Friday, 3 June 2011

3rd Letter On DEHP Scare


Perhaps the DOH's new regulations, proposed in the wake of the DEHP food scare, in which manufacturers will be required to hire food safety technicians to oversee newly mandated quality control procedures (as reported in the Taipei Times June 2nd), have been considered and passed too hastily and without sufficient criticism. Since these new food safety technicians will be in the employ of manufacturers whilst holding responsibility for product safety, their position will be one easily undermined by a particularly, let us say, "hasty" manufacturer. Not only may their job security become subject to their cooperation, with testing equipment and other necessities to their job becoming "temporarily unavailable", but far worse may be the prospect of them becoming legal fall guys for an unscrupulous and determined manufacturer. Whilst the new regulation appears to aim for the internalizing of food safety standards, it may in reality provide dodgy manufacturers with a subtle means of outsourcing their legal responsibilities.

If these new "food safety technicians" turn out to be graduates from food science departments at local Universities whose four years of study have gotten them into debt, and who are otherwise struggling in the job market, then their possible entrapment by a ruthless employer will no doubt have a future government reading the riot act. Yet it will have been the government, acting in political haste now, who will have been partly responsible for this should it occur.

The real tragedy here is that none of this is necessary. It is only the widespread, unexamined and reflexively applied premise that regulation must achieved by government, as evinced by Yang Ji-charng's letter today (June 3rd), that prevents Taiwanese from instantiating a far more efficient marketized system of food safety regulation. Such a system would work on the same basic principles of random inspections and contingent certification as the current FDA regime, but with the added advantage of greater resources being brought to bear on the problem owing to the profitability of trusted certification demanded by large scale retailers. The prospect of competition in food safety certification would only raise the costs of corruption and error to certification companies - provided they are not insulated from competition by government.

Of course, I do not expect that properly Liberal solutions to the problem of achieving food safety regulation will be adopted either by this government or the next. What I do expect is that the current haste by politicists of both colours to capitalize on the current food scare will create several secondary problems some years from now. To paraphrase G.K. Chesterton, one of the great disadvantages of government haste, is that it takes such a long time to count its consequences.

Yours freely,
Michael Fagan.

(Sent: Friday June 3rd 2011. Unpublished by the Taipei Times.)

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