2022 Australia New Zealand Food Regulatory System Horizon Scan

The Horizon Scan is the first step in reform and modernisation of the Australia New Zealand Food Regulatory System since its inception in the 2000s. In December 2021 Food Ministers agreed to key actions to progress the reform agenda.

The Australia New Zealand Food Regulatory System: Horizon Scan to support the System Strategic Direction for 2023-2026. Consultation Paper.

PSGR's submission to the consultation concerned the fact that there appeared to be little frank introspection in the Horizon document concerning the scale of increase in synthetic chemicals and products of biotechnology (novel entitites) in the food supply - and the lack of inquisitorial capacity of regulatory agencies.

Over the long term this regulatory and science lag - from under-resourcing of regulators and independent scientists - would mean that the agencies were unable to perform their duties adequately, in order to promote trust in food. No scientists are currently securely funded in order to triangulate industry claims of food safety. As we stated

In addition to the absence of dedicated laboratories and scientists who can explore and challenge industry claims of safety, there is an absence of turning to, or deferring to independent scientific communities of experts for information. We also observe that regulatory scientists are handicapped by an absence of a dedicated scientific community outside the regulatory environment with block funding to explore new knowledge relating to risk from shifts in technologies relating to food and safety.

The PSGR's response identified that the consultation paper paid insufficient attention paid to inadequate processes of risk assessment that could compromise food safety claims. Instead, the consultation paper focused on key trends and issues, rather than long term challenges for the Joint Food Regulation System.

As PSGR stated:

Existing regulatory practices revolve around industry supplying data for regulation and from reliance on industry scientists with significant practical expertise. We recognise how and why the Horizon Scan document has focussed on broader food-scape issues rather than overriding obligation to provide safe and nutritious food. It is because such a focus would involve a substantial alteration to regulatory cultures and practices that would politically challenge relationships with commercial industries. However, this position where one stakeholder holds disproportionate power, emasculates, or de-fangs the regulator, who then cannot achieve its highest objective of protecting public health and safety.

The 'A world-class collaborative food regulatory system focused on improving and protecting public health and safety' paper has not discussed systemic problems where under-resourced regulators, who lack inquisitorial powers have essentially become box tickers.

It is evident that regulation of chemicals and biotechnologies are systematically failing at the global scale (see Persson et al 2021), leading to larger at-scale risks.

Partnership/stakeholder rhetoric in the paper failed to identify that so often, stakeholders as industry, have a financial interest in weak authorisation and under-regulation. It failed also to address the issue of lobbying by industry sectors and their representatives.

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