The Grumpy Old Man

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....is current food labelling of allergens and enforcement of regulations adequate?....

....Is current Food labelling and its detailing of allergens legislation adequate and do manufacturers and suppliers of food really understand the full ramifications and dangers associated with these requirements?...

The death of a teenager following a flight from Heathrow to Nice after she had eaten a poorly labelled baguette at Heathrow airport has prompted new legislation to be proposed that tightens up food labelling. The Daily Telegraph reports the teenager's father saying "I think we are moving to a tipping point for things to actually change. So things that have previously been in the dark are now going to come out into the light. And that's really, really important and only good will come from that". These sentiments are laudable but investigation by BBC Watchdog programme suggests that enforcement of even current regulations is non-existent.

That's fine, but the problem with allergies and allergic reactions is far more complex and far more extensive than is currently openly reported. Grumpy does wonder whether even the Food Standards Authority, who are involved in the current review of labelling and other legislation fully understand the problem. Either that or they are having extreme trouble in defining an adequate framework that covers all eventualities in what is an extremely difficult and complex situation having many different nuances and levels, all being equally important. It is hoped that the FSA is not reacting to input from the food industry demanding watering down of the regulations for their own profit driven ends.

To digress for a while, Grumpy would claim a little "hands-on" experience as he has a potentially life-threatening allergy and so does Mrs Grumpy.

Grumpy's allergy is relatively simple, it is to penicillin and penicillin-based products. This does lead to problems when tough infections are involved and therefore need anti biotic treatment His allergy was first identified when he developed a "nettle rash" in his 20s. Yet while in hospital, years later on another matter even after having identified his penicillin allergy, staff still gave him penicillin medication, not once, but twice. What was important from this was that the reaction to the latter incident was totally different from the nettle rash, with the latter reaction certainly being life-threatening. What was galling, was that the treatment was repeated some six hours later with an identical effect. It was only when Matron (a post still filled at the time) muttered "I'll have none of that on my ward" as she removed the offending drip!

Mrs Grumpy's case is far more complex. As a coeliac it is imperative she follows a totally gluten-free diet

For some time it had been suspected that there were other allergic reactions going on and these were eventually tied down to aspirin and aspirin-based products. The basic compound of aspirin is called salicylic acid. Being a vegetable-based acid, it is very common across a wide spectrum of foods The problem is nowhere near as well known as gluten problems and was only pinpointed as techniques for detecting specific substance allergies developed. A further problem with aspirin is that it's 'salicylate' base appears in varying concentrations across a wide range of "normal" foods, particularly plant-based products such as fruit and vegetables. Like Grumpy's penicillin allergy the symptomatic reaction to this substances can vary each time and has been known to provoke life-threatening anaphylaxis. The problem with many of them is that it has never been fully known exactly what prompted the "attack".

The solution to these two problems is relatively simple, even obvious, is to avoid consumption of them. Gluten is a well-known digestive problem and is frequently clearly marked in the contents list of most, items that contain it. On the other hand, "salicylate" is much less understood and thus more difficult. The only way that has been controlled is by consulting a chart giving the percentage concentration of the salicylate ion in each food. Only experience has allowed the individual to ascertain the cumulative quantities of which products are safe for him/her. This can, however, still be somewhat hit and miss.

Within the domestic environment, controls can easily be imposed around these two criteria, however problems arise when one is away from that domestic environment eating in cafes and/or restaurants. It is granted that these establishments are now required to identify products containing gluten but the majority of them are actually not qualified to make that statement. This is not an assumption, it is an assertion. It is this assertion together with whether and how it is dealt with in the forthcoming legislation that is crucially important.

Because the slightest bit of these allergens in food can cause an "attack" which can go on to full life-threatening anaphylaxis, it is absolutely crucial that the forthcoming legislation deals with the problem. And, contrary to public opinion, it is a real problem as Mrs Grumpy has experienced, on a number of occasions.

Knowing the ingredients in your recipe is fine, however the crucial problem to be addressed (primarily because the human body can be so sensitive to these allergens) is that of cross contamination. As an example of this, we have knowledge of an allergic reaction from a plain omelette. We believe this came from the omelette being made in a frying pan that had just been used for frying a product containing gluten, thus contaminating the oil with the gluten. One can imagine that deep fat fryers so be delivered fast food establishments are probably responsible for similar effects.

On our travels we have come across restaurants that are quite capable of managing the situation. One National Trust establishment we visited had a kitchen that was run by a celiac chef and every item on the menu was gluten free (and might I say absolutely scrummly delicious), and actually cost no more than "normal" food. So it can be done. We are also aware of a cafe in our local town that similarly is owned by a celiac. Once again he does a superb line in gluten free cookies, sandwiches, soup and other goodies. Again his prices are just the same as the competition next door, the only difference being his taste better! So again it can be done.

The one thing that both of these examples show is not only the possibility of gluten-free eating establishments but also demonstrate that if you are selling something gluten free, in order to avoid cross contamination it is absolutely essential that a completely separate gluten-free kitchen is used for food storage and preparation. It is clear to the Grumpy family that the training of chefs and staff in the majority of eating establishments is woefully inadequate. It is no good eating establishments marking food "gluten-free" because most of the time it's not, containing cross contamination happens and such menu notices are therefore useless, and in some cases dangerous, to the sufferer.

As far as he can see, Grumpy believes the current legislation demands that establishments label their food as containing gluten and other allergens although most already do that. However they all hide behind this when they should be labelling the dishes that are gluten-free. To do that they need to reinforce staff training, discipline and certification. In the same way as hygiene certificates are issued for public health considerations, allergen management procedures should be likewise certificated, regularly tested and enforced. In this way it can be ensured that food outlets are up-to-date and reflect the current level of food allergies. This training and certification should apply to all staff, at whatever level, handling or associated with food.

The catering industry must begin to realise that this is a real problem and needs a "total" approach to address it. Gluten-free restaurants must operate a totally gluten-free kitchen. Unless this is done then cross contamination takes place. (See on what problem mentioned earlier) It is no use whatsoever to the coeliac, or any other allergy sufferer when eating out in a cafe restaurant or fast food outlet to simply label a product on the menu as "gluten-free" unless it was prepared in a gluten-free kitchen. Likewise with other allergens, the slightest quantity of many of them can cause allergic reactions with potentially fatal consequences. The use certified gluten-free ingredients is totally negated by the risk of cross contamination if they are not processed in a "totally gluten-free kitchen that has not been used for conventional food preparation".

The whole system needs to be overhauled, the identification of these products on menus is a good idea, however the problem is people operating this system invariably do not know that these allergens can "get into" the dish from sources other than the ingredients they are adding.

As an example it is noted that there is a reported increase in allergic reactions to celery, used in celery salt. A number of years ago this is largely unknown but, should the legislation be properly worded, it may be possible to include such "newly identified" allergies, perhaps even address the far more complex problem of salicylate concentration!

With the apparent increase in food allergies surely now is the time for our learned scientists and academics to undertake more research ascertaining the cause of allergies, their treatment and investigation of substances now causing allergic reaction that have not done so before. Grumpy would hazard a not too wild guess that it could be associated with the chemicals that are so liberally sprayed on food crops as they grow, harvested and are stored, together with the, in Grumpy's view, excessive use of flavour and shelf storage life enhancing chemicals.

Unless the new legislation being proposed by the UK government covers these aspects, there will continue to be more and more instances of allergic reactions leading to anaphylaxis and death. The food industry seems very fond of claiming certain foods to contain "0% sugar" (meaning sugar free). The use of "0%" rather than "free" is just the marketing man's ploy to give a marketing claim some scientific credence. If they can claim products to be "0% sugar" why do they not use the same when talking about allergens (like gluten). This is because the EU legislation actually specifies that food can be claimed gluten-free provided it contains less than 2 mg of gluten per kilo of product (or 0.0002%). This may not seem very much, however when cross contamination is found to give problems, then even this percentage is considerable. It is therefore essential that far better training is mandatory for all staff managing and working in a kitchen producing goods for sale to the general public. As an example of this we have found that the best coeliac friendly restaurants are actually owned and or run by a coeliac themselves. Such training and qualification of staff should also be subject to the same inspections to which hygiene is subject.

Furthermore now is most certainly time to initiate further and far deeper research into this problem that is far more widespread than the general public appreciate. This is particularly important as the BBC television programme "Watchdog" highlighted the level of ignorance of these matters in cafes and fast food outlets. Their investigation showed that out of thirty such outlets, only six were found compliant with even current legislation.