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

My 10-year/$25,000 Report to the House Subcommittee on Science, Space, & Technology on Metric System Adoption in Honor of National Metric Week, dated October, 10, 2022

Well, the first/last(?) More Than 1.6 Kilometer Ahead awards are out.

Then, on Monday, October 10, 2022, I sent a concern to the House Subcommittee on Science, Space, & Technology regarding our lack of metric system adoption. I requested a Congressional hearing and tried to lay out my case for why this issue is vital to our country.

The first page of my 10-page concern. Know the goals of your audience.

Will I get a response? I have no idea, but I am also attempting to interest the media looking for support/coverage.

Trying to put 10 years of research into a 10-page document was no easy feat, and I didn’t have an opportunity to run the document past people, so I own all my mistakes in it. Still, I did my best with what I had (including Grammarly). I’ve already started to find typos, but I can hope its substance means more to people than some surface blemishes.

Using my (at best) meager layout skills, I tried to build my case based on my knowledge of the subject. I must have “touched” more than 200 documents as I pulled my “case for the metric system” for the Subcommittee.

I had to look up old information, confirm dates, leverage old graphics, find new ones, and generally worked to make the most “rock solid” explanation possible for serious federal consideration. I only get one shot at this, and people’s lives are at stake due to dosing errors alone.

Produced in three sections, the first section centered on the stated goals of the House Subcommittee’s “Congressional Oversight Plan.” I did everything I could to point to the intersections of the Subcommittee’s Plan and the metric system project.

Section 2 contains what I call my “Initial Documentation.”

I started with the New York Times article dated August 18, 2020, by Alanna Mitchell:

My biggest question: Why are we still redefining our feet (our new “survey foot” goes into place on January 1, 2023) when the metric started in about 1790?

Second 3 contains my request for a Congressional hearing on the topic of the metric system.

I’m trying to make this issue about multiple costs

I tried to work into the document the concept of “our costs” for not adopting the metric system. In lives lost or derailed due to dosing errors, in time wasted looking up conversions, and (let’s face it) our country looks ignorant to the rest of the world. (I have a theory about why so many people from other countries look at my blog. Think “car wreck.”)

What put me on this path?

My contact at the National Institute of Standards and Technology sent me a link to a hearing that took place back in March of this year, and it got me thinking and digging.

After clicking around on the site, I came across this icon.

That icon led me to this page https://science.house.gov/contact/whistleblower

And that page led me to this sentence in the second paragraph:

If you have information to share regarding concerns about federally-funded science, research or technology-related programs, please contact us.

https://science.house.gov/contact/whistleblower

And I do have grave concerns about our lack of metric system adoption. So I pulled together my document and sent it in in honor of National Metric Week.

Either I can make a compelling case, or I can’t. It is now up to others to decide.

Here are a few quotes in my lame attempt to get you to read the entire, ~1,700-word report, but it does have a lot of graphics.

The experiment that John Quincy Adams worried about in 1821 ended very long ago, and the metric system won. Almost every place but here.

Linda Anderman, Page 1 of the report

How much will it continue to cost us in health, safety, education, commerce, and international scientific standing within the world to coninue on our current trajectory?

Linda Anderman, page 2 of the report

Dosing mistakes can be lift-threatening! Avoid if possible. The metric system will help us get this right.

linda Anderman, page 6 of the report

I closed the report with the quote I wrote many years ago, but still holds true.

When you think about all the problems in the world (war, illness, environmental disasters), once we fix our metric system problem, we never have to fix it again. No country that has switched to the metric system as switched back.

linda anderman, page 10 of the report.

Please try to overlook any typos or poor layout of this document, but feel free to share.

It’s a public record now. Let’s see if we can get this discussion back on the table after a 40-year lapse in attention.

Thanks for sticking with me.

Linda