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.

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…

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.]

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.



Update, Book Reviews, and the Metric System

I realize I have yet to post this year, but worry not, as I’ve been working on things “behind the scenes.” Let’s chalk much of this year up to “technical difficulties” on multiple levels + COVID log jams—almost everywhere—from medical care to retailer printer availability. Rest assured, I just keep working to refine my approaches to this material. I’m feeling pretty good about my plans. Stay tuned.

In the meantime, I’d like to draw your attention to several, recent books on how we humans approach numbers and a little problem called “math anxiety,” which many of us have. (Without numbers, and their concepts, who needs the metric system? And since we need numbers, let’s make them as easy to use as possible.)

Making Numbers Count: The Art and Science of Communicating Numbers, Chip Heath & Karla Starr, (2022)

Chip Heath is a professor at the Stanford Graduate School of Business. This work (along with other books written with his brother, Dan) highlights basic information about how numbers tend to trip us up. (Or why we have difficulty conceptualizing numbers once there are more than a few of them.)

From the book’s introduction:

We’ve come to believe, after working with these principles for years, that almost every gnarly number has something—an analogy, a comparison, another dimension—that will allow us to translate it into something we can remember, use, and discuss with others.

Page XVI

Bravo. And then, the book backs these words up with example after example to illustrate how we can improve upon communicating “numbers.”

It takes real work/research/creativity to avoid just throwing out numbers that—to most people—are profoundly alienating.

Plus, don’t miss the appendix of this less-than-200-page book. It lays out the simple rules such as:

Rule #1: Round with Enthusiasm

…When we heave a nonuser-friendly number across the room to our audience, we are dumping extra work on them. (Page 138).

And that’s why YOU have to do the work for your audience. Of course you don’t have to, but then don’t be surprised when all eyes glaze over.

Rule #2: Concrete is Better
Use whole numbers
, not too many. Preferably small. (Page 140)

And while I’ve espoused the mostly unnecessary evil of fractions (algebra and scientific notation acknowledged), we need to remember we scare small children with this stuff.

Fractions are generally awful because the complexity takes you out of the flow of things. Quick, how would you like 6/19 of that pie…Converting a fraction to a decimal eliminates some of the math—no more weird denominators—but still isn’t intuitive. “Would you like .316 pies?”

Page 140

Counting: How We Use Numbers to Decide What Matters, Deborah Stone (2020)

The index lists only six sections:

1) There’s No Such Thing as a Raw Number
2) How a Number Comes to Be
3) How We Know What a Number Means
4) How Numbers Get Their Clout
5) How Counting Changes Hearts and Minds
6) The Ethics of Counting

Under “How We Know What a Number Means,” it states:

If you want to decipher accurate meanings of numbers, channel your inner sociologist…
Ready for a quiz? Don’t be fooled. It looks like arithmetic, but it’s really about social anatomy

Does 3 X 20 equal 2 X 30? (Page 65)

The short, somewhat confusing answer is: “Sixty minutes aren’t always 60 minutes if you understand how people use time.” (You’ll need to borrow [support your local libraries] or buy the book to learn the rest of the answer.)

The Art of More: How Mathematics Created Civilization, Michael Brooks, (2021)

Again, I refer to the book’s introduction that relates to just how much trouble we tend to have with numbers as human beings:

In school, we are assured that maths is an essential skill; a passport for success; something that we have to pick up. And so we obediently, though often reluctantly, gather the tools of maths and do our best to learn how to use them. Some enjoy it; most don’t. And then, at some point, almost every one of us gives up.

Page 3

Brooks comes at this material in a way I found interesting by talking about the passions and interests that drove various individuals and countries to push mathematical frontiers.

It is part of my assertion that the Enlightenment helped foster the development of the metric system (or SI as it’s known in the rest of the world) and Brooks makes a great connection that resonates with me:

When transferred onto a set of wooden sticks known as the slide rule, logarithms powered centuries of science and engineering. The slide rule facilitated the Enlightenment, the Industrial Revolution, the nuclear age and the space race.

Page 153

As you might guess, I have many more books on math (or “maths” as they say across the pond) that I’ve collected during the past decade of work on this project.

If nothing else, I hope I’ve pointed out that we humans and numbers don’t always get along well. However, there are those exceptional folks who find math easy. Me, I flunked algebra in high school, but found statistics in college interesting. So many of us are better at some kinds of numbers than others.

Thanks for reading this far.

Questions? Comments? Concerns? That’s what the comment section is for and I approve all comments that are “on subject” and respectful of others.

Note: I posted my first blog almost exactly 10 years ago on July 24th. I currently have almost 420,000 pageviews. Thanks everyone!

Keep in mind that the 1866 Law on the metric system was adopted on July 28, 1866. Happy anniversaries!