Worrying about precise definitions is not something that comes naturally to me – I am more of a broad brush sort of person. So many are the arguments that I have with Alex, the acme of precision in definitions terms – and many are the rude names that I have called him when, yet again, he has pulled me up, quite rightly, for some careless inaccuracy. However, for once last week, we found ourselves batting on the same team.
Alex was taking issue with the incorrect use of terms around gluten. Read his very interesting blog here. The term specified by the regulations (clause 44) for products which have less that 20 parts per million of gluten is ‘gluten-free’ but not everyone is using it. He singled out Waitrose whose porridge, he had noticed, was labelled ‘free from gluten’ – but Waitrose are by no means the only offenders.
Now you might quite reasonably point out that ‘free from gluten’ means, effectively, the same as gluten free – and yes, it probably does. But probably is not good enough.
Allergen labelling has come a very long way over the last 20 years and its hard-achieved clarity is of massive (indeed life saving) importance to allergy sufferers and anyone wanting to avoid specific foods or ingredients. But it is only helpful when it is totally clear and unambiguous – as soon as any ambiguity creeps in, it is devalued. Look, for example, at precautionary ‘may contain’ allergen labelling (PAL).
Because PAL was always voluntary there were no set formats which could be used. As a result, every company who chose to use it came up with their own form of words. It certainly did not help that there were no agreed standards for what should or should not carry PAL (e.g. no agreed level of allergen below which it was safe for an allergy sufferer). However, the fact that there are something like 50 different forms of words used on products carrying PAL has just meant that they are all, effectively, meaningless: no one knows what any of them are actually meant to mean.
This is a situation which, as most of you will know, we are seeking to remedy with an accreditation scheme which would set both some levels and agreed terms – but we are still long way from achieving that.
Meanwhile, in this instance Alex is entirely right. When regulations are designed to give precise information, they must be adhered to because the precision of the information is what it is all about. As soon as you alter the way the information is delivered, you risk misinterpretation. Uncomfortable but not a disaster with gluten labelling, but potentially fatal with allergen labelling.
You keep at them to get things accurate and clear! I’ve wound up in hospital after eating wheat-laden potato crisps – in the days before I realised they put wheat on potato crisps. Sheesh. Nowadays, if I’m not certain of a food, I go hungry. Much simpler than risking my life and spending two days in hospital.
> Worrying about precise definitions is not something that comes naturally to me – I am more of a broad brush sort of person.
Well, to me it is not a matter of WORRYING about precise definitions, it is a matter of being pleased to be precise in using precise definitions and being pleased when people with whom one is interacting are precise as well.
> So many are the arguments that I have with Alex, the acme of precision in definitions terms – and many are the rude names that I have called him when, yet again, he has pulled me up, quite rightly, for some careless inaccuracy.
Well, if people are precise then conversations can produce precise results and progress can be made.
The phrase to be used, specified by the regulations, is gluten-free rather than gluten free.
The regulations state gluten-free with a hyphen between the two words, so why have you edited that so as to give gluten free with a space rather than a hyphen?
I hope that you note this comment and move to precision rather than broad brush.
I recognise that in our culture that rather than value precision and move forward that I might well be criticised for mentioning the matter of the hyphen; and then whether it matters may become discussed.
Yet, in the article to which you refer, the labelling on the packet is still not going to be in accordance with the regulations!
William Overington
26 January 2016
Thank you for your comments.
As regards gluten-free versus gluten free, I am assuming that this term is normally used in front of the product it is describing so hyphenating the descriptor (gluten-free) would be grammatically correct. If it is not being so used, then I would assume that the hyphen would not be required. But, of course, I may be wrong…
Much amused by the hyphen – William is quite right – it’s used throughout the FSA guidance document. I hadn’t noticed it or given it a second thought. On reflection, even for my high standards of pedantry, this is perhaps one picky point too far!
I guess interpretation and understanding in the consumer is important here. There’s a small risk that the consumer might believe ‘free from gluten’ to mean something slightly different to ‘gluten free’ (such as zero gluten). I don’t think that risk exists between gluten free and gluten-free.
> On reflection, even for my high standards of pedantry, this is perhaps one picky point too far!
Well, it is not pedantry, it is precision.
Pedantry is defined by the on-line Oxford Dictionary as
Excessive concern with minor details and rules
Precision is firstly defined by the on-line Oxford Dictionary as
The quality, condition, or fact of being exact and accurate:
The on-line Oxford Dictionary is available at the following webspace.
http://www.oxforddictionaries.com/
The issue is central to the labelling regulations.
It seems to me that if a food manufacturer is unable or unwilling to even copy the term gluten-free from the regulations document and use it correctly on packaging, then there is an issue of whether there can be confidence that that food manufacturer is able and willing to apply the regulations correctly to the testing of the food.
It may be that there are food technologists working with care and precision regarding producing the food and getting it tested and that the labelling on the packaging is typeset by someone else. Yet there should be overall management control and management must manage.
.William Overington
27 January 2016
Maybe freefrom gluten means these oats were grown in a field which at has not previously grown Barley, Wheat, or Rye. But, lots of us coeliacs know we cannot eat oats! When is “avenin” going to be taken more seriously?! Other countries recognise the probem!
Jane wrote:
> But, lots of us coeliacs know we cannot eat oats! When is “avenin” going to be taken more seriously?!
I found the following on the web.
http://www.food.gov.uk/sites/default/files/top-allergy-types.pdf
Oats is not listed in the 14 allergens in that document.
The document states as follows:
quote
The Food Information Regulation, which comes into force in December
2014, introduces a requirement that food businesses must provide information
about the allergenic ingredients used in any food they sell or provide.
end quote
The document then states:
quote
There are 14 major allergens which need to be mentioned (either on a label or through provided information such as menus) when they are used as ingredients in a food. Here are the allergens, and some examples of where they can be found:
end quote
Are those two quotes mutually incompatible?
I found the following.
https://www.coeliac.org.uk/gluten-free-diet-and-lifestyle/gf-diet/oats/
Perhaps Michelle’s Blog could have a whole post about avenin.
Is it possible to test for avenin?
Is there a legal definition of avenin-free?
Could there be a category for foods that have been tested regarding avenin in the FreeFrom Food Awards for 2017? If so, the very existence of that category might be an incentive for some manufacturers.
How much would it cost for there to be such a category?
If the amount is non-zero, can that amount be raised?
It is not only avenin that is not in the list used in the regulations.
There is also, for example, raspberry.
Could another post in Michelle’s blog (a different post from the one wholly about avenin) try to gather a list of other allergens which cause at least one person a problem?
William Overington
9 February 2016
The oat situation is frustratingly confusing – see ” target=”_blank”>this post a few weeks ago. In medical terms I just do not think that enough is known about any of these proteins apart from gliadin to make any sort of medical prognosis – or to have any realistically effective tests.
Jane wrote:
> When is “avenin” going to be taken more seriously?!
What would Jane like to be done about avenin, and by whom please?
William Overington
10 February 2016