Baby Formula, the Pandemic, and the Metric System

I recently got pushback from a media outlet because it recorded a podcast five years ago about the metric system, and it didn’t want to go over old territory. Brother.

U.S. ounces and U.K. ounces
are not the same size! As you can see from the “9,” U.S. ounces are bigger.

Not only is our metric system landscape constantly changing, but it impacts us in ways we don’t even see coming at us. When you heard about our shortage of infant formula in the United States, did you consider that our lack of metric system adoption added at least two new hurdles to our babies (and others) getting safe food? Well, it did.

From our unthinking perspective: Why just solve a dozen different urgent, life-saving problems when you can add two more due to our lack of metric system adoption in the United States? I think it is safe to say that the U.S.’s continued isolation in our measurement system does not bode well for the world in general. (My blog. My opinion.) However, it is a correctable problem. I think we all deserve more information about this measurement problem (see my request for a Congressional hearing with the House Subcommittee on Science, Space, & Technology) on our 200+ year measurement car wreck. But there are resources on this subject in the short term: National Institute of Standards and Technology.

We added at least two obstacles into our American baby formula crisis through our lack of international measurement standards

The Federal Trade Commission administers the Fair Packaging and Labeling Act (FPLA). The law itself directs the agency to put into place:

….additional regulations where necessary to prevent consumer deception (or to facilitate value comparisons) with respect to descriptions of ingredients, slack fill of packages, use of “cents-off” or lower price labeling, or characterization of package sizes.

https://www.ftc.gov/legal-library/browse/statutes/fair-packaging-labeling-act

Let’s face it, a global pandemic is horrible, and we’ve been going through it for almost three years. Just trying to keep everyone safe from invisible, evolving viruses is an emergency on its own.

Then, we created a situation we fundamentally shouldn’t have. Because of the COVID pandemic, supply chains broke down in many unanticipated ways. All over the place. One place parents really felt it was a loss of infant formula and mixes. While the problem had multiple factors, I only want to address a couple of the metric-system-adoption failures here.

Problem #1: Lack of dual labeling at a minimum as required by current law for product importation (U.S. customary and metric system [SI] units). At the minimum. Other laws are also at play here. I can’t possibly cite all of them. But, I’m sure that others in the government could produce this information if called upon to do so.

Problem #2: Potential conversions errors when mixing unfamiliar units associated with the metric system and U.S. customary units. Getting that information out to parents may, or may not, have been a successful/unsuccessful campaign. I have no idea, but what’s below should, to me, have been completely unnecessary.

Try to convince me this isn’t stupid and dangerous for everyone in this country.

As I understand it, the original problem started with the U.S. Food & Drug Administration missing contamination at an infant formula manufacturing site in the United States. This created a national supply-chain crisis. The manufacturer, Abbott was also to blame. It’s a huge outfit with more than 100,000 employees. The White House recognized this issue’s importance immediately and started working on it from various angles as children/infants (and others) suddenly couldn’t get the food they needed to live.

The Biden Administration went so far as to fly formula from other countries to the United States. Called “Operation Fly Formula,” A statement dated June 22, 2022, says:

In May, the Food and Drug Administration (FDA) announced that the agency is exercising enforcement discretion so that Nestlé can export additional infant formula into the U.S. Nestlé will import both standard and specialty infant formulas, including…

https://www.whitehouse.gov/briefing-room/statements-releases/2022/06/22/president-biden-announces-ninth-operation-fly-formula-mission/

Let’s look at the phrase “… the agency is exercising enforcement discretion…”

Since the FPLA is meant to avoid deception directed at consumers, and crooks have used units of measure since time immemorial*, so all commodities must state their contents in the prevailing units (be they metric, U.S. customary, or both), including for infant food. It’s a health a safety and a commerce issue.

Dual labeling

One problem we have is that packages in our country need to be “dual labeled” where there is enough room to do so, (see National Institute of Standards and Technology labeling site). This also involves the Uniform Packaging and Labeling Regulation.

Of those packages examined, 17% declared the net quantity of contents in only metric units. Almost 57.5% of those metric packages were found to be noncompliant with current FPLA dual labeling requirements. [Emphasis mine.]

https://www.nist.gov/pml/owm/laws-and-regulations/packaging-and-labeling

So, under the law, you have to dual-labeled products for distribution in the United States. Of course, infant formula never meant for export to the United States would only have metric system units on them. That was never a problem until we tried to import infant formula during a pandemic. Then, suddenly, it became part of a much larger problem. Completely unnecessary and avoidable.

As indicated by the FDA Guidance Document: “Guidance for Industry: Infant Formula Enforcement Discretion Policy, dated May 2022“:

FDA intends to temporarily exercise enforcement discretion concerning specific requirements for infant formulas that may not comply with certain statutory and regulatory requirements and is seeking information from manufacturers regarding their products’ safety and nutritional adequacy. 

Well, that solved one problem…

Conversion errors

So, the Administration did lots of things to supply our babies with food, and other countries tried to help us in an emergency. The White House lifted the dual labeling requirement for the time being. Of course, that leads to problems shifting from an import problem to a “consumer use” problem and the potential of conversion errors while mixing formulas. Such a problem would be Impossible in a solely SI world.

Here is my problem with writing about conversion errors. I couldn’t find any fundamental, accessible research on error rates. I found LOTS of things that said conversion errors are bad, but I could never get a good enough answer about what rates of conversion errors there are. But errors are made. Everyday. I assure you. We can’t stop all conversion errors, but we can stop the stupid ones like constantly trying to use two incompatible measurement systems side by side for 200+ years in this country.

So, what happens when Americans suddenly end up with only metric system units on hand? Easy. They get confused, so the federal government must then get the word out about using these mostly unfamiliar measurement units, so their kids don’t get sick and die from malnutrition. Whatever path led us here could not possibly be a good one. How much did it cost to whip up the poster above, and how much time and effort went into getting that conversion guidance into the right hands? If the efforts were successful, then lots and lots of resources, from the federal government right down to the doctors’ offices. Those are steep taxpayer dollars, my friend.

If we only used metric system units, both of these problems would disappear. Once and for all.

Please help get the word out.

Thanks,

Linda