On The DEHP Scare

The leading editorial in the Taipei Times today is a response to the recent revelation that a drinks manufacturer in China had been adding the plasticizer DEHP to its' products (some of which, e.g. Sunkist juice, I have myself drank). The plasticizer is apparently a cheaper alternative to act as a "clouding agent" than palm oil (it is not soluble in water). Turton pulled a table from somewhere listing the names of the drinks and their respective DEHP content in parts per million - the range is between 2ppm and 34ppm, which seems very high in comparison with the U.S. EPA's limit for DEHP in drinking water as a tiny 6ppb (parts per billion). I don't know anything about the toxicity to the human body of DEHP at these concentrations, so it could be that there is a real danger or it could be that the danger is exaggerated if the regulator's limits are set hysterically low. Some brief googling turns up an abstract for a study indicating that DEHP ingested by pregnant rats produces some damage to the liver, kidneys and testes of their litter. However, the conclusion to another paper states that...

"The general view of DEHP toxicity is therefore that mechanisms for adverse effects do exist in rodents, but that these do not appear to be of great significance in non-human primates and that the evidence that such mechanisms could be operative in humans is lacking."

So from these two papers, it seems that both the banning and strict limitation of DEHP in drinks is due to a "better safe than sorry" policy, rather than certain knowledge of its' toxicity to humans. Can anybody improve on that conclusion?

"Indeed, the latest incident exposed not just the shocking news of potentially harmful chemical additives in beverages and dairy products, but also suggested the existence of loopholes in the nation’s food safety system."

OK so potentially harmful chemical additives. Well I think we're potentially looking at an hysterical over-reaction here, fuelled in part, no doubt, by the mere fact that the drinks manufacturer is located in China - as in Turton's snark:

"Wouldn't the list of poisons not found in food products coming out of China be shorter?"

Yet supposing, for the sake of argument, that DEHP at these concentrations does indeed pose a serious health risk to the human body, the salient question is surely how to best prevent its use by potentially unscrupulous manufacturers. In regard to this question, does the existence of legal loopholes in the Taiwan government's food safety regulatory regime actually surprise anyone? It seems to me that there are one or two similar food scares just about every year. Moreover, the enforcement of these regulations has to be done through inspections, which can never be carried out on more than a small proportion of imported goods simply due to the scale and consequent cost to a government with a limited budget. Consequently, should it really be so surprising that now and again a few dodgy items slip by the regulatory regime unnoticed? I think not.

Under a marketized system of regulation (i.e. companies expressly set up in order to verify the safety of food items), such as has existed in the electronics industry more or less since the beginning with UL and others, these problems would largely disappear since the value to importing manufacturers of their products being able a trusted food safety brand would surely outweigh the cost to them of submitting product samples for testing. The regulatory company would thus be in a position to reliably verify the safety of the vast majority of imported food products, since they have a profit incentive to expend the resources doing this - an incentive which would no doubt be significantly augmented by the policies of retailers to only stock food products licensed by those regulatory companies with the best market reputations. A government agency faces no such incentive but rather a mountain of costs for which they need to plead to central government for an increased budget.

Of course, under both systems it is true that manufacturers exporting food products to Taiwan would have an incentive to comply with the respective food safety regulations. Likewise, it is also true that under both systems there may occassionally be unscrupulous manufacturers who will try to evade the regulation. However, this must be judged against the fact that the current system seems to experience this sort of problem annually, and the larger resources that a marketized system of regulation could likely bring to bear on the problem. On purely utilitarian grounds, I think such a market system of regulation trumps the government agency model.

Yet I think it should also be noted that since human error can never be mitigated or eradicated completely, and since the management of risk typically involves some trade off between values, it is fair to say that no system of food safety regulation will ever be perfect. Perhaps, however, a market system would spare us the continuing scare stories and the growing tendency toward public panic and distrust of both the market and all things Chinese.