Doesn’t this open up the market for a newcomer to make verified sesame-free bread?
When FDA declares a new allergen, the top lawyer of the company that has presence from NY to SF seats down with the CEO, they then ask all the manufacturing units to do an audit of the said allergen use and then hire a third party auditor to verify if the allergen is used at all not just at their retail locations but in the entire supply chain. This involves the place where wheat is harvested to the restaurant where the bread is served. For a large company this is a millions of dollars and several quarters of project.
The lawyer and CEO needs to chalk out the plan. If they want to make sure their bread does not contain the said allergen they have to update all their processes right from where they buy their wheat to where they test their bread for the said allergen and retrain their staff, suppliers, QA etc. this adds millions of dollars in additional expenses per year.
Not only all this is complex that makes the bread expensive for EVERYONE, it is also much more prone to error.
It is much easier for your small local company to provide sesame free bread at slightly higher price to those who need it. You wont get it in the middle of death valley but that is fine.
The FDA was expecting that companies spend millions to ensure that the products are free of sesame to help people with allergies, but companies realize that it's easier to just add sesame into their products.
I am not sure the government could do now to help people with sesame allergies. Ban sesame outright from certain products? Mandate that certain companies produce sesame-free products?
Its not like adding small amounts of an allergen is a victimless. Lots of people with moderate to serious allergies eat things every day which "may contain" their allergen.
Eg: transaction structuring which is illegal in most places.
Bread is made fresh every day, has a shelf-life of 3 days tops. The logistics are usually measured in hours. The effort to scrub the bakery, transport the gluten-free/nut-free/whatever every day, seperated is thus non specialized and a huge cost in addition to a production of a small facility. So you can get gluten-free bread by a industrial facility speacilized on it, wrapped in plastic. But you can not get it from your local bakery chain.
Add to that the legal damocles swoard hanging over you and mixed artisanal production of small quantities becomes fiscally irresponsible for small buisnesses. In theory you could open a bakery, tailored to a specific allergy set in a dense urban environment. But the rest of the world, a drive away from you, will not have that option.
Case in point: Italy has a wheat-rich cuisine and they give up to 140€ per month to people with Celiac disease to offset the higher costs of gluten-free food:
https://www.euronews.com/my-europe/2019/03/08/the-rise-and-r...
"Fine. Now _everything_ has Sesame in it. What are you going to do? _Settle_ with us?"
I know there's a lot of things that work like this (handicap ramps for instance) but if you don't draw a line somewhere it does get overly expensive.
If sesame is in fact poison for a specific subgroup, this shifts the mass market option from “eh it’s probably fine, how often does cross-contamination happen” to “definitely poison for me, I’d better seek an alternative.”
It’s lifesaving to those that do.
Somehow bakeries in Switzerland are doing just fine with sesame being a declared allergen and keeping them separate but American ones just can’t be bothered to handle a life threatening ingredient thoroughly carefully.
It’s just impossible because US scale /s
If it weren't for companies acting in bad faith, they wouldn't have to play regulator cat and mouse. If you removed the regulations altogether, your big bakers would be even more lax with allergens and people would get sick.
As long as making sesame bread is allowed while making bread without sesame is prohibitively expensive (because you need to ensure there are not even trace amounts present) it's obvious what most companies will choose.
It is clear what the outcome of the regulations was supposed to be, products with sesame and products without. But they were poorly planned regulations, and the companies are more than happy to work to the letter of the law.
But maybe this is actually fine, because a company willing to cleanly process allergen free product can capture that market segment.
Having wheelchair ramps at corners, especially new ones, big chains, large institutions, seems great. Forcing the new 1 person boutique down the street to spend $250k+ to add every possible accommodation for language and accessibility, doesn't seem so great.
There are tons of stories of effective extortion over "accessibility" issues
Your comment also suggests the same solution for the bread. If you don't like that there is sesame in it then you should build a robot to remove the sesames. That's the same as saying "I didn't translate my text for you but you can find some other way to get it translated".
(And note that in some cases "new" construction must work with existing constraints. I'm thinking of a sign I saw in Carlsbad Cavern saying no wheelchairs past this point. The loop that was denied wheelchairs contained a pinch point a wheelchair couldn't go through. Man made the path, nature put the rocks there.)
Are you saying these are examples of over-regulation?
> You need to judge over-regulation as it relates to society as a whole.
That doesn't seem to be a heuristic. E.g. "wheelchair ramps are cheap over the lifetime of a building, so it's obvious we should add them" is a good justification of something not being over-regulation - the "bang for buck" heuristic. But the quoted text doesn't contain a heuristic, so we can't judge anything based on it.
Serious question as a non native english speaker, is this a correct way of saying it?
I think bread is usually baked in an oven ..
(some bread you can also make in a pan, but you cannot cook bread in my understanding)
But in the broader sense, it seems to also mean the preparing of meals, but I never encountered it like this.
"Kochen (von lateinisch coquere, „kochen, sieden, reifen“ entlehnt) ist im engeren Sinne das Erhitzen einer Flüssigkeit bis zum und am Siedepunkt, im Weiteren das Garen oder Zubereiten von Lebensmitteln allgemein"
"es kocht" literally means, it is boiling.
the problem with 'cooking bread' is that 'baking bread' is a set phrase, not that baking doesn't count as cooking
The wider meaning is pretty common in German to the point I find it hard to believe any native speaker wouldn't ever have used "kochen" to refer to something other than literally boiling water.
edit: and a rice cooker is definitely not a small oven.
Baking is more of a evaporation.
And the german definition of cooking in the narrow sense is defined like this, but in a broader sense apparently usable for everything with preparing meals.
And I never used a rice cooker, so no idea how to classify that ..
To the rice cooker point, I'd argue that an oven uses a heating element of some form (electric coils, gas flame, wood fire) to heat the air in a closed environment, and the air transfers heat into an item. In contrast, a rice cooker uses a heating element to directly heat a metal pot, and the metal pot transfers heat into an item. Usually that's going to be a combination of rice and water, but you can e.g. pour pancake batter into the pot and get a large souffle pancake, or put bread dough into the pot and get a loaf of bread. The trick is that the metal pot is much more efficient at transferring heat than the air is, so the rice cooker doesn't need to be at the same temperature as an oven to get the same amount of heat into whatever you're cooking.
In german you would not, one would roast it. (but we have 2 words, roasting "rösten" on the bbq and "braten" would be in a pan. But a "Braten" would be in an oven.)
Kind of not that consistent (like it usually is with natural language).
In general I think those terms were invented, before there were things as a rice cooker.
On the other hand, "cooking bread" is like 2/10 weird.
I'm not sure what the difference is, except the US goes one step further and asks "please don't say it may have an allergen if you don't have to". It results in products definitely having the allergen, but is "may contain" any better than "definitely contains"?
> In Switzerland, there are also the following rules regarding trace allergens when declaring allergens: in the event of possible contamination of more than one gram per kilogram of food, the note "May contain traces of ..." must be included. The limit for sulphur is 10 milligrams per kilogram and for gluten 200 milligrams
It sounds like Switzerland does the same thing the US used to do where manufactures have a lazy cop-out? It doesn't sound any stricter at all.
One gram per kilo for sesame is not hard.
I have had a rather unpleasant day due to an unknown contaminant in approximately 10mg of material as part of a day's food. Obviously the contaminant was well under 10mg.