Shock horror. Mayday. Sacré bleu. Even the normally staid
Church Times raised an eyebrow (5 Oct) at reports that the days of home-made
jam, that stalwart of the produce stall at the church fete, could be numbered.
Re-using food containers, it seems, could fall foul of European regulation
1935/2004 and/or 2003/2006. Apparently the WI have been bombarding the Food
Standards Agency’s switchboard with anxious phone calls, and everybody’s in a
right old tizz, including, predictably, the Daily Mail.
So let’s just all calm down a little, and see what all the
fuss is about.
You’d think, wouldn’t you, that even a bumblecrat would have
the sense to look at prime sources before issuing panic edicts, but then you
obviously don’t understand the way the bumblecratic mind works, and how it took
eight years before somebody read the small print of regulation 1935/2004 and
uttered the battlecry of the bumblecrat – “whey-hey guys, look at this what I have just found. We’re
back in business.”
There is absolutely nothing in these regulation to give the
WI the wibbly-wobblies and cause the good ladies to fear the end of
civilisation as we know it. They were sensible measures introduced as a
precaution as new food packaging materials (mainly new forms of plastic) were
being introduced. You can read the whole of the regulations here – they’re not
secret:
But if you are particularly busy, just read this bit,
Article 3 of reg 1935/2004 -
(3) The principle underlying
this Regulation is that any material or article intended to come into contact
directly or indirectly with food must be sufficiently inert to preclude
substances from being transferred to food in quantities large enough to
endanger human health or to bring about an unacceptable change in the
composition of the food or a deterioration in its organoleptic properties.
The significant words here are ‘sufficiently inert’, and
certainly not ‘organoleptic properties’, which is scientist-speak for taste or
smell, and of these two words ‘sufficiently’ is the one to focus attention on.
This European regulation was introduced to ensure that food
packaging manufacturers and food processing companies only used packaging
materials which were safe to use with the intended product, because in certain
combinations of food and packaging, and some cooking processes, chemicals could
migrate from the packaging and contaminate the food, causing people
unfortunately to snuff it.
The other regulation, 2003/2006 [sic, 2006], is aimed at the
manufacturers of food containers and labels. It was a bit of an afterthought,
to make sure that any labels used on food containers didn’t have anything in
the ink or adhesive that could migrate to the food, and, once again, cause
people unfortunately to snuff it. And
the preamble specifically states that ‘the rules of Good
Manufacturing Practice should be applied proportionately to avoid undue burdens
for small businesses.’
But nowhere in these regulations will you find any mention
of glass. There was no need to mention glass. Glass is about as inert a food
containing material as it’s possible to be. About the only thing that can
migrate to your WI marmalade is the pong of previous pickled onions, which no
amount of sterilisation or cleaning seems to be able to get rid of. You can
look at some of the research into the safety of glass as a food container
material here:
The real danger in this European legislation is not what the
legislation actually says, but how it is going to be interpreted by member
states, and in the UK our bumblecrats love finding loopholes and exploiting
them to the point of absurdity, and then passing the buck of further
interpretation down the quango food chain until your local council feels
obliged to ban something without really having any idea why it’s doing it,
except that it seems like a Good Idea and gives people something to do to
occupy the hours between nine and five.
There is, incidentally, a similar absurdity in the
regulations governing the performance of recorded music in public places,
including small church halls, that followed the imposition of of the PPL
licence at the beginning of 2012. The reporting requirements – by volunteers –
are beginning to impose a burden which is quite disproportionate to the money
involved, which is quite literally pennies.
Legislation which is allowed to produce such ludicrous
nonsense by the inexorable application of the principle of reductio ad
absurdum by bumblecrats is ipso facto bad legislation, and it needs robust
challenge.
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