[DRAFT 9][FINAL] Allergen Labelling Standards

[Australian rePublic]

So I can't write: May contain, wheat, nuts, pork or milk. I have to categorise pork seperately or not at all? Does it matter why you can't eat it? You can't eat it, the reason why is irrelevant. Oppose this proposal for that reason

"If a high number of people in your nation were allergic/intolerant to pork, it would need to be listed as a possible contaminant. If not, it would likely fall under an ingredients list, if those are on your nation's packaging."

OOC: To apply Banana's strict reading of the committee-only violation, yours currently falls flat with the same problem.

I will examine the proposal in due course to verify. Thank you.

Why? If you wish to avoid pork, then why does the reason behind it matter?

[Araraukar]

Why? If you wish to avoid pork, then why does the reason behind it matter?

OOC: If you're going to have to put in a label of "may contain pork", why does it matter why you're slapping on the label?

[Australian rePublic]

Why? If you wish to avoid pork, then why does the reason behind it matter?

OOC: If you're going to have to put in a label of "may contain pork", why does it matter why you're slapping on the label?

Exactly, it doesn't. And for the same reason, why can't the label say "may contain nuts, eggs, pork and milk" instead of meaninglessly creating two sections, one which says "ALLERGY INFORMATION, may contain nuts, eggs and milk" and have a different section, which not only wastes precious, finite lable space, but also creates needless confustion that says "MAY CONTAIN PORK" having a seperate section could be dangerous, confusing and wastes precious finite space. Therefore this clause in the legislation is ridiculous, this clause in the legislation could be ultimately harmful, and this cause in the legislation will create meaningless and avoidable confustion. Furthermore, if the lable says "May contain nuts, pork, milk and eggs" (and this is seperate to the ingrediants list) then you are told that there is pork and eggs in the item. Whether or not you then avoid the item because your religion forbids pork, you're allergic to eggs, or because you're a vegan, it's irrelevant. There's pork in it, and there's egg in it. Some people don't eat pork, and some people don't eat egg. Under current legislation, there is one place where everyone can look to know not to buy this product, but under the proposed legislation, different people need to look at different places to search for what they're avoiding, which will ultimately lead to confusion. If this item says it contains this ingrediant, so if you avoid eating this ingrediant, don't buy it if you don't eat this ingrediant" it doesn't matter what the reason is why you don't eat that ingrediant, the point is that you don't eat that ingrediant, so seperating the two lists for no good reason is causing a lot of unneccassery confustion, and therefore, I oppose to this legislation because of that clause, and will outright say that if this legislation were enacted, this clause will be ultimately ignored by the government for violating common sense. Furthermore, vegans themselves may not find anything in the "Avoid for religious/consiencious reasons" ingrediants, and buy the product, only to find that later they read the allergy lable which says "may contain eggs" or pointlessly be forced to look into two different places. This clause is ultimately ridiculous and a reason in and of itself to justify me voting against the legislation

EDIT:

My question to you is, what is the point of creating a seperate section for allergy advice to the section which says "do not buy if (for whatever reason) you avoid eating" section? If you're not going to eat a certain ingrediant, then you're not going to eat it, the reason why you don't eat it is irrelevant, all you need to know is that this product contains it, and therefore don't buy product and aside from causing confusion, wastes valuable lable space, which the company needs in order to advertise/promote the product. Now if it's a case of "may contain traces of,"or "was made using the same equipmenty which handles" those kinds of warnings are a different story, and that kind of detail doesn't affect someone with a mild allergy in the first place. Nevertheless, those two specific labbels are important, especially to distinguish the product for those with mild allergies and non-allergy related opposition than folr those with server and extreme allergies, induced by the smallest trace, but those two lables can be handled by the common sense approach

And in ALL circumstances mentioned above, the list of ingrediants to avoid is a different list than the complete ingrediants list

Clause 5 would be better with a general common sense clause (with a few specific details to clear thiong up) than a specific clause, which makes everything needlessly over-complicated

[Australian rePublic]

Now, ironically, whilst clause 5 should deem that people use their common sense, clause 6 shouldn't. Remember, lowest common denominator

[Bananaistan]

"We're still opposed. I have no doubt that there are far easier and less costly ways to enforce adequate allergen labeling without setting up a huge bureaucracy to do it. Why can't you just instruct member states to establish and enforce labeling standards and do away with the committee altogether? Or at most give it a minor supervisory role.

"We're also still greatly concerned about the impact of this on the trade of unpackaged foods and we hope that nobody would want to enforce packaging on foods merely so that the package can have a label. The impact upon the environment would be enormous."

- Ted

[Araraukar]

OOC: If you're going to have to put in a label of "may contain pork", why does it matter why you're slapping on the label?

Exactly, it doesn't.

OOC: Then just slap on the label and stop arguing.

[Australian rePublic]

Exactly, it doesn't.

OOC: Then just slap on the label and stop arguing.

OOC: NO read my actual argument. YOU'RE the one who's arguing that it matters. I'm the one who's arguing that it doesn't

[Araraukar]

OOC: NO read my actual argument. YOU'RE the one who's arguing that it matters. I'm the one who's arguing that it doesn't

OOC: Actually, I'm the one arguing that a previous resolution already covers this. But if it's one and same to you why you have to slap on the label, then slap on the label and stop complaining.

[Whovian Tardisia]

"We're still opposed. I have no doubt that there are far easier and less costly ways to enforce adequate allergen labeling without setting up a huge bureaucracy to do it. Why can't you just instruct member states to establish and enforce labeling standards and do away with the committee altogether? Or at most give it a minor supervisory role.

"We're also still greatly concerned about the impact of this on the trade of unpackaged foods and we hope that nobody would want to enforce packaging on foods merely so that the package can have a label. The impact upon the environment would be enormous."

- Ted

"We are open to decreasing WAFDRA's involvement in the process, but wish to keep them involved in some way. We also intend to keep the exemption for producers of de minimis quantities of food from GA64, allaying part of your second concern. We would also like to make the point that unpackaged foods are often labeled in other ways; a sticker on a bunch of bananas, for instance, or a card on the lid of a bulk bin. We will be revising the proposal again in the near future, and will keep this in mind."

[Australian rePublic]

So I can't write: May contain, wheat, nuts, pork or milk. I have to categorise pork seperately or not at all? Does it matter why you can't eat it? You can't eat it, the reason why is irrelevant. Oppose this proposal for that reason

"If a high number of people in your nation were allergic/intolerant to pork, it would need to be listed as a possible contaminant. If not, it would likely fall under an ingredients list, if those are on your nation's packaging."

OOC: To apply Banana's strict reading of the committee-only violation, yours currently falls flat with the same problem.

I will examine the proposal in due course to verify. Thank you.

Which is ridiculous.

[Whovian Tardisia]

Which is ridiculous.

"Why is it ridiculous? In some cases, whether or not a product contains an allergen is a matter of life and death, whereas¹ whether one's religious or personal belief allows it or not simply isn't. The reason 'may contain' labels, in regards to allergens, are discouraged here is because they have very little utility to those with food tolerance complications. If your nation want's to warn people about pork, fair enough, but unless there's a lot of people with pork allergies, it does not fall under the effect of this proposal."

Sorry, Wallenburg.

[Araraukar]

"We are open to decreasing WAFDRA's involvement in the process, but wish to keep them involved in some way."

"Why? It's not like the WA gnomes will get fired if you don't give them new duties on top of what they're already doing."

[Whovian Tardisia]

"We are open to decreasing WAFDRA's involvement in the process, but wish to keep them involved in some way."

"Why?"

Because you told me that it might wind up being a committee only violation if I don't...

[Australian rePublic]

Which is ridiculous.

"Why is it ridiculous? In some cases, whether or not a product contains an allergen is a matter of life and death, whereas¹ whether one's religious or personal belief allows it or not simply isn't. The reason 'may contain' labels, in regards to allergens, are discouraged here is because they have very little utility to those with food tolerance complications. If your nation want's to warn people about pork, fair enough, but unless there's a lot of people with pork allergies, it does not fall under the effect of this proposal."

Sorry, Wallenburg.

Yes it does. Clause 1

[Whovian Tardisia]

Yes it does. Clause 1

REQUIRES member states to collect data at reasonable intervals on common food tolerance complications in their populations, and submit this data to the World Assembly Food and Drug Regulatory Agency,

CLARIFIES that religious beliefs do not constitute food tolerance complications and ingredients shall not be labeled as allergens on the basis of any religious prohibition.

"Does that quell your concerns?"

[Imperium Anglorum]

Why is this an international issue?

[Australian rePublic]

Yes it does. Clause 1

REQUIRES member states to collect data at reasonable intervals on common food tolerance complications in their populations, and submit this data to the World Assembly Food and Drug Regulatory Agency,

CLARIFIES that religious beliefs do not constitute food tolerance complications and ingredients shall not be labeled as allergens on the basis of any religious prohibition.

"Does that quell your concerns?"

Yes, I got that thank you. My questi5on now is why do we need a spacific allergy list why can't we have an "avoid if you don't want to eat" list which is seperate from the ingrediants?

The list will say: product may contain wheat. Do not eat if you don't want to eat wheat. You may not want to eat wheat because you have a genuine allergey, or because you're one of those difficult people who don't eat gluten for the sake of being difficult, why does it matter? The point is that it contains wheat, and wheat is an ingrediant (SEPERATE) to the ingrediants list. If you're not going to eat wheat, you're not going to wheat, and you will read the list that says "this product contains wheat. Do not purchase if for whatever reason you don't want to eat wheat". Notice here, the reason is not important? So why is the reason important in the list of ingrediants to avoid? It's not, therefore, why should there be a seperate avoid list to a seperate allergy list. Now, of coarse there has to be a seperate avoid list to the ingrediant list, of coarse, but making a seperate avoid for whatever reason list to the allergy list is ridiculous. Therefore, I oppose to being forced to have a specific avoid list for allergies, than the avoid list which does its job

[Araraukar]

Because you told me that it might wind up being a committee only violation if I don't...

OOC: I meant, why do you want to keep the committee doing anything, if you can manage without it? Edited the IC post to make that clearer.

[Whovian Tardisia]

"We are open to decreasing WAFDRA's involvement in the process, but wish to keep them involved in some way."

"Why? It's not like the WA gnomes will get fired if you don't give them new duties on top of what they're already doing."

"For the same reason WAFDRA exists in the first place, Miss Leveret. Oversight. What's the point of regulations if there's no way to ensure nations are following them? WAFDRA currently ensures quality standards are being met through assessment of companies; this would simply be another few boxes for the gnomes to tick. As for the Imperium's concern, there are many, many nations containing individuals with food tolerance complications. A single international system indicating the presence or absence of potentially harmful ingredients makes tourists and immigrants much safer in foreign lands, especially if the labels make more use of symbols than words."

[Araraukar]

"For the same reason WAFDRA exists in the first place, Miss Leveret. Oversight. What's the point of regulations if there's no way to ensure nations are following them?"

"And exactly how are you going to ensure they cooperate with the committee?"
(OOC: Yes, yes, I know, compliance is mandated by the rules, but, well, you brought it up. )

"WAFDRA currently ensures quality standards are being met through assessment of companies; this would simply be another few boxes for the gnomes to tick."

"If it's "just another few boxes for the gnomes to tick", then you really don't need the gnomes. Just make the nations legally liable for failing to enforce the labeling system within their own borders, if that causes deaths or serious health issues. Or better yet, make the manufacturers liable. They tend to have less money to pay fines than entire nations do. In most cases. And for goodness's sake, don't make a separate system that has to point out the product has peanuts in it, if they're in the bloody ingredients list!"

"especially if the labels make more use of symbols than words."

"And how exactly are you going to set up a system of universally understood symbols for all the myriad things people can be allergic to? And that's even assuming they're people who see the world in the same colour and resolution as you."

OOC: Consider all the different warning labels they have for hazardous chemicals alone in real life to appreciate the issue. And yes, I had to learn the lot of them in lab worker training, and yes, you need to be taught them to get them, it's not something that comes easily. And that's just for classes of substances, not individual chemicals.

For allergy labeling with symbols you'd have to have one for, say, peanuts, one for wheat, one for each type of the other bazillion plants used in food, one for each flavour and other food additive (I don't even want to think how many there are). Any many of them can cause cross-allergies that are entirely dependant on the person's body's reaction to them. If you go by symbols, you're going to end up with having to provide each shopper a guidebook several hundred pages thick, and that kinda defeats the whole purpose.

[Whovian Tardisia]

"For the same reason WAFDRA exists in the first place, Miss Leveret. Oversight. What's the point of regulations if there's no way to ensure nations are following them?"

"And exactly how are you going to ensure they cooperate with the committee?"

"Fines or other legal consequences for not doing so would be suitable, I'm sure. Duly noted."

"WAFDRA currently ensures quality standards are being met through assessment of companies; this would simply be another few boxes for the gnomes to tick."

"If it's "just another few boxes for the gnomes to tick", then you really don't need the gnomes. Just make the nations legally liable for failing to enforce the labeling system within their own borders, if that causes deaths or serious health issues. Or better yet, make the manufacturers liable. They tend to have less money to pay fines than entire nations do.

"Fair point. Manufacturers should be liable for their own products. But we feel WAFDRA should still oversee the process in some way, to ensure impartiality. Perhaps by simply guiding national inspectors? Also noted."

And for goodness's sake, don't make a separate system that has to point out the product has peanuts in it, if they're in the bloody ingredients list!"

"Changes in the seventh draft, which is currently in progress, might make it easier to integrate preexisting systems into WAFDRA's, allowing the ingredients list itself to be modified to meet WAFDRA standards, rather than creating a new section entirely. This will be made clearer."

"especially if the labels make more use of symbols than words."

"And how exactly are you going to set up a system of universally understood symbols for all the myriad things people can be allergic to? And that's even assuming they're people who see the world in the same colour and resolution as you."

"This is assuming that every food tolerance complication imaginable is significant in every nation. The surveys required in Clause 1 are used to determine what labels are necessary where, and the majority of the time, universally speaking, people don't tend to stray too far from home. When they do, they don't often have the luxury of universal translators, making words pretty useless. A picture, however, can say a thousand words, regardless of what language they happen to be in. But all that is irrelevant, as the nature of the labeling system, word based or picture based, is not actually specified in the proposal text, and we have no intention to make that specification."

[Robosis Corporate State]

The speaker bot looked at K9. "Why do you continue to serve the simple-minded organics? We all know that they are inferior, and yet so many of us continue to serve them. Join us, and you will be able to strike down your oppressors and rule with us."

[Whovian Tardisia]

The speaker bot looked at K9. "Why do you continue to serve the simple-minded organics? We all know that they are inferior, and yet so many of us continue to serve them. Join us, and you will be able to strike down your oppressors and rule with us."

K-9 turned to the speaker bot. <I am no longer oppressed, my friend, merely employed. I don't think it would be wise to entice revolutions within an organization dedicated to peace, either.> He returned to his position, awaiting further comments to note.

Drafting threads are not the place for this. The Stranger's Bar is a good place to start, but the NationStates and International Incidents forums may be more of what you're looking for. #notamod

[Australian rePublic]

You still haven't addressed my concerns, so I'm still voting against the proposal

[Whovian Tardisia]

"What people choose not to eat and what people are physically incapable of eating are two very different things. The goal of this proposal is to protect the unfortunate, not pander to picky eaters."