Open Letter to the Government, Food & Hospitality Industries

The hospitality industry’s overall goal is to provide guests with a “reviving” experience; but why are people with food allergies, diabetes and food vulnerabilities generally left out of the equation? *

My name is Ron Cook, and I am a retired food industry technical manager, BRC auditor, and father to a 10-year-old Type 1 diabetic daughter.?

I don’t know about you, but I am, and have been for many years, concerned about the lack of nutritional data (specifically carbohydrates) available in the majority of food venues - cafes, restaurants, street vendors, ice-cream vans etc. for diabetics (allergens are mostly catered for, especially after the introduction of “Natasha’s Law”) - but ask in a restaurant what the carbohydrate value is of any of their meals and they will, in the majority, look at you as if you were from a different planet.

The original 2014 EU Directive - Food Information for Consumers applies to “food in the final state in which it is supplied to the caterer or to the?final consumer. However, the FIC places a responsibility on?all businesses in the supply chain to pass on food information. This means the final food products can be provided to caterers and consumers with the correct information. The requirement to provide information?applies to catering as well as non-catering sales to consumers. It also applies to catering services provided by transport undertaking as long as they are departing from within the EU.

With one exception, the specific rules apply only to foods presented to caterers or consumers in prepacked form. EU member states can decide individually what information should be provided with food sold loose or?prepacked for direct sale?in their territories.?The?exception?is that?allergen information?must be provided with such food”

If this legislation was in force in 2014, and allergen information had to be provided for loose and prepacked food in at that time, why have people died because of the lack of labelling or information provided in other ways? Two years after this legislation was enacted; Natasha?Ednan-Laperouse died because of a sandwich with no allergen information on the packaging, and “Natasha’s Law” was introduced on 1st?October 2021 and now, “Owens Law” is being campaigned for.

There are approx. 20-30 deaths from allergenic responses in the UK each year of which 10 are due to food reactions, yet the newspapers, magazines, research studies etc. are pushing for more and more allergen controls when, in theory, this control should already be in place with the above legislation. I applaud the fact that allergens should be promoted and advertised but, why are diabetics and other vulnerable groups being discriminated against?

The first ever report into mortality from the National Diabetes Audit has outlined some shocking statistics into death rates among people with diabetes, published recently by the NHS Information Centre for health and social care.

The report found that up to 24,000 people with diabetes in England die earlier?from causes that could have been avoided through better management of their condition.

Some of these 24,000 will have died because they couldn’t manage their food intake properly - the wrong foods, too much of one type, not enough exercise etc., but if all foods were nutritionally labelled, they would at least know how many carbohydrates they were eating and therefore know how much insulin to dose for, thereby perhaps reducing this shocking number.?

Every producer of food product relies on their suppliers to provide specifications for every ingredient supplied - sometimes extremely detailed documents as many in the food industry know, therefore there is no reason why nutritional data should not be available to everybody, everywhere.?

Diabetes is relentless - 24/7/365 - never a day off - mental health issues and burnout - you blame yourself and feel like a failure for having this hidden but insidious condition - no-one really sees the problems that you face, and if you have a diabetic child, it is even worse.?Diabetes is Relentless

The mental health battles that many diabetics go through is heart breaking - frustration, anger, worry, restrictive, fatigue, lack of sleep and therefore tiredness, the constant weighing of food and carbohydrate/insulin calculation, endless finger pricks and injections, if you are not lucky enough to have an insulin pump or sensors, endless hospital appointments?etc. etc. - and for parents of diabetic children, you have all of the above plus the strain of trying to keep your child’s values in line - this is regardless of whether it is hot or cold (temperatures affect blood glucose levels), too much/too little exercise, are they drinking enough water at school, are they stressed over homework - emotions can really affect blood sugars - are they being bullied at school because of their diabetes and again etc. etc. - is it too much to ask that for this portion of the population, the basic requirement of knowing the nutritional values of your food be available??

A diabetic, or the parent of a diabetic child inspects food labels for the nutritional content of that food (especially carbohydrates), if it is not there, we don’t buy because, without it, you cannot calculate the insulin dosage required to counteract those carbohydrates.?

This data is found on all packaged food products BUT NOT on any loose or prepacked products, nor can you find it on any menus (unless you are very lucky) in restaurants, cafes, street vendors, ice-cream vans etc. Why?

The NHS runs a course called DAPHNE which “is a way of managing type 1 diabetes and provides?people with the necessary skills to estimate the carbohydrate in each meal and to inject the right dose?of insulin” - the only problem with this is that when they state people they actually mean those over 18-years-old - this scheme also excludes the parents of diabetic children from being able to take part - it is another ridiculous waste of time, money and resource - if you get to 18-years-old then presumably you know how to look after yourself but, parents of newly diagnosed children do not - another reason for?nutritional data to be available everywhere.

This is why I am campaigning for full nutritional data to be on all foods, and have started a petition on YouGov to try and amend?current legislation to enable nutritional data to be available for everybody to help keep them safe. Petition

The following are some of the comments made by food industry?professionals in response to my posts -

“It's a shame more responsible business leaders aren't making these labelling changes?independently. Benefits would be twofold:?

1. demonstrating such organisations to be industry leading, who fully value the health and safety of?their customers at all times,?

2. help further raise the profile on this issue and ultimately help force through legislative change”.?

“I like the part about a sign in close proximity because it's practical and intention setting. The FSA offer a tick sheet.... that’s dangerously pathetic compliant.?The label/signs/disclaimers/tick sheets do not reduce risk. Competency reduces risk. Even without a label. Knowing the ingredients is only part of the story”.?

“Some carers of those with eating disorders really don’t want this information on the packaging same as with information on the menus in restaurants. However how do I know how much insulin I need if I don’t know the carb content?”?

“The cost of food labels, sustainability or waste generated, and the risk may even increase. Chefs?aren't taught labelling standards. The cost of food will also increase. The law needs to set theintention.?Be aware of what can harm people. If you are a food business, then you are liable if you hurt somebody”.

“This law encourages avoiding packing food not increasing safety.?Industry has ignored the policy makers, so the law is pretty impractical. It's hard for the general public (including people working in food, policy makers and consumers) to understand allergies, the law, or labels)”.?

“This should be rectified when the new calorie labelling law comes into force in April 2022”.?-?No, it will not - the calorie labelling legislation will only require 'calories' to be shown and only then in limited places (companies with 250 staff or more) - full 'nutritional' data - protein, fat, carbohydrate etc. needs to be either labelled in this country or placed in close proximity to the food or on menus or diabetics will not be able to calculate their insulin dosage - calorie counting is one thing if you are on a diet, but your actual health in terms of staying alive is another. It will not, in my opinion do anything for the obesity problems we face - education and training will do far more - even the NHS struggles with calories/nutrition etc. (personal experience here…).

“In the meantime, the proactive approach will be for responsible business leaders to make decision?to "get out in front" by independently implementing updated labelling that includes full nutritional?data on all foods. Then this will clearly demonstrate that those are the organisations who truly?place the health and safety of their customers at the top of the agenda.?Both groups are many and on an immeasurable scale. They both cry out for the same thing,?transparency, and accessibility of information about what is in food”.?

“Even some EHOs don't see the vast proportion of people using allergy information as a guide for?their own health. Or are scared of getting sued too. There are also many impacts on health through?stress and social exclusion, common to all dietary preferences. Avoiding a certain food is extremely?difficult, even if you know the law inside out, it's antisocial, impossibly time consuming or unreliable?to ask in a lot of scenarios”.?

“Actually, the most complacency I ever faced from a restaurant manager was a graduate food tech?MSc, she ate over the buffet with her hands and didn't understand the need for soap and hand?towels at a kitchen hand wash basin. Complete minger. But she definitely knew about bacteria. She?has a fancy certificate. No common sense, or manners (at least for her role).?I won't eat there!?That's how it should work, but it's not obvious, even the FHRS and SSFB don't mention allergies,?Barely”.?

I have now written to all major supermarkets and, so far, received just 3 replies - they all say the same - “we comply to legislation, but take on board what you say”... not one of them has enough commercial sense to see that if they did label comprehensively, they would gain more trust, be seen to be transparent and gain a lot more customers from the affected groups (4.9 million diabetics alone).?

The UK company who started all this by failing to add an allergens label to a sandwich (remember - this was law at the time), still do not label products outside of the UK - why? Because they are not forced to - really caring company even after all that has gone before - some people never learn - ignorance and complacency is rife... (N.B. the FIC directive is EU in origin - Paris is in the EU but still does not care enough to safeguard its people or force food supply companies to).

I have also written to all national newspapers (including specific reporters and editors-in-chief) with so far only 1 response, and even this has not progressed - they were all fast enough to promote “Natasha’s Law” when it suited their circulation figures though - the FSA has still not responded, even after multiple attempts - Diabetes UK did respond but with a politically correct response after numerous messages.?

I have also written to my MP, Robert Jenrick, who informs me that he has a meeting planned with ministers at DEFRA to discuss this issue - no further information on this.

I have also written to Jo Churchill MP,?Parliamentary Under-Secretary of State for Vaccines and Public Health?but also as yet, have had no response.?

We now live in a world where we?expect?the McDonald’s, KFC’s, Burger Kings etc. to give us this level of detail. If we were looking to have the same repetitive and generic experience though, we would?always?go to the franchise restaurants. This is about our?one-of-a-kind, locally owned restaurants. Now more than ever we need to support our local restaurants, but we also need you to meet us halfway, because for those impacted by food allergies, diabetes, or other food vulnerabilities, you’re just not making it any easier for us. *

Restaurants, bakeries, street vendors etc. have the potential to convert families impacted by food allergies, diabetes, and other food vulnerabilities, from one-time visitors into some of their most loyal customers. This unique community has the potential to be a word-of-mouth marketing powerhouse, but these venues need to win them over first. *

There are 4.9 million diabetics + 2 million allergy sufferers + another 2 million vulnerable group people in the UK -?

Put people’s health before profits.

Put knowledge before ignorance.

Put training before ineptness.

Put commitment before complacency.

The labelling legislation needs to change to a simple format - if it’s food - label it regardless of packed, pre-packed, loose or on a plate...

* with thanks to Katie L. Moreno for her (slightly amended) but inciteful comments.