CE’s column: Consultation produces better rules

December 2008

The weather pundits are predicting a long, hot, dry summer. While this is great news for those of us planning a beach holiday, unfortunately it also means ideal conditions for the production of toxic honey.

Last Easter 22 people were very sick, some ending up in hospital, after an outbreak of tutin honey poisoning in the Coromandel. In the right climatic conditions honey bees gather tutin-laden honeydew secreted by vine-hoppers feeding on the native tutu bush. Tutin is highly toxic to humans and as little as 1 teaspoon (approximately 10ml) of toxic honey can badly affect the human nervous system. Symptoms include vomiting, delirium, giddiness, increased excitability, stupor, coma and violent convulsions, and it can be lethal. Since records began in New Zealand in 1889 there have been many people who died or were incapacitated and hospitalised from eating tutin in honey.

So, if it is so poisonous, why haven’t there been greater controls before now? The situation hasn’t been entirely unregulated. Under the Food Act all food sold to the public must be safe to eat. The Animal Products Act requires beekeepers to manage the risk of their honey containing tutin either by removing hives and honey frames containing honey for human consumption before the risk period, or by closely monitoring the tutu, vine-hopper and foraging conditions in the 3 km radius around the apiary while honey is being produced.

‘Institutional knowledge’ by beekeepers has meant the industry has been alert to the risk and has managed it voluntarily for the domestic market, with mandatory controls applying only to exported products.

Until the 22 cases in March this year the last reported case was one person hospitalised in 1991. Before that there was a single incident in 1984, but several more cases each decade prior to that. The reported deaths were all before 1918.

Because the tutu plant is only found in New Zealand, tutin poisoning doesn’t occur anywhere else, and there is little science on the toxin. Since the 2008 poisonings NZFSA has collected enough scientific data on which to base a maximum safe level of tutin in honey sold for human consumption. We’ve established that the maximum level of tutin in extracted honey should be 2 milligrams per kilogram, and in comb honey just 0.1 milligrams per kilogram. Comb honey is potentially more risky than extracted honey because any toxin present may be concentrated in small parts of the comb. Those levels are now contained in a new standard which applies to beekeepers, packers and exporters producing honey commercially, no matter where it is sold.

I wanted to talk about the tutin honey standard in this column because it’s timely, but also because it’s a useful example of the benefits of the consultation that NZFSA undertakes regularly on all manner of issues that affect New Zealand businesses and consumers.

Consultation won’t always lead to consensus. Some issues will be controversial and some positions are firmly entrenched regardless of the science, as Dr Stuart Slorach noted when he referred to the aspartame debate in his September report on NZFSA’s risk management processes. At NZFSA, we’re determined that consultation adds value; that it is approached with an open mind and is not a charade. Excessive consultation is a form of procrastination and should not be used as a substitute for decision-making. Effective consultation occurs when it gives stakeholders and regulators the opportunity to understand other viewpoints and when participants are prepared to move in light of new information or evidence. At the end of the day accountability for the decision rests with us, the regulator. NZFSA is the ultimate authority when it comes to setting the rules to ensure the safety of food eaten by the public. We set those rules by looking at the scientific data and weighing up the risks.

But the value of consultation in the tutin honey case is that the scientists and regulators here at NZFSA don’t necessarily understand how beekeepers (or any industry group) run their business. We can only gain an understanding of the options by consulting with those who work every day with the product and can help us find the best ways to ensure the integrity of their product and the safety of their customers. There might be more than one way to deal with an issue and we can only understand all the options when we consult with an open mind. In effect, we take the science to the users. They then have the opportunity to apply their knowledge of the business (or hobby) to suggest practical solutions that mitigate risks and ensure the safety of the food they produce.

NZFSA’s own consultation and participation guidelines identify the need for stakeholders to be involved as much as possible in any process, such as setting a standard, which results in decisions to provide an appropriate level of protection. We want consultation to be a two-way street – where stakeholders engage and we, as regulators, listen – and vice versa. We want to develop a considered and effective outcome though genuine mutual understanding. I think we’ve achieved that with the new tutin honey standard, which is considerably improved following input from beekeepers and the public.

The standard provides a number of options for beekeepers, packers and exporters to demonstrate they’re making sure their honey is safe. It recognises that testing is just one way to effectively manage the contamination risk, and it recognises that beekeepers in different regions may have different levels of risk to manage. It provides the flexibility to allow beekeepers to implement strategies that suit their particular situation. The standard comes into force on 25 January 2009, and will be reviewed after the first season to check it’s effective. Thanks to the comprehensive consultation process we’ve been involved in this will not be news to the honey industry. Beekeepers are informed and engaged and we think together we’ve come up with a standard that is workable across the industry, especially for the smaller ‘hobbyist’ beekeeper.

NZFSA Chief Executive
Andrew McKenzie