Brian Moore : Failing to engage in the scrum is not an offence...Really?

http://www.espn.co.uk/premiership-2013-14/rugby/story/209873.html
 
Brian Moore has lashed out at Richard Cockerill for apparently failing to know the basics of scrum laws.
 
"There is no offence of not taking the hit or engagement or coming together or anything else. That a former international hooker either does not know this or chooses to invent offences with which to berate all and sundry is risible"
 
Cockerill had accused his teams opposition of stepping backwards during scrum engagements.
 
However the scrum addendum trial law 20.1 says:
 
"Following a pause, the referee will then call "set" when the front rows are ready. The front rows may then engage. The “set” call is not a command but an indication that the front rows may come together when ready. The sanction for any infringement will be a free kick."
 
Law (j) suggests that moving in such a way that the scrum becomes unstable is also a penalty:
 
"(j) Stationary and parallel. Until the ball leaves the scrum half’s hands, the scrum must be stationary and the middle line must be parallel to the goal lines. A team must not shove the scrum away from the mark before the ball is thrown in. "
 
Surely stepping back falls under law (j) and "coming together or engaging" falls under law 20.1 ammendment. Brian Moore is clearly wrong in my mind.
 
I think it's an important one, because I've frequently seen teams penalised for "not talking the hit" in the international game, whether this is used by referees as a convenient euphemism or not.

It wouldnt be the first time Brian Moore has been wrong. He does tend to talk before thinking a lot but he certainly is entertaining.

Brian Moore loves the word risible