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Showing posts with label 1935/2004. Show all posts
Showing posts with label 1935/2004. Show all posts

Wednesday, 10 October 2012

Jam Jars - the Musical



The scene – a dusty office in the grandly titled Health & Environment Dept in your local town hall. Walter (49) is an Environmental Health Officer, or EHO. Priscilla (17) is on work experience.

Priscilla           Please, Sir, could you find me something to do? I’m dead bored.
Walter            “Do?” What d’you mean, “do”? You’ve been making the tea. What more do you want?
Priscilla            Well, it’s just that I haven’t learnt anything here, yet. And I’ll be expected to...
Walter             You are on Work Experience, young lady. You are not expected to learn anything, but to Experience Work.
Priscilla           But I haven’t seen any work going on, and I’ll have been here for three months next Tuesday. I mean, aren’t you supposed to be going out and inspecting things? Like premises? I quite fancy inspecting premises. It sounds really, like, cool. I’d like to close something down. That would be a real work experience, closing something down. Like for example Premises. If they, were, you know, a bit dodgy, with people snuffing it all over the place from E-coli thingies, you know.

Walter             First thing, young lady: put that kettle on again. And we don’t have time to go around inspecting premises. Good heavens, do you know how many Premises there are? Probably hundreds. Inspect one and we’d have to inspect all of them, and then where would we be? Masses of paperwork, and most of the time it would be raining.  And talking of paperwork, have you finished the filing? I know the system’s hard to understand, but that’s the whole point. It’s hard work finding anything in the files. It can take days. I go home sometimes and I say to the wife, I say, Hilda, that’s the wife, I say to her, we found that file I was telling you about on Sunday, and she’s as thrilled as I am, bless her.

Priscilla           I think I will put the kettle on. Excuse me.

Walter             Where’s the wretched girl’s file? Heavens, it’s on my desk. That will never do. Still, might as well have a shufti for a refresh. [he reads the file. Stasis, apart from occasional expressions of disbelief, such as ‘bloomin’ Ada’ . Then he reads aloud]

                        Baccalaureate, Sorbonne. Huh, bloody foreigners. Tripos, Cambridge, at 13. Load of tripe, more like. [pause, as he skims through several pages of CV]. What’s this? Summer job at Pizza Parlour? That’s better. Much, much better.

Priscilla           (enters, with tea tray.) I’ve brought you some ginger biccies. They were in the EHO tin in the kitchen. They’re a bit soft, but I’ve rubbed the green furry bits off. Shall I pour?

Walter             Ah! Tea and biccies! Pour away, girl. Excellent!

                        Now then. I’m at conference this afternoon with the mayor. You can’t reach me because the Golf Club don’t allow mobile phones on the links. But when you’ve done the washing-up and the filing you might have a look at this. It’s a bit old, but there might be some juice in it yet. It’s Euro directive 1935/2004...

Anyway, must rush. Lock up when you go, won’t you?

Priscilla goes off to the kitchen for a moment, but returns immediately.

Priscilla (to audience)            

I was really sorry for ‘im, snuffing it like that on the eighteenth. Food poisoning, apparently. Odd, ‘cos he was so busy being busy that he’d only had a ginger biccy all day.

                        Now then. I’d better experience some work. So what’s this? European regulation 1935/2004...

                        [she sits in Walter’s chair, puts on his reading glasses and begins to make copious notes.]


Envoi: Thank heaven for the Wallies and the Prissies who rule our lives with such wisdom from their desks in the town hall




                       





Tuesday, 9 October 2012

The Great Jam Jar Panic of 2012



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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