Posted on 01/04/2013 7:45:19 PM PST by Vince Ferrer
Division of Dockets
Management (HFA-305)
Food and Drug Administration
5630 Fishers Lane, rm. 1061
Rockville, MD 20852
Any submissions received must include the Agency (FDA), Docket No. FDA-2011-N-0921 and Regulatory Information Number RIN 0910-AG35.
The full text of the proposed rulemaking is available at:
http://www.ofr.gov/OFRUpload/OFRData/2013-00123_PI.pdf
Commenting on proposed rules isn't a waste of time, at least in my experience with the Office of Inspector General and the Centers for Medicare & Medicaid services.
Perhaps this is me being cynical, but the federal system had been dashed upon a rock in 1861. Though between then and 1913 the election of senators through state legislatures continued to give states a more or less direct means of pursuing their interests in the national government, it was by that time more playacting. It was a short time after 1913 that our limited Republic went down the scrapper.
That may have had something to do with the democratization of the senate or the creation of the federal reserve and income tax amendment which you mentioned. It could have been the triumph of progressivism in the crises (which they never let go to waste) of WWI and the Great Depression. Certainly the switch in time that saved nine contributed, horribly. I don’t like to see it all as Civil War hangover, but that to me is the great turning point, not the 17th amendment.
Okay, but what government? Federal, state, local? Are you aware there’s a difference, or is it all of a piece to you? Have you ever bothered reading the 10th amendment, or have any basic knowlwdge of the machinery of our constitutional government? The words “general welfare” somehow blind people to the limited nature of federal power. Nit sure why, except that they personally like it when the feds do more things, and as such grab onto whatever’s available to justify themselves.
If you'd read some of my other posts, you'd see that I have a very good understanding of the difference between local, state and federal governments. So stop being sarcastic and claiming that I don't know what the constitution says.
Hiw do you even know what the people are and aren’t able to do for themselves.l? Ugh, nevermind. That would be a pointless digression. What you quote doesn’t say what you say it says, is the main point. Far tron it. All it says is that Congress can levy taxes in so and so ways for so and so ends. Why regulating the national food supply for safety purposes jumps out at you from that is utterly beyond me.
Even though you are clearly being sarcastic here, and allowing your sense of libertarian romanticism to blind you, I will give this a serious answer. I have found that answering the wilfully blind often seems futile (because they refuse to accept any facts that don't fit in their world view), but occasionally lurkers FReepmail to let me know how much they appreciate the information. The nature of your replies suggests that you genuinely do not know the vast amount of work going on behind the scenes to ensure that those oranges, that lettuce, that steak, that can of soup you so casually throw into your shopping basket won't make you sick or kill you.
The fact is that no one has the means, and very few people have the know-how to determine if a particular food is safe to eat. (As an aside, I *do* have the know-how, but I most certainly don't have the high-tech equipment in my kitchen to be able to test foods.) Can you do PCR in your kitchen? Do you have an HPLC or a mass spec machine in your living room? Do you know how to culture and identify bacteria, and do you have a selection of incubators (for growing different kinds of bacteria) in your home? Do you have all of the chemical reagents and equipment necessary to test for adulterants? If your answer is "no", then I have every reason to believe that you do not, in fact, have the ability to determine whether the food you purchase is safe or not.
As an example, botulin (a bacterial toxin) is odorless and tasteless; you have no way to know a can of food is deadly just by looking at it. Unfortunately, a teaspoon of that food is enough to kill you. Another example is E. coli H157:O7, which can be present in meat or produce at quantities sufficient to permanently disable or kill you--but it is invisible. These are just two examples; there are countless ways that food can become bacterially contaminated. That doesn't take into account the multitudes of other ways foods can become unfit to eat, through accident or wilful misconduct. Do you remember the melamine problem in pet foods a few years ago, where hundreds of pets died from food that looked perfectly good?
Another food safety issue is the investigation to determine the cause of outbreaks. Imagine that you land in the hospital because of botulin poisoning--how can you possibly know where you were poisoned? Did you get it from the can of beans you ate last week, or was it something at the restaurant you visited a couple of days ago? There are large enough problems with food safety in the current regulated environment; I shudder to think how difficult it would be to consistently acquire wholesome food if there were no regulations. Both human error and deliberate adulteration would run rampant in a regulation-free environment. I suppose, in your libertarian-colored world, people would just magically know which foods are dangerous and avoid them. But in the real world, that's unlikely to happen.
The FDA already does a decent job of trying to keep our food supply safe, but 3,000 deaths and nearly 50,000,000 illnesses still occur every year. The purpose of the new regulations is to improve the system so as to be even less reactive and more preventative.
“it *is* conservative to believe that the government should fulfilled its constitutionally mandated functions”
Where is the FDA mandated, again? Kindly quote the article and section. Or are you going to go on about the taxing power again?
Well, since you already know the pertinent section of the Constitution, I don't have to quote it again.
I consider any factor that kills more Americans than war (currently 3,000 deaths from tainted food per year, versus less than 7,000 from the entire Iraqi and Afghanistan wars) is absolutely a matter of general welfare.
Hmm, maybe I should dig up the quote about protecting Americans from all enemies, foreign and domestic, too. It sure seems like tainted food could be classified as an enemy...
Agent orange sprayed in cotton fields, seriously?
I am left nearly speechless. I have no idea where people dig up stuff like this. Is there a book on urban legends that everyone but me refers to?
I farm. I have been farming for 30 years. In the southeastern United States cotton is sprayed with defoliant.
I do not know urban legends. I am a rural person dedicated to food production.
Cotton is also fed in some feedlots. Makes the beef go blind very very young but who cares, it is just food.
I farm. I have been farming for 30 years. In the southeastern United States cotton is sprayed with defoliant.
I do not know urban legends. I am a rural person dedicated to food production.
Cotton is also fed in some feedlots. Makes the beef go blind very very young but who cares, it is just food.
Speaking of the Triumph of Progressivism, there is a documentary available to view on-line; Agenda: Grinding Down America. It’s 90 minutes, well worth the time: http://vimeo.com/52009124
The libertarian mindset seems to believe that food safety will happen on a voluntary basis, and that willful misconduct can be managed after the fact. The former is a pipe dream but I suppose the latter can work, but only after the fact when many people have died. I've worked in the food industry for 30 years now, and I can say that, for the most part the industry is populated by ethical, moral and conservative people. Even so, I am regularly shocked by what some companies/individuals will do, and how they willingly place others at risk, to increase profits. This applies to manufacturers, distributors, and retailers.
I also love the argument against a federal approach to food safety. Again, this mindset is for people who don't understand the industry. I'm sure if Jimmah in Georgia is processing peanuts into peanut butter, and the local regulatory agency finds salmonella, because Jimmah isn't following the proper food safety guidelines, that it would be easy to look the other way because, after all, Jimmah is the top employer in the community. So when someone gets sick in Minnesota from his peanut butter, how will the separate agencies ever find the source of the poisoning, or do something to stop it. They won't.
As you point out, it would require a great deal of sophisticated equipment, and the training in how to use it, to ensure your food supply is safe. Yeah, one family producing their own food can probably control things to the point that poisoning is rare. But you gotta love an argument that doesn't see any difference in feeding one family vs. 300+ million people.
What's comical is that these same people will demand manufacturers provide endless information about their products on the label so they can make "informed" decisions. Prior to government regulation, there would be no indication on a label regarding allergens. "Allergic to tree nuts? Sorry about that anaphylaxis, we didn't mean to make breathing so challenging. Too bad you're not carrying an EpiPen."
And let's not get started on pharmaceuticals. How many traveling salesmen were hawking their own elixer just a few generations ago? They killed and injured a lot of people. Sulfanilamide in diethylene glycol, anyone? Yeah, requiring toxicity testing of pharmaceuticals is such an overreach of federal powers. Good grief. But the process worked, the company was punished, but not until more than 100 people had died - mostly children. The company never notified anyone that the product was deadly, only that they should return it. Makes you wish for the good ol' days, huh?
More than 10% of all pharmaceuticals in the world today are counterfeit. Great, we should let everyone buy drugs from whatever source they can find on the internet, because government regulation of drugs is unconstitutional. I'm sure our libertarian friends believe organized crime cares about their product, but if they don't, that market forces will force them out of business. Rolling eyes.
Doctor: "Your symptoms are getting much worse. Why didn't you take the medication I prescribed?"
Patient: "I did. I bought it from some Canadian pharmacy because it was so much cheaper. I've been taking it just like you told me."
Doctor: "The drugs you purchased were nothing but dextrose and coloring. If only you had purchased the drug locally, where the FDA was ensuring efficacy, I might have been able to help you...."
Again, and in my humble opinion, the FDA and the USDA are behemoths of regulation and inefficiency, and have become much more intrusive and influential than they should be. That said, we are much better off today than we were before they were created, and the arguments against their constitutionality are absolutely mind-boggling.
Ok, so what? Crop herbicides used on cotton are used before boll opening. They only use harvest aid products after boll opening and these products are contact leaf defoliants. They are not systemic. Also, the cottonseed meal isn't exposed to the defoliants because the cotton fiber and hulls are there to protect it from any exposure.
I do not know urban legends
It appears that you do. You should be more careful what you read on the internet.
Cotton is also fed in some feedlots. Makes the beef go blind very very young but who cares, it is just food.
The same cotton they use to make clothes? Is that what you think? Cottonseed meal was used a great deal in feed, and it may still be to some degree, but with new methods of processing, there is very little oil left in the byproduct. Feedlot producers used CSM because of the high oil content.That oil content isn't there any longer.
Farmers also use whole cottonseed, but, if I remember correctly, it is used primarily in dairy. This is a great product for protein, fiber and fat intake.
The only risks that I am aware of from these forms of cotton is from gossypol toxicity due to excessive intake. But blindness isn't a result of this - at least that I've ever read about or seen. Most beef and dairy producers know enough about these products to avoid toxicity levels in their herds. But there's always some idiot who does otherwise.
Farmers will also use cottonseed hulls in feed, but that is mostly for fiber and has never been a cause for blindness.
There is rarely any pesticide residue found in cottonseed meal. If and when they do find it, it's presence is so minute that it cannot cause any problems in humans or animals. Dangerous chemicals can be found in the foods you eat every day. They occur naturally and the miniscule amounts pose absolutely no threat to your health. Our ability to measure in the smallest quantities has created an industry of fear. This chemicalphobia is for people who fear things they don't understand. The internet is, for the most part, responsible for this phenomenon.
Okay. You and DemMom can keep eating your Cotton Food. Does not matter to me.
Again. I am a farmer. I do not get my agriculture information from the internet or Your Urban Legend Magazine. I get my information from my peers and decades of experience.
Pound sand.
Your peers and experience have left you woefully misinformed about cotton, and all the products that come from cotton. I grew up on a farm, had my secondary education conducted in the school of agriculture, and have worked with meat suppliers for over two decades. In all that time, I've never once heard of cotton byproducts causing beef cattle to go blind. Have you contacted Alex Jones?
Most farmers I know have a much better grasp of science than you do. But then, they don't believe everything they hear or read either.
Thank you for the support.
While I fully understand the libertarian philosophy, it depends on people being uniformly honest, and on people having an expert knowledge on just about anything. Since neither of those are very likely, libertarianism will remain a romantic ideal that just isn’t practicable in the real world.
I completely agree that federal agencies, in general, have become too bloated, bureaucratic, and heavyhanded, and desperately need trimming. That doesn’t mean we can do without the public health functions provided by the CDC/FDA/EPA/USDA/NIH/etc., because we can’t. Could those agencies be made more efficient and focused? Probably. Could their functions be streamlined? Probably. Are they performing constitutionally mandated functions? Absolutely.
I’m completely unimpressed that cottonseed oil is used in food products. I notice that all kinds of oils are used in foods; I assume (because I’m familiar with the way food regulations work) that if there were detectable levels of toxins in those oils, to the point where they pose a health hazard, they would not be authorized for food use.
Some farmers have Ph.D.s and do research. I come from an agricultural background, too, and have a Ph.D.
One of the most popular talks I ever saw at a scientific conference was presented by a farmer, complete in plaid shirt, jeans, cowboy boots and big hat. The good doctor/farmer spoke about cows pooping dioxin contaminated poop. (They were chewing on the pasture fencing, and a chemical used in treating the wood was converted to dioxin in their guts.)
That talk was standing-room only. The incongruity of a farmer addressing a bunch of stuffy scientists will always be stuck in my mind.
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