Wednesday, January 28, 2015
Don't Write Blog Posts Late at Night
The original version of this post had the math backwards, as an astute reader pointed out. Sorry about that. The real news is that, based on a sample of 450 products analyzed by the U. S. Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau (TTB) for the 2014 Alcoholic Beverage Sample Program (ABSP), 31 percent of the beer, wine, and spirits products sold in the United States do not comply with TTB rules. The 2013 results were about the same.
The 2014 sample included 190 distilled spirits, 155 malt beverages, and 105 wines. One-hundred-thirty-nine products were non-compliant; 73 distilled spirits, 46 malt beverages, and 20 wines.
The most common offense? Alcohol content that did not match the label. In some cases, the actual alcohol content places the product in a different tax classification.
Another common violation is labels that do not match their approved Certificate of Label Approval (COLA) due to changes that are not allowable revisions. Approximately 25 percent of the non-compliant labels contained such changes in information. As least one product in the sample went on the market without ever submitting a COLA.
Is 69 percent compliance good enough? Is that even a fair way to read this report? Four-hundred-fifty is a small sample size when TTB reviews more than 100,000 labels, advertisements, and other material each year. But it’s the only measure we have of TTB’s effectiveness at "assuring that alcohol beverages sold in the United States are properly described on the container."
(My statistics consultant advises that a sample size of 450 should be 95 percent accurate, regardless of the size of the universe.)
I know what TTB’s mission is because I read it in the TTB labeling brochure, under the heading “How TTB Protects the Public.” It begins:
“American adults who enjoy an occasional alcohol beverage of their choice do so without fear that the product they are consuming might not be labeled properly. Why don't they need to worry? Because a small Government agency takes pride in assuring that the alcohol beverages sold in the United States are properly described on the container.
“TTB takes tremendous pride in its strategic mission to ‘Protect the Public,’ which is designed to assure the integrity of alcohol beverages in the marketplace, verify and substantiate industry member compliance with laws and regulations, and to provide information to the public as a means of preventing consumer deception.”
I apologize to everyone who read the original post. My problem with math is that I often miss obvious mistakes, especially late at night. I should also give you the link to TTB's original release, so you can figure it out for yourself.