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Keep it REAL, stop Ultra Processed syn-bio-tech foods.

Stop FSANZ proposal P1055 to change the definition of GM foods. It will create a loophole for industry to bring Ultra Processed syn-bio-tech food into the market without safety testing or labelling.

Your right to informed consent about the ingredients in the food you buy is at stake. Not only that, under proposed new food regulations in Australia and New Zealand, New Breeding Technology (NBT) foods will not be required to undergo a safety assessment. These NBT foods include Ultra Processed syn-bio-tech foods that use new genetic modification technologies such as CRISPR to alter organisms in order to produce food ingredients.

To make matters worse, these NBT foods will not be required labelling to disclose GM technologies were used in the process of creating the food.

As a result you could be buying a ‘steak’ at your local supermarket with its  protein sourced from the excrement of a genetically manipulated yeast grown in bioreactors at an industrial refinery plant,  fed with a chemical mix of Carbon Hydrogen Oxygen (CHO). 

This would not be disclosed on the label.  Plus, these products would not be subject to safety testing, or the testing of benefit and risk to human health.

If this concerns you, please do the following now: 

1. Write to the  state / federal representative in your electorate 

2. Ask them to represent your concerns in parliament.

3. Describe your concerns in your own words. 

4. Feel free to attach my letter (below ) as a reference to your personal email. 

Please take this opportunity to make your voice on this matter heard, and exercise your right to freedom of expressing your opinion. 

LETTER TO STATE / FEDERAL REPRESENTATIVE 

As a constituent of your electorate, I would appreciate it if you could make representation to the Federal Minister for Health and Aged Care, the Hon Mark Butler on the following matter:

The Food Standards Australia New Zealand Act 1991 is ensuring a high standard of public health protection in Australia and New Zealand in the specific area of food safety, in production, at the point of sale, and the point of consumption.   This is a key strength of the Act and the regulatory framework in place as overseen by the regulatory Authority, Food Standards Australia New Zealand (FSANZ).

A key weakness of the Food Act is that it does not consider individual or public health outcomes associated with the foods regulated by FSANZ.  This is a gap in the Act that can no longer be ignored, especially considering the state of public health, with the chronic disease epidemic costing the Australian economy at least $5 billion per annum in health costs directly related to overweight and diet risk, at least $24 billion per annum in lost productivity. There is no price tag for the cost of human suffering.

Let me explain my concerns about the Food Act more clearly:

The Food Act as per latest version 2018, defines ‘safety’ very narrowly, limiting the scope of authority of FSANZ.  The term ‘food’ however, is defined very widely, including products that can be represented as food, but are not actually food.  This creates a very wide scope for industry to manufacture and sell products ranging from real, minimally processed, animal and plant foods to ultra-processed animal and plant components mixed with synthetic, chemical, and artificial ingredients. This wide scope is great for trade, but not transparent for consumers and in many cases detrimental to health. As you might be aware, Ultra Processed Foods have been scientifically linked to eight out of ten chronic diseases including obesity, cancer, cardiovascular disease, arthritis, as well as increased risk for mortality. 

Hence, the current Food Act offers a high standard protection for industry yet falls short on standards that would be reasonable to expect for the protection of public health, and positive health outcomes for Australian and New Zealand citizens. 

A current and active threat to public health is Proposal P1055, currently under review by FSANZ and open for public consultation until 10 September.  The proposal seeks to redefine gene technology and GM foods.  

I am concerned that by changing this definition, a loophole will be created for industry to introduce New Breeding Technique foods into the marketplace. NBT foods include foods with ingredients resulting from synthetic and genetic engineering processes. When this proposal is accepted NBT foods will not require FSANZ pre-market safety testing or clear labelling as required by the current definition and regulation of GM foods.  

The argument made by FSANZ is that these new products can be compared to conventional foods on an equal outcome and characteristics basis.   With regards to characteristics, the only characteristics assessed by FSANZ in its safety assessment are:

1)Presence of foreign DNA in final food organism, and 

2)Novel characteristics in the food.   

A footnote is provided for characteristics: ‘A food characteristic is considered Novel if it has not previously been present in conventional food, or if it has been altered and now falls outside the documented range for conventional foods.’

As you can see ‘characteristics’ is not defined clearly in the comparison, again offering industry great liberty for interpretation.

Just to illustrate, the implications are that you could be buying a ‘steak’ at your local supermarket, labelled ‘steak’ with energy (kj/cal), macro- (protein, fats, carbohydrates) and micro-nutrients (vitamins, minerals) and additives (e.g. preservatives) listed, similarly to a real steak from an animal.  The fact that the protein from this NBT steak could have been sourced from the excrement of a genetically manipulated yeast grown in bioreactors at an industrial refinery plant,  fed with a chemical mix of Carbon Hydrogen Oxygen (CHO), would not be disclosed on the label.  Plus, these products would not be subject to safety testing, or the testing of benefit and risk to human health. This, because on an outcome characteristic comparison basis – a protein is a protein.  It is clear many of these foods will be Ultra Processed Foods re-emerging in a new shiny jacket as NBT foods, where the production process itself is proprietary information and patented, and not disclosed to the public.

The entire validity of Proposal P1055 is resting on the conclusion of ‘low risk’ based on the key assumption in the safety assessment by FSANZ that NBT foods can be considered as the same low risk as conventional foods.   Within the narrow scope of ‘safety’ in the Act this may be a legally correct statement, however within the real context of the protection of the standard of public health this is a false equivalence, like saying an apple is the same as an orange because they are both fruits and grow on a tree.     A comparison of a narrow scope of not clearly defined characteristics does not tell the whole story.  The actual public health outcomes and the epidemic of chronic disease relating in part to food have been completely ignored in this safety analysis by FSANZ.

A further concern is that The Office of the Gene Technology Regulator (OGTR) was consulted in this risk assessment.  The same OGTR conducted a risk assessment in 2021 for the commercial supply of a genetically modified Covid-19 vaccine by AstraZeneca Pty Ltd. At the time, OGTR made a ‘low risk’assessment based on assumptions (one can only assume provided by AstraZeneca Pty Ltd) including 1) GMO/mRNA would not travel through the body beyond the injection site and, 2) GMO/mRNA would not alter DNA of the recipient.  Indications from the latest research available are these assumptions were wrong, and there are real health risks and unintended consequences associated with mRNA vaccines.  The AstraZeneca GM Covid-19 vaccine has since been removed from the market due to clear evidence of harm to recipients, including death. It would never have been authorised for use if a proper independent risk and safety assessment had been done in the first place.  

The contribution of GM and mRNA vaccines to acute and chronic morbidity and mortality including Long Covid should be investigated properly, before carte blanche is given to the food industry and affiliate syn-biotech partners for a similar mRNA biotech platform to synthetically, and genetically edit foods and ingredients to be sold as or as part of foods.  The Australian population depends on the availability of real and healthy food for health and life itself. 

There is a real risk of harm to the populations of Australia and NZ if this proposal P1055 is accepted.  It furthermore poses a threat to industry, especially for growers and producers of organic and GMO-free produce and foods.  The proposal, if accepted, also paves the way to the potential for real and traditionally bred animals and plants to be genetically modified and patented by industry.  A coup de la Vie, a capture of life itself. 

I’m pleading for you to use your ministerial powers to pause the proceedings of this Proposal P1055 and allow more time for much needed public debate on this important matter.  

Reform is needed to ensure the Food Act truly ensures a high standard of real public health protection for Australia and New Zealand and is not predominantly used as a regulatory instrument by industry for financial benefit.  We need to go back to first principles and the prime directives of FSANZ and OGTR:

Food Standards Australia New Zealand (FSANZ)

To ensure a high standard of public health protection in Australia and New Zealand.

The Office of the Gene Technology Regulation (OGTR)

Protecting the health and safety of people and the environment by identifying and managing risks posed by, or as a result of gene technology and Genetically Modified Organisms.

If human health and the current state of public health, with an epidemic of chronic disease, much of it preventable and lifestyle, especially food related, are not considered by these public institutions mandated to protect our health, what hope do we have? 

I appreciate your representation of my concerns in Parliament and hope you will use your ministerial powers to pause FSANZ Proposal P1055 and initiate a much-needed public debate on this matter and the matter of realigning our public institutions and regulators such as FSANZ and OGTR with their prime directives to protect the health and safety of people and the environment and ensure a high standard of public health protection.   

We owe it to ourselves, our children, and future generations to pause and reflect, and have a proper civilised public debate on these existential matters.  Our health, lives and future depend on it!

Yours sincerely,

Ms Petra T E Hooijenga

Proud Australian citizen since 2007

Disclaimer: Please feel free to fact-check my writing, I am aware that my perspective with links provided is only part of the whole picture. The subject requires holistic critical thinking and analysis from multiple perspectives. Not all new technology is bad, the contrary, it can be used to elevate the true natural health of humanity, and all sentient beings and life on this precious planet Earth. It is a matter of applying a higher consciousness approach to the problems and challenges we are faced with.

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Petra Hooijenga MSc CPN