This is a terrible idea. Infant digestive tracts are unable to accommodate a steady diet of Tim's coffee, maple syrup, and Labatt's. It would lead to gross malnutrition, deferential self-effacement, and a compulsion to apologize for everything.
Ah, but if you supplement the Canadian diet with iron-rich foods, you avoid the malnutrition. Can’t do anything about the self-effacement and compulsion to apologize, though (but is that really such a bad thing?)
I know not everything is about my thing, but this issue really seems like it would have been alleviated if Democrats could focus more on improving existing bureaucracy when in office rather than on just blasting more money into the machine.
If FDA had adequately consulted and informed other agencies about this decision and its impact, there are plenty of smart people in the admin who could have alleviated this before it became a crisis.
Fundamental competence was one of the top selling points for Biden & contrasts with Trump. It’s also something they could really accomplish even without congress. But I do think it requires serious focus from top levels of the executive to make it work.
Doing battle with a sclerotic bureaucracy would consume time, public attention, and even some political capital (just from fending off critical news and takes from the effort).
I'm an evil conservative, but even I can't blame Biden for now focusing on that.
I think you’re too generous. On net I’m probably still a Biden supporter, but if you’re going to advocate for “big” government (including loads of generous social programs), as I largely do, you damned well better be making sure government works well. The baseline should be _at least_ as competent and cost effective as private sector.
FDA, when it shut down a huge portion of formula supply without considering the consequences, massively fucked up. Not the first time, not the last. The FDA, like the CDC, is slowly but surely becoming notorious for fuckups. If we can’t trust our regulators, why should we trust regulation at all - would the market have let our children starve, or driven mothers to panic and desperation in the presence of clear alternatives?
It’s not enough to believe in the power of government to improve peoples lives, democrats need to bust their asses to prove it. Elected office is an honor and a privilege, not just another 9 to 5, and we should absolutely expect more.
I'll take it as a given that the plant needed to be shutdown for safety reasons, but they could say:
"We need to block this supply because of the bacteria. We are temporarily allowing baby formula approved by <Canada/Germany/similar situation> to be imported legally."
Does malnourishment not kill? Does driving hours a day while overtired and desperate to find food for your child not kill? We’ve gone over this with COVID already (“but COVID also kills kids - see random example plucked from obscurity - so schools should stay shut until COVID is eradicated no matter the cost”) and I wish I could say I’m surprised that people aren’t generalizing the lesson.
I held off on making this comment earlier and I’m disappointed it is necessary:
I have doubts about the public’s ability to think about or understand the fact that we don’t live in a post-material world. Sometimes there actually are material constraints. I see progressives regularly spout bullshit like “just give everyone a house”, and “nobody should have to work if they don’t want to” and “all healthcare should be free” and not appreciate that things like food and housing and education and healthcare do not just materialize out of the ether. Similarly, regulations that destroy supply (even flawed supply) needs to be questioned.
The fuckup is not in the recall, but in doing the recall without a plan for keeping children healthy and fed.
I could not agree with you more. The insistence on making single-variable decisions with blinders on is destroying confidence in agencies like the FDA or CDC.
Businesses manage to consider more than one variable all the time - why the fuck can't regulators? It's not like this kind of thing is too difficult to figure out. Companies like Walmart, Amazon, and Facebook deal with this kind of thing every day. There's no reason that government shouldn't be able to think through tradeoffs too - and it *needs to* if we want the kind of strong social support systems and competent governance that so many of us want (myself included).
While I agree that the functioning of bureaucracy is often overlooked, this decision had such a critical impact because two companies have such dominance over the formula industry.
In fairness, the Biden administration is vastly more competent than the Trump administration was. It's not even close. It's also more competent than W's was, although the ratio is lower there.
This is essentially our situation. My wife and I accidentally each bought large quantities of formula (because it's expensive and you use a lot so it just makes sense to buy in bulk) at the same time right before the shortage really started. We recently ran out of that excess supply and decided since our kid was eleven months that we would just switch to cow's milk. I can't imagine how much more stressful this situation is for parents of younger babies.
I also just want to say this has been yet another instance where the "anything other than breast milk is ruining your kid's life" crowd are really annoying and destructive. Saying things just put in the effort to relactate is really anti-helpful and adding mental stress for parents that are already in an extremely difficult situation.
It really does feel like a cult. We had our baby at a top tier research hospital and everything was supposedly extremely evidence based (including in their communications). I'll totally buy that breast milk is better all things considered but the degree of emphasis and way it was communicated really felt very strange and cult like. I know a lot of topics in the parenting wars are like this (looking at you, sleep training monsters!) but this might be the most extreme.
We were hoping to be in this situation. My supply has decreased a bit faster than our 11 month old was weaning, so we figured we’d supplement with formula to bridge the gap. Then the formula shortage hit, and we messaged our pediatrician’s office to see if we could be flexible about the 12 month rule. All they responded with was that we needed to wait until the year mark to begin substituting at all. No questions about her solids diet (varied) or the rest of her liquid diet (breastmilk several times a day).
We didn’t have time to become amateur pediatric researchers on why cow’s milk before 12 months is recommended against, so I drove around town trying to find an extra tin or two to make it to June. And now I feel guilty for taking one of the 25 remaining tins at my local Target.
More broadly, is there some way the federal government could give overall reliability ratings to foreign regulatory agencies? Part of what makes this so sensible is it's a very reasonable bet the Canadian equivalent of the FDA more or less knows what they're doing. Ditto for most rich-world regulators on a lot of issues, and who knows, maybe some developing-country regulators as well. We obviously want to have our own regulatory agencies making their own determinations, but a government that says "here are some foreign agencies that are staffed by qualified professionals, and in a pinch, you're not going to get anybody killed following their instructions" would seem way more reasonable and normal. And if, like, the Swiss pharmaceuticals regulator (or whoever) is weirdly corrupt and incompetent for idiosyncratic reasons, that would be good to know too!
This is actually something I very briefly looked into back when covid vaccines had been approved in Europe but not the US.
Apparently there's something akin to that for drugs so your idea is at least within the realm of the possible. I don't/didn't feel like reading more into the specifics of it but there's info at this link here.
What makes it even more frustrating is that they keep taking these kinds of positions and never really seem to learn from them. They really should have learned from the "no peanuts until 12 months" fiasco and tried to figure out how they ended up taking a hard line that actually hurt kids and improved the process for issuing guidelines. It really doesn't help their credibility. When I heard the "never feed a baby under 12 cow's milk" line, I assumed it was overblown.
The FDA seems to stumble from failure to failure. Maybe food or drug regulation is especially challenging but it seem to have more problems than all the other federal agencies combined.
I suspect the FDA is actually poorly run but I'm guessing the idea that it's uniquely poorly run among federal agencies is just the availability heuristic talking. The VA, the Secret Service, the DOJ, the FBI... plenty of federal agencies haven't exactly covered themselves in glory of late.
My casual feeling is that the FDA fucks up a lot, but at least they're fucking up hard problems. It seems like there are plenty of agencies that are just as effective at fucking up easy problems.
May I introduce you to CMS, the Centers for Medicare and Medicaid Services, and FDA's sibling at HHS?
Or the DEA, which had one job when it comes to opioids -- preventing their diversion from legitimate medical use -- was the only entity in the country with a birdseye view of the manufacturer and distribution of opioids, including literally setting production quotas for each manufacturer, and received detailed reports of where it was all going, but mostly just stood there and watched as it happened?
...or generally just any regulatory agency that is charged with managing a complex economic system?
How many times do we need to learn that regulation needs to be as light as possible and that a centralized economic planning commission (which is what the FDA continues to grow toward) results in inefficiency, shortages and capture by the rich and powerful?
Seems like as good a place as any for me to yell into the void: The fact that the shutdown of *one* factory can put us in crisis mode is pants on head stupid.
I wonder if particularly onerous regulations helps cause the kind of market consolidation that leads to this?
Getting a plant qualified by the FDA to produce this is pretty costly, and that may pose a barrier to entry, and/or enhance the competitive advantage of being a big company in general.
I don't believe the regulation to be overly onerous. I lived in China in the midst of one of its many "we just killed a thousand-odd infants" scandals related to contaminated baby formula. This is, IMO, just one of those things where it leads to consolidation *despite* being necessary.
I'm not sure there's a way to craft a regulatory regime light-touch enough to avoid this market being run by 3 companies while actually maintaining the safety of the incredibly finicky, easily-contaminated product that we feed to the objective most vulnerable (and emotionally most valuable) population among us.
It might not be possible to do both. I suspect that that determination will require a lot of technical expertise about food production, and I don't have that.
I do have experience dealing with the FDA from a medical device design, safety analysis, and manufacturing standpoint, and I do think that many of the FDA's requirements there are pretty onerous - and not very effective at really mitigating safety risks, and so probably unnecessary.
It is a different animal than food production, but I kind of assume (perhaps unfairly) that the bureaucracy will function similarly across the board.
I'm in favor of light-touch regulation on a variety of topics; OSHA's construction site provisions might as well be (and I suspect were) designed to be impossible to follow so that one can politicize enforcement.
Childcare regulations are another area I'm familiar enough with to feel confident.
Production of powdered dry goods from extremely perishable precursors, destined for easy-to-poison children?
I'm not inclined to brook the typical "it'll be fine" libertarian line on this one. I would want a disinterested, educated observer to tell me what to do.
Which is why we need to pay the damned civil service well enough to entice some of the private sector's experts to come over and ride herd on their former colleagues.
Would you be so kind as to expand on the OSHA construction site provisions? I have not heard about this, and I would very much like to know more. Thank you!
* Do not shut down key infant formula production facilities on the basis of questionable safety issues.
* Allow foreign baby formula to be sold in the United States.
* Stop demonizing parents who feed their babies formula, it's a miracle of modern science whose production and quality needs to be treated as a source of national pride. In China they have no such scruples about breastfeeding vs. formula – formula is widely regarded as superior to breastfeeding and indeed American formula is massively sought after there. People buy pallets of it to ship back to China.
I saw that Abbot has rebutted this saying that the strains of bacteria found at the plants does not match the bacteria that killed the 2 babies. Has there been further evidence come to light about it?
Finitely many. Which is fewer than the infinitely many that would die from a plant permanently contaminated with cronobacter toxins. Sooner or later, the plant would have to shut down and clean itself; the question is just when. You can argue that it should have shut down later, so that we could build and start a backup plant first, but arguing that the plant never should have shut down is silly.
I do not have kids, but I’d be curious to know if anyone with young kids went to their pediatrician and inquired about feeding and received advice akin to “you can give them milk and some food” or if doctors (and parents) are mostly risk averse here and just stress finding formula since it is most nutrient-dense. Maybe age of the doctor would make certain answers about what is okay more or less common…
Personal anecdote my mother has told me in the past: I was a fat baby and cried a lot and when she went to the doctor they suspected I just still hungry often. She began putting cereal in my bottle way before her other kids. I suspect this was just practical advice/something the doctor suggested and I turned out fine and presumably stopped crying.
Again, I know nothing on how these things shake out in reality, but Emily Oster’s work is one fairly recent piece of analysis that shows we don’t have very good evidence that many existing parental guidelines make much of a difference in kid’s outcomes.
I already replied to a different comment, but I can say that we asked our pediatrician’s office if we could introduce cow’s milk for combo feeding (she gets tons of varied solids and mostly breastmilk but we need to supplement one bottle a day with formula) since our baby is 11 months old. They didn’t budge on the year guideline.
This isn’t the only example of the FDA being dumb about formula, it’s only the latest one. Anyone interested in the topic or in the topic of radical FDA procedural reform should check out Scott Alexander’s discussion of how our formula formulation was killing babies for 20 years while European formulations were not for very simple and well understood reasons: https://astralcodexten.substack.com/p/details-of-the-infant-fish-oil-story?s=r
I mean… that’s not even an accurate portrayal of the headline of that article, let alone the content. We’re talking about IV drips, not formula, and a pretty rare medical condition. And the FDA, given its remit, did pretty well.
Strong disagree on them doing pretty well, but fair in my misremembering it being formula. I read that when it was originally published last year and kept infant and nutrition and FDA bureaucracy but missed IV.
Again, within the context of its remit, it did fine.
That its remit makes it impossible to do much of anything quickly with the resources its provided is not, in and of itself, the fault of the FDA.
Go yell at your Representative.
As for the article, it was a good recounting of the circumstances, but this paragraph:
"My problem is: doing anything in medicine is illegal until you clear a giant hurdle. To clear the hurdle, you have to pay millions (sometimes billions) of dollars, fill in thousands of pages of forms, conduct a bunch of studies that can be sabotaged for reasons like “this drug is too good so it would be unethical to have a control group”, and wait approximately ten years. You have to clear this hurdle to do anything, even the most obviously correct actions. Everything starts out illegal, and then a tiny set of possible actions is exempted from the general illegality. The easiest name for this hurdle is “the FDA”, since they’re the agency charged with enforcing it."
requires a bit more examination. In the absence of this regulatory regime, you have the bad old days where patent medicines with lead and mercury killed God-knows-how-many tens of thousands annually. So sure, let's refine the FDA's remit, give it the legal framework to expedite reviews as needed, provide more resources... but acting like it's worse than what came before is another of those stupid, libertarian fantasies.
We seem to be particularly bad at these kind of collective public health (or p.h. adjacent) issue.
I'm sure both social and bureaucrattc dysfunction is involved, but it seems like instead of basically saying something like 'There is a baby formula shortage, so if your child is over X months of age and otherwise healthy, please consider...' and trusting the enough of the public can understand and will try to comply, we get all kinds of tortured messaging in an attempt to achieve a similar result.
It closely parallels the 'masks aren't effective' guidance early in the pandemic.
They could have just come out and repeatedly said 'masks are somewhat effective, but we need to reserve them for front-line workers until supply improves.'
Instead of trying to manipulate the public, give an honest and straightforward message and let the chips fall where they may.
True story: when my wife delivered in an NHS hospital in the 80s, the midwives encouraged her to drink beer "to let the milk down". Don't recall whether they specified Guinness, but "Guinness for nursing mothers" is a very well-established adage.
I hate to be “that mom” but I’m really tired of these “breast isn’t REALLY best so we should just feed formula and that’s valid and OK” and then this formula shortage happens and parents are left holding the butts. There are a lot of great things about formula except for the fact that it can’t be produced at point of use by an individual. Mothers are heavily encouraged by social pressure to completely switch babies onto formula if they even think they might not be able to breastfeed. It’s never really looked upon as a viable alternative to use alongside breastfeeding. This is in large part due to the mommy wars and “breast is best” mothers acting like you’re giving your child poison if a drop of formula ever passed baby’s lips.
If mom is mostly breastfeeding for the first 9 months to a year and something like a massive supply issue with formula occurs (but that will never happen!) she can simply work to increase her supply again short term, get through the crisis, and by then as Matt pointed out, the baby will be older and your options are much more flexible. This would also make it easier to supply babies and other people who absolutely DO need formula during a crisis.
In other words - sometimes there are better options than a hard line on infant feeding in either direction.
I realize I'm coming from a very specific situation but I really disagree with this. My wife had supply issues basically from the start with kid one. He lost way more weight than acceptable for a newborn. Basically every lactation consultant and all the social pressure was "just work harder" to increase your supply and you'll get there. It didn't happen and it was insane amount of work for my wife and she was devastated by it. We tried again with kid two and it also just didn't work but we were in a much better position to realize the situation and quickly changed course. Mental health is much better and both kids are happy and healthy. So now basically any time anyone offers the solution just work harder to produce more milk, it makes my blood boil.
Yeah I get that ant it’s specific to your situation - your family obviously needs formula and I’m not arguing that my idea would work for everyone. I think it would work for enough people that it would potentially have made a difference in this supply chain scenario. It’s the “all or nothing” approach broadly that I think is bad. I’m not commenting on anyone’s personal experience which I know can be difficult and emotional.
Yeah, we might be in different filter bottles but all the doctors we've interacted with have been on the "breast is best, and we very very strongly discourage formula use".
My daughter started going after solid foods and refusing any kind of infant cereal at 5 months, so we sat down with her doc and went over what would be necessary to ensure she got everything she needed. She breastfed about half the time at 7 months, tapering to nothing by 11 months.
So she got loads of cow’s milk and we made sure her solids included the rest. It was *odd* to have a 6 month-old child clamoring for lamb curry at dinner but she’s fine.
I don't know why but I find that last sentence hilarious. It might be related to having an incredibly picky 20 month old (whose favorite food is somehow broccoli).
Oh dear. I think this article suffers from an excess of Reasonableness. This seems to be the key paragraph, and I think there might be a little hiccup:
“Under the current circumstances, I think advising parents of older babies that they can switch to animal milk would both give them peace of mind and also (more importantly) help resolve the underlying crisis. Consumption would rapidly fall by 10-30 percent, which would allow shelves to be restocked. That would reduce the incentive of parents with time and money to burn to stockpile or hoard formula, which would further alleviate shortages.“
If the FDA advises parents of older babies that they can switch to cow’s milk, is every parent going to listen? Formula consumption is not going to fall by 30%.
Really, with the exception of Slow Boring readers and Emily Oster fans, will anyone listen? Perhaps most parents will think “the FDA is advising this out of desperation [as indeed they are]. Cow’s milk is obviously second-best. I’ll keep buying formula whenever I can, just to be safe.”
Asking parents to turn on a dime and ignore years of child-rearing advice is a lot. Doing it after the public health community has spent two years lighting its credibility on fire is practically futile.
If people are having a hard time finding formula and a bunch of doctors go on tv telling people it’s ok for older babies to switch, and maybe they should to be patriotic and save the younger babies, I bet a lot of people would.
Probably some. And I suppose I shouldn’t discourage the FDA from making a forthright statement “this is what the best pediatric science says” without engaging in their usual public health psychologizing. Get those doctors on TV. Why not.
It’s not exactly scientific, but just a sense I get of the national mood right now. In a time of inflation and endless pandemic, I don’t think you’re going to get many people who are still willing to trust public health officials, curtail their consumption and (as they see it) risk their babies’ health for the sake of their country.
As a parent to a baby, I think the general consensus on my mom’s discord is that the guidelines are overly stringent and we follow them because we don’t feel we have the license not to. Given any wiggle room from public health officials many of us would be totally fine with swapping, myself included. I’m mad that I bought a tin of formula a couple of days ago when I clearly didn’t need to for my 11 month old at the direction of my pediatrician’s office.
"Adopt Canadian guidelines for older babies"
This is a terrible idea. Infant digestive tracts are unable to accommodate a steady diet of Tim's coffee, maple syrup, and Labatt's. It would lead to gross malnutrition, deferential self-effacement, and a compulsion to apologize for everything.
This could make twitter tolerable and pancakes more tasty. I fail to see the downside.
"This could make twitter tolerable..."
But only on the assumption that most twitter-users are babies, whereas
Oh. You may be on to something.
Don't forget the compulsion to put gravy and cheese on french fries. Also, speaking French!
Speaking French: not a Canadian thing.
Speaking Quebecois: a Quebec thing.
Hating French: an Alberta thing.
Pretending to be open-minded about Francophonie: an Ontario thing.
Liking poutine: A Canadian thing (even if you don’t like the Québécois)
Not liking that the Anglos like poutine: A Québécois thing (even if you don’t like poutine)
Being confused at what the Canadians have done to disco fries: A Jersey thing
The Canadian WHO relief document recommends mixing cow's milk, water, and a teaspoon of maple syrup rather than sugar
I believe that the Canadian group is not " the WHO," but rather "Guess Who".
Completely different band.
And their exact recommendation on glucose replacement was:
"No sugar tonight in my coffee/ no sugar tonight in my tea."
Ah, but if you supplement the Canadian diet with iron-rich foods, you avoid the malnutrition. Can’t do anything about the self-effacement and compulsion to apologize, though (but is that really such a bad thing?)
"(but is that really such a bad thing?)"
Taking an unapologetic stand on apologizing: you're clearly not Canadian.
No, I am from Michigan. Best of both worlds lol.
While true, they CAN handle poutine.
Peameal for preemies.
I know not everything is about my thing, but this issue really seems like it would have been alleviated if Democrats could focus more on improving existing bureaucracy when in office rather than on just blasting more money into the machine.
If FDA had adequately consulted and informed other agencies about this decision and its impact, there are plenty of smart people in the admin who could have alleviated this before it became a crisis.
Fundamental competence was one of the top selling points for Biden & contrasts with Trump. It’s also something they could really accomplish even without congress. But I do think it requires serious focus from top levels of the executive to make it work.
Doing battle with a sclerotic bureaucracy would consume time, public attention, and even some political capital (just from fending off critical news and takes from the effort).
I'm an evil conservative, but even I can't blame Biden for now focusing on that.
Though it does direly need to be done.
I think you’re too generous. On net I’m probably still a Biden supporter, but if you’re going to advocate for “big” government (including loads of generous social programs), as I largely do, you damned well better be making sure government works well. The baseline should be _at least_ as competent and cost effective as private sector.
FDA, when it shut down a huge portion of formula supply without considering the consequences, massively fucked up. Not the first time, not the last. The FDA, like the CDC, is slowly but surely becoming notorious for fuckups. If we can’t trust our regulators, why should we trust regulation at all - would the market have let our children starve, or driven mothers to panic and desperation in the presence of clear alternatives?
It’s not enough to believe in the power of government to improve peoples lives, democrats need to bust their asses to prove it. Elected office is an honor and a privilege, not just another 9 to 5, and we should absolutely expect more.
No, this is not the fuckup you think it is. If anything the question is whether they acted soon enough. They found Cronobacter. It kills.
I'll take it as a given that the plant needed to be shutdown for safety reasons, but they could say:
"We need to block this supply because of the bacteria. We are temporarily allowing baby formula approved by <Canada/Germany/similar situation> to be imported legally."
Does malnourishment not kill? Does driving hours a day while overtired and desperate to find food for your child not kill? We’ve gone over this with COVID already (“but COVID also kills kids - see random example plucked from obscurity - so schools should stay shut until COVID is eradicated no matter the cost”) and I wish I could say I’m surprised that people aren’t generalizing the lesson.
I held off on making this comment earlier and I’m disappointed it is necessary:
I have doubts about the public’s ability to think about or understand the fact that we don’t live in a post-material world. Sometimes there actually are material constraints. I see progressives regularly spout bullshit like “just give everyone a house”, and “nobody should have to work if they don’t want to” and “all healthcare should be free” and not appreciate that things like food and housing and education and healthcare do not just materialize out of the ether. Similarly, regulations that destroy supply (even flawed supply) needs to be questioned.
The fuckup is not in the recall, but in doing the recall without a plan for keeping children healthy and fed.
I could not agree with you more. The insistence on making single-variable decisions with blinders on is destroying confidence in agencies like the FDA or CDC.
Businesses manage to consider more than one variable all the time - why the fuck can't regulators? It's not like this kind of thing is too difficult to figure out. Companies like Walmart, Amazon, and Facebook deal with this kind of thing every day. There's no reason that government shouldn't be able to think through tradeoffs too - and it *needs to* if we want the kind of strong social support systems and competent governance that so many of us want (myself included).
Not saying you're wrong, but does the FDA have the authority to weigh the importance of practical concerns vs. a strict focus on health & safety?
While I agree that the functioning of bureaucracy is often overlooked, this decision had such a critical impact because two companies have such dominance over the formula industry.
As best I can tell, much of the reason that two companies have such dominance is because of their lobbying for regulation keeping out competitors.
In fairness, the Biden administration is vastly more competent than the Trump administration was. It's not even close. It's also more competent than W's was, although the ratio is lower there.
This is essentially our situation. My wife and I accidentally each bought large quantities of formula (because it's expensive and you use a lot so it just makes sense to buy in bulk) at the same time right before the shortage really started. We recently ran out of that excess supply and decided since our kid was eleven months that we would just switch to cow's milk. I can't imagine how much more stressful this situation is for parents of younger babies.
I also just want to say this has been yet another instance where the "anything other than breast milk is ruining your kid's life" crowd are really annoying and destructive. Saying things just put in the effort to relactate is really anti-helpful and adding mental stress for parents that are already in an extremely difficult situation.
It really does feel like a cult. We had our baby at a top tier research hospital and everything was supposedly extremely evidence based (including in their communications). I'll totally buy that breast milk is better all things considered but the degree of emphasis and way it was communicated really felt very strange and cult like. I know a lot of topics in the parenting wars are like this (looking at you, sleep training monsters!) but this might be the most extreme.
Lol.
On sleep, I unceremoniously dumped her in her new nursery at 4 months and let her cry it out for three hours while I literally sat on my wife.
On day two she cried for ten minutes and gave up, cooed for a bit and went to sleep.
On day three, cooing and sleep.
Not bad for no effort on my part, lol.
I wasn't willing to literally hold my wife down, and so the sleep training failed on most of our kids.
Maybe I should have though.
My kid weaned wayyy before a year on her own, so #^€% those judgmental idiots.
With no breasts between us my husband and I decided to ruin our kids' lives with formula.
How dare you not assault random passersby and milk them?
I appreciate the correct pluralization.
We were hoping to be in this situation. My supply has decreased a bit faster than our 11 month old was weaning, so we figured we’d supplement with formula to bridge the gap. Then the formula shortage hit, and we messaged our pediatrician’s office to see if we could be flexible about the 12 month rule. All they responded with was that we needed to wait until the year mark to begin substituting at all. No questions about her solids diet (varied) or the rest of her liquid diet (breastmilk several times a day).
We didn’t have time to become amateur pediatric researchers on why cow’s milk before 12 months is recommended against, so I drove around town trying to find an extra tin or two to make it to June. And now I feel guilty for taking one of the 25 remaining tins at my local Target.
More broadly, is there some way the federal government could give overall reliability ratings to foreign regulatory agencies? Part of what makes this so sensible is it's a very reasonable bet the Canadian equivalent of the FDA more or less knows what they're doing. Ditto for most rich-world regulators on a lot of issues, and who knows, maybe some developing-country regulators as well. We obviously want to have our own regulatory agencies making their own determinations, but a government that says "here are some foreign agencies that are staffed by qualified professionals, and in a pinch, you're not going to get anybody killed following their instructions" would seem way more reasonable and normal. And if, like, the Swiss pharmaceuticals regulator (or whoever) is weirdly corrupt and incompetent for idiosyncratic reasons, that would be good to know too!
This is actually something I very briefly looked into back when covid vaccines had been approved in Europe but not the US.
Apparently there's something akin to that for drugs so your idea is at least within the realm of the possible. I don't/didn't feel like reading more into the specifics of it but there's info at this link here.
https://www.fda.gov/international-programs/international-arrangements/mutual-recognition-agreement-mra
The AAP has a bad habit of taking extreme dogmatic positions that go beyond the evidence. This is how we got a surge in peanut allergies.
What makes it even more frustrating is that they keep taking these kinds of positions and never really seem to learn from them. They really should have learned from the "no peanuts until 12 months" fiasco and tried to figure out how they ended up taking a hard line that actually hurt kids and improved the process for issuing guidelines. It really doesn't help their credibility. When I heard the "never feed a baby under 12 cow's milk" line, I assumed it was overblown.
If you own a stethoscope and a white lab coat, then by definition you can't be wrong!
Absolutely! Just look at those supplement ads on daytime tv
The FDA seems to stumble from failure to failure. Maybe food or drug regulation is especially challenging but it seem to have more problems than all the other federal agencies combined.
I suspect the FDA is actually poorly run but I'm guessing the idea that it's uniquely poorly run among federal agencies is just the availability heuristic talking. The VA, the Secret Service, the DOJ, the FBI... plenty of federal agencies haven't exactly covered themselves in glory of late.
My casual feeling is that the FDA fucks up a lot, but at least they're fucking up hard problems. It seems like there are plenty of agencies that are just as effective at fucking up easy problems.
May I introduce you to CMS, the Centers for Medicare and Medicaid Services, and FDA's sibling at HHS?
Or the DEA, which had one job when it comes to opioids -- preventing their diversion from legitimate medical use -- was the only entity in the country with a birdseye view of the manufacturer and distribution of opioids, including literally setting production quotas for each manufacturer, and received detailed reports of where it was all going, but mostly just stood there and watched as it happened?
...or generally just any regulatory agency that is charged with managing a complex economic system?
How many times do we need to learn that regulation needs to be as light as possible and that a centralized economic planning commission (which is what the FDA continues to grow toward) results in inefficiency, shortages and capture by the rich and powerful?
He did: https://www.slowboring.com/p/mailbag-lamb?s=r
Seems like as good a place as any for me to yell into the void: The fact that the shutdown of *one* factory can put us in crisis mode is pants on head stupid.
I wonder if particularly onerous regulations helps cause the kind of market consolidation that leads to this?
Getting a plant qualified by the FDA to produce this is pretty costly, and that may pose a barrier to entry, and/or enhance the competitive advantage of being a big company in general.
I don't believe the regulation to be overly onerous. I lived in China in the midst of one of its many "we just killed a thousand-odd infants" scandals related to contaminated baby formula. This is, IMO, just one of those things where it leads to consolidation *despite* being necessary.
I'm not sure there's a way to craft a regulatory regime light-touch enough to avoid this market being run by 3 companies while actually maintaining the safety of the incredibly finicky, easily-contaminated product that we feed to the objective most vulnerable (and emotionally most valuable) population among us.
Open to thoughts on the matter though.
It might not be possible to do both. I suspect that that determination will require a lot of technical expertise about food production, and I don't have that.
I do have experience dealing with the FDA from a medical device design, safety analysis, and manufacturing standpoint, and I do think that many of the FDA's requirements there are pretty onerous - and not very effective at really mitigating safety risks, and so probably unnecessary.
It is a different animal than food production, but I kind of assume (perhaps unfairly) that the bureaucracy will function similarly across the board.
I'm in favor of light-touch regulation on a variety of topics; OSHA's construction site provisions might as well be (and I suspect were) designed to be impossible to follow so that one can politicize enforcement.
Childcare regulations are another area I'm familiar enough with to feel confident.
Production of powdered dry goods from extremely perishable precursors, destined for easy-to-poison children?
I'm not inclined to brook the typical "it'll be fine" libertarian line on this one. I would want a disinterested, educated observer to tell me what to do.
Which is why we need to pay the damned civil service well enough to entice some of the private sector's experts to come over and ride herd on their former colleagues.
Would you be so kind as to expand on the OSHA construction site provisions? I have not heard about this, and I would very much like to know more. Thank you!
Great advice. I'd add:
* Do not shut down key infant formula production facilities on the basis of questionable safety issues.
* Allow foreign baby formula to be sold in the United States.
* Stop demonizing parents who feed their babies formula, it's a miracle of modern science whose production and quality needs to be treated as a source of national pride. In China they have no such scruples about breastfeeding vs. formula – formula is widely regarded as superior to breastfeeding and indeed American formula is massively sought after there. People buy pallets of it to ship back to China.
2 babies died because of the plant contamination.
I saw that Abbot has rebutted this saying that the strains of bacteria found at the plants does not match the bacteria that killed the 2 babies. Has there been further evidence come to light about it?
And how many babies are going to die because of this formula shortage?
Finitely many. Which is fewer than the infinitely many that would die from a plant permanently contaminated with cronobacter toxins. Sooner or later, the plant would have to shut down and clean itself; the question is just when. You can argue that it should have shut down later, so that we could build and start a backup plant first, but arguing that the plant never should have shut down is silly.
I do not have kids, but I’d be curious to know if anyone with young kids went to their pediatrician and inquired about feeding and received advice akin to “you can give them milk and some food” or if doctors (and parents) are mostly risk averse here and just stress finding formula since it is most nutrient-dense. Maybe age of the doctor would make certain answers about what is okay more or less common…
Personal anecdote my mother has told me in the past: I was a fat baby and cried a lot and when she went to the doctor they suspected I just still hungry often. She began putting cereal in my bottle way before her other kids. I suspect this was just practical advice/something the doctor suggested and I turned out fine and presumably stopped crying.
Again, I know nothing on how these things shake out in reality, but Emily Oster’s work is one fairly recent piece of analysis that shows we don’t have very good evidence that many existing parental guidelines make much of a difference in kid’s outcomes.
Our pediatrician said that once she started eating solids (~9 months) we should phase out formula in line with increasing solids.
I already replied to a different comment, but I can say that we asked our pediatrician’s office if we could introduce cow’s milk for combo feeding (she gets tons of varied solids and mostly breastmilk but we need to supplement one bottle a day with formula) since our baby is 11 months old. They didn’t budge on the year guideline.
Amazing how little genuine expertise most MDs seem to confer on the holder.
Same story here as Ray, just that she started going for solids at 5 months, lol.
She’s a large but healthy kid so it was fine here too.
This isn’t the only example of the FDA being dumb about formula, it’s only the latest one. Anyone interested in the topic or in the topic of radical FDA procedural reform should check out Scott Alexander’s discussion of how our formula formulation was killing babies for 20 years while European formulations were not for very simple and well understood reasons: https://astralcodexten.substack.com/p/details-of-the-infant-fish-oil-story?s=r
I mean… that’s not even an accurate portrayal of the headline of that article, let alone the content. We’re talking about IV drips, not formula, and a pretty rare medical condition. And the FDA, given its remit, did pretty well.
Strong disagree on them doing pretty well, but fair in my misremembering it being formula. I read that when it was originally published last year and kept infant and nutrition and FDA bureaucracy but missed IV.
Again, within the context of its remit, it did fine.
That its remit makes it impossible to do much of anything quickly with the resources its provided is not, in and of itself, the fault of the FDA.
Go yell at your Representative.
As for the article, it was a good recounting of the circumstances, but this paragraph:
"My problem is: doing anything in medicine is illegal until you clear a giant hurdle. To clear the hurdle, you have to pay millions (sometimes billions) of dollars, fill in thousands of pages of forms, conduct a bunch of studies that can be sabotaged for reasons like “this drug is too good so it would be unethical to have a control group”, and wait approximately ten years. You have to clear this hurdle to do anything, even the most obviously correct actions. Everything starts out illegal, and then a tiny set of possible actions is exempted from the general illegality. The easiest name for this hurdle is “the FDA”, since they’re the agency charged with enforcing it."
requires a bit more examination. In the absence of this regulatory regime, you have the bad old days where patent medicines with lead and mercury killed God-knows-how-many tens of thousands annually. So sure, let's refine the FDA's remit, give it the legal framework to expedite reviews as needed, provide more resources... but acting like it's worse than what came before is another of those stupid, libertarian fantasies.
We seem to be particularly bad at these kind of collective public health (or p.h. adjacent) issue.
I'm sure both social and bureaucrattc dysfunction is involved, but it seems like instead of basically saying something like 'There is a baby formula shortage, so if your child is over X months of age and otherwise healthy, please consider...' and trusting the enough of the public can understand and will try to comply, we get all kinds of tortured messaging in an attempt to achieve a similar result.
It closely parallels the 'masks aren't effective' guidance early in the pandemic.
They could have just come out and repeatedly said 'masks are somewhat effective, but we need to reserve them for front-line workers until supply improves.'
Instead of trying to manipulate the public, give an honest and straightforward message and let the chips fall where they may.
Reading about infant feeding supply chains is so much better than actually feeding infants.
Import Irish baby formula. Has extra Baileys Irish Crème, which helps babies sleep through the night.
"...Baileys Irish Crème..."
Guinness or feck off.
True story: when my wife delivered in an NHS hospital in the 80s, the midwives encouraged her to drink beer "to let the milk down". Don't recall whether they specified Guinness, but "Guinness for nursing mothers" is a very well-established adage.
This is the content I pay for.
I hate to be “that mom” but I’m really tired of these “breast isn’t REALLY best so we should just feed formula and that’s valid and OK” and then this formula shortage happens and parents are left holding the butts. There are a lot of great things about formula except for the fact that it can’t be produced at point of use by an individual. Mothers are heavily encouraged by social pressure to completely switch babies onto formula if they even think they might not be able to breastfeed. It’s never really looked upon as a viable alternative to use alongside breastfeeding. This is in large part due to the mommy wars and “breast is best” mothers acting like you’re giving your child poison if a drop of formula ever passed baby’s lips.
If mom is mostly breastfeeding for the first 9 months to a year and something like a massive supply issue with formula occurs (but that will never happen!) she can simply work to increase her supply again short term, get through the crisis, and by then as Matt pointed out, the baby will be older and your options are much more flexible. This would also make it easier to supply babies and other people who absolutely DO need formula during a crisis.
In other words - sometimes there are better options than a hard line on infant feeding in either direction.
I realize I'm coming from a very specific situation but I really disagree with this. My wife had supply issues basically from the start with kid one. He lost way more weight than acceptable for a newborn. Basically every lactation consultant and all the social pressure was "just work harder" to increase your supply and you'll get there. It didn't happen and it was insane amount of work for my wife and she was devastated by it. We tried again with kid two and it also just didn't work but we were in a much better position to realize the situation and quickly changed course. Mental health is much better and both kids are happy and healthy. So now basically any time anyone offers the solution just work harder to produce more milk, it makes my blood boil.
Yeah I get that ant it’s specific to your situation - your family obviously needs formula and I’m not arguing that my idea would work for everyone. I think it would work for enough people that it would potentially have made a difference in this supply chain scenario. It’s the “all or nothing” approach broadly that I think is bad. I’m not commenting on anyone’s personal experience which I know can be difficult and emotional.
It's like we socially, collectively, oscillate between extremes.
Either 'breast is best and you are a failure if you don't breastfeed' or 'formula is just as good and how dare you shame mothers who don't breastfeed'
A boring but reasonable stance of:
'breast is best, but formula is good enough in almost all situations, so don't stress out about it too much one way or the other.'
...doesn't get much social visibility.
(Even though I think that's basically the american pediatrics official stance.)
Yeah, we might be in different filter bottles but all the doctors we've interacted with have been on the "breast is best, and we very very strongly discourage formula use".
My daughter started going after solid foods and refusing any kind of infant cereal at 5 months, so we sat down with her doc and went over what would be necessary to ensure she got everything she needed. She breastfed about half the time at 7 months, tapering to nothing by 11 months.
So she got loads of cow’s milk and we made sure her solids included the rest. It was *odd* to have a 6 month-old child clamoring for lamb curry at dinner but she’s fine.
I don't know why but I find that last sentence hilarious. It might be related to having an incredibly picky 20 month old (whose favorite food is somehow broccoli).
My kiddo was very similar to this, including lusting after things like lamb curry!
Oh dear. I think this article suffers from an excess of Reasonableness. This seems to be the key paragraph, and I think there might be a little hiccup:
“Under the current circumstances, I think advising parents of older babies that they can switch to animal milk would both give them peace of mind and also (more importantly) help resolve the underlying crisis. Consumption would rapidly fall by 10-30 percent, which would allow shelves to be restocked. That would reduce the incentive of parents with time and money to burn to stockpile or hoard formula, which would further alleviate shortages.“
If the FDA advises parents of older babies that they can switch to cow’s milk, is every parent going to listen? Formula consumption is not going to fall by 30%.
Really, with the exception of Slow Boring readers and Emily Oster fans, will anyone listen? Perhaps most parents will think “the FDA is advising this out of desperation [as indeed they are]. Cow’s milk is obviously second-best. I’ll keep buying formula whenever I can, just to be safe.”
Asking parents to turn on a dime and ignore years of child-rearing advice is a lot. Doing it after the public health community has spent two years lighting its credibility on fire is practically futile.
If people are having a hard time finding formula and a bunch of doctors go on tv telling people it’s ok for older babies to switch, and maybe they should to be patriotic and save the younger babies, I bet a lot of people would.
Probably some. And I suppose I shouldn’t discourage the FDA from making a forthright statement “this is what the best pediatric science says” without engaging in their usual public health psychologizing. Get those doctors on TV. Why not.
It’s not exactly scientific, but just a sense I get of the national mood right now. In a time of inflation and endless pandemic, I don’t think you’re going to get many people who are still willing to trust public health officials, curtail their consumption and (as they see it) risk their babies’ health for the sake of their country.
As a parent to a baby, I think the general consensus on my mom’s discord is that the guidelines are overly stringent and we follow them because we don’t feel we have the license not to. Given any wiggle room from public health officials many of us would be totally fine with swapping, myself included. I’m mad that I bought a tin of formula a couple of days ago when I clearly didn’t need to for my 11 month old at the direction of my pediatrician’s office.