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.