FDA orders bakers to list allergens. There are stiff penalties if you are allergenic but don't list the allergen.
So? Bakers claim their product contains allergens, even if they don't.
FDA doesn't like it.
So? Bakers add allergens on purpose, so they can rightly claim it contains them.
It's surreal and awesome.
Ironically, I never even knew this, but apparently the proposition only exists because Jane Fonda thought it would draw left-leaning voters to the polls to hopefully vote for Tom Bradley over George Deukmejian in the 1986 race for California governor. She and the other proponents didn't even think the proposition itself would pass. But the proposition did pass and Bradley wasn't even elected!
This caused a problem when they added Vitamin A to the list of chemicals known to cause reproductive harm since one thousandth of the no effect level is far below the RDA for pregnant women.
Good luck refusing to get off the plane because you see the cancer warning and decide not to risk it.
Everyone ready for a trip to the happiest place on earth?
One of the first things you see walking in...
> The Disneyland Resort contains chemicals known to the state of California to cause cancer and birth defects or other reproductive harm.
…and literally, it may or may not be nuts.
FDA orders bakers to list allergens. There are stiff penalties if you are allergenic but don't list the allergen.
So? Bakers look at their production processes and determine there's a chance that enough allergens get into the product due to cross contamination to list it on the label, just in case.
FDA doesn't like it. They expect the bakers to fix their cross-contamination issues at great expense to themselves.
So? Bakers add allergens on purpose, so they can rightly claim it contains them. It's cheaper than setting up a clean room for every product line.
FDA orders bakers to list allergens. There are stiff penalties if you are allergenic but don't list the allergen.
So? Bakers look at their production processes and determine there's a chance that enough allergens get into the product due to cross contamination to list it on the label, just in case.
FDA doesn't like it. They expect the bakers to fix their cross-contamination issues at great expense to themselves.
So? Bakers add allergens on purpose, so they can rightly claim it contains them. It's cheaper than setting up a clean room for every product line.
FDA doesn't like it.
Which is insane.
I worked in a factory that packaged food, if one product contained an allergen, there was no way you could guarantee that a tiny amount of that allergen wouldn't get into some amount of the next product on that production line. No way. Not any possible way. You can clean all you want, you can do whatever you want, you can mandate whatever procedures you want, but there's just no way. Even if every half-awake half-sober completely uncaring third shift production worker (like 1990's era me) does everything exactly right, which they won't, even if they actually cared to, which they won't.
The FDA is putting manufacturers in an impossible position, and it's insane.
I have food allergies, believe me, I get it. But there's just no way. If a manufacturing facility produces products with tree nuts, someone with an allergy to tree nuts has to treat every product produced in or near that facility as though it contains tree nuts. That's reality.
The FDA is not dealing with reality. The problem here is the US federal government.
An ecosystem of centralized, mass production of baked goods is part of the problem, at least.
>They still exist, and some of them just make plain bread,
Honestly have never seen this, every bakery bakes at least something else that can be described as more than just plain white bread.
I used one for quite a while, even though I don't have any food allergies. I just stopped because I was eating too much fresh out of the oven bread.
I don't think that's right. You don't necessarily need all 2^n kinds of facilities, because there might not be a commercial demand for products needing every one of those combos.
Bread is flour, water, yeast, and heat. It feeds people. It's easy to make anywhere you have those things, which is... almost everywhere.
It doesn't require production lines or manufacturing facilities or packaging or even freight. All those things are artificial contrivances, and if they make it hard to practically address concerns like allergens, then maybe they're not a viable approach to providing foodstuffs after all.
If anything, centralization is the best tool to detect and avoid issues like this. Locally, every decision is completely reasonable. It’s only zoomed out that it doesn’t make sense.
No one is trying to do anything evil. Every step is individually quite reasonable and well within ethical bounds. The issue is that you can produce systems comprised solely of reasonable and ethical decisions that nonetheless yield an outcome that every actor would describe as bad.
That is a useful way to interpret this situation and others, because you don’t waste your time looking for a boogeyman to call Evil and instead it prompts you to zoom out and operate on the bigger picture.
My dream is "game theory" taught in schools, so we can all more productively discuss public policy, etc.
The field of "mechanism design" may interest those to whom this speaks to. From Wiki (https://en.wikipedia.org/wiki/Mechanism_design):
> Mechanism design is a branch of economics, social choice theory, and game theory that deals with designing games (or mechanisms) to implement a given social choice function. Because it starts at the end of the game (the optimal result) and then works backwards to find a game that implements it, it is sometimes called reverse game theory.
It’s a coordination problem.
> How long must it go on
They can last indefinitely at immense cost.
> until we say "No, this is evil."?
Call it evil for as long as you want, especially if you’d prefer it remain unsolved. When you feel like solving it, a different framing will be much more useful.
But I think it's a stretch to say nobody is being evil or unethical, because there's no consensus about what those entail.
Now I'm not saying thats what they did, perhaps they were scumbags, but its possible they did try to do what I said above and had the best intentions.
Asking everyone to "play nice" or "don't be evil" also often does not work in practice. I mean I'd love it if it did, but such is life.
> Use of a ‘may contain….’ statement, or similar, to indicate that the product may contain an allergen as a result of possible cross-contamination, must not take the place of good manufacturing practices (GMPs) in a food business.
> GMPs must be in place to prevent cross-contamination
[1] https://www.efanet.org/news/news/4327-efa-responds-to-codex-...
[2] https://www.fsai.ie/business-advice/labelling/labelling-alle...