- Email: [email protected]
Lessons learned from providing a free nutrition labelling tool for industry—the Australian experience
ARTICLE IN PRESS
JOURNAL OF FOOD COMPOSITION AND ANALYSIS
Journal of Food Composition and Analysis 17 (2004) 565–574 www.elsevier.com/locate/jfca
Report
Lessons learned from providing a free nutrition labelling tool for industry—the Australian experience Judy Cunningham*, Luisa Trevisan, Gregory Milligan Evaluation & Surveillance Section, Food Standards Australia New Zealand, Modelling, PO Box 7186, Canberra BC 2610 Australia Received 23 June 2003; received in revised form 20 February 2004; accepted 2 March 2004
Abstract Food Standards Australia New Zealand (FSANZ) establishes a common set of food standards for use in two countries—Australia and New Zealand. These standards require, among other provisions, that almost all packaged foods carry a nutrition information panel containing information on the levels of energy, protein, fat, saturated fat, carbohydrate, sugars and sodium in 100 g and in a serving of the food. In 2001, FSANZ developed a free, web-based nutrition labelling tool to assist manufacturers to meet these nutrition labelling requirements. A customized database, containing nutrient information on consumer-ready foods, food additives and specialized food ingredients, was developed based on Australian national food composition tables. Detailed explanatory notes were prepared. After 18 months of operation, we have identified a number of areas where unforeseen issues have arisen: the difficulty of including reliable, representative data for specialized food ingredients; inadequate information technology infrastructure among users; lack of user knowledge about nutrients and foods; weak literacy and mathematical skills among some users; heavy demand for assistance from FSANZ staff; and the need to consider aspects of legal liability. The lessons learned by FSANZ in providing this labelling tool are relevant for other national food composition programs. Crown Copyright r 2004 Published by Elsevier Ltd. All rights reserved. Keywords: Nutrition labelling; Food composition data; Internet
*Corresponding author. Tel.: +61-2-6271-2213; fax: +61-2-6271-2290. E-mail address: [email protected] (J. Cunningham). 0889-1575/$ - see front matter Crown Copyright r 2004 Published by Elsevier Ltd. All rights reserved. doi:10.1016/j.jfca.2004.03.004
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1. Introduction Australia and New Zealand share a joint food-standards-setting system for labelling and determining the composition of foods. This joint system between the two nations was established under a Treaty that took effect in July 1996. A joint Australia New Zealand Food Standards Code (‘the Code’) was developed over a number of years (Food Standards Australia New Zealand, 2003). Since December 20, 2002, the two countries have shared the same set of standards for the labelling and composition of foods. One of the changes established in the Code was a mandatory requirement, under Standard 1.2.8 Nutrition Information, for nutrition information panels to be included on almost all packaged foods; previously this had been a voluntary requirement in both countries. This standard applies to foods sold in Australia or New Zealand, whether manufactured in these countries or imported from other countries, and aims to allow consumers to make informed choices when purchasing food. Under the joint Code, nutrition information panels must carry information on the average content of seven nutrients—energy (expressed in kilojoules and optionally in kilocalories), protein, total fat, saturated fat, carbohydrate (as either available carbohydrate or carbohydrate by difference), total sugars and sodium. Values must be expressed on both a per 100 g and per serving basis, with serving size determined by the manufacturer. Fig. 1 provides an example of a nutrition information panel that is used on food labels in Australia and New Zealand. The quantities of other nutrients, such as calcium, lactose or total omega 3 polyunsaturates, may be declared in the panel subject to certain requirements. Nutrition information labelling requirements vary greatly between countries. The Australian and New Zealand requirements for nutrition information panels were developed taking account of Codex Alimentarius requirements although Codex does not currently require declaration of sugars, saturated fats or sodium (Codex Alimentarius Commission, 1993). The Australian and New Zealand requirements are similar to those of the United Kingdom (European Council, 1990) but are substantially different from those of the United States (US Government, 2003) and
Fig. 1. Example of a nutrition information panel for packaged food, as required in Australia and New Zealand, including only the seven nutrients for which information must be included. Information on other nutrients or other biologically active substances may be included subject to certain conditions. Numerical values presented in nutrition information panels must include no more than three significant figures.
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Canada (Canadian Government, 2002); in Australia and New Zealand, inclusion of data for % Daily Values, trans fatty acids and cholesterol is not mandatory. At the time the Code came into being, FSANZ recognized that industry, particularly small industry, would need assistance with the preparation of nutrition information panels. Neither country had sufficient spare analytical capacity to enable all the myriad food products that would require panels to be analysed in the laboratory in a timely manner. As small industry was unlikely to be able to bear the costs of laboratory analysis in any case, a decision was therefore made to develop a free nutrition labelling tool. The challenge given to the food composition team at FSANZ was how to take the concept of a free nutrition labelling tool and prepare an easy to use, widely accessible product.
2. Methods and materials After much consideration it was agreed that an internet-based product was the solution to the requirement of ease and accessibility. A two-stage approach was required in developing this product—developing the supporting database and developing the software that allows values in this database to be used in recipe calculations. In the first stage of the project, a nutrient database known as AUSNUT Special Edition was developed based on an existing Australian food composition database developed for the most recent Australian National Nutrition Survey (NNS), which was conducted in 1995, together with some additional data on common industry ingredients and sodium-containing food additives. Compilation of AUSNUT Special Edition was not a simple task as the database from which it was developed did not contain any values for sodium. Sodium values therefore had to be derived for approximately 4000 foods, based on available Australian analytical data, calculation or imputation. This stage of the project drew heavily on food composition expertise within FSANZ. In the second stage of the project, a product now known as the Nutrition Panel Calculator (NPC) was developed. Two versions of the product, using two different programming languages, were developed to meet user needs and Australian government requirements for website accessibility for those who are visually impaired or have other disability-related software. This paper will focus on the latter version that will soon become the sole version of the NPC and which is based on Cold Fusion (Macromedia Inc.) programming. Because FSANZ does not have an inhouse programming capacity, it was necessary to employ contract programmers to carry out this work. The NPC is accessed through the FSANZ home page (www.foodstandards.gov.au). The introductory NPC screen is illustrated in Fig. 2. The NPC uses a recipe approach that allows users to search for and select the ingredients they require, input information on the amounts used, and adjust the nutrient profile to take into account moisture gain or loss during processing. It also has a facility where users can incorporate nutrient data for their own custom ingredients. The end product of the NPC is a printed image of the nutrition information panel ready for scanning into labels, together with information on the names and quantities of all ingredients used, which is kept for accountability purposes. For reasons of confidentiality, the NPC does not store recipe information and users must re-enter recipes if they make any changes to product formulation.
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Ingredient search Weights and servings
Nutrition Information Panel data
Fig. 2. Entry screen to the Nutrition Panel Calculator, a nutrition labelling tool developed to assist Australian and New Zealand industry comply with binational food standards.
Once the NPC was available on the website, on-line feedback forms were also developed, an enquiry email address ([email protected]) established and a comprehensive set of explanatory notes developed. User feedback has guided the production of further explanatory material and changes to AUSNUT Special Edition, outlined below. The process of developing, testing and implementing the Australian database and the software required the time of two staff members for approximately 18 months. The first version of the NPC was released in October 2001. In future it is hoped that a separate version of the NPC drawing on New Zealand food composition data, will be developed.
3. Results and discussion The NPC has been operational for over 18 months and has largely received very positive feedback, particularly from small business users. Although we have not logged all use of the NPC we estimate that it is accessed approximately 2000 times per month. Not all NPC users are from the food industry and some are from countries other than Australia and New Zealand. FSANZ has learned a number of important lessons from the operation of the NPC that are likely to be relevant to other countries contemplating providing a similar product. These lessons are outlined below.
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3.1. Difficulties in including the foods required by industry users National food composition databases are prepared for a number of reasons, but most of these reasons relate to the assessment of daily nutrient intake. Therefore most national databases, including Australia’s, contain information on basic foods available at retail level or on finished, ready-to-eat products. This is often not the information that the food industry needs when preparing nutrition information for its own particular products. While the food industry needs information on basic foods such as eggs, milk and butter, they also need information on food additives, specialized ingredients such as modified starches and various grades of basic foods, such as ground beef supplied with a range of specified fat contents, or wheat flour supplied at set protein contents. Early in the process of developing AUSNUT Special Edition popular brands of foods available in supermarkets were surveyed to identify the most common food additives and specialty ingredients. Nutrient data were developed for non-retail ingredients such as maltodextrin and dextrin roasted starch (additive number 1412), from literature information and from information supplied by Australian industry. These ingredients were included because they may be present at relatively high proportions in the finished foods and therefore have the potential to make a substantial impact on the overall nutrient profile of the finished food. Food additives were included in the database only where the additive contained sodium and therefore its use, even though representing a small proportion of the final food, could potentially increase overall sodium content. Eight common sodium-containing additives, including sodium metabisulphite (223), sodium benzoate (211), sodium nitrite (250) and sodium nitrate (251), were included to the database. However this process overlooked many common food ingredients and food additives. For example in Australia, commercial bakers often do not work from basic ingredients such as wheat flour, yeast, salt and water, but are supplied with pre-mixed ingredients such that a specialty grade of flour of set protein content is mixed with a bag of pre-mix and a set amount of water. Similarly, butchers making sausages mix set amounts of ground meat and fat with a premix that contains all the flavour and preservative ingredients required. FSANZ received numerous requests from butchers and bakers for nutrient data for the particular premix they use, a request FSANZ could not fulfil. The only solution identified to date for dealing with the specialty premix market is to refer food manufacturers to their ingredient supplier for the required information, which can then be incorporated into their recipe using the NPC’s custom ingredient facility. In the early days of the NPC this lack of data caused problems for users as many ingredient suppliers did not hold information on the seven nutrients that must be declared. In some cases the only information supplied was technical specifications such as moisture loss on drying. At other times all that was available was nutrient data generated in another country, typically the United States, which did not include all the information required in Australia and New Zealand. Although suppliers now seem to be aware of the importance of providing their clients with the information they need, FSANZ is in the process of developing additional information on more common ingredients. The next release of AUSNUT Special Edition will contain information on a range of colours, starches, preservatives and fibrous ingredients. The greatest knowledge gap now is for comprehensive nutrient data for spices. At present AUSNUT Special Edition only contains information for chilli, pepper, curry powder and mixed
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spice, a list that will be expanded slightly for the next data release. In a ready-to-eat food a spice will typically be present only at nutritionally insignificant levels. However in a product such as a spice paste, where a particular spice may represent up to 50% of the product presented for sale, it is obviously important for the user to be able to access reputable nutrient data for particular spices. The only feasible option for these manufacturers is to use the USDA (2002) nutrient database. Australia is a multicultural society and many small businesses import or manufacture foods using ingredients common in their homeland but for which FSANZ holds no nutrient information. There is also a fledgling industry using indigenous ingredients such as wattle seeds, which are currently not included in AUSNUT Special Edition. In future analytical programs we hope to include some additional foods to go some way to satisfying these needs. Under the nutrient definitions established in the Code, there are a large number of ingredients that will not make any significant contribution to the content of the seven nutrients that must be declared. These ingredients include buffering agents, calcium- and potassium- containing additives, and gums. It was therefore decided early in the development process not to include such ingredients in AUSNUT Special Edition. This overlooked two important considerations. The first was the desire of industry to satisfy themselves that they had fulfilled their duty of care to their clients by incorporating information on all ingredients they used, whether or not they have any nutritional significance. The second consideration was that, when sufficient quantities of these non-nutritive ingredients are included in a food, they have the effect of diluting the calculated nutrient profile. For example, if a food contains 2% vegetable gum and 2% citric acid and 1% other additives, this represents 5% of the finished product and therefore omission of these ingredients from a recipe essentially overstates the declared nutrient profile by around 5%. The naming of foods in a database is crucial to its correct use. Because AUSNUT Special Edition draws on information on consumer-ready foods, the names and descriptions used often make no mention of the names commonly used in industry. For example, it includes information on glucose powder and syrup, but these products are often supplied under the name ‘dextrose’. AUSNUT Special Edition uses a coding system that divides foods into major classes (e.g., milk, fats and spreads, confectionery) and then assigns a unique identifier within that class. A food called simply ‘honeycomb’ can be identified, from its coding system, as a confectionery product and is the sweet, chewy product made from sugar, syrup and raising agents. It is not the waxy structure of the beehive that is sometimes sold under the same name, but users who are not familiar with the coding system have used this line incorrectly. This highlights the importance of using relevant, unambiguous naming and description systems in labelling databases. 3.2. Requirement for adequate information technology systems Both the providing organization and users need adequate information technology systems to enable on-line access. This has been a significant stumbling block for the NPC and the source of about half of user complaints. When FSANZ first launched the NPC, the organization’s website operated using a very narrow bandwidth connection that could transfer only 128 kB of information per second. This was adequate for a website receiving little use or where only very small parcels of information are transferred at any time. It was inadequate for the demands placed on it by users of the NPC.
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Users accessed the NPC and then found it could take minutes to perform a single search operation. When compilation of a recipe entails multiple operations, users found it was taking them sometimes an hour to complete a single recipe, which is obviously unsatisfactory. Eventually FSANZ upgraded its Internet connection and this has eliminated a large number of complaints. However in Australia many Internet users still access the Internet through a modem, which is typically a 56 kB modem at the domestic or small business level. This makes the use of the NPC to develop nutrition information panels for a large number of multi-ingredient products a very slow process. A further impediment for these users is that they cannot telephone for assistance while using the NPC as the modem uses their telephone line unless a separate line has been installed. 3.3. Some users lack knowledge about nutrients and foods Small businesses in Australia are those with fewer than twenty employees (Australian Bureau of Statistics, 2002). In many of these companies, employees will not have specialist skills in nutrition or food science. Although the NPC was developed so that it is easy to use, there are some instances where users need an understanding of how processing impacts on nutrient levels in order to use it correctly. This is particularly the case where users need to identify the situations where use of the NPC is not suitable for their product. For example, a company making meat-filled pastries fried in a blended, hydrogenated frying fat needs to understand that it may not be possible to use the NPC to accurately estimate the fat and saturated fat content of their food because it can be difficult to estimate fat uptake during frying. Frequently users advise that they have no concept of what the nutrient levels in their product should be so they cannot judge whether or not the values they have developed using the NPC are appropriate. In the explanatory notes we have attempted to provide detailed information to users outlining the limitations of the NPC and the times when laboratory analysis is the only feasible option, as well as some information on how to judge the values they develop using the NPC. There is also a level of misinformation about nutrients that impedes NPC use. For example, some users believe that the NPC contains misleading information because it presents values for the saturated fat content of olive oil and almonds, for example, whereas some users believe that these foods contain only monounsaturated or polyunsaturated fats. There may be a small number of users who simply choose not to use the NPC to prepare their nutrition information panels because the data it contains do not support their preconceived ideas of what is in their products. 3.4. Some users will have weak literacy and mathematical skills Many Australian small businesses that use the NPC can really be considered ‘micro’ businesses, as they have no employees or are a partnership between two people. Many NPC users are small growers selling a range of home-produced foods such as jams at local markets, or operate a parttime business to help provide additional family income, or are from a non-English speaking background manufacturing the foods of their homeland. A small proportion of these and other NPC users may not have strong literacy and mathematical skills and because their business is very small they do not have colleagues to assist them by providing these skills. If a user does not have good literacy skills, it is difficult to read the instructions supplied with the NPC. If a user does not know how to spell the names of ingredients, he or she cannot search for them on the NPC. In a
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recent development FSANZ has attempted to overcome these problems by developing a new set of instructions that use language appropriate to a reading age of around 12 years, whereas previous instructions were unintentionally written for users whose language skills were closer to those of a university graduate. Alternative spellings of ingredients have also been incorporated into the searchable fields. One major problem with providing on-line assistance to NPC users is the information technology skills needed to, for example, open an Adobe PDF file. While this may surprise most food composition professionals, some NPC users have never previously used a computer until required to develop a nutrition information panel for their products. In 2001, almost one-third of small businesses in Australia were operated by people aged over 50 years and many of these people will not have had the benefit of training or experience in the use of computers during their formal education. These users may be frightened of using a computer and would prefer to have a paper-based labelling product. In some cases the easiest way for these people to use the NPC is to suggest that they ask their grandchildren or neighbour’s children to help them with the computer. For some users FSANZ suggests they visit their local public library for assistance with the Internet or to provide access to a computer for those who do not own one. However many of our users live in rural areas where the closest library may be over 100 km away. While there has been strong growth in the number of small Australian businesses using computers in recent years, in June 2001 one third of small businesses still did not use computers and only just over half of small businesses used the Internet (Australian Bureau of Statistics, 2002). By making the assumption that Australian small businesses are willing and able to use information technology resources, FSANZ failed to address the needs of a significant proportion of our client base. NPC users also require a degree of skill in manipulating numbers, even though the NPC performs most of the required calculations. For example, users can enter information on the proportions of their ingredients by entering the actual mass or volume used, in grams, kilograms, millilitres or litres; if they choose, users could enter quantities simply as a percentage of the recipe. Inevitably there are users who use a mixture of the two and fail to recognize the problem that results (for example, a user may enter a recipe calling for 2 kg of flour and 2% gluten as 2 kg flour and 2 g gluten instead of 40 g gluten). There are some users who wish to enter information in cups, or teaspoons, or even in bags of flour. For some of these users, working out how to convert two cups of oil into a mass or volume measure is an arithmetic exercise that they do not feel comfortable doing, particularly while simultaneously coping with an unfamiliar computer. 3.5. Demand for assistance Given the identified shortcomings in the AUSNUT Special Edition database and sometimes the lack of user skills, there has been heavy user demand on FSANZ staff for assistance with preparation of nutrition information panels. At one stage, dealing with this demand was fully occupying two staff members out of a team of only 2.5 people and at present we estimate it requires the equivalent of one full time staff member. Apart from detracting from the ability of staff to undertake other activities, constantly dealing with user problems and criticism impacts on staff morale.
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3.6. Legal liability With the NPC, FSANZ provided a tool specifically designed to assist industry comply with regulatory requirements. It was therefore necessary to carefully consider issues of the legal liability of both FSANZ and users. An extensive disclaimer is provided at the entry point to the NPC and users are alerted to legal provisions in Australia and New Zealand that relate to diligence and to defences against failure to comply with standards. Extensive information is provided on the limitations of the NPC and the situations under which it is recommended that companies send their products for laboratory analysis. The development of the NPC has highlighted the importance of scientists working together with lawyers when developing food composition databases and their supporting educational materials. 3.7. Lessons learnt from the development of the NPC The development of the NPC has taught FSANZ a number of important lessons that are relevant for future Australian food composition publications and for other countries’ national food composition programs: *
*
*
*
*
when developing a nutrition labelling tool, establish a multi-disciplinary project team that includes lawyers, information technology specialists and communications specialists; identify user needs and develop a database to match these needs, rather than trying to fit user needs to existing data sources; do not overestimate user skills and ensure that educational material is presented in simple, nontechnical language; provide sufficient staff to deal with user queries and train these staff to deal with difficult problems; and review progress frequently and provide regular enhancements based on user feedback.
4. Conclusion The NPC has enabled small food manufacturers, in particular, to meet regulatory requirements at a minimal cost and has led to increased recognition of the importance and practical use of food composition data.
References Australian Bureau of Statistics, 2002. Characteristics of small business. Australian Bureau of Statistics, Canberra, Catalogue No. 8127. Canadian Government, 2002. Regulations Amending the Food and Drug Regulations (Nutrition Labelling, Nutrient Content Claims and Health Claims). Retrieved 1 April 2004 from the Canada Gazette Home Page on the World Wide Web: http://canadagazette.gc.ca/partll/2003/20030101/html/sor11-e.html. Codex Alimentarius Commission, 1993. Codex Guidelines on Nutrition Labelling. CAC/GL 2-1985 (Rev. 1-1993). Retrieved 1 April 2004 from the Codex Alimentarius Home Page on the World Wide Web: ftp://ftp.fao.org/codex/ standard/en/CXG 002e.pdf.
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European Council, 1990. Council Directive 90/496/EEC on nutrition labelling for foodstuffs of 24 September 1990. Official Journal of the European Communities L276 of October 1990. Luxembourg: EC, 40–44. Food Standards Australia New Zealand, 2003. Food Standards Code. Vol. 2. FSANZ, Canberra. US Department of Agriculture, Agricultural Research Service (USDA), 2002. USDA National Nutrient Database for Standard Reference, Release 15. Retrieved 3 June 2003 from the Nutrient Data Laboratory Home Page on the World Wide Web: http://www.nal.usda.gov/fnic/foodcomp. US Government, 2003. Code of Federal Regulations, 21CFR 101.9. US Government Printing Office. Retrieved 1 April 2004 from the Food and Drug Administration Home Page on the World Wide Web: http://www.accessdata.fda.gov/ scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?FR=101.9.
JOURNAL OF FOOD COMPOSITION AND ANALYSIS
Journal of Food Composition and Analysis 17 (2004) 565–574 www.elsevier.com/locate/jfca
Report
Lessons learned from providing a free nutrition labelling tool for industry—the Australian experience Judy Cunningham*, Luisa Trevisan, Gregory Milligan Evaluation & Surveillance Section, Food Standards Australia New Zealand, Modelling, PO Box 7186, Canberra BC 2610 Australia Received 23 June 2003; received in revised form 20 February 2004; accepted 2 March 2004
Abstract Food Standards Australia New Zealand (FSANZ) establishes a common set of food standards for use in two countries—Australia and New Zealand. These standards require, among other provisions, that almost all packaged foods carry a nutrition information panel containing information on the levels of energy, protein, fat, saturated fat, carbohydrate, sugars and sodium in 100 g and in a serving of the food. In 2001, FSANZ developed a free, web-based nutrition labelling tool to assist manufacturers to meet these nutrition labelling requirements. A customized database, containing nutrient information on consumer-ready foods, food additives and specialized food ingredients, was developed based on Australian national food composition tables. Detailed explanatory notes were prepared. After 18 months of operation, we have identified a number of areas where unforeseen issues have arisen: the difficulty of including reliable, representative data for specialized food ingredients; inadequate information technology infrastructure among users; lack of user knowledge about nutrients and foods; weak literacy and mathematical skills among some users; heavy demand for assistance from FSANZ staff; and the need to consider aspects of legal liability. The lessons learned by FSANZ in providing this labelling tool are relevant for other national food composition programs. Crown Copyright r 2004 Published by Elsevier Ltd. All rights reserved. Keywords: Nutrition labelling; Food composition data; Internet
*Corresponding author. Tel.: +61-2-6271-2213; fax: +61-2-6271-2290. E-mail address: [email protected] (J. Cunningham). 0889-1575/$ - see front matter Crown Copyright r 2004 Published by Elsevier Ltd. All rights reserved. doi:10.1016/j.jfca.2004.03.004
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1. Introduction Australia and New Zealand share a joint food-standards-setting system for labelling and determining the composition of foods. This joint system between the two nations was established under a Treaty that took effect in July 1996. A joint Australia New Zealand Food Standards Code (‘the Code’) was developed over a number of years (Food Standards Australia New Zealand, 2003). Since December 20, 2002, the two countries have shared the same set of standards for the labelling and composition of foods. One of the changes established in the Code was a mandatory requirement, under Standard 1.2.8 Nutrition Information, for nutrition information panels to be included on almost all packaged foods; previously this had been a voluntary requirement in both countries. This standard applies to foods sold in Australia or New Zealand, whether manufactured in these countries or imported from other countries, and aims to allow consumers to make informed choices when purchasing food. Under the joint Code, nutrition information panels must carry information on the average content of seven nutrients—energy (expressed in kilojoules and optionally in kilocalories), protein, total fat, saturated fat, carbohydrate (as either available carbohydrate or carbohydrate by difference), total sugars and sodium. Values must be expressed on both a per 100 g and per serving basis, with serving size determined by the manufacturer. Fig. 1 provides an example of a nutrition information panel that is used on food labels in Australia and New Zealand. The quantities of other nutrients, such as calcium, lactose or total omega 3 polyunsaturates, may be declared in the panel subject to certain requirements. Nutrition information labelling requirements vary greatly between countries. The Australian and New Zealand requirements for nutrition information panels were developed taking account of Codex Alimentarius requirements although Codex does not currently require declaration of sugars, saturated fats or sodium (Codex Alimentarius Commission, 1993). The Australian and New Zealand requirements are similar to those of the United Kingdom (European Council, 1990) but are substantially different from those of the United States (US Government, 2003) and
Fig. 1. Example of a nutrition information panel for packaged food, as required in Australia and New Zealand, including only the seven nutrients for which information must be included. Information on other nutrients or other biologically active substances may be included subject to certain conditions. Numerical values presented in nutrition information panels must include no more than three significant figures.
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Canada (Canadian Government, 2002); in Australia and New Zealand, inclusion of data for % Daily Values, trans fatty acids and cholesterol is not mandatory. At the time the Code came into being, FSANZ recognized that industry, particularly small industry, would need assistance with the preparation of nutrition information panels. Neither country had sufficient spare analytical capacity to enable all the myriad food products that would require panels to be analysed in the laboratory in a timely manner. As small industry was unlikely to be able to bear the costs of laboratory analysis in any case, a decision was therefore made to develop a free nutrition labelling tool. The challenge given to the food composition team at FSANZ was how to take the concept of a free nutrition labelling tool and prepare an easy to use, widely accessible product.
2. Methods and materials After much consideration it was agreed that an internet-based product was the solution to the requirement of ease and accessibility. A two-stage approach was required in developing this product—developing the supporting database and developing the software that allows values in this database to be used in recipe calculations. In the first stage of the project, a nutrient database known as AUSNUT Special Edition was developed based on an existing Australian food composition database developed for the most recent Australian National Nutrition Survey (NNS), which was conducted in 1995, together with some additional data on common industry ingredients and sodium-containing food additives. Compilation of AUSNUT Special Edition was not a simple task as the database from which it was developed did not contain any values for sodium. Sodium values therefore had to be derived for approximately 4000 foods, based on available Australian analytical data, calculation or imputation. This stage of the project drew heavily on food composition expertise within FSANZ. In the second stage of the project, a product now known as the Nutrition Panel Calculator (NPC) was developed. Two versions of the product, using two different programming languages, were developed to meet user needs and Australian government requirements for website accessibility for those who are visually impaired or have other disability-related software. This paper will focus on the latter version that will soon become the sole version of the NPC and which is based on Cold Fusion (Macromedia Inc.) programming. Because FSANZ does not have an inhouse programming capacity, it was necessary to employ contract programmers to carry out this work. The NPC is accessed through the FSANZ home page (www.foodstandards.gov.au). The introductory NPC screen is illustrated in Fig. 2. The NPC uses a recipe approach that allows users to search for and select the ingredients they require, input information on the amounts used, and adjust the nutrient profile to take into account moisture gain or loss during processing. It also has a facility where users can incorporate nutrient data for their own custom ingredients. The end product of the NPC is a printed image of the nutrition information panel ready for scanning into labels, together with information on the names and quantities of all ingredients used, which is kept for accountability purposes. For reasons of confidentiality, the NPC does not store recipe information and users must re-enter recipes if they make any changes to product formulation.
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Ingredient search Weights and servings
Nutrition Information Panel data
Fig. 2. Entry screen to the Nutrition Panel Calculator, a nutrition labelling tool developed to assist Australian and New Zealand industry comply with binational food standards.
Once the NPC was available on the website, on-line feedback forms were also developed, an enquiry email address ([email protected]) established and a comprehensive set of explanatory notes developed. User feedback has guided the production of further explanatory material and changes to AUSNUT Special Edition, outlined below. The process of developing, testing and implementing the Australian database and the software required the time of two staff members for approximately 18 months. The first version of the NPC was released in October 2001. In future it is hoped that a separate version of the NPC drawing on New Zealand food composition data, will be developed.
3. Results and discussion The NPC has been operational for over 18 months and has largely received very positive feedback, particularly from small business users. Although we have not logged all use of the NPC we estimate that it is accessed approximately 2000 times per month. Not all NPC users are from the food industry and some are from countries other than Australia and New Zealand. FSANZ has learned a number of important lessons from the operation of the NPC that are likely to be relevant to other countries contemplating providing a similar product. These lessons are outlined below.
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3.1. Difficulties in including the foods required by industry users National food composition databases are prepared for a number of reasons, but most of these reasons relate to the assessment of daily nutrient intake. Therefore most national databases, including Australia’s, contain information on basic foods available at retail level or on finished, ready-to-eat products. This is often not the information that the food industry needs when preparing nutrition information for its own particular products. While the food industry needs information on basic foods such as eggs, milk and butter, they also need information on food additives, specialized ingredients such as modified starches and various grades of basic foods, such as ground beef supplied with a range of specified fat contents, or wheat flour supplied at set protein contents. Early in the process of developing AUSNUT Special Edition popular brands of foods available in supermarkets were surveyed to identify the most common food additives and specialty ingredients. Nutrient data were developed for non-retail ingredients such as maltodextrin and dextrin roasted starch (additive number 1412), from literature information and from information supplied by Australian industry. These ingredients were included because they may be present at relatively high proportions in the finished foods and therefore have the potential to make a substantial impact on the overall nutrient profile of the finished food. Food additives were included in the database only where the additive contained sodium and therefore its use, even though representing a small proportion of the final food, could potentially increase overall sodium content. Eight common sodium-containing additives, including sodium metabisulphite (223), sodium benzoate (211), sodium nitrite (250) and sodium nitrate (251), were included to the database. However this process overlooked many common food ingredients and food additives. For example in Australia, commercial bakers often do not work from basic ingredients such as wheat flour, yeast, salt and water, but are supplied with pre-mixed ingredients such that a specialty grade of flour of set protein content is mixed with a bag of pre-mix and a set amount of water. Similarly, butchers making sausages mix set amounts of ground meat and fat with a premix that contains all the flavour and preservative ingredients required. FSANZ received numerous requests from butchers and bakers for nutrient data for the particular premix they use, a request FSANZ could not fulfil. The only solution identified to date for dealing with the specialty premix market is to refer food manufacturers to their ingredient supplier for the required information, which can then be incorporated into their recipe using the NPC’s custom ingredient facility. In the early days of the NPC this lack of data caused problems for users as many ingredient suppliers did not hold information on the seven nutrients that must be declared. In some cases the only information supplied was technical specifications such as moisture loss on drying. At other times all that was available was nutrient data generated in another country, typically the United States, which did not include all the information required in Australia and New Zealand. Although suppliers now seem to be aware of the importance of providing their clients with the information they need, FSANZ is in the process of developing additional information on more common ingredients. The next release of AUSNUT Special Edition will contain information on a range of colours, starches, preservatives and fibrous ingredients. The greatest knowledge gap now is for comprehensive nutrient data for spices. At present AUSNUT Special Edition only contains information for chilli, pepper, curry powder and mixed
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spice, a list that will be expanded slightly for the next data release. In a ready-to-eat food a spice will typically be present only at nutritionally insignificant levels. However in a product such as a spice paste, where a particular spice may represent up to 50% of the product presented for sale, it is obviously important for the user to be able to access reputable nutrient data for particular spices. The only feasible option for these manufacturers is to use the USDA (2002) nutrient database. Australia is a multicultural society and many small businesses import or manufacture foods using ingredients common in their homeland but for which FSANZ holds no nutrient information. There is also a fledgling industry using indigenous ingredients such as wattle seeds, which are currently not included in AUSNUT Special Edition. In future analytical programs we hope to include some additional foods to go some way to satisfying these needs. Under the nutrient definitions established in the Code, there are a large number of ingredients that will not make any significant contribution to the content of the seven nutrients that must be declared. These ingredients include buffering agents, calcium- and potassium- containing additives, and gums. It was therefore decided early in the development process not to include such ingredients in AUSNUT Special Edition. This overlooked two important considerations. The first was the desire of industry to satisfy themselves that they had fulfilled their duty of care to their clients by incorporating information on all ingredients they used, whether or not they have any nutritional significance. The second consideration was that, when sufficient quantities of these non-nutritive ingredients are included in a food, they have the effect of diluting the calculated nutrient profile. For example, if a food contains 2% vegetable gum and 2% citric acid and 1% other additives, this represents 5% of the finished product and therefore omission of these ingredients from a recipe essentially overstates the declared nutrient profile by around 5%. The naming of foods in a database is crucial to its correct use. Because AUSNUT Special Edition draws on information on consumer-ready foods, the names and descriptions used often make no mention of the names commonly used in industry. For example, it includes information on glucose powder and syrup, but these products are often supplied under the name ‘dextrose’. AUSNUT Special Edition uses a coding system that divides foods into major classes (e.g., milk, fats and spreads, confectionery) and then assigns a unique identifier within that class. A food called simply ‘honeycomb’ can be identified, from its coding system, as a confectionery product and is the sweet, chewy product made from sugar, syrup and raising agents. It is not the waxy structure of the beehive that is sometimes sold under the same name, but users who are not familiar with the coding system have used this line incorrectly. This highlights the importance of using relevant, unambiguous naming and description systems in labelling databases. 3.2. Requirement for adequate information technology systems Both the providing organization and users need adequate information technology systems to enable on-line access. This has been a significant stumbling block for the NPC and the source of about half of user complaints. When FSANZ first launched the NPC, the organization’s website operated using a very narrow bandwidth connection that could transfer only 128 kB of information per second. This was adequate for a website receiving little use or where only very small parcels of information are transferred at any time. It was inadequate for the demands placed on it by users of the NPC.
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Users accessed the NPC and then found it could take minutes to perform a single search operation. When compilation of a recipe entails multiple operations, users found it was taking them sometimes an hour to complete a single recipe, which is obviously unsatisfactory. Eventually FSANZ upgraded its Internet connection and this has eliminated a large number of complaints. However in Australia many Internet users still access the Internet through a modem, which is typically a 56 kB modem at the domestic or small business level. This makes the use of the NPC to develop nutrition information panels for a large number of multi-ingredient products a very slow process. A further impediment for these users is that they cannot telephone for assistance while using the NPC as the modem uses their telephone line unless a separate line has been installed. 3.3. Some users lack knowledge about nutrients and foods Small businesses in Australia are those with fewer than twenty employees (Australian Bureau of Statistics, 2002). In many of these companies, employees will not have specialist skills in nutrition or food science. Although the NPC was developed so that it is easy to use, there are some instances where users need an understanding of how processing impacts on nutrient levels in order to use it correctly. This is particularly the case where users need to identify the situations where use of the NPC is not suitable for their product. For example, a company making meat-filled pastries fried in a blended, hydrogenated frying fat needs to understand that it may not be possible to use the NPC to accurately estimate the fat and saturated fat content of their food because it can be difficult to estimate fat uptake during frying. Frequently users advise that they have no concept of what the nutrient levels in their product should be so they cannot judge whether or not the values they have developed using the NPC are appropriate. In the explanatory notes we have attempted to provide detailed information to users outlining the limitations of the NPC and the times when laboratory analysis is the only feasible option, as well as some information on how to judge the values they develop using the NPC. There is also a level of misinformation about nutrients that impedes NPC use. For example, some users believe that the NPC contains misleading information because it presents values for the saturated fat content of olive oil and almonds, for example, whereas some users believe that these foods contain only monounsaturated or polyunsaturated fats. There may be a small number of users who simply choose not to use the NPC to prepare their nutrition information panels because the data it contains do not support their preconceived ideas of what is in their products. 3.4. Some users will have weak literacy and mathematical skills Many Australian small businesses that use the NPC can really be considered ‘micro’ businesses, as they have no employees or are a partnership between two people. Many NPC users are small growers selling a range of home-produced foods such as jams at local markets, or operate a parttime business to help provide additional family income, or are from a non-English speaking background manufacturing the foods of their homeland. A small proportion of these and other NPC users may not have strong literacy and mathematical skills and because their business is very small they do not have colleagues to assist them by providing these skills. If a user does not have good literacy skills, it is difficult to read the instructions supplied with the NPC. If a user does not know how to spell the names of ingredients, he or she cannot search for them on the NPC. In a
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recent development FSANZ has attempted to overcome these problems by developing a new set of instructions that use language appropriate to a reading age of around 12 years, whereas previous instructions were unintentionally written for users whose language skills were closer to those of a university graduate. Alternative spellings of ingredients have also been incorporated into the searchable fields. One major problem with providing on-line assistance to NPC users is the information technology skills needed to, for example, open an Adobe PDF file. While this may surprise most food composition professionals, some NPC users have never previously used a computer until required to develop a nutrition information panel for their products. In 2001, almost one-third of small businesses in Australia were operated by people aged over 50 years and many of these people will not have had the benefit of training or experience in the use of computers during their formal education. These users may be frightened of using a computer and would prefer to have a paper-based labelling product. In some cases the easiest way for these people to use the NPC is to suggest that they ask their grandchildren or neighbour’s children to help them with the computer. For some users FSANZ suggests they visit their local public library for assistance with the Internet or to provide access to a computer for those who do not own one. However many of our users live in rural areas where the closest library may be over 100 km away. While there has been strong growth in the number of small Australian businesses using computers in recent years, in June 2001 one third of small businesses still did not use computers and only just over half of small businesses used the Internet (Australian Bureau of Statistics, 2002). By making the assumption that Australian small businesses are willing and able to use information technology resources, FSANZ failed to address the needs of a significant proportion of our client base. NPC users also require a degree of skill in manipulating numbers, even though the NPC performs most of the required calculations. For example, users can enter information on the proportions of their ingredients by entering the actual mass or volume used, in grams, kilograms, millilitres or litres; if they choose, users could enter quantities simply as a percentage of the recipe. Inevitably there are users who use a mixture of the two and fail to recognize the problem that results (for example, a user may enter a recipe calling for 2 kg of flour and 2% gluten as 2 kg flour and 2 g gluten instead of 40 g gluten). There are some users who wish to enter information in cups, or teaspoons, or even in bags of flour. For some of these users, working out how to convert two cups of oil into a mass or volume measure is an arithmetic exercise that they do not feel comfortable doing, particularly while simultaneously coping with an unfamiliar computer. 3.5. Demand for assistance Given the identified shortcomings in the AUSNUT Special Edition database and sometimes the lack of user skills, there has been heavy user demand on FSANZ staff for assistance with preparation of nutrition information panels. At one stage, dealing with this demand was fully occupying two staff members out of a team of only 2.5 people and at present we estimate it requires the equivalent of one full time staff member. Apart from detracting from the ability of staff to undertake other activities, constantly dealing with user problems and criticism impacts on staff morale.
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3.6. Legal liability With the NPC, FSANZ provided a tool specifically designed to assist industry comply with regulatory requirements. It was therefore necessary to carefully consider issues of the legal liability of both FSANZ and users. An extensive disclaimer is provided at the entry point to the NPC and users are alerted to legal provisions in Australia and New Zealand that relate to diligence and to defences against failure to comply with standards. Extensive information is provided on the limitations of the NPC and the situations under which it is recommended that companies send their products for laboratory analysis. The development of the NPC has highlighted the importance of scientists working together with lawyers when developing food composition databases and their supporting educational materials. 3.7. Lessons learnt from the development of the NPC The development of the NPC has taught FSANZ a number of important lessons that are relevant for future Australian food composition publications and for other countries’ national food composition programs: *
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when developing a nutrition labelling tool, establish a multi-disciplinary project team that includes lawyers, information technology specialists and communications specialists; identify user needs and develop a database to match these needs, rather than trying to fit user needs to existing data sources; do not overestimate user skills and ensure that educational material is presented in simple, nontechnical language; provide sufficient staff to deal with user queries and train these staff to deal with difficult problems; and review progress frequently and provide regular enhancements based on user feedback.
4. Conclusion The NPC has enabled small food manufacturers, in particular, to meet regulatory requirements at a minimal cost and has led to increased recognition of the importance and practical use of food composition data.
References Australian Bureau of Statistics, 2002. Characteristics of small business. Australian Bureau of Statistics, Canberra, Catalogue No. 8127. Canadian Government, 2002. Regulations Amending the Food and Drug Regulations (Nutrition Labelling, Nutrient Content Claims and Health Claims). Retrieved 1 April 2004 from the Canada Gazette Home Page on the World Wide Web: http://canadagazette.gc.ca/partll/2003/20030101/html/sor11-e.html. Codex Alimentarius Commission, 1993. Codex Guidelines on Nutrition Labelling. CAC/GL 2-1985 (Rev. 1-1993). Retrieved 1 April 2004 from the Codex Alimentarius Home Page on the World Wide Web: ftp://ftp.fao.org/codex/ standard/en/CXG 002e.pdf.
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European Council, 1990. Council Directive 90/496/EEC on nutrition labelling for foodstuffs of 24 September 1990. Official Journal of the European Communities L276 of October 1990. Luxembourg: EC, 40–44. Food Standards Australia New Zealand, 2003. Food Standards Code. Vol. 2. FSANZ, Canberra. US Department of Agriculture, Agricultural Research Service (USDA), 2002. USDA National Nutrient Database for Standard Reference, Release 15. Retrieved 3 June 2003 from the Nutrient Data Laboratory Home Page on the World Wide Web: http://www.nal.usda.gov/fnic/foodcomp. US Government, 2003. Code of Federal Regulations, 21CFR 101.9. US Government Printing Office. Retrieved 1 April 2004 from the Food and Drug Administration Home Page on the World Wide Web: http://www.accessdata.fda.gov/ scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?FR=101.9.