FOOD LABELLING LAW AND POLICY
REVIEW
PUBLIC CONSULTATION 2010
SUBMISSION
Mrs Gail Matthews
Chair
Western Australian Consumer Council
Kidney Health Australia
Online:
Email:
Post:
www.foodlabellingreview.gov.au
FoodLabellingReview@health.gov.au
MDP 138, GPO Box 9848 Canberra ACT 2601
Summary and Recommendations
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Food Labelling Law and Policy is responsible for ensuring the provision of adequate
information relating to food to enable consumers to make informed choices.
Food Labelling must support education campaigns designed for consumers with Chronic
Disease, at the point of sale so they can make an informed choice for their particular
circumstances.
Food Labelling must promote health safety to protect consumers from acute episodes of
ill health resulting from contamination, decay or potentially serious reactions to food
ingredients.
It is highly recommended that potassium levels be listed as a compulsory nutrient
on food labels. Consumption of excess potassium for people with Chronic Kidney
Disease (CKD) may cause an irregular heartbeat, cardiac arrest or death.
Dieticians provide educational support and advice for people with Chronic Kidney
Disease on their dietary requirements and restrictions and how to interpret the Nutrition
Information Panel on food.
Introduction
The Kidney Health Australia National Consumer Council, (KHA NCC) incorporating the
Kidney Health Australia WA Consumer Committee, (KHA WACC) provides a formal consumer
advocacy structure for the expression of issues affecting people living with Chronic Kidney
Disease to improve health outcomes and quality of life. The KHA WACC welcomes the
opportunity to provide a submission to this review.
Potassium is a mineral found in many foods we eat. It plays a vital role in keeping our hearts
regular and muscles working correctly. Whilst current food labelling provides useful
information to consumers, some consumers, particularly older people, people with poor vision
or people with lower level of education and income find them confusing. The food labels are
not immediately visible to consumers as they are placed on the side or back of products.
KHA WACC recommends a front of panel labelling system or a thumb-nail approach, as it is
easier to see at a glance and easy to interpret. Front of panel labelling should complement
not necessarily replace existing Nutritional information currently on food packaging.
To avoid consumer confusion one format should be introduced. An extensive government
education campaign must follow the implementation informing consumers how to interpret the
labelling system.
Chronic Kidney Disease
Chronic Kidney Disease (CKD) is a major public health problem. CKD progresses at the rate
that requires 2500 individuals each year in Australia to commence dialysis or have kidney
transplantation.1
One in three Australian adults are at risk of CKD and one in seven have some degree of
CKD.2 In 2008 there were over 18,000 patients with End Stage Chronic Kidney Disease
receiving renal replacement therapy.3 The number of people on dialysis has averaged a 6%
growth rate per year over the past decade.4 The number is increasing by approximately 10%
per year in Australia.
CKD contributes substantially to health care expenditure in Australia and is increasing much
faster than expenditure on total health care. In 2004-05 CKD accounted for 1.7% of total
expenditure ($898.7 million), an increase of 33% since 2000-01 ($573.6 million).5
The best available evidence on cost per person per year on dialysis is:
- Hospital Haemodialysis - $82,764
- Satellite Haemodialysis - $48,631
- Home Haemodialysis - $44,739
- Peritoneal dialysis (CAPD) - $56,828
On 2005 figures the cumulative cost of dialysis from 2004 to 2010 is expected to be $4.5
billion. The cost of a transplant for a kidney recipient in the first year is $65,375 – $70,553.6
Based on the above trends the health care costs associated with Chronic Kidney Disease are
substantial and any programs which focus on better management of his debilitating disease
would be welcomed.
1
ANZDATA Registry Report 2009, Australia and New Zealand Dialysis and Transplant Registry, (1-2) Adelaide,
South Australia.
2
Kidney Health Australia (www.kidney.org.au)
3
ANZDATA Registry Report 2009, Australia and New Zealand Dialysis and Transplant Registry, Adelaide, South
Australia.
4
Kidney Health Australia (www.kidney.org.au)
5
Australian Institute of Health and Welfare 2009. Health care expenditure on chronic kidney disease in Australia. Cat.
no. PHE 117. Canberra: AIHW.
6
Cass,A., Chadban,S., Craig,J., Howard,H., McDonald,S., Salkeld,G., & White,S. The Economic Impact of EndStage Kidney Disease in Australia. Kidney Health Australia, Melbourne, 2006 [available at http://www.kidney.org.au/].
Potassium and CKD
Potassium is a major concern for people with CKD, Coronary Heart Disease (CHD), Diabetes
and people on potassium lowering medication for prevention of hypertension. The
consumption of foods containing potassium must be controlled to prevent hyperkalaemia
(high serum potassium) and conversely hypokalaemia (low serum potassium). End Stage
Kidney Disease patients undergoing therapy by dialysis must observe strict dietary limits on
potassium intake, as the kidneys control potassium excretion, and build-up of blood
concentrations of potassium may trigger fatal cardiac arrhythmia. Hyperkalaemia can be
asymptomatic and can express with muscle weakness, paralysis, cardiac arrhythmias/arrest
or even death.
Cardiac patients and patients on potassium elevating drugs need to limit their potassium
consumption. People with Diabetes or Coronary/Ischaemic Heart Disease including
hypertension are susceptible to kidney problems and hyperkalaemia.
The Role of Food Labelling
Food Labelling has a vital role to play with people with CKD because of its potential to
assist people in making the correct food choice. Food labelling provides information at point
of sale to complement and support education which teaches consumers on their dietary
needs.
Fresh foods rich in potassium are known and well documented in National Nutrient
Databases. It's the potassium content of processed foods with additives that is unknown.
Patients assume if potassium is not on the label then it isn't in the product and consumers are
risking hyperkalaemia. Given that hyperkalaemia is potentially life threatening it must be
introduced as a requirement on Nutrition Information Panels.
The Food Labelling Law and Policy Review Board need to do more to address public health
issues beyond food safety and respond to the need of people with fatal consequences in their
diet. Education must accompany changes to food labelling to ensure consumers understand
what labels mean and how to interpret the system of eating guidelines.
Thank you for the opportunity to provide a submission to the Food Labelling Law and Policy
Review Board.
Yours Sincerely
Gail Matthews
Chair - WACC