Suggest self-revocation clauses MPI The FSANZ Act provides for Minor Procedure for transitional arrangements so Proposals as a means to remove Code that after transition these (i.e. provisions that have ceased to have effect. clause 2.2) no longer appear in Reliance on this expedited procedure the Code. If this is addressed by enables simpler and clearer provisions and other means this should be noted requirements, particularly for stakeholders in the Approval Report The intent is that the Code will be amended to remove sections 1.2.3—1A and S10—1A after they cease to have effect (i.e. once the prescribed transitional period expires). This will occur by means of a code maintenance proposal. Association of Analytical New South Wales Food Advice from analytical laboratories confirms Communities is developing a Authority that ELISA kits are available to detect lupin reference method for lupin. (see section 2.3.4) Australian laboratories are not currently NATA accredited for Development of NATA accreditation is lupin testing. It is unknown demand driven. NATA accreditation will whether non-European importers increase with the need for lupin analysis. have facilities for lupin testing. Costs to industry and New South Wales Food FSANZ does not accept that such costs have government have been Authority been inadequately addressed or inadequately addressed and are underestimated in its assessment. See in likely to be underestimated this regard, section 2.4 and the Decision RIS at Attachment C. The Decision RIS was subject to independent assessment by the Office of Best Practice Regulation. FSANZ adopted a cautious approach in estimating cost. For example, upfront costs of implementation to government are estimated to be around $28,400 per jurisdiction - $20,000 for staff training and $8,400 for integrating new regulation into their administrative procedures. However such costs may well be less given that the change involves adding one additional allergen to an existing allergen management framework rather than implementing a new procedure. Due regard was also given to the increased need for and cost of food testing and analysis for compliance purposes. The cost to government and industry of this measure was taken into account by FSANZ. However, FSANZ considers that these costs are outweighed by the benefits to consumers due to reduced number of adverse health reactions associated with consumption of lupin and lupin products and reduced financial and wellbeing costs to lupin sensitive individuals.
Suggest self-revocation clauses for transitional arrangements so that after transition these (i.e. clause 2.2) no longer appear in the Code. If this is addressed by other means this should be noted in the Approval Report MPI The FSANZ Act provides for Minor Procedure Proposals as a means to remove Code provisions that have ceased to have effect. Reliance on this expedited procedure enables simpler and clearer provisions and requirements, particularly for stakeholders The intent is that the Code will be amended to remove sections 1.2.3—1A and S10—1A after they cease to have effect (i.e. once the prescribed transitional period expires). This will occur by means of a code maintenance proposal. Association of Analytical Communities is developing a reference method for lupin. Australian laboratories are not currently NATA accredited for lupin testing. It is unknown whether non-European importers have facilities for lupin testing. New South Wales Food Authority Advice from analytical laboratories confirms that ELISA kits are available to detect lupin (see section 2.3.4) Development of NATA accreditation is demand driven. NATA accreditation will increase with the need for lupin analysis. Costs to industry and government have been inadequately addressed and are likely to be underestimated New South Wales Food Authority FSANZ does not accept that such costs have been inadequately addressed or underestimated in its assessment. See in this regard, section 2.4 and the Decision RIS at Attachment C. The Decision RIS was subject to independent assessment by the Office of Best Practice Regulation. FSANZ adopted a cautious approach in estimating cost. For example, upfront costs of implementation to government are estimated to be around $28,400 per jurisdiction - $20,000 for staff training and $8,400 for integrating new regulation into their administrative procedures. However such costs may well be less given that the change involves adding one additional allergen to an existing allergen management framework rather than implementing a new procedure. Due regard was also given to the increased need for and cost of food testing and analysis for compliance purposes. The cost to government and industry of this measure was taken into account by FSANZ. However, FSANZ considers that these costs are outweighed by the benefits to consumers due to reduced number of adverse health reactions associated with consumption of lupin and lupin products and reduced financial and wellbeing costs to lupin sensitive individuals.
proposal_1026_-_lupin_as_an_allergen.docx