Analysis of Submissions No. Organisation Question 1 Question 2 Question 3 1. Australian Consumers Association Do not provide sufficient detail to protect public health and safety. A review of the entire process is not necessary. Policy principles should specify; MRLs are both chemical and commodity specific, A list of restricted chemicals should be established, Zero tolerance applies where there is noMRL, Conservative default MRLs apply only when low level of residue and one-off incident or first occurrence, Establish MRLs that aren’t approved but detected in foods on an ongoing basis. A very low default MRL should be established to ensure it only applies to products where very low levels of chemicals are detected, indicating inadvertent presence or contamination, not ongoing, intentional presence of that particular chemical. A conservative default MRL such as that established in Japan should be established. 2. Food Beverage Importers Association Support Draft Policy Principles. Support Codex MRLs and default tolerance level.
6. Dairy Australia Support Draft Policy Principles. Default MRLs for all chemicals without MRLs. Codex MRLs should reflect Australian MRL labelling requirements. A systemic review by APVMA and FSANZ of all chemicals with different MRLs to Codex should be undertaken. 7. Australian Chicken Meat Federation Support Draft Policy Principles. Consider a sixth principle along the lines of: “not unduly limit the capacity to market products that do not represent an unacceptable health risk to consumers.” 8. Food technology Association, Victoria Support Draft Policy Principles. Align MRLs with Codex. Australia and New Zealand apply one standard. Support default MRLs. 9. Animal Health Alliance (Australia) Ltd. Support Draft Policy Principles. 10. Australian Fruit Juice Association Support Draft Policy Principles.
18. Cadbury Schweppes Support Draft Policy Principles. Suggest additional guiding principles: Promoting greater consistency between Australia and New Zealand and establishing a single standard for maximum residue limits. Promoting greater agreement with CODEX, or other internationally recognised standards. Support establishing default level for those agvet chemical residues where there are no, or known risks for overexposure or where there are minimal health or safety risks associated with exposure, and establishing a restricted chemicals list to which default level does not apply. Suggest that the Code should include a separate New Zealand listing for MRLs until that time where there is a single set of MRLs for Australia and New Zealand. 19. Unilever Australia Support Draft Policy Principles. This is an area that presents a major risk to food manufacturers as it is not possible to be compliant with the current Standard 1.4.2 MRL for imported foods. 20. Bottrill Research Pty Ltd. Support Draft Policy Principles. 21. Measurement Standards Laboratory of New Zealand The draft policy principles are appropriate but may not be sufficient. Additional principle: any changes to the regulation of residues should be technically enforceable. This principle can be followed by taking technical advice from the National Analytical Reference Laboratory of the Australian National Measurement Institute and/or from MSL.