There are peanut allergies. People can die if they eat a peanut by mistake. [
Peanut Allergies Over-Reaction]
At the same time, there is a peanut shortage [
Soaring Peanut Prices Hurt Food Banks]
Looks like a job for government regulators. (I've been on both sides, with a decade as both a regulator and a decade as a private business and a decade in the non-profit / activist sector).
First, at the point the peanut is harvested, you put in
rules against harvesting bad peanuts. Ok, this really has nothing to do with deaths from peanut allergies, but you've been called and it doesn't sound unreasonable.
Peanut Stewardship: Second, you institute a state procurement plan to pay for
destruction of bad peanuts. You've been told it's really expensive to remove bad peanuts. So you tax peanut butter, peanut oil, the producers of new peanut snacks, to help pay for the inspection and removal of bad peanuts.
Now, since the peanut collectors are getting state funds (from peanut butter tax), it's reasonable to require more rules and regulations of these nut collectors. In addition to the rules for
what happens to bad peanuts removed through the subsidy program, you add a line about what
may happen to the good peanuts. Surely it's reasonable to track them.
The easiest way to regulate this is to declare all peanuts "bad" or "waste" or "p-waste", and then to set conditions under which they can be "de-wasted".
Local P-Waste Reuse: You want to know how many peanuts are eaten locally. Vermont is a small state with porous borders. Since trucking is harder to track than you thought, you define "local" as the "United States of America". If the peanuts are sold to Florida, California, Texas, Alaska or Hawaii, they must be tracked. Define "local" as USA.
An anti-externalization/anti-globalization activist/watchdog suggests that sale of good peanuts could still be a loophole for export of bad peanuts to countries with little infrastructure to deal with them. "Up to 80%" P-Waste exports result in crying children photos.. Regulators are paying so much for the bad peanut destruction, that would be a terrible loophole, a shame, if some bad peanuts were labelled good peanuts, and paid for by exporters instead of charged to the state subsidy... it would be a failure of the whole state subsidy program if bad peanuts got through.
Again, you don't actually have the authority to under RCRA Waste regulation to seize or regulate good peanuts.
So you define all peanuts as 'pwaste' even if they are
not charged to the bad peanut removal program (because they were good peanuts).
Although they are not charged to your bad peanut removal program, the good peanuts must be tagged as "p-waste" at the point of collection. They can be "un-wasted" if they qualify as good. This is how you capture Reuse under RCRA, which has defined reuse not to be waste.
You institute a toe-tag label program. Every single peanut collected in Vermont is labeled "p-waste", so that you maintain the authority in case a bad peanut is labelled a good peanut. Do not tag bad walnuts, bad almonds, stones, dirt, roots, or as waste, as these are not "covered nuts". Not all waste is "p-waste", and not all "p-waste" is waste, and not all p-waste is covered by the subsidy... clear enough.
Now, to define how good peanuts, not charged to the program, may be used. Some good peanuts go into peanut butter, some go into peanut oil, some go into snacks. You now ask the collectors to identify whether the peanuts are going into a snack, an oil, or a butter. The collectors and farmers explain they don't know, they sell peanuts to a
peanut buyer who grades and processes peanuts for sale.
To simplify, since the farmers are allowed to sell for "local" use, and most local reuse in Vermont is for snacks, you define local use to be snacks. You then write a rule that the collectors can only sell peanuts to snacks, and that if sold as snacks, they cannot be charged to the bad peanut program. But first they must be tagged as bad peanuts, so that snacks do not become a loophole for
poisoning people.
This is not a game. Remember, environmentalists have pictures of poor children. People die. The ebattled regulators have been accused by watchdogs of being pushed around by peanut collectors and processors, you need to demonstrate you can regulate this. Be firm.
Now, peanuts sent for non-local reuse can be defined to be butters or oils. You now need a plan from the peanut buyers, the ones who process peanuts for sale to oil, butter, and snack manufacturers. You don't want to complicate the paperwork you've created, so you ban the processors from selling for "local use" (forgetting you have defined the USA as "local", or perhaps not caring, or perhaps just living up to the laws you've written - its a thankless job).
If a peanut is sold as good to the "export" market for oils and butters, it must have been tagged a "waste" but must not have been charged to the "waste" program. The professional peanut processors complain that selling perfectly good peanuts labelled as "waste" violates the health laws of the importing nation, which is trying to keep bad (waste) peanuts out of their products, and bans use of "waste" peanuts to make butters and oils. Cleverly, you see this is an attempt to reopen the loophole, and must stand firm.
Now, the processor must define a plan for the export of "un-wasted" peanuts, regulated but not charged to the waste peanut program. The plan needs to account for whether peanuts are sold for oil, waste, or snacks. Is the shell removed? Explain how the shell is left intact for the snack market, or removed for the butter market. What? Some snacks, such as candy bars, remove the shells? Simple, just explain that in your plan so that sales can be approved. Stop complaining.
Wait. The bill you sent for waste peanut destruction shows that some peanuts have been removed. While there was a plan and an understanding that peanuts would be removed for use, the missing peanuts must be labelled and tracked. That is, in addition to not charging for them through the waste peanut program, and selling them only through a certified non-local (export) oil, butter, or snack program, you must INDIVIDUALLY account for the peanuts removed from individual bags of "p-waste".
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| All in all they're all just bricks in the wall |
The processor tries to explain "triage". The people like collectors or sorters are trained to remove bad peanuts. They are not trained to know which peanuts are best sold for candy bars, peanut oil, or crunchy style or smooth peanut butter. That happens at the buyers, or according to the purchase order QA/QC of the buyers. Oil buyers have a different specification for "good" peanut than snack buyers. In fact, a perfectly tested working peanut might not be right for the individual snack, oil, or butter factory.
The fact that a shell-on peanut is not accepted by the oil factory does not mean the shell-on peanut was "bad", but it will
become "waste" if you send it to someone who doesn't or cannot shell peanuts. This is the same fallacy of "tested working" and "fully functional" computers, they are not all acceptable at the best buyers. Because your solution didn't work for them, that doesn't make them bad people!
