(your address)

February 2018

(ministers address)

Dear Minister

Within the next 60 days you will be asked to approve Application A1136 Protein Glutaminase as a Processing Aid (Enzyme) as member of the Australia and New Zealand Ministerial Forum on Food Regulation.

This application has caused considerable concern to the 14,000 member Food intolerance Network, who launched a petition which has gained 11,600 signatures to date without any attempt to gain media attention. The petition is available here http://bit.ly/2kkSth0 

I ask that you do NOT approve this Application but refer it back to FSANZ to review its decision on the following grounds

•    it is not consistent with the objectives of the legislation which establishes FSANZ
•    it does not provide adequate information to enable informed choice

In my view, this enzyme cannot legally be classified as a Processing Aid and hence hidden from the view of consumers for several reasons, the most prominent being that declaring Protein Glutaminase as a Processing Aid is in breach of Object (c) of the Food Standards Australia New Zealand Act 1991: the provision of adequate information relating to food to enable consumers to make informed choices.

A simple alternative exists which FSANZ has not adequately considered and which addresses these grounds for review, which is to approve Protein Glutaminase as an Additive under 1101 Proteases in the existing Food Standards Code. In this way it appears on the Food Ingredients label and consumers can make an informed choice, rather than having it disappear from the label as a Processing Aid.

Protein Glutaminase is clearly a Food as defined by the Food Standards Australia New Zealand Act 1991, where Food includes (a) any substance or thing of a kind used, capable of being used, or represented as being for use, for human consumption (whether it is live, raw, prepared or partly prepared); and (c) any substance used in preparing a substance or thing referred to in paragraph (a). Therefore Protein Glutaminase should be treated as a food subject to full disclosure rather than hidden as a Processing Aid.

Yours faithfully


(your signature)