VEGA News Item

Defining Vegetarianism for the Food Standards Agency - 05/11/2004
We continue with testimony for standards for consumers, customers, and citizens, as well as challenges for choice and enterprise among manufacturers and retailers without undue restraints, bureaucracy, and surfeits of legalistic paperwork.

1. We were disappointed that our request for a second representative was rebuffed on grounds of space, although this restriction was not obvious at the occasion. It did not allow us to give a full account of our activities over many years on the topics likely to arise; further, we have been busy with meetings, conferences, and consultations with DEFRA, FSA, and consumer organizations and agencies, as well as manufacturers and retailers, trying to express in positive assertions and enterprise the value to the whole community of vegetarian research and ideals, rather than into a legally defined and unenterprising division between the niche of veganism and the rut of lacto-ovo vegetarianism and other bastard forms.

2. These endeavours mean that we have been much involved with labelling declarations on products of the live/deadstock industry (which enjoys hefty subventions from public funds); accordingly, we were further disappointed that our efforts at relating the meeting’s affairs with the Farm Animal Welfare Council’s pronouncements on labelling were also rebuffed.

3. British consumers need much more information and education on matters of food production and its corollaries than creations of unnecessary legal divisions that will cost a lot in time and money and stifle the interest and enterprise the FSA is trying to foster in other contexts. The FSA must not overrate the competence and resources of NGOs and registered charities vying with the might of the highly-financed food industry. We look to the FSA to raise our game without loss of our independence and certainly not with unnecessary legal hurdles.

4. We were involved with MAFF in monitoring “the vegetarian shopping basket”. The vegetarians being noted for their consumption of fruit and vegetables, this collaboration focused on issues such as nitrate and pesticide levels, as well as contamination with mycotoxins. Our assessments of nutritional factors began with iodine, selenium, and vitamin B12 and D in particular. Most of these projects, to which may be added the unfolding of the story on plant and animal proteins and fats, have assumed much wider importance. We regret that the FSA’s energies on some of these matters have ignored the special significance for vegetarians, as shown in recent examples such as folate and other B vitamins and in utterances on consumption of fish and marine foods. Our efforts on these matters continue, but we appeal for collaborations with the FSA matching and surpassing those we enjoyed with the MAFF in the vegetarian interest.

5. Our despatch of 21 October 2004 explained much of our background and earnests at informing customers and consumers trying vegetarianism in its various forms, and possibly returning to animal-dominated dietaries at least better informed and demanding. Waiting at queues at the buffet leaves plenty of time for strict veggies, often solitary, while the lacto-ovos are lumped by unenterprising and ill-informed caterers into a category and segregation they could uncomplainingly accept in unison for tasty expressions of the real thing. We are trying with “portfolio” statin-effective items for caterers’ menus to overcome this barrier in a positive way. Appropriate recommendations are in hand with caterers at the FSA and Royal Society of Medicine and for providers of food in institutions and at events.

6. I have some special remarks regarding your report:

6.1 General
6.1.1 The EU connexion introduces translations and interpretations that the meeting hardly anticipated. The French writ runs to provinces in the West Indies; in Europe in general populations with dietary customs and practices, as well as needs, have to be considered. For instance, we have to take account of veggie-minded populations of South Asian or of Caribbean origins whose dietary needs, risks and customs may
be inadequately considered; correspondingly, exclusions related to the other dietary restrictions must be entertained, e.g. for diabetics, celiacs, and people with allergies (e.g. nuts). Ingredients and formulations in fortified foods, supplements, and drugs, e.g. calcium, vitamin D, and lactose, as well as colourings, presumably fall within the FSA’s purview and were mentioned at the meetings, as were pet foods. Products for babies and toddlers require special care and illustrate our reservations over use of Suitable for… statements.
6.1.2 Definitions of words such as animal, meat, milk, and dairy need overhauling for the intended purposes. Some are suitable for references from recent legislation on animal welfare and food labelling. The scientific word animal covers all the species mentioned or alluded to in your report. I came away from the meeting with the impression that we had at least convinced the Hindu representatives that British animal milks and dairy-produce and derivatives were cruelly produced and unsuitable for them. This is noteworthy: it has taken some doing. The word vegetarian in your 3rd bullet-point in the Vegetarian section on page 2 should read lacto-ovo vegetarian; use of the word in the last bullet point is apt, as preparation of food for consumption by vegetarians would not implicate animals, although the farming would, e.g. in competition with “vermin”. (Vegetarians would have concerns, however, in general welfare, hygiene, and environmental concerns, as well as mode of treatment, e.g. by injection – and thus handling – or addition to feed or water, as in the precautions to limit the spread of salmonella in poultry and eggs; and the search for a vaccine for badgers, cattle, and other commensals against bovine TB is another among “the range of issues such as animal welfare and environmental concerns that can dominate this area”). Vaccination, antibiotics, and feedstuffs converted consumers to vegetarianism during the BSE crisis faster than any eloquence that we could muster; relapses fuelled by hefty subsidies unfortunately reversed these gains from the BSE crisis; consumption of eggs is rising again as the threat of salmonella recedes and powerful marketing and value-adding and imports buck the Edwina Currie effect.

7. Veganism

As we suggested in the conclusions of our last letter introduction of the word vegan makes for unnecessary misunderstandings and confusions: vegetarian, lacto-ovo vegetarian, lacto-vegetarian etc define the various grades in the scientific manner, and span popular intermediate practices of meat-reducers, dairy-frees, meat-frees… without blocking the momentum in challenging developments in the market to attract real vegetarians (aka vegans).

8. Cross-contamination

8.1 Contamination, e.g. with pesticide residues, and MRIs, are usually pitched in ppm terms. There seems to be no good reason to relax such requirements, and to rate all such undesirable contamination at the limits of the certified analytical methods that TSOs and EHOs can command. Bacteria may be detected with even greater sensitivity and may be used as markers of cross contamination. Bulk somatic cell counts for acceptable cow-milk may run at 150,000 cells per ml; higher levels would begin to indicate infection with mastitic organisms incurring an immune response. Such details should be available by IT methods that we have described to all consumers of animal-derived milks and dairy produce. Contaminants may be multiple and variegated: “meat” for instance, may be of mammalian or avian origin. Would limits be set on an aggregated basis, or individually for each defined component?

8.2 The rush to set standards with precise figures may be attended by various practical difficulties. Working examples on typical causes of concern for veggies are (as well as the obvious instances you cite):

8.2.1 Chicken stock used instead of vegetable stock
8.2.2 Bakery products cooked in tins greased with animal fat; or glazed with cow-milk.
8.2.3 Cross-contamination in multi-purpose manufacturing and inadequate washing or disinfection.
8.2.4 Drip and other forms of contamination in refrigerators and chill cabinets with mixed loads and inadequate packing and washing.

8.3 In some of these instances bacterial identification may yield essential clues in detection. We can cite an example in which a vegetarian meal was included, surprisingly, in an outbreak of meat-borne food-poisoning. The veggie consumer had accepted gravy that had been made with meat stock and re-heated.

8.4 Then we can cite examples of cross-contamination in restaurants in which a diner has been sick and affected meals uncovered on the tables; or of the chef taken ill in the kitchen and sick over a bowl of salad, which was washed, spun, and served in the restaurant, adding a pathogenic residue in an otherwise healthy green salad.

8.5 Some of these examples are of general importance but of added significance for fastidious vegetarians (notwithstanding the complacency of some over the means by which animals deliver their eggs and milk); these “important problems” are not often-enough “clearly recognized”. Non-vegetarians have yet to treat veggies at a collation with the defence that, say, smokers would accord at table to non-smokers. That table has turned for non-smokers; how long will it take to lift a similar embarrassment for committed veggies?

8.6 Analysis and measurement of relevant contaminations pose many problems. They are likely to be variable. A recent example we know of concerned a plant-milk made in a factory also producing dairy-products. Detection of lactose in a soya-milk indicated cross contamination with dairy-products. GM-soya protein was detected in this “non-GM” product too. The content of lactose could be expressed in the parts per 10,000 mode, but the sugar comprises only a small fraction of liquid milk, so the contamination could be regarded at a much higher level if cow-milk rather than separated lactose was regarded as the adulterant. Statements that processing aids do not reach consumers are dubious because, as in cheese-making, breakdown products, usually unidentified, of the enzymes, antibiotics, and bacteriocins are left in the final commodity.

8.7 I might add that I read the labels on the bottled water on the tables at a recent meeting at the FSA. A figure was given for the fluoride content in very small print and in units I was unable to understand, but probably higher than 1 part in 10,000. Fluoride and fluoridation are current issues that engage veggies of all types as much or more than many consumers. This just illustrates the need for much more prominent information for consumers in all categories, well-defined or not, to assess for themselves, with objective interpretations from and scrutiny by the FSA.

8.8 All of this emphasizes our hope that the FSA will assist vegetarian-minded consumers to standards of choice and enjoyment in the full plough-to-plate expression, and spur greater enterprise to that estimable end by food producers, manufacturers, and retailers.

Alan Long

Hon Research Adviser
VEGA Research

Registered Charity No. 1045293
© VEGA - 2008