Tuesday, 31 May 2011

2nd Letter On DEHP Scare


Having followed the news reports and editorials concerning the ongoing DEHP scare for a week, I am frustrated by the fact that two crucial points remain conspicuous by their absence.

First, how was the revelation that Yu Shen Co (昱伸香料有限公司) had used the prohibited plasticizer DEHP brought to light? Was it the result of random FDA inspections? Were the FDA tipped off by a competitor, either to Yu Shen or to those manufacturers whom Yu Shen supplied? Could the revelation have come from a "whistle-blower" either within Yu Shen or within the FDA (or elsewhere)? Cue bono? I have nowhere seen an answer on this score, yet what are reporters for if not to find answers to just such questions as this?

Second, given the possibility of marketizing food safety regulation through the brand strength of testing and certification companies, what purpose does the FDA's existence serve? How many food scares has the FDA prevented? From reading the reports and editorials on the ongoing DEHP scare, the FDA does at least seem to serve one purpose: that of strengthening an Orwellian double-think reflex among the public - namely, the premise that only government is capable of regulating food safety, even as it conspicuously fails in the instance in question. Quelle surprise: quelled critique.

I have seen plenty of reports quoting DPP legislators in their failed attempts to be subtle whilst political point scoring against the KMT administration, yet where are the reports informing the public of possible flaws in the FDA's approach to regulation? Where are the editorials critical of the institutional design of the DOH and FDA?

Yours freely,
Michael Fagan.

(Sent Tuesday 31st May 2011. Unpublished by the Taipei Times)


  1. I wonder how it was found out myself. Unfortunately we'll probably never know the full story, sort of like the arsenic in the oil thing with western franchises. Reporters aren't known for doing a good job, no matter where they're from.

    I have a feeling that the GIO nixes most letters to the editor. All published material must make it past their censors.

    Makes me wonder if there is a market for 3rd party verification in Taiwan with testing done in Taiwan, but the company based outside of Taiwan due to legal and technical issues(i.e. slander and libel charges, guys visiting your home late at night, kidnapping of your children, etc). The possibilities with the internet and proper marketing are interesting.

  2. "I have a feeling that the GIO nixes most letters to the editor."

    They don't - of that I'm fairly confident given the content of some of my published letters that have squeezed through and those of one or two others... which is a self-reminder that I should start listing the published and unpublished letters in a sidebar or something.

    "...if there is a market for 3rd party verification in Taiwan with testing done in Taiwan, but the company based outside of Taiwan..."

    There is - as the presence of giants like SGS in Taiwan testifies, but I would guess the scope is fairly limited (not only by weak market demand, but by administrative cobwebs). In any case, how tight are the profit margins of "food" producing companies and what are their current costs in meeting FDA requirements? Any third party testing is going to cost a shiny penny or two and that's on top of whatever the existing FDA requirements are. I suspect it's one of those cases where there might be sufficient market demand under less tightly regulated and better legal conditions: a case of can't get there from here.

  3. I'm wondering if you have a book I can borrow, since the library in Changhua sucks.

    Fiat Money Inflation in France: How It Came, What It Brought, and How It Ended by Andrew Dickson White


    I'd have to say that the testing market is weak because there's no large financial penalty or long term sales decline to selling poison. I'd think a random testing center that accepted donations could possibly work.

  4. (Your comment got spammed for some reason)

    White's book is online at several places, e.g. gutenberg and mises (as a pdf). I haven't read it. For old references like that, you can bet the chaps at Mises, the IEA, Gutenberg etc will almost certainly have them as free downloads.

    "...there's no ... or long term sales decline to selling poison."

    Why wouldn't there be - if - consumers know that certain food supplements and sports drinks being offered to them contain potentially toxic additives* and other supplements and sports drinks don't?

    The key is consumer demand for information.

    *I'm not going along with the "poison" designation until I see some fairly solid reasoning on concentration levels and generalization from rat studies to people. Until then, it's a potentially toxic additive (pta) to my mind.

  5. Actually, earlier tonight I was talking with someone (Taiwanese) about the DEHP scare and he seems to think that the story was brought to light as the result of a random test carried out by the FDA. Has that been reported in Chinese but not in English? Or am I just being lame and simply haven't found the right article?


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