Saxon Genitive or adjective

When does a noun can be used as a adjective avoiding the use of saxon genitive? I am writing a tittle that states: "FDA's, EPA's, and TTB's regulations", but I would like to avoid using the saxon genitive (if possible) because the tittle looks longer and more complicated. I would prefer to say "FDA, EPA, and TTB regulations." Is the second sentence correct? Can we use FDA, EPA, and TTB as if they were adjectives?

Note: FDA, EPA, and TTB are US Regulatory Agencies.

Thank you,

No, you cannot use things like FDA as adjectives: there is no such thing as **FDAer regulations* or **FDAest regulations* — nor can anything be **very FDA*, or **more FDA* than another any more than regulations can ever "be" FDA. So it is not acting as an adjective there.

However, even though they cannot be adjectives, it’s perfectly fine to use them as attributive nouns instead: FDA regulations.

In noun phrases like — well, like noun phrases, for example — the noun noun is there acting as an attributive noun, not as an adjective.

Similarly in the first words in each pair of words in chicken soup, paper tiger, house boat, windshield wipers, bus stop, England team, and moon rover.

In contrast, the first word in each of these pairs is actually acting as an actual adjective here: hot soup, Bengal tiger, lost boat, disposable wipers, fast stop, English team, and lunar rover.

For extra fun, compare the job of running in all three of running water, running shoes, and running scared. Only the first of those is normally considered an adjective, while the second is a gerund (and so a noun) and the third is even more verbal no matter how to you read it.

A good but simple test for all this is to try to apply the X=Y formula given a pair like X Y. If it works, then X is acting like an adjective and if not, it isn't. So while we can say that in the case of running water that the water is running, you cannot analogously say that the shoes are running, let alone that scared is running.

In the same way, with hot soup, you can say that the soup is hot, but with chicken soup, you cannot say that the soup is chicken. Using the X=Y test on FDA regulations, we can see that FDA must be acting as a noun not acting as an adjective, since you cannot say that the regulations are FDA. Now, if they were federal regulations instead, then the first word would indeed be acting as an adjective, since you can certainly say that the regulations are federal.

I think the classification of the part of speech of words like "FDA" is actually not necessarily as simple as tchrist indicates, but in any case, "FDA, EPA, and TTB regulations" is entirely correct and preferable to "FDA's, EPA's, and TTB's regulations".

The genitive ending -'s is usually preceded by an entire noun phrase

In English, the most common and productive construction using the "genitive" form is to use an entire noun phrase as a determiner. This means that there should be a valid noun phrase, not just a noun, before the 's.

Acronyms for organizations may take the definite article when used as noun phrases (it's complicated)

Because of this, "FDA's, EPA's, and TTB's regulations" sounds a bit odd to me (and likely to a number of other people) because there are many people who don't generally don't use "FDA" as a noun phrase by itself: we use the definite article and talk about "the FDA".

However, thes situation is complicated because there is a fair amount of variability in the use of the definite article with acronyms for organizations like this: see the question Is it proper to use "the" before the name of a government organization? for some discussion, and note that the websites of these organizations illustrate the difficulty:

• the FDA website does contain examples of "the FDA" being used: 1, 2, so apparently whoever is in charge of setting or enforcing style guidelines for documents on the website considers it acceptable style to use the definite article before "FDA".

• the EPA website has a number of examples of "EPA" used without a definite article to refer to that organization (e.g. "EPA is proposing to repeal the CPP and rescind the accompanying legal memorandum"), although there is at least one example of it being used with the definite article that may have slipped through whoever checks to make sure things conform to their style guide:

  The President's proposed budget outlines EPA's planned program activities for fiscal year 2019 (October 1, 2018 to September 30, 2019) and associated resource requirements.

  The proposed FY 2019 budget for the EPA provides $6.146 billion to support the Agency’s new FY 2018 – FY 2022 Strategic Plan and mission of protecting human health and the environment. This budget maintains core environmental protection with respect to statutory and regulatory obligations, and provides the direction and resources to return the EPA to its core mission of protecting human health and the environment. This can be accomplished by engaging with state, local, and tribal partners to create and implement sensible regulations that also work to enhance economic growth.

  (FY 2019 Budget)

• the "About US" page on the TTB website uses "TTB" without a definite article to refer to that organization

Based on this, if you used the genitive, the proper form might be something like "the FDA's, EPA's, and TTB's regulations". But you can avoid the complication of figuring out whether to use a definite article before "FDA", "EPA" and "TTB" by using the non-genitive construction.

"Noun adjuncts"/"Attributive nouns"/nouns "used as adjectives"

As I said at the start, "FDA, EPA, and TTB regulations" is indisputably correct, but it is more difficult to determine what the part of speech of "FDA" is in this construction. There are some issues with the criteria that tchrist uses to argue that these are not adjectives.

• Gradability: tchrist points out that "FDA" cannot be used in comparative or superlative constructions, or preceded by the adverb "very", which can be summarized by saying that it is not gradable. However, as Cerberus mentions in the comments, not all adjectives are gradable. Most adjectives can be "coerced" into being gradable, but there are some that seem highly resistant to this; for example, former and next: we can't say more former, the most former, very former or more next, the most next, very next. (Etymologically, the adjectives former and next in fact oringate from comparative and superlative forms, which gives us a historical explanation for why they don't themselves have comparative and superlative forms, but in present-day English they aren't easily classified this way.)

• Predicability: another criterion tchrist mentions is the ability to use a word as a predicate. It is indeed true that most adjectives can be used as predicates such that "an adj noun" is pretty much equivalent in meaning to "a noun that is/was adj".

  However, not all adjectives work this way. The adjective former that I mentioned above is not commonly used as a predicate ("a former president" != *"a president who is former"); Edwin Ashworth's answer to Name for when an adjective modifying a noun leaves the class of objects the noun describes mentions a few more examples such as "an alleged criminal", "a mere youth", and "a heavy smoker".

Otto Jespersen's Modern English Grammar on Historical Principles, Part II: Syntax, Volume 1 (1914) discusses this problem and has a good overview of some relevant issues, including some that have not been mentioned yet.

• stress: in some circumstances (although not necessarily all), the stress of a noun phrase written with spaces can indicate that it is not a compound; for example, the English noun phrase "a stone wall" can be pronounced with the main stress or accent on "wall", which differentiates it from German Steinmauer which, aside from being written together, is definitely pronounced with stress on the first element, or from the English compound verb stonewall (or the compound place name "Stonewall" as in "Stonewall Inn") which also must be stressed on the first syllable, in accordance with the rules for stressing English compound words.

  I think that the noun phrase "FDA rules" can be pronounced with the main stress or accent on "rules", so it seems to me that we should say that "FDA" can be used attributively outside of compounds.

  (Also, it is clearly possible to use "FDA" before adjectives: "FDA advisory panel", "FDA advisory committee", "FDA regulatory requirements".)

  The "compound or not compound" issue is actually distinct from the "is the first element an adjective or a noun?" issue, however.

• Coordination: often, what Jespersen calls "first-words" may be coordinated with adjectives, or may come before adjectives.

  There are examples of FDA being used in coordinate structures containing adjectives:

  • As part of the agreement between FDA and European officials

  • the notion of gaining FDA and European approval via the European Medicines Agency (EMA)

  Coordination is complicated and not foolproof evidence for part-of-speech, but this does seem to provide some support to the idea that "FDA" is acting like an adjective in this construction.

• Use of one: sometimes, the "prop word" one, which is typically used after an adjective to make a noun phrase (as in "a good one"), can be used after a "first-word": Jespersen gives, among other examples, "both the quack theory and the allegory one" (p. 317).

  While "FDA one" doesn't seem to be common, I did find some examples on the web (not from any reputable sources, but it's still worth something as linguistic evidence):

  • I would personally trust a university study over an FDA one in the U.S., however, to use an analogy.

    ("Can This Medicinal Herb Remove Fluoride from the Water Supply?", by Nick Meyer, AltHealthWORKS)

  • Good article , but the patent to which the author linked lapsed a long time ago, so it's not even an intellectual property issue, just an FDA one. (comment by LexPatriae, Aug 24 2016, on "The Lack of EpiPen Competitors is the FDA's Fault" at www.reddit.com/r/Anarcho_Capitalism)

Jespersen's conclusion (p. 325) is that

• "first-words" that can take the endings -er, -est or -ly, -ty, -try, -ness are clearly adjectives

• other kinds of "first-words" may have an "approximation to, rather than the full attainment of, the adjectival status"; Jespersen calls these substantival adjuncts (p. 327)

Anyway, this is a rather long explanation, but the important point is that

• it's absolutely fine to say "FDA, EPA, and TTB regulations"

• some people might not agree that this constitutes using "FDA, EPA, and TTB as if they were adjectives", but the situation is a bit unclear

• In fact, using this construction lets you avoid dealing with the issue of whether or not to use a definite article before acronym like "FDA" when you are using it as a noun phrase (the genitive construction is standardy based on attaching -'s to the end of a noun phrase, then using the resulting genitive phrase as a determiner)