Gut Feeling, Soul Foods and Animadversions -
"It doesn't agree with me" complain consumers with allergies, intolerances and aversions to a range of foods and to their own cherished dislikes. EU regulators and our own FSA out their brains to work on labelling curtailments that seem to relieve manufacturers and retailers of responsibilities and fail to assist discriminating customers making their individual well-informed choices of food that they can like and enjoy. Not all is-yet-in the genes. We wish to remain on the FSA’s consultation list for the present subject and similar topics. We have joined in consultations and meetings with the FSA and DEFRA on a number of subjects. We are a registered charity with no commercial involvements.
1. We reiterate recommendations already given to the FSA in other labelling matters. Our invitations have not been accepted for a visit to a major retailers’ with an official (s) of the FSA to demonstrate on-site choices that some customers make on the basis of information on foods and ingredients on the shelves. The significance of allergenicity and intolerance looms large in these decisions and aversions. It is likely to increase with advances in nutrigenomics and other omics (including economics). 2. Support accrues for our recommendations that modern IT should overcome restrictions of space on labels for information that may be sought by customers with particular interests and needs. Such information should be available in store and at home (serving an increasing population of customers who order goods by phone, post, or e-mail for delivery without visiting the retailers’ premises). Manufacturers’ and retailers’ websites should carry illustrations of all the information on goods and labels sold under their brand names or other wrappings. A limit should be set on all such descriptions on space occupied by claims or advertising not of an objective and informative nature. These recommendations should cater for choices needing further contemplation; they would also offer manufacturers and retailers scope for eliciting a salutary and well-versed appreciation of foodstuffs. (We note also that pets can exhibit allergies and intolerances; although we understand that pet-foods are outside the FSA’s responsibilities, owners may feed their animals with commodities mainly intended for consumption by humans. Formulations of medical drugs and supplements in medical and veterinary contexts need similar attention). 3. Food allergies and intolerances are part of a range of causes of consumers’ abstentions and aversions in their choices of food, household goods and supplements and pharmaceuticals. Practice of these regimens may be partial or patchy or develop into full boycott, for reasons that might be broadly described as religious, ethical, cultural, or political. Expression of these promptings must be well-versed (and therefore dependent on sound claims and informative labelling) and it must avoid prompting extremes such as anorexia or other eating disorders. Children and adolescents are a population needing full advice and parental sympathy, as well as educational guidance, to practise what they believe in without undue compromise in an imperfect world in which flexing the muscle of self-discipline and informed choice should offer scope for manufacturers and retailers to compete and for the FSA and other agencies to comprehend without impressions of fussing in the nanny state. In this understanding and in contrast to allergies and intolerances associated with some raw products these aversions are not altered by processing. Concentration of the food industry on a limited range of staples with diversity in utilization and processing, coupled with applications for other domestic purposes and with risks of various means of contact and exposure, can be expected to lead to an apparent frequency in the risks of allergy. Wheat and soya represent good examples and need more attention than difficulties, which can be circumvented at the moment with little difficulty, involving, say, strawberries. 4. Typical aversions and avoidances prompted on such non-nutritional and more or less unselfish grounds might include ( and illustrating the full range of plough-to-plate, farm-to-fork standards the FSA should embrace in its environmental and animal welfare responsibilities) are: 4.1 Organic and conservation husbandry 4.2 Vegetarian persuasions; which would include the population of meat-reducers and dairy-frees, anxious to avoid meat, milk, eggs, and fish and derivatives thereof (which would include by-products and co-products, such s whey, buttermilk, casein, egg-white etc). 4.3 Interpretation of Jewish, Muslim, Seventh Day Adventist abstentions and practices. Animal welfarists, for instance, are intolerant, like the government-appointed Farm Animal Welfare Council, of the practices involved in ritual (or religious) slaughter and demur at purchasing meat and derivatives from these processes and of components sold undistinguished as ingredients in prepared foods and catering. 4.4 “Organic” interpretations inform the choices and aversions of consumers abstaining from complicity in objectionable farming practices and intensifications. Processing would not diminish the taint. Such considerations would entail aversions in categories such as 4.4.1 GMOs and GM-foods and derivatives and ingredients. 4.4.2 Locally grown produce 4.4.3 Dollar bananas and crops from Caribbean islands 4.4.4 Food miles, global warming, and energy-conservation 4.4.5 “Free range” and Freedom husbandry and low-input farming 4.4.6 Economics and Trading Practices: 18.104.22.168 Fair Trade 22.214.171.124 Associations with the output of disreputable regimes or manufacturers or retailers or outlets. 5. Processing of wheat in general processing methods does not relieve the threats faced by celiacs. The documents in hand appear to assume that production of soya oil can remove risks of allergenicity, whereas it has also been accepted, somewhat surprisingly, that similar threats persist through the processing to make peanut ( arachis) oil. These are among vegetable oils used for toiletries and cosmetics and for pharmaceutical applications and therefore possibly transferred into the digestive and respiratory systems, as well as by absorption through the skin; indeed, such exposures may trigger robust dietary reactions for many years subsequently. Such inclusions in foods and toiletries of synthetic colorants derived from coal tar have been blamed by consumers, parents and teachers for behavioural and learning problems in the home and at school. Lanolin (sheep’s wool wax) is another fatty substance used for bodily applications; it is associated with allergenicity and the appropriate warnings should be included on the domestic toiletry creams on general and specialized sale. 6. Intensity of response and effects on consumer demand and choice may be less strict than the regimen imposed on a celiac sufferer. Mutation within only a short evolutionary span (of, say, about 10,000 years) of the dominant European lactase-switch- gene means that lactose intolerance is becoming absent in many families; even consumers with intolerance can stomach small quantities of lactose. Similar accommodation may be occurring in domestic animals other than humans. In general, lactose intolerance after weaning is natural for all mammals; “the full significance of a digestive genetic modification keeping unusual mechanisms in play after early childhood has not been evaluated. Dairy-products contain aversive substances of more consequence than lactose and consumers know to choose fermented or processed products with little need on this count to alter wording and warnings on labels. 7. For celiacs (who may have more than a single cereal intolerance) the prospects are still unclear, both as regards to the intensity and specificity or their reactions, as well as on the information on the label that they can interpret for themselves and for alternative foods that are increasingly being sought by consumers professing various types of wheat allergy (some combined with reactions, for a range of reasons, to yeasts and fermented foods, some of which may generate ethyl alcohol in the normal functions of the human digestive system). Cereals possibly suitable to some celiacs and other consumers may be spoilt by carry over of the ubiquitous wheat in milling; dedicated mills may be able to produce wheat-free oats acceptable to celiacs for whom small scale artisan and organic equipment for general-purpose milling would be unsuitable. 8. Orthodox Jews, interpreting the Beth Din’s rulings, have shared with vegetarians reservations over yeast extracts, such as Marmite, made in factories also manufacturing meat extracts, such as Bovril. This common aversion, albeit for different reasons, can be avoided by purchase of imported Marmite made in a factory manufacturing to the Beth Din’s standards and satisfying vegetarians’ abhorrence of the workings of the meat-industry. Such attitudes as these may change within a short period owing to reorganisations in the food-industry; the FSA should ensure that appropriate labelling and announcements keep consumers informed. These are not isolated instances. Parents of children with exquisite intolerances of milk products resort to vegetarian foods as dairy-free, even some approved and recommended. Some of the ranges of non-animal “ dairy”-products “suitable” for vegetarians ( and vegans and vegetalians) have been found –after unfortunate incidents- to contain traces of lactose ( as well as of GM-components) demonstrating some cross contamination in the “dairy”. 9. Evidence exists that many consumers declare allergies and intolerances to foods without recognition by orthodox authorities. Labelling, testing, and easy access for self-screening on the basis of exclusion diets are not adequate to cope with a common challenge with possibly avoidable nutritional harm. Regulations should not be set with little opportunity for changes as research continue, nor should “difficult” subjects be ignored. These considerations have surfaced in the controversy, which is likely to rage for some time, over GM-foods and the doubts over non-GM assurances. Objections to these developments in breeding and traceability introduce compromises and suspicions of adverse reactions, such as allergies with unpredictable aversions and sincerity among consumers, commentators, and entrenched detractors. It would be fair at least to expect producers of dairy-milks and derivatives to warn intending purchasers that feed the animals-even in organic and Freedom Food regimes-contains GM components (e.g. soya and maize). Transmission of supposed allergens from feed to food may be debatable, but opponents to GM cite more relevant misgivings over the consequences in the environment and animal welfare. Similar- and probably more cogent-information should be offered on the use of drugs (including antibiotics, some-like the penicillins-with recognized allergenicity) on the animals yielding the milk and meat in question. 10. Labelling of beers, wines, spirits and fruit juices still omits mention of ingredients and processing agents ( such as finings), unless such information is offered voluntarily ( e.g. by Samuel Smith’s brewery and adherents to German Reinheitsburo stipulations). These disclosures are of special interest to vegetarians, as the finings may comprise gelatinous materials derived from blood, milk, eggs, or fish; they would also be associated with removal of yeast remnants and other ingredients and enzymes (possibly GM used in the fermentation). Although fining agents may be of vegetable (e.g. alginates from seaweed) or mineral ( e.g. bentonite) origin and although they clarify the beverage by precipitation and may not therefore be counted as constituents of the liquor, the reluctance to disclose their use is lamentable and infringement of the standards the FSA purports to uphold in the conscientious consumer’s interest. These strictures obtain-and restrict choice-particularly to cask and bottle-conditioned ales, but are less relevant for pasteurised products; and they are not necessary, some beverages being left cloudy and not chill-proofed. 11. Fluoridation is another disputatious subject in which consumers and researchers are ill-served by labelling. Some beverages (e.g. juices) are made from concentrates diluted shortly before sale at a bottling or canning plant with water from its local supply. Bottled drinking waters may also contain an appreciable quantity of fluoride. A well-informed discussion of fluoridation needs the appropriate details to guide the customer’s choices and aversions. 12. We recommend case by case considerations of aversions (including those described as intolerances and due to allergens); with spurs from the FSA and similar European authorities to set high standards on manufacturers and retailers to exploit the economical means that we suggest to serve the market with objective information. 12.1 Many current changes and extended research and screening, with an avoidance of generalizations (e.g. of all tree-nuts, perhaps unduly influenced by what is known about ground nuts) and allowance for all the rigour, relevance, and practice of aversions should provide customers with every opportunity for informed choices in their own self-assessments. 12.2 Research and enterprise must be devoted to alternatives to enrich the choices for interesting dietaries by for example, celiacs and people informed by concern for animal welfare and the environment and the consequent scientifically-based aversions to harmful practices in farming, food, health, and use of the land.