic realities, technology development and uptake.
But equitable and evidenced-based standards do not mean either heavy handed oversight or absence of oversight.
We would have debates every day the House sat if food standards were to be debated in all our Parliaments. We would do nothing else but debate food with evidence, science and risk taking a backseat. Thus the real challenge for trans-Tasman food standards is to reflect the evidence but to balance that against risk.
Standards must be a mix of the two and not necessarily in equal portions. Standards that do not reflect risk gave us the pre-Food Standards Code requirements of the New Zealand regulations that contained 28 standards for grains and grain products and the standard that permitted cats in restaurants apparently because New Zealand’s Prime Minister at the time, Robert Muldoon, was a cat lover.
Participation of both nations in standards-setting ensures robustly debated outcomes but only so long as principles of evidence and risk, benefit and cost, and oversight but not political influence are maintained.
I recognise we still have the jam standard, the ice cream standard and the Red Bull standard from the past 15 years. But strong leadership, good governance, rationality and proportionality are, we hope, winning out.
Those are the goals for the Food Treaty arrangements and the trans-Tasman standards setting in the next 20 years. And to quote Churchill from 1925: You must look at the facts because they look at you.
So, well done to the Food Treaty which has won many battles. I would like to pay particular tribute to all those here today who were part of its establishment of the Food Treaty and those who are its its current caretakers. Finally, a message of good luck to FSANZ for making standards development an art form now and in the future.
Agin D (2010). More than Genes: what science can tell us about toxic chemicals, development, and the risk to our children. Oxford University Press: Oxford, 2010.
Kim E (2015). The amazing multimillion-year history of processed food. Scientific American: The Science of Food, Special Collector’s Edition, 2015.
Langworth RM (2012). Churchill: in his own words. Ebury, 2012. https://www.churchillcentral.com/quotes
Ottaway PB (ed) (2008). Food fortification and supplementation: technological, safety and regulatory aspects. Woodhead Publishing: Cambridge UK, 2008.
Rhodes J (2011). Four deadly disasters caused by food. Smithsonian: Washington, 2011 http://www.smithsonianmag.com/arts-culture/four-deadly-disasters-caused-by-food
Shrimpton DH. Safety of vitamins and minerals added to foods: an overview of international expert opinions on micronutrient safety. Food fortification and supplementation: technological, safety and regulatory aspects. Woodhead Publishing, 2008.
Wears A (2012). 4 battles won by using food as a weapon. At http://www.cracked.com/quick-fixes/4-battles-won-by-using-food-as-weapon/ ]