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Sat, 24 Aug 1996 08:26:30 -0400
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<<Disclaimer: Verify this information before applying it to your situation.>>
 
Even appropriate standards increase costs because every time something is
meaningfully regulated there has to be some system for assuring compliance.
This is anacross the board fact.  Cost increases are less for those
companies that are already meeting the standard, but they still have to
implement government-approved testing, monitoring, and quality control
systems, and they do have to handle increased paperwork associated with
related reporting requirements.  If there is no system for assuring
compliance, what good is the regulation?
 
There is no regulation saying that you cannot burn my company to the ground
because I am giving you too much competition, nor should there be.  If you
burn my company to the ground, you will be convicted of arson, not of trying
to eliminate the competition.  Further, I could then sue you in a civil suit
for damages relating to your willful destruction of my business.  Similarly,
if a company "fakes it" and puts "gluten free" on its label (or cassien
free, or Kosher, or any number of other designations) when it is not, there
are already laws in place that will punish the offendor.  Any person who was
deceived to their detriment by such false labeling also has grounds for a
civil suit against said company.
 
Of course, the above example only applies to false labeling or mislabeling,
which could occur either through incorrect listings of ingredients or
incorrect use of a designation.  If legislation were enacted that required
manufacturers to specifically list every ingredient in every product, we
would ultimately end up with lengthy labels that say things like "modified
food starch (from wheat, corn, or rice); palm, safflower, or corn oil;" and
so on.  Large companies cannot be =reasonably= expected to change their
labels every time some small change is necessitated by supply, so instead we
will end up with lists of what ingredients MAY be in the product.  This
would be the only way manufacturers could protect themselves against error
or unexpected change.  Would we be any better off than we are now?
 
Companies producing specialized foods would not have such problems because
they don't substitute where it matters and they make it their business NOT
to err.  This is part of the reason their products are so expensive.  If
rice flour is in short supply this month, they will pay the higher price
because it is what we, their customers, need and expect.  They provide the
service we need, so we purchase their products.  If other companies were
required to follow suit with regard to exact labeling, the competition over
supplies could create an unfair advantage because the big companies can
afford to go out and purchase the large quantities of tapioca starch needed
to use up the boxes that list tapioca starch instead of corn starch.  So
then the smaller companies (who are still the only ones providing what we
need) are at least faced with higher prices for necessary ingredients, and
may even have problems finding what they need to make their product and stay
in business.  After all, their boxes may list "tapioca starch" AND proudly
advertise: "contains no corn."
 
The clients of the firm I work for include both businesses and regulatory
agencies (including the State of Alaska).  I have a vested interest in both
sides of the issue, and it tends to keep one's attitudes rather balanced.
 
Through educating ourselves with regard to under what guises gluten may be
found, we can avoid it.  If I see "modified food starch" or any of the other
code words that mean "potential gluten" on the label, I won't eat the
product.  It's that simple.  If there is something I am suspicious of on an
otherwise safe-appearing product, I will try contacting the manufacturer
and/or posting a question here.  My only gluten reactions in the past two
years (since I really started being dilligent) have been accidental
"poisonings" by well-meaning friends who didn't think.  It was my call to
trust their judgment, and I paid for it.  I also suspect they won't do it
again, they felt so bad, but they also won't blame me if I bring my own
food.  I don't need more labeling to tell me what I can't eat -- what I need
are more products that I =can=.  Legislation would not be conducive to the
development of more such products.
 
Shawn Anderson
 [log in to unmask]
 Juneau, Alaska

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