4 ms·

> But people with allergies don't disregard the labels, they buy a different product. I have a nut-allergic friend who has given up on reading the labels and r

by lmm 3y ago

> But people with allergies don't disregard the labels, they buy a different product. I have a nut-allergic friend who has given up on reading the labels and relies on his own common sense, because the labels are on everything now. (Worse, if you look at what's happened with sesame, manufacturers now deliberately incorporate sesame into their recipes so that they can put the warning labels on, because that's cheaper than the risk of selling a product that doesn't contain sesame). > If the label was only on products with a significant risk of causing cancer from ordinary use, it would be rare and people wouldn't ignore it. In other words, if it was only on the products that would otherwise be banned. How do you imagine that this might be accomplished? If manufacturers have the choice of a) go through an approvals process b) put a warning label on their product, they're going to pick b, every time. > We didn't ban cigarettes, we informed people of the risk: And the result is that smoking has fallen a lot more slowly than predicted and millions of people have died.

AnthonyMouse 3y ago
> I have a nut-allergic friend who has given up on reading the labels and relies on his own common sense, because the labels are on everything now. There is a difference between containing nuts and being processed on equipment that also processed nuts. The difference matters more for some people than others. > Worse, if you look at what's happened with sesame, manufacturers now deliberately incorporate sesame into their recipes so that they can put the warning labels on, because that's cheaper than the risk of selling a product that doesn't contain sesame This is what happens when you have bad rules. They have a machine which has processed nuts in the past, it isn't cost effective to remove every trace of nuts from it, so they accurately labeled their product as one processed on equipment that has processed nuts. Maybe the trace amounts aren't enough to matter, but the consequences can be dire so they're cautious. Isn't this supposed to be about safety? They only added nuts to the product after you prohibited them from being conservative. And they're being atypically conservative because the "dangerous" label isn't applicable to most of their customers who they then don't have to worry about being deterred. > How do you imagine that this might be accomplished? If manufacturers have the choice of a) go through an approvals process b) put a warning label on their product, they're going to pick b, every time. Why is the company even involved in the process? They produce a new product and it initially gets a label that says it hasn't been tested, which will rightfully deter customers when most existing products don't have that label. The government performs its testing to check if it's harmful, prioritizing based on which new products are expected to be popular, and once published their results go on the label one way or the other. If the company wants to get rid of the untested label or not have it present at release they can pay for expedited evaluation and go to the front of the line, but all popular products get tested relatively quickly and so untested products are suspect, and products evaluated as unsafe then have to be labeled as unsafe. > And the result is that smoking has fallen a lot more slowly than predicted and millions of people have died. As compared to the times when we've prohibited other substances and people all stopped using them immediately?
- lmm 3y ago
  > Maybe the trace amounts aren't enough to matter, but the consequences can be dire so they're cautious. Isn't this supposed to be about safety? Safety should be about safe outcomes, not about maximising the number of warnings. > They only added nuts to the product after you prohibited them from being conservative. And they're being atypically conservative because the "dangerous" label isn't applicable to most of their customers who they then don't have to worry about being deterred. There's nothing atypical about it. They're finding the cheapest way to avoid liability and they genuinely don't care whether that means "being conservative" or poisoning their customers, and it's not going to result in good outcomes for the customers. > Why is the company even involved in the process? They produce a new product and it initially gets a label that says it hasn't been tested, which will rightfully deter customers when most existing products don't have that label. The government performs its testing to check if it's harmful, prioritizing based on which new products are expected to be popular, and once published their results go on the label one way or the other. Presumably you're going to campaign for the massive increase in taxation that would be necessary to enable the government to do testing comparable to what's currently done in any remotely reasonable timeframe? (And some kinds of testing simply can't be done fast - if you want to test for negative after-effects that may take years to show up, there's no way to make that not take years). > As compared to the times when we've prohibited other substances and people all stopped using them immediately? As opposed to market consensus on what was expected. And yeah, frankly, banning substances generally does reduce consumption; not to zero, but to significantly less than without the ban.
- oezi 3y ago
  > Why is the company even involved in the process? They produce a new product and it initially gets a label that says it hasn't been tested, which will rightfully deter customers when most existing products don't have that label. The government performs its testing to check if it's harmful, prioritizing based on which new products are expected to be popular, and once published their results go on the label one way or the other. This a fundamental point of misunderstanding. The government in case of the FDA doesn't test products. They just review the documentation that manufacturers submit. In case of medical devices which are similar to an existing approved medical device (a 410k) for instance the FDA charges $21,760 for this review ($5,440 if you are a small business) and under law has to have the review complete within 90 days. To compare: performing just one of the required tests such as biocompatibility often costs more. The FDA also doesn't write labels for you. That is entirely your responsibility as a manufacturer and frankly impossible without having complete insight into manufacturing and design.

by lmm 3y ago

AnthonyMouse 3y ago

> I have a nut-allergic friend who has given up on reading the labels and relies on his own common sense, because the labels are on everything now. There is a difference between containing nuts and being processed on equipment that also processed nuts. The difference matters more for some people than others. > Worse, if you look at what's happened with sesame, manufacturers now deliberately incorporate sesame into their recipes so that they can put the warning labels on, because that's cheaper than the risk of selling a product that doesn't contain sesame This is what happens when you have bad rules. They have a machine which has processed nuts in the past, it isn't cost effective to remove every trace of nuts from it, so they accurately labeled their product as one processed on equipment that has processed nuts. Maybe the trace amounts aren't enough to matter, but the consequences can be dire so they're cautious. Isn't this supposed to be about safety? They only added nuts to the product after you prohibited them from being conservative. And they're being atypically conservative because the "dangerous" label isn't applicable to most of their customers who they then don't have to worry about being deterred. > How do you imagine that this might be accomplished? If manufacturers have the choice of a) go through an approvals process b) put a warning label on their product, they're going to pick b, every time. Why is the company even involved in the process? They produce a new product and it initially gets a label that says it hasn't been tested, which will rightfully deter customers when most existing products don't have that label. The government performs its testing to check if it's harmful, prioritizing based on which new products are expected to be popular, and once published their results go on the label one way or the other. If the company wants to get rid of the untested label or not have it present at release they can pay for expedited evaluation and go to the front of the line, but all popular products get tested relatively quickly and so untested products are suspect, and products evaluated as unsafe then have to be labeled as unsafe. > And the result is that smoking has fallen a lot more slowly than predicted and millions of people have died. As compared to the times when we've prohibited other substances and people all stopped using them immediately?

lmm 3y ago
> Maybe the trace amounts aren't enough to matter, but the consequences can be dire so they're cautious. Isn't this supposed to be about safety? Safety should be about safe outcomes, not about maximising the number of warnings. > They only added nuts to the product after you prohibited them from being conservative. And they're being atypically conservative because the "dangerous" label isn't applicable to most of their customers who they then don't have to worry about being deterred. There's nothing atypical about it. They're finding the cheapest way to avoid liability and they genuinely don't care whether that means "being conservative" or poisoning their customers, and it's not going to result in good outcomes for the customers. > Why is the company even involved in the process? They produce a new product and it initially gets a label that says it hasn't been tested, which will rightfully deter customers when most existing products don't have that label. The government performs its testing to check if it's harmful, prioritizing based on which new products are expected to be popular, and once published their results go on the label one way or the other. Presumably you're going to campaign for the massive increase in taxation that would be necessary to enable the government to do testing comparable to what's currently done in any remotely reasonable timeframe? (And some kinds of testing simply can't be done fast - if you want to test for negative after-effects that may take years to show up, there's no way to make that not take years). > As compared to the times when we've prohibited other substances and people all stopped using them immediately? As opposed to market consensus on what was expected. And yeah, frankly, banning substances generally does reduce consumption; not to zero, but to significantly less than without the ban.
oezi 3y ago
> Why is the company even involved in the process? They produce a new product and it initially gets a label that says it hasn't been tested, which will rightfully deter customers when most existing products don't have that label. The government performs its testing to check if it's harmful, prioritizing based on which new products are expected to be popular, and once published their results go on the label one way or the other. This a fundamental point of misunderstanding. The government in case of the FDA doesn't test products. They just review the documentation that manufacturers submit. In case of medical devices which are similar to an existing approved medical device (a 410k) for instance the FDA charges $21,760 for this review ($5,440 if you are a small business) and under law has to have the review complete within 90 days. To compare: performing just one of the required tests such as biocompatibility often costs more. The FDA also doesn't write labels for you. That is entirely your responsibility as a manufacturer and frankly impossible without having complete insight into manufacturing and design.