[DRAFT 9][FINAL] Allergen Labelling Standards

[States of Glory WA Office]

"The honorable Ambassador from Draconae's suggestions have been implemented. If there are any final objections, speak now or forever hold your peace."

Neville: We have a problem with Clause 6b.

Fairburn: Hold on a minute! You're not officially assistant yet!

Neville: I'll deal with the paperwork later. Anyway, it is a common practice for foodstuffs that do not contain allergens per se to be manufactured in the same locations as foodstuffs that do indeed contain allergens. For some individuals, their intolerance complications are so severe that any risk of cross-contamination with allergens must be appropriately signposted so that they may err on the side of caution. Clause 6b, to our understanding, prevents this. Is this intentional?

[Folik]

We 100% support this. Safety should ALWAYS trump sovereignty and we find those complaints laughable.

[Araraukar]

Fairburn: Hold on a minute! You're not officially assistant yet!

OOC: Neither is Fairburn officially ambassador yet either, according to your siggy.

IC: *rolling one of the drafts into a tube, Janis starts shooting dried peas at Fairburn*

[Capercom]

I concur with States of Glory WA Office in regards to the issues with:

6. REQUESTS that WAFDRA avoids, when at all possible:

a. Unnecessarily placing warning labels on products consisting entirely of an ingredient harmful to those with food tolerance complications, such as nuts and milk.
b. Placing labels that are vague, for instance, labels stating that a product “may contain” an ingredient harmful to those with food tolerance complications.

Food products share facilities with each other in almost every nation. A company that makes trail mix that includes nuts of all kind, may also package sunflower seed bags. Due to the extreme sensitivity/intolerance some may have to, say peanuts, it is not even worth the risk to eat that bag of sunflower seeds, as it was made in a factory that contained peanuts.

The companies are not doing it to be "vague", they are doing it because "Product may contain nuts" is an easier read than "Peanuts are used in this facility 200 yards and 4 doors away from the ingredients in this package, but in case you have a crazy severe allergy, we wanted to let you know this may have some peanut dust that could kill you."

If there were explicit guidelines on what needed to be said in each instance of potential threat to allergen contamination, determined WAFDRA, then that would be different. But to just state "avoids...placing labels that are vague, for instance, labels stating that a product "may contain" an..." only hurts the people you're trying to protect.

WA also does not have the funds, nor the desire, to pay every company to help build completely brand new facilities for each ingredient packages, which is what would have to happen under this Proposal due to 6b, or millions of businesses across the world would have to choose which product to stop making so their factories could be compliant or face bankruptcy/closure.

Without the re-examination, re-drafting, or deletion of Article 6, you do not have the support of myself and the nation of Capercom.

(edits: spelling)

[Jarish Inyo]

This is still flawed and leaves a way for nations like mine not to have to follow this resolution and still be in compliance with it.

[Uan aa Boa]

Neville: I'll deal with the paperwork later. Anyway, it is a common practice for foodstuffs that do not contain allergens per se to be manufactured in the same locations as foodstuffs that do indeed contain allergens. For some individuals, their intolerance complications are so severe that any risk of cross-contamination with allergens must be appropriately signposted so that they may err on the side of caution. Clause 6b, to our understanding, prevents this. Is this intentional?

I believe that provision was added at my suggestion. It is my belief that, given the opportunity, manufacturers will seek to evade any liability by issuing a uniform warning that any and all products "may" contain any and all allergens. While no doubt protecting the manufacturer from litigation, this has the effect of providing no useful information to a person with an allergy, forcing them to avoid all manufactured foods. This entirely defeats the spirit of the proposal.

With clause 6b in place, governments will be able to require that manufacturers give a clear statement on whether or not their products contain allergens and hold them to account for cross-contamination, causing them to improve their practices rather than shift their responsibilities onto citizens.

[States of Glory WA Office]

With clause 6b in place, governments will be able to require that manufacturers give a clear statement on whether or not their products contain allergens and hold them to account for cross-contamination, causing them to improve their practices rather than shift their responsibilities onto citizens.

Neville: What if a clear statement is made in good faith that no allergens are present yet unavoidable cross-contamination occurs, resulting in a dangerous allergic reaction? If such a situation occurs, our government will be sure to hold your nation accountable.

[Capercom]

With clause 6b in place, governments will be able to require that manufacturers give a clear statement on whether or not their products contain allergens and hold them to account for cross-contamination, causing them to improve their practices rather than shift their responsibilities onto citizens.

So you're suggesting every nation has its entire food industry uprooted, instead of providing some sort of regulation requiring specific verbiage for potentially cross-contaminated products.

What you're asking of the food industry is almost impossible. To truly have a guarantee so you can "give a clear statement on whether or not their products contain allergens" means literally 0 potential allergens in the same air space as other foods. Ever.

Your employee wants to bring in peanuts for lunch? He/she needs to never carry them into the same building as food production, needs to change his/her clothes and wash his/her hands thoroughly before walking into an airlock chamber that sterilizes the air, before he/she walks into work. Once he/she wants to eat said peanuts for lunch, he/she has to reverse the entire process previously stated so he/she can get out of the building to get his/her lunch, to then repeat the entire sterilization process again, after also thoroughly brushing his/her teeth post-meal.

Once again, literally (definitionally, not slang) not feasible for companies to be "clear" and specific, without spending millions of currency in each nation.

This. Will. Not. Work.

Capercom still stands behind and fights for people who have all range of intolerance to allergens. I just have to be realistic, and this isn't the best way to aid those people.

[Whovian Tardisia]

This is still flawed and leaves a way for nations like mine not to have to follow this resolution and still be in compliance with it.

"As previously stated, either explain or shut up, Ambassador!" Ambassador Pink snapped. "You have been trying my patience and not been any help throughout this entire process. I insist that you vacate the chamber at once!"

Ignore cannon fired. You have been warned, not just by me, that your statements are not helpful and unwelcome. I'm not a mod, but I feel like I'm being flamed here. Knock it off.

"Sorry about that." Ambassador Pink continued, calming himself. "Now, the topic at hand:"

Neville: I'll deal with the paperwork later. Anyway, it is a common practice for foodstuffs that do not contain allergens per se to be manufactured in the same locations as foodstuffs that do indeed contain allergens. For some individuals, their intolerance complications are so severe that any risk of cross-contamination with allergens must be appropriately signposted so that they may err on the side of caution. Clause 6b, to our understanding, prevents this. Is this intentional?

"This was not intentional. However, we stand by the fact that this can be a sneaky way for companies to waive liability. We may need to think of a compromise."

*rolling one of the drafts into a tube, Janis starts shooting dried peas at Fairburn*

Had Ambassador Pink not known Miss Leveret and her work as well as he did, his current mood may have caused him to flare up again. However, he understood somewhat her mischievous nature, and simply shot her a quick, disapproving look before continuing.

The companies are not doing it to be "vague", they are doing it because "Product may contain nuts" is an easier read than "Peanuts are used in this facility 200 yards and 4 doors away from the ingredients in this package, but in case you have a crazy severe allergy, we wanted to let you know this may have some peanut dust that could kill you."

If there were explicit guidelines on what needed to be said in each instance of potential threat to allergen contamination, determined WAFDRA, then that would be different. But to just state "avoids...placing labels that are vague, for instance, labels stating that a product "may contain" an..." only hurts the people you're trying to protect. ...

...Without the re-examination, re-drafting, or deletion of Article 6, you do not have the support of myself and the nation of Capercom.

"The suggested guidelines sound reasonable. Perhaps in the form of a 'Cross-Contamination Risk Factor'? This will be noted."

[States of Glory WA Office]

"As previously stated, either explain or shut up, Ambassador!" Ambassador Pink snapped. "You have been trying my patience and not been any help throughout this entire process. I insist that you vacate the chamber at once!"

Fairburn: Might I suggest defenestration as an option?

*rolling one of the drafts into a tube, Janis starts shooting dried peas at Fairburn*

Um...are peashooters covered by the Nullifiers?

[Jarish Inyo]

This is still flawed and leaves a way for nations like mine not to have to follow this resolution and still be in compliance with it.

"As previously stated, either explain or shut up, Ambassador!" Ambassador Pink snapped. "You have been trying my patience and not been any help throughout this entire process. I insist that you vacate the chamber at once!"

I don't have to do either. But I'll give you a hint. You are assuming something. And that something determines if a nation has to anything more then a survey. Assuming the citizens will even answer the survey to begin with. I can't be the only one that sees the flaw.

[Araraukar]

*rolling one of the drafts into a tube, Janis starts shooting dried peas at Fairburn*

Um...are peashooters covered by the Nullifiers?

OOC: Not a potentially lethal attack, so probably not. You can, of course, decide if she actually hits him. You might've been away, but presuming freeze-frame pause and resume, her annoyance with Fairburn hasn't gone anywhere.

I can't be the only one that sees the flaw.

OOC: No, but you're the only one that keeps bringing it up. Either point it out to them if you want them to correct it, or keep silent and let them try to pass it with the loophole so you can take advantage of it.

[Jarish Inyo]

Um...are peashooters covered by the Nullifiers?

OOC: Not a potentially lethal attack, so probably not. You can, of course, decide if she actually hits him. You might've been away, but presuming freeze-frame pause and resume, her annoyance with Fairburn hasn't gone anywhere.

I can't be the only one that sees the flaw.

OOC: No, but you're the only one that keeps bringing it up. Either point it out to them if you want them to correct it, or keep silent and let them try to pass it with the loophole so you can take advantage of it.

Very good point. There isn't any reason for me to help the author either close the loophole or get them to figure out the loopholes on their own.

[Capercom]

"The suggested guidelines sound reasonable. Perhaps in the form of a 'Cross-Contamination Risk Factor'? This will be noted."

I'm glad we can discuss conflicting viewpoints on matters and still try to make a positive change on the world!

OOC: As someone whose girlfriend and mother both have a crazy list of food allergies (girlfriend can't eat any hint of wheat, tomato, potato, onion, garlic, peppers amongst other things), this is an important topic in my daily life, so I may seem more emphatic about this than other proposals. My fear would be in real life, which is not what NS/WA is I know, but my fear would be that imposing such items listed in the Proposal on corporations would lead to further shady practices, not the betterment of the allergic people, regardless of what laws would be in place to punish them for such acts if found out.

[Uan aa Boa]

Neville: What if a clear statement is made in good faith that no allergens are present yet unavoidable cross-contamination occurs, resulting in a dangerous allergic reaction? If such a situation occurs, our government will be sure to hold your nation accountable.

If a manufacturer in your nation made a clear statement in good faith that their product did not contain cyanide, but it turned out that it did, would prosecutions not follow?

The companies are not doing it to be "vague", they are doing it because "Product may contain nuts" is an easier read than "Peanuts are used in this facility 200 yards and 4 doors away from the ingredients in this package, but in case you have a crazy severe allergy, we wanted to let you know this may have some peanut dust that could kill you."

Your faith in corporate integrity is touching. In reality, however, life threatening allergies are rare enough that losing the business of all sufferers is cheaper than both taking precautions against contamination and the risk of litigation. Concern for the consumer has nothing to do with it.

[States of Glory WA Office]

Neville: What if a clear statement is made in good faith that no allergens are present yet unavoidable cross-contamination occurs, resulting in a dangerous allergic reaction? If such a situation occurs, our government will be sure to hold your nation accountable.

If a manufacturer in your nation made a clear statement in good faith that their product did not contain cyanide, but it turned out that it did, would prosecutions not follow?

Neville: I am not aware of the biology of your species, but for us humans, I'd imagine that there would be little variance in how we react to cyanide, not to mention that a food company has hardly any business handling cyanide in the first place. On the other hand, there is much variety in how people react to allergens even among those who have allergies and it isn't out of the ordinary for a food company to handle peanuts.

[Bears Armed]

not to mention that a food company has hardly any business handling cyanide in the first place.

OOC: There are traces of cyanide occurring naturally in apple pips, peach stones, apricot stones, and some other seeds of edible fruit.

[Draconae]

"The honorable Ambassador from Draconae's suggestions have been implemented. If there are any final objections, speak now or forever hold your peace."

OOC: What exactly did you change between your forth and fifth drafts? I can't really see much.

b. Placing labels that are vague, for instance, labels stating that a product “may contain” an ingredient harmful to those with food tolerance complications.

"Perhaps you could add 'unless contamination of a food with said ingredient is likely'?"

[Whovian Tardisia]

"The honorable Ambassador from Draconae's suggestions have been implemented. If there are any final objections, speak now or forever hold your peace."

OOC: What exactly did you change between your forth and fifth drafts? I can't really see much.

You didn't request much. Simply the wording changes in the subclauses of Clause 3 and replacing every ampersand with the word "and".

b. Placing labels that are vague, for instance, labels stating that a product “may contain” an ingredient harmful to those with food tolerance complications.

"Perhaps you could add 'unless contamination of a food with said ingredient is likely'?"

"That would be the simplest way around it, but the lack of utility the label holds is still a concern. We feel a Contamination Risk scale would be more useful for the consumer, allowing those with severe food tolerance complications to be better informed of a food's risk, or lack thereof, to their health."

[States of Glory WA Office]

not to mention that a food company has hardly any business handling cyanide in the first place.

OOC: There are traces of cyanide occurring naturally in apple pips, peach stones, apricot stones, and some other seeds of edible fruit.

Well, yeah, but fruit doesn't tend to be processed in factories (I'm using the phrase 'tend to' because I know that someone is going to link me to a Wikipedia page about factory-produced Granny Smiths or something like that).

[Araraukar]

Well, yeah, but fruit doesn't tend to be processed in factories

OOC: I'm fairly sure that fruit are processed and canned in factories to produce canned fruits...

[States of Glory WA Office]

Well, yeah, but fruit doesn't tend to be processed in factories

OOC: I'm fairly sure that fruit are processed and canned in factories to produce canned fruits...

OOC: Apart from your spoiler tag fail...

Really? Canned fruit is a thing? I mean, OK, I've heard of canned pineapples, and canned tomatoes may or may not count as fruit (though I don't want to open that can of worms *ba-dum psh*) but canned pears? Why?

[Imperium Anglorum]

Really? Canned fruit is a thing? I mean, OK, I've heard of canned pineapples, and canned tomatoes may or may not count as fruit (though I don't want to open that can of worms *ba-dum psh*) but canned pears? Why?

OOC: Literally anything to do with canned anything is the fact that it can be easily transported and easily keeps.

[Araraukar]

OOC: Apart from your spoiler tag fail...

OOC: *cough* Too much of writing replies with hand-written code...

Really? Canned fruit is a thing? I mean, OK, I've heard of canned pineapples, and canned tomatoes may or may not count as fruit (though I don't want to open that can of worms *ba-dum psh*) but canned pears? Why?

Pears, apricots, peaches, pineapple, papaya, mango, mandarin and others. Mainly costs but also availability. Fresh fruit are seasonal, canned fruit are available year-round.

OOC: Literally anything to do with canned anything is the fact that it can be easily transported and easily keeps.

^That too.

[States of Glory WA Office]

OOC: At this rate, the only thing not worth canning is laughter.