The Volokh Conspiracy

Fighting Trans-Fats in Court:

On Monday, the Center for Science in the Public Interest filed a class-action suit against KFC to force the fast-food chain to eliminate (or at least disclose) its use of partially hydrogenated oil — described by CSPI as "the chemically altered, trans-fat-laden oil that kills roughly 50,000 Americans per year." The suit, filed in District of Columbia Superior Court, alleges that KFC's use of partially hydrogenated oil without explicitly informing consumers violates D.C.'s local consumer protection laws.

"Grilled, baked, or roasted chicken is a healthy food-and even fried chicken can be trans-fat-free," said CSPI executive director Michael F. Jacobson. "But coated in breading and fried in partially hydrogenated oil, this otherwise healthy food becomes something that can quite literally take years off your life. KFC knows this, yet it recklessly puts its customers at risk of a Kentucky Fried Coronary." . . .

"District of Columbia law allows consumers to seek relief from the courts when companies fail to disclose essential facts about their products," said CSPI litigation director Stephen Gardner. "That KFC uses the worst frying oil imaginable to prepare its chicken is something that KFC should absolutely be required to disclose at the point of purchase."

The lead plaintiff in the case is retired physician Arthur Hoyte, who claims to have eaten at KFC numerous times unaware of the risks to his health.

"If I had known that KFC uses an unnatural frying oil, and that their food was so high in trans fat, I would have reconsidered my choices," said Dr. Hoyte. "I am bringing this suit because I want KFC to change the way it does business. And I'm doing it for my son and others' kids-so that they may have a healthier, happier, trans-fat-free future."

CSPI's complaint is here. The New York Times reports on the suit here.

UPDATE: More on this suit from Overlawyered.com and Michael Krauss.

redheadlaw7 (mail):
What's next? Someone suing Taco Bell because they didn't know that ordering a 7 layer burrito with extra sour cream and guacamole was bad for them? If that were a viable claim...then I'd be the first to ask "where do I sign up?". I mean, after all, the beans are loaded with protein and the lettuce and tomato would constitute at least two servings of vegetables...what's unhealthy about that? Sheez!
6.14.2006 11:37am
Syd (mail):
It's easy to sneer, but if they are using an ingredient you would not expect to find in fried chicken, one that is linked to heart attacks, their customers should know.
6.14.2006 11:45am
A.S.:
What a complete joke. This is a DOCTOR who is unaware that eating fried food could potentially be bad for you? The guy should lose his medical license.

And it is time for the Health Fascists like CSPI to go away.
6.14.2006 11:51am
MDJD2B (mail):
A.S. and Syd,

Trans-fats are worse for you than alternative fats that can be used in frying. Some of hte fast food chains allegedly use them here, but not in certain other countries that regulate them.

This is not like the stupid suits by obesre people who claim not to know that eating 16 Big Macs a day make you fat. This is a request for elimination or disclosure of a harmful substance that is easily replaceable.

Perhaps this should be done by legislation instead of lawsuit, but the issue is not as absurd as youmake it out to be. Requiring disclosure (if not removal) seems to me to be a reasonable exercise of the state police power.
6.14.2006 12:01pm
Bobbie:
Nearly any product can be dangerous. The question is whether the maker of the product, here KFC, should be able to use a dangerous substance without warning the consumer.
6.14.2006 12:03pm
redheadlaw7 (mail):
Am I the only one who's heard of online and instore nutritional guides?

KFC has one on its website, and surprise surprise, it lists trans fat.
6.14.2006 12:06pm
Jack S. (mail) (www):
One of the most wonderful milk dipping cookies, the infamous Oreo was the subject of lots of transfat debate.

As with most 'dangerous' objects which in America includes just about anything one can think of it boils down to informing the victim beforehand.

6.14.2006 12:07pm
Medis:
As is often the case, the situation is more complicated than some of the commentators are suggesting. This specific issue arises because one cannot tell just from the nature of the food that it contains particularly high levels of trans fat, since that depends heavily on the oil used in preparation. In that sense, two pieces of seemingly identical fried food can contain very different levels of trans fat.

That said, this is not the sort of issue best resolved through litigation. Indeed, the FDA has already mandated that nutrition labels on packaged food include information about trans fat content (which became effective January 1, 2006, although the FDA has granted some extensions).

Something similar could be done with respect to fast food. In general, I think a good case can be made that fast food should be subject to labeling requirements, since people are increasingly relying on fast food for a significant portion of their dietary intake. But even if you don't think general labeling is necessary, labeling with respect to this issue may be a good idea, again because one cannot tell from simple inspection what oil was used in preparation.
6.14.2006 12:11pm
Jeek:
coated in breading and fried in partially hydrogenated oil, this otherwise healthy food becomes something that can quite literally take years off your life.

Those years without delicious breaded chicken fried in trans fats simply wouldn't be worth living! =D
6.14.2006 12:18pm
Medis:
redheadlaw7,

How often do consumers check the websites of fast food companies before eating their food? Indeed, how often do consumers even know in advance exactly what fast food chain they will use, and what they will order?

It makes sense for the relevant information to be conspicuously available at the time and place where the consumer makes his or her decision about what to order. Indeed, that's why we require nutrition labels on packaged food, as opposed to putting it on a website or a master chart somewhere.
6.14.2006 12:22pm
Anonymousss (mail):
this problem would be solved if people would just avoid kfc and eat real fried chicken instead.
6.14.2006 12:24pm
The Drill SGT (mail):
consumer product safety law always makes me laugh. My wife (the lawyer) used to share the articles from one of her journals, they were always worth the read. Examples:

1. guy installs a diving board on a 4 ft deep above ground back yard pool, dives in, breaks neck, sues the world and wins.

2. Professional butcher removes the interlock on the safety guard on his meat slices (the circular saw kind). Slices thumb off. sues because manufacturer should have designed it so that he could not bypass safety devices. wins

3. need a talk about step ladders? there is not a blank spot on them that doesnt have a warning label.

consumer products lawsuits, the attorneys and the juries are amazing.
6.14.2006 12:34pm
redheadlaw7 (mail):
Medis,

Respectfully, the nutritional information is available at most fast food stores. I've requested it every time I've decided to "try" low-carbing it. There are even signs conspicuously posted in most of these places that say nutritional info is available upon request. They keep the handouts conveniently beside the register.

If the point is that we want to protect the people that don't feel like asking for this information, then I guess that's another story.

I guess my point is, if one is so inclined to monitor what goes into their body because they are concerned about their health...the info is readily available.
6.14.2006 12:38pm
redheadlaw7 (mail):
Upon further reflection, maybe there should be more obvious labeling. After all, some poor soul has made it necessary for all hairdryer manufacturers to clearly warn "do not use while in the shower."
6.14.2006 12:42pm
Sigivald (mail):
Medis: Do you seriously suggest that Trans Fats are somehow so incredibly dangerous that KFC should be required to have a big red sign saying something like "Danger! KFC Chicken contains Trans Fats and Will Murder You With Flavour!"?

Because otherwise, if the risk from a meal is as low as everyone that isn't CSPI thinks it is, isn't the requirement for "conspicuous" and "relevant" (who decides if using any [or some arbitrary threshold of] trans fat is relevant? The neo-prohibitionists at CPSI? The FDA?) information a complete overreaction?

And won't it typically lead to people simply ignoring the proliferation of signs and hysterical information?

I mean, Christ, it's not like the chicken is full of hydrogen cyanide. We're talking something that moderately to slightly increases the risk of heart disease if you consistently eat a goodly amount of it, and nothing more.

(Full disclosure: After long experience, I reflexively despise anything CSPI does. This reaction has not yet once done me harm.)
6.14.2006 12:45pm
Cyrus (www):
Frivolous or not, if this suit gets KFC to switch to healthier oil, it can only be a good thing.
6.14.2006 12:49pm
Splunge (mail):
To be fair to both KFC and the FDA, part of the problem has been that our understanding of the role of fats in heart disease has changed several times over the past few decades. It's still not wholly resolved.

Part of the problem has been that sometimes a diet high in fats is correlated with increased risk of heart disease, and sometimes (e.g. the famous 'Mediterranean' diet) a diet high in fats is correlated with a reduced risk of heart disease. Gradually we've come to understand that all fats are not equal, and some are bad for you and some are actually good. But only slowly are we learning which is which.

The problem is exacerbated by the fact that there are many different possible chemical variations on 'fat.' That is, 'fats' are not just one type of chemical but many, and somewhat surprisingly it turns out each has to be independently assessed for its effect on health -- there does not turn out to be much in the way of generalizations about the entire class of compounds that we can make.

Furthermore, fats are chemically modified by the packaged and fast food industry to improve the texture or storage life quality of their foods. No one tested these modifications before, because we used to think that we could deal with 'fats' as a single class, more or less, and that minor modifications would produce, well, minor changes in how they effect people. Now we are seeing that, surprisingly, minor chemical modifications in fat can make major changes in how they effect people. No one saw this coming. So the FDA is struggling to think out how to deal with this, and the packaged and fast-food industry is scrambling to keep up.

Personally I think they're both trying to do the best they can, but the situation is confusing, $billions are at stake, and there is probably a significant lack of trust on both sides. The actions of the parasites in this legal case are only going to delay resolution of the problem, because they'll siphon off $millions for their own pockets, because they'll ruin any tentative bridges of trust and make everybody become highly legalistic and defensive, and because they'll present the issues in stark black and white when scientifically they're anything but. But this is why people -- including myself and most other scientists I know -- frequently want to hang all the lawyers.
6.14.2006 12:50pm
Mark H.:

3. need a talk about step ladders? there is not a blank spot on them that doesnt have a warning label.



LOL. How long before the bottom step has a built-in talking scale? "Get off now, your weight exceeds the safety rating of this ladder," or if you're under the weight limit, some other warning...
6.14.2006 12:50pm
Paul Gowder (mail):
It's times like this when I hark back to the happy days of 1L tort law. Lets assume, arguendo, that this case is analagous enough to a negligence theory that the standard ways we think about negligence apply here. KFC is causing a harm to consumers, and we want to know (channeling Learned Hand for a second) whether the cost of that harm is greater than the benefit. Well, that depends on the benefit. If the benefit to KFC from using transfat is zero or close to zero (because there's no significant taste or cost difference), then it seems entirely rational to hold it, the entity with superior information and a massive market position in fried chicken, liable for using the harmful substance. (Least cost avoider and all that.)

Without that information, it's too hasty to prejudge the suit.
6.14.2006 12:56pm
JohnAnnArbor:
CSPI used to crusade against salt as if it should be forbidden in all food. I'm always suspicious of them because their motives are suspect. They waged war on Olestra, claiming it caused horrible problems (while ignoring studies that showed it didn't). There have been questions about conflict-of-interest in food promotion, too.
6.14.2006 12:58pm
Russ Meyer (mail):
This is absolutely insane. Only a lawyer could possibly defend something so stupid.

I don't go to KFC expecting health food. I know it can cause heart disease, mostly b/c I have been conscious during my lifetime, during which it has been pelted into me. KFC hasn't been on TV extolling the virtues of how its food is chock full of vitamins and will restore 20 years to your life. Only someone with the mind of a fourth grader could look at this and think KFC isn't for unclogging arteries.

And this guy is a doctor?!?!?! I hope his patients start suing him for failing to know anything about the causal effects between food and the human body.

Finally, Cyrus, here's a mind blowing idea - if you don't like the oil KFC uses, go to a different restaurant. Do you really believe that the rest of the unwashed masses are so stupid that only a god like yourself should be able to determine where they eat?
6.14.2006 1:00pm
Humble Law Student:
Medis raises good points. The issue is this. Trans-fatty acids are much more dangerous than other fats, like unsaturated fat. While "fat" in general is considered bad, trans-fatty acids are much, much worse than other fats. Of course, when you eat fried food, you can expect that it is bad for you. However, this fat in particular is much more dangerous to your health than an ordinary individual would think.

I don't agree either that litigation is the way to solve this. But, I think its important to recognize the differences.

I just hope this campaign and the pressure it brings will convince KFC to change the oil it uses.
6.14.2006 1:00pm
Tflan (mail):
Down with transfat!

Go back to lard.

It's all natural.

And delicious.
6.14.2006 1:06pm
therut:
I recommed a 75% decress in funding for law schools they are dangerous to our psychological health and pursuit of happiness and are nagging us to death like a harpy wife. As one physician to another this physician is a nut and I expect a health zealot or a payed hack. I wonder when the food police are going to come to my home and arrest me for endangering my health with homecooking. Oh and don't forget the reason refried beans are so good is the LARD.
6.14.2006 1:07pm
Wizened:
How shockingly unreasonable for people to expect explicit, obvious warnings that the food they're being sold is poisonous!
6.14.2006 1:09pm
Michelle Dulak Thomson (mail):
Sigivald,

(Full disclosure: After long experience, I reflexively despise anything CSPI does. This reaction has not yet once done me harm.)

Amen to that. If I'd only read one CSPI-inspired news piece, I'd be moderately anxious. As it is, I've read a couple dozen or so, and when it dawns on you that you're dealing with a group that basically thinks existence is a threat to your health, you do begin tuning it out.

Medis, I would be interested to know what counts for you as "fast food." Is it only chains like McD, KFC, &c., or also independent vendors? No one ever seems to sue Pam's Old-Fashioned Burger Hut or whatever for non-disclosure of calorie, trans-fat, &c. info, and yet I suspect that local eateries account for as much intake of "unhealthful" foods as chains do.

It's obvious enough that a lot of the energy behind such campaigns is simply and solely hatred of large corporations. The campaign against soda machines in schools is the most recent example. The SF Chronicle editorialized more than once in favor of banning them, citing childhood obesity, diabetes, &c., and I thought at the time, "OK, why not limit them to diet sodas?" The soda manufacturers proposed exactly this, and the Chron was still against, on the grounds that diet sodas have "no nutritional value." Neither, in the sense they mean, does water; but they don't propose banning sales of bottled water, or for that matter water fountains. Go fig.
6.14.2006 1:12pm
Jason Fliegel (mail):
The KFC near my house has a poster which includes nutritional information. I don't know if transfats are included on that poster, but they are certainly included on this website:

http://www.yum.com/nutrition/menu.asp
6.14.2006 1:28pm
Houston Lawyer:
There's a restaurant in town that sells a dessert called "Tres Leches", which is basically white cake soaked in three different types of cream. You can feel your arteries clogging up as you eat it. I had to finish my wife's portion as well as my own the other night and I suffered for hours. That doesn't even compare to another offering in another restaurant of pulled pork on a bun soaked in mango flavored butter. I generally just pass out at the office after that one.

I don't even want to know how bad that stuff is for me. Restaurants shouldn't have to get notarized waivers to sell this stuff either. Nobody forced me to eat this stuff and I haven't been force fed with KFC either.
6.14.2006 1:30pm
Ship Erect (mail) (www):
Humble Law Student - "Fat" is actually quite good for you, such as the fat found in nuts, non-hydrogenated vegetable oils, and the like. Fat is absolutely essential for a healthy brain, particularly in very young children. That said, I don't know anyone who thinks fried chicken is good for you, because chicken skin is incredibly unhealthy.

Michelle Dulak Thompson - It's obvious enough that a lot of the energy behind such campaigns is simply and solely hatred of large corporations.

There would be no campaign against trans fat if corporations did not need a longlasting stable cooking oil due to the industrialization of food. Trans fat was invented to make oil last for a long time in a solid form, easy to transport. Now that we know the health problems associated with it, it is surely best to get rid of trans fats from our diet--there is absolutely no human need fulfilled by them. Big companies do just fine without trans fats--look at Oreos, for example, which have no trans fats anymore.

Do you think the 1964 Surgeon General report naming smoking as a health risk was also motivated by a hatred of large corporations?
6.14.2006 1:30pm
Ship Erect (mail) (www):
Forgot this:

The soda manufacturers proposed exactly this, and the Chron was still against, on the grounds that diet sodas have "no nutritional value." Neither, in the sense they mean, does water

Water has no nutritional value compared to diet soda? You realize that it is not caffeinated, right?
6.14.2006 1:32pm
Medis:
redheadlaw7,

As an aside, I think we need to distinguish between litigation and regulation in this area. It may well be that fast food restaurants are trying in good faith to adequately inform consumers (although as I recall, a significant percentage of fast food restaurants do not post nutritional information in the store or provide brochures). In that sense, holding them liable for damages may be inappropriate.

But that doesn't mean regulation of these activities is a bad idea. For one thing, a standardized system would make it easier for consumers to know exactly how to get this information. For another, there is always going to be a conflict of interest for restaurants between promoting their products and providing accurate and conspicuous nutrition information, and competitive forces may exacerbate this problem. A regulation could both address this conflict in incentives and relieve this competitive pressure.

Sigivald,

I'd say the FDA is the right agency to make those determinations. And I don't know about you, but I frequently consult the FDA-mandated nutrition labels on packaged food. So, for me at least, the FDA has not gone so overboard as to render this system useless for consumers.

Russ,

Don't you remember the KFC ad where the slim wife tells her couch potato husband it is time to start eating better, and then gives him a bucket of KFC? It's a classic.

Anyway, I very much support the idea of letting consumers put pressure on restaurants over trans fat. Such consumer pressure has proven remarkably effective in many similar situations. But first the consumer has to know what is going on.

Michelle,

I'd be fine with extending a label rule to small chains and solo restaurants if they sold the same items, prepared in the same way, and over sufficiently long periods of time. In other words, if your food is standardized to a sufficiently high degree, it seems to me it can be effectively labelled.

And that is basically what I mean by "fast food"--food which is not made-to-order, but rather highly standardized. In fact, that is a large part of the appeal of fast food--people know that anywhere they go in the US, and perhaps even the world, a bucket of KFC will contain the same things and taste the same.

But anyway, other people have objected to applying such a rule to small chains and solo restaurants, for at least a couple reasons. One is that many such places do a lot of made-to-order preparation, so the labels would be inaccurate in some cases. Personally, I don't see that as a problem--you can still have the labels for the standardized stuff, and consumers will know that made-to-order preparations will vary from the standardized stuff.

Another argument is that small chains and solo restaurants could not bear the cost of the rule due to a lack of economies of scale. I actually have no idea how expensive it is to do this--it seems to me a lot of relatively small vendors of packaged foods have found a way. Regardless, rather than having no rule at all, you could just have a less burdensome version of the rule for small chains and solos. Of course, if that would be too misleading, then maybe no rule at all would be better.

In any event, I have no desire to defend everyone who might favor such a rule on their own terms. But for me, this really has nothing to do with the size (or global nature) of the corporations involved.
6.14.2006 1:49pm
markm (mail):
KFC already switched to an allegedly healthier frying fat. From the NY Times article: "Trans fats became a part of fast-food meals in the 1980's, after consumer groups demanded that the chains stop frying in beef tallow and palm oils because those products are highly saturated." Oops, the "healthier" chemically transformed fats are actually less healthy. You might blame the scientists, or the consumer groups that ran with partial information and got trans fats used nearly everywhere, but don't blame KFC!

As for the doctor who is the lead plaintiff here: If he knew anything about nutrition in America, he would know that for a couple of decades, trans fats were used nearly everywhere that fat was added to foods. If he were really worried about "unnatural fats", he would not have been eating out on deep-fry, because it's either going to be a trans fat or its going to be a saturated fat like tallow, lard, or palm oil. The unsaturated natural fats that are healthier (e.g., olive oil) can't take the heat of deep frying, at least not in a restaurant where the frying oil will be held at the frying temperature all day.

And finally, if you're worried about the kind of fat, you should first worry about how much fat you're eating. There's no fat so healthy that a piece of chicken dipped in it can be as healthy as a grilled piece of chicken.
6.14.2006 1:51pm
Jennifer (mail) (www):
Markm just beat me to my point: We have to remember that the fast food chains started using these oils because of consumer complaints and marketing concerns about health. KFC used to use lard (a natural substance) in which to fry their chicken, and rightly so. Lard rules. So does chicken soaked in buttermilk before being coated and fried in lard at home. Mmmmmmm!

Am I the only one who remembers that it used to be "Kentucky Fried Chicken"? They started using "KFC" isntead, to get the "Fried" out of the name, in the 1980's diet craze when people were against anything fried and McDonald's first introduced salads. (Remember when people used to think that, so long as it was "salad" it was healthy? Ha ha ha.)
6.14.2006 2:09pm
Frank Drackmann (mail):
This reminds me of when they ruined movie theatre popcorn in the 90s by switching from coconut oil to vegetable oil. Nothing beat those McDonalds fries cooked in Beef tallow either. I wonder if fast food places still soak their fries in bleach like we used to in the 80s?
6.14.2006 2:11pm
Angus:
This case is a bit crazy, but would not be a case at all except for one fact. The oil used in KFC is deliberately chemically altered in such a way as to make it more dangerous.

Had KFC used an unhealthy oil that existed in natural form, no court would even hear it. But since this oil is an artificial, manmade substance, it can fall under government regulations covering unsafe additives.
6.14.2006 2:12pm
Ken Arromdee (mail):
I had to finish my wife's portion as well as my own the other night and I suffered for hours.

I am curious as to how you could have "had" to eat food. Did the food hold a gun on you demanding that you eat it?
6.14.2006 2:21pm
The Snob (mail):

Had KFC used an unhealthy oil that existed in natural form, no court would even hear it. But since this oil is an artificial, manmade substance, it can fall under government regulations covering unsafe additives.


You sure about that? What if they chose lower-cost, less-healthy beef tallow over olive oil?
6.14.2006 2:23pm
JohnAnnArbor:

I'd be fine with extending a label rule to small chains and solo restaurants if they sold the same items, prepared in the same way, and over sufficiently long periods of time. In other words, if your food is standardized to a sufficiently high degree, it seems to me it can be effectively labelled.

Translation: I'm fine with making up random regulations and imposing them on other people, without caring what the cost is to them.
6.14.2006 2:32pm
Angus:
The Snob,

Yes, I believe that. There might be public pressure to get them to switch, but if they use a naturally occuring substance, they wouldn't have a leg to stand on.

Similarly, that is where the tobacco industry got into legal trouble. It wasn't the tobacco, but the additives they put in it to make it more addictive.
6.14.2006 2:34pm
redheadlaw7 (mail):
I'm curious what Jonathan Adler's thoughts are on the subject. He is after all somewhat of a regulation guru. So Jonathan...what do you think about all of this? Would it be plausible to ask all food vendors to identify and label the nutritional information of all food sold?
6.14.2006 2:37pm
frankcross (mail):
I'm not a big fan of CSPI or KFC, but I'm a little intrigued by the anger about this.

Are you angry that we regulate asbestos and keep it out of products? Are you angry that we regulate food products in various ways, for safety and cleanliness? Are you angry that we regulate automobiles with safety standards?
6.14.2006 2:38pm
John Burgess (mail) (www):
My health, and that of numerous others I am confident, would improve if CSPI were banned utterly. They are excellent at racheting up unwarranted fear and axiety. That has deleterious effects on my blood pressure.

Can we at least demand that CSPI creeps wear a large, red warning tag when then enter places of business?

I propose the following wording:


DANGER! WARNING! DANGER!

The person wearing this tag is busily engaged in the process of doing bullship science! Stand well clear of him/her at all times.

Do not listen to what is uttered by this person or sponsoring organization as it will both damage your sense of reason and overload evolutionary advanced BS detection systems. There is some evidence that these utterances can cause high blood pressure and racing pulse. If you start believing what this person or sponsoring organization says, you will believe anything.


I think a 23"x19" label would be adequate.
6.14.2006 2:41pm
Michelle Dulak Thomson (mail):
Ship Erect,

There would be no campaign against trans fat if corporations did not need a longlasting stable cooking oil due to the industrialization of food. Trans fat was invented to make oil last for a long time in a solid form, easy to transport. Now that we know the health problems associated with it, it is surely best to get rid of trans fats from our diet--there is absolutely no human need fulfilled by them. Big companies do just fine without trans fats--look at Oreos, for example, which have no trans fats anymore.

Not sure this makes entire sense. You say that corporations "needed" a "longlasting stable cooking oil." Now we know it's harmful, and suddenly there is "absolutely no human need" fulfilled by it. Obviously this can't all be true. If corporations started using trans fats because they "needed" oil easier to transport and store, then unless the transportation and storage advantages have independently disappeared, the "need" is still there, regardless of our new knowledge. How do you see that need being supplied? Are there no costs at all to anyone?

And then this:

Water has no nutritional value compared to diet soda? You realize that it is not caffeinated, right?

So lacking caffeine is in itself a "nutritional value" now? If that were the issue, there's lots of caffeine-free diet soda; I've bought it occasionally when the ordinary diet soda was out of stock at this or that market. But if caffeine is the issue, someone might at least have said so. No one, so far as I know, has proposed forbidding students tea or coffee.
6.14.2006 3:00pm
Malvolio:
Trans fat was invented to make oil last for a long time in a solid form, easy to transport. Now that we know the health problems associated with it, it is surely best to get rid of trans fats from our diet--there is absolutely no human need fulfilled by them.
Uh, except for the human need for oil that lasts for a long time in a solid form and is easy to transport.
6.14.2006 3:05pm
Dick King:
Here is an interesting article about asbestos litigation.
6.14.2006 3:10pm
Michelle Dulak Thomson (mail):
Malvolio,

Damn you for one of those annoying people who say things better and shorter than I do. I wasted a couple grafs saying that.
6.14.2006 3:10pm
Medis:
JohnAnnArbor,

You say: "Translation: I'm fine with making up random regulations and imposing them on other people, without caring what the cost is to them."

First, I draw your attention to the fact that I specifically addressed costs later in that post. In general, even in the part you quote, considerations of cost are implicit, because presumably the costs associated with ascertaining nutritional content are what make it impractical to require every dish prepared at any restaurant--as opposed to only highly standardized items--to have a nutrition label.

Second, I'm not sure what you mean by "random", but I have been suggesting something based on the FDA's current label mandate for packaged food, which as of January 1, 2006, included trans fat. In that sense, I am deferring to the expertise of the FDA on the issue of exactly what information would be most useful to food consumers.

In general, if there are some prohibitive costs associated with such a proposal, or other good reasons to think it would be a bad idea, I'd be happy to consider them. But I don't see any such reasons as yet.
6.14.2006 3:13pm
Russ Meyer (mail):
frankcross,

Here's the issue. When people originally put asbestos in buildings, most people did not know that it could cause cancer. However, only a true moron would not know going to KFC for a tasty bucket of wings could damage your health. I think I realized it could be unhealthy at the age of ten when I rubbed a piece of chicken on a paper napkin and could soon see my fingers on the other side.

Those involved in this lawsuit are either looking for a quick buck and want to impose more regulations on people by further limiting choice, or they are so stupid they should be sterilized in the best interests of evolution so they cannot spread their idiocy to the rest of the planet.

We see suits like this and lawyers suddenly wonder why people want tort reform?
6.14.2006 3:16pm
frankcross (mail):
Russ, they are pushing this because they are true believers, but you're not responding to their point.

It is true that at the time asbestos was first used, we didn't know of the harms. But now we do. And we ban the use of asbestos in new construction, with limited exceptions I think. Are you outraged about that ban? Don't you think that people should be able to freely choose whether their building is full of asbestos? Only a true moron would not realize the danger there.

I'm just curious about all the outrage. Transfats are probably worse for you than marijuana or a lot of other stuff that society has banned. I don't favor a ban, but a big warning might discourage people and keep them from imposing externality healthcare costs on the rest of us through insurance rates.
6.14.2006 3:21pm
Medis:
As an aside, there is obviously no "need" for fast food restaurants to use oils high in trans fat, as already many fast food restaurants do not. As is often the case, it is a matter of cost, not need, and apparently one of the biggest current costs would be converting over existing restaurants to use the alternatives.

Of course, these costs should be taken into account when setting a trans fat policy. But if informed consumers would prefer food with less trans fat, and made eating decisions accordingly, that would allow the market to sort out how to handle these costs, which seems like a good idea to me.
6.14.2006 3:21pm
logicnazi (mail) (www):
As many posters have pointed out KFC does have health information availible if you ask. Thus the claim is that KFC is in the wrong by not displaying the existance of trans-fat in a sufficently noticeable fashion. While it might be nice to have the FDA create a general rule that any use of trans-fat requires a warning label or clear notification such a rule does not now exist so what possible grounds could there be for picking out KFC? The only justification I can think of is that the use of trans-fat here would be unexpected or that a reasonable person would believe that there weren't trans-fats being used here.

This argument is of course absurd. I mean KFC is a fast food joint. A reasonable member of the public would never assume they are particularly healthy.

I seriously doubt this suit is really motivated by a desire to inform the public or anything of the kind. I suspect the individuals really object to people going to KFC at all and hope that by making them display unappetizing health facts all over people won't eat at KFC.
6.14.2006 3:24pm
Alan Gunn (mail):
How about this for a lawsuit?

Economists pretty much agree that each lawyer added to the mix reduces gross domestic product by about $2.5 million (old figure--probably more now). They also agree that every $7.5 reduction in GDP causes one death--this is the familiar (and true) "poverty kills" point. So, whenever a law school graduates three lawyers, someone will die as a result. That makes producing lawyers a lot more dangerous than a meal at KFC.

Class action against the law schools, anybody?
6.14.2006 3:33pm
Medis:
logicnazi,

Although I think this case is ultimately a clear loser, the issue might be a little closer on the facts than your summary suggests. One of the relevant facts is that over the last few years, the health risks associated with trans fat have been widely published, including an FDA advisory. Another relevant fact is that some of the other fast food restaurant chains besides KFC have responded to these known health risks by cutting their use of trans fat oils.

So, it is not exactly an issue of people being unaware that fast food in general is unhealthy to some degree. Rather, it is an issue of people being unaware that KFC's fast food is particularly unhealthy, and perhaps to a negligent degree in light of the recent information about trans fat.

In short, a reasonable person might not expect KFC's food to be healthy in some general sense. But a reasonable person might not expect KFC to be continuing to use trans fat oils under these circumstances.
6.14.2006 3:35pm
Harry Eagar (mail):
Amen to Sigivald's judgment of CSPI.

Also, how did this plaintiff manage to live long enough to retire?
6.14.2006 3:37pm
SL (mail):
My only question is - Does the used trans fat cooking oil make better biodiesel that the other stuff?
6.14.2006 3:41pm
Houston Lawyer:
Ken

It's really good and I don't do doggy bags. I felt compelled.
6.14.2006 3:54pm
frankcross (mail):
Alan Gunn, economists do not pretty much agree to that. In fact, it's been economically disproved. The biggest figure ever estimated by an economist was $1 million per lawyer by Steve Magee, and he quickly abandoned that. He reanalyzed the data and found that lawyers overall add much more to the economy than they harm it.
6.14.2006 4:01pm
Kristian (mail) (www):

Frivolous or not, if this suit gets KFC to switch to healthier oil, it can only be a good thing.


Nope, not buying that claim. McDonald's fries have not been the same since the Hindu suit that led to abondoning Lard and going to vegetable oil. But then, if you mena making a previoulsy desirable taste, yet moderately poor health choice now so upalatable that you no longer buy any of it, perhaps you are correct.
6.14.2006 4:15pm
Russ Meyer (mail):
Anyone here ever see Demolition Man? Because the vision of the future offered by Dr. Raymond Cocto seems to be what a few people here want - XXX "is not good for you, and it has been deemed that anything not good for you is bad, hence - illegal. Salt, redmeat, chocolate, bad language, uneducational toys, and anything spicy."

And as for the asbestos argument, inhaling the carinogen is passive. However, no one is holding my mouth open and pouring trans fat down my gullet.

This is absolutely shameless. We have taken a potentially good thing - the need to warn consumers about some stuff they might not be aware of - to an extreme(every consumer I know figured out a long time ago that fast food is not good for your heart).

Tort reform now!
6.14.2006 4:30pm
MDJD2B (mail):
I hark back to the happy days of 1L tort law...and we want to know (channeling Learned Hand for a second) whether the cost of that harm is greater than the benefit.


One problem here is that users of trans fats save money using them , but the health costs are borne by others at a much later date. So KFC's savings are at the expense, many years later, of its customers and those who pay for their health care. So it seems reasonable to address the use of trans fats at a societal level, just as with asbestos and other toxic substances with widespreaad exposure and a delayed effect.

BTW, I despise CSPI too. But even a stopped clock is right twice a day.
6.14.2006 4:37pm
frankcross (mail):
No, inhaling asbestos isn't passive. You would just have to go to the website for the buildings you visit and see their reports on asbestos content before you visit them.

I actually think that a court would be foolish to ban transfats, and never would do so. It might order labeling.
6.14.2006 4:50pm
Cousin Dave (mail):
frankcross: "Are you angry that we regulate asbestos and keep it out of products?"

To the extent that it might have prevented the WTC collapse, yes. To the extent that it might have prevented the Challenger accident, yes.

And a note to Angus: Asbestos is a totally natural product.
6.14.2006 4:50pm
Cousin Dave (mail):
Medis: "Of course, these costs should be taken into account when setting a trans fat policy. But if informed consumers would prefer food with less trans fat, and made eating decisions accordingly, that would allow the market to sort out how to handle these costs, which seems like a good idea to me."

Well, that would be all right if it worked that way. But the point of the lawsuit that we're duscussing is to subvert both the market and the legislature. A handful of lawyers, jurors, and judges will decide for everyone. We have no say in the matter.
6.14.2006 4:55pm
Thorley Winston (mail) (www):
We see suits like this and lawyers suddenly wonder why people want tort reform?


Agreed we need to go to a loser pays system except for class action suits, in which case the prevailing party ought to be able to receive treble damages.
6.14.2006 4:57pm
Timothy (mail) (www):
KFC posts nutrition guides in its stores, there are also pamphlets in the stores.
6.14.2006 5:06pm
Medis:
Cousin Dave,

As I said above, I agree that "this is not the sort of issue best resolved through litigation."

Timothy,

As an aside, are you sure they do that in every restaurant?

In any event, as I noted above, even if KFC is making a good faith effort, I think there could be a real benefit to standardizing and regulating the nutritional disclosures provided to consumers of fast food.
6.14.2006 5:37pm
David M. Nieporent (www):
One problem here is that users of trans fats save money using them , but the health costs are borne by others at a much later date. So KFC's savings are at the expense, many years later, of its customers and those who pay for their health care.
The first group isn't a "problem," because the customers are the beneficiaries of the savings. And the second ("those who pay for their health care") represents a choice. I get no claim on you, your activities, or third parties because I volunteer to pay for your health care.
6.14.2006 7:07pm
Ferguson:
Trans fat is funny. Apparently, the whole switch-over from using trans fat to not using it passed me by, but I have been noticing the ubiquitous 'No Trans Fat!' on every grocery in the store. Great marketing tool: add something terrible to your product, then take it out and advertise that you did. KFC, are you listening?
6.14.2006 7:44pm
Nunzio (mail):
Does KFC still use the "finger-licking-good" slogan?

Also, are transfats part of the "Colonel's secret recipe"?
6.14.2006 8:51pm
A. Zarkov (mail):
Splunge:

Good post. I can only add the extra calories (never mind whether the source is fat) people consume eating out (not only fast food) seems to be the main contributor to the large weight gain we in the US have experienced over the last 20 years. Obesity does have a social consequence: type 2 diabetes. It’s going to cost a lot to treat all these people, and these costs will ultimately be socialized. So what people eat these days in restaurants matters and matters a lot, unless we go back to stay-at-home moms determining the family’s nutrition.
6.14.2006 10:04pm
Frank Drackmann (mail):
I ate at mcdonalds or the equivalent for nearly 8 yrs including college and medical school. Weighed 129 lbs at the beginning, 127 at the end.
6.14.2006 11:20pm
Medis:
David M. Nieporent,

You say: "I get no claim on you, your activities, or third parties because I volunteer to pay for your health care."

I'm not sure I buy this. If you and I are part of some mutual insurance pool whereby everyone insures payment of each other's health care costs, why don't we all have a legitimate interest at stake when some third party causes injury to one or more members of our pool?

In insurance law, this is called subrogation--insofar as I have indemnified your loss, I can substitute for you and assume your legal claims relating to the loss. So I don't see why I, as your health care insuror, could not assert a claim against a third party who wrongfully caused you harm, resulting in health care costs that I ended up paying.

Moreover, in insurance situations there is an obvious moral hazard problem (which in mutual insurance pools can take the form of free-riding). So, it also makes sense for mutual insurance pools to adopt behavorial restrictions designed to combat free-riding.

Of course, I don't mean to imply that insofar as a civil society represents a mutual insurance pool of sorts, it would be justified in attempting to eliminate all risky behavior, since presumably the right to take reasonable risks of our own choosing is something we would often want to retain. But we can legitimately protect ourselves from moral hazards and free-riding, since by definition these behaviors would not occur in the absence of civil society (ie, if we had to bear the costs ourselves), so one cannot retain the right to engage in such behavior.
6.14.2006 11:53pm
Splunge (mail):
[W]e ban the use of asbestos in new construction, with limited exceptions I think. Are you outraged about that ban?

Absolutely. Asbestos is a useful material that saves lives and is perfectly safe when properly enclosed. You might as well ban electricity because, when household wiring is done poorly, some people will accidentally come into contact with deadly voltages of electricity and die.

Fact is, in the modern world your life is in the hands of engineers all the time. They do such routinely stellar work, however, that you aren't even aware of the hundreds of times a day you dodge death by milliseconds or fractions of an inch because deadly forces or materials are properly channeled to serve you instead of endanger you.

Perhaps the very success of modern engineering, especially in contrast to such routinely fallible and undependable institutions as government or the law, is why so many folks seem to fall into the sad delusion that the world is naturally, or can be made into by laws and courts, a safe place, and life a journey that one can reasonably navigate with a child-like unawareness.
6.15.2006 1:08am
Splunge (mail):
A. Zarkov, thank you for the reply. I am not concerned about socialized costs of diabetes per se, because there are two cases:

(1) Few people get it. That means the cost per person is small, and my share can be regarded as merely an act of (forced) charity. I can deal.

(2) Many people get it. But this means the net cost per person is small, because most or all people will receive back in benefits much of what they pay in taxes. This situation is just a weird shell game where you rob Peter (the taxpayer) to pay...Peter! (the diabetes patient).

I will agree separately, however, that socializing any cost that hits most or all people is a priori insane. We've all got to pay the costs anyway, so why not pay them directly, instead of indirectly by first paying the government and then having the government pay our creditors? Especially bearing in mind that a Federal parisitocracy must be set up to manage the transfer and paperwork, and will inevitably siphon off some of the wealth we're transferring from our right pocket to our left.

I am reminded of looking at my paycheck when I was a graduate student and noticing the first time Federal tax was taken out. And I thought: wait a minute, I'm being paid from a research grant, so I'm being paid with tax money. Why tax the tax money I get? Why not just pay me less of it in the first place, and save on accounting and postage costs? We live in a strange and cynical world, I tell you.
6.15.2006 1:35am
Theodore Roosevelt (mail):
Reminds me of Sir Humphrey and the politician's syllogism, in "Yes Minister":

"Something must be done. This is something. We must do it."

Lawyers will litigate....it's an irrefutable law of nature. Main problem as I see it is causation, the purpoted link between diet and heart disease is under a state of flux and it NOW appears that carbohydrates are as bad as lipids. Of course that will change.
6.15.2006 11:22am
Medis:
Splunge,

So are you against engineering standards?
6.15.2006 11:41am
Splunge (mail):
Am I against engineering standards set by lawyers? Of course. Just as strongly, I daresay, as lawyers and judges would oppose having scientists and engineers set the standards for what may and may not be considered proven fact in a court of law.

However, as you probably know, scientists and engineers set and enforce their own standards, in order to protect the guild against unscrupulous or incompetent individual members. Do I support those standards? Very much so. And I have done my share, from time to time, to punish shoddy, bogus, or deceptive work by my peers. Any professional tribe, if it is to survive and keep the trust of the public -- I'm talking to you, Mr. Hastert -- must be the harshest possible critic of its own transgressing members.
6.15.2006 12:04pm
Sigivald (mail):
Fergusno: Actually, I suspect most products labeled "no trans fat" never had it in the first place.

Much like I've seen various products that naturally have no fat, and never had fat added, labeled "fat free".

(Water is fat free and very low sodium!)
6.15.2006 12:34pm
Seamus (mail):

KFC posts nutrition guides in its stores, there are also pamphlets in the stores.



But don't you understand that CPSI won't be satisfied until there's a big black skull-and-crossbones icon next to every item on the KFC display menu that they don't like? And even that won't satisfy them if people keep buying the stuff. ("Mmmmm. Trans fats.") Their real goal is to make it impossible for people like me, who like to eat KFC chicken once or twice a year, to do so.
6.15.2006 12:40pm
Medis:
Splunge,

As an aside, the rules of evidence specifically provide for scientists, engineers, and so forth to provide their expert opinions. So, lawyers consciously defer to such experts on factual matters, and allow them to aid the jury in reaching factual conclusions.

Anyway, so suppose I hire an engineer to make something for me, and without my knowledge, he violates the applicable engineering standards while doing my project. As a result, when I try to use this substandard product, it fails and injures me.

Do you think I should be able to sue my engineer for damages?
6.15.2006 1:04pm
Splunge (mail):
Of course! But that would be because the terms of your contract specified a certain type of product as commonly understood by the guild, and you would then call actually qualified engineers to testify to the fact that this man's work did not meet those standards, and so he did not fulfill his side of the contract, causing you loss and damages, et cetera and so forth.

I do realize the Court considers the opinion of experts, but it does not defer to them. Always, the jury or the judge is the final determiner of what the Court considers "fact." In the same way, what constitutes good engineering should always be decided by an engineer, never by a lawyer.
6.15.2006 1:35pm
therut:
I'm waiting for lawyers to sue God. But wait that would mean they would have to admit there is a God. So forget that idea. Maybe they could sue Nature or Evolution since that is what they believe made us unable to eat trans-fats and not have some health problems from it. But then being born or in the case of abortion not even being born is 100% a health risk. I just say Please God save us from ourselves and the foolishness of lawyers.
6.15.2006 2:00pm
Medis:
Splunge,

I'm no longer sure what you are complaining about. What you say should happen in a contracts case also happens in a torts case. When something like industry standards are relevant to a torts case, the parties will submit evidence about industry standards (eg, industry publications containing standards), and they will bring in industry experts as witnesses. Those experts will testify about those standards and explain how they think those standards should be applied to the facts of the case.

So, if this process is good enough for a contracts case, I don't see why you think it isn't good enough for a torts case.

Anyway, so you walk into the engineer's shop and buy something off the shelf. There is no written contract. The product is substandard, it fails, and it injures you.

Should you be able to sue the engineer for your resulting damages?
6.15.2006 2:18pm
Al Maviva (mail) (www):
Reading discussions like the one supra in comments, makes me want to pluck out my eyes, slash my tongue, cut off my hands, and just to be safe, puncture my eardrums with a nice Mont Blanc pen, just so there is no risk of me ever practicing law again. That we as a profession can take this kind of pie-in-the-sky utopian dreaming ("wouldn't it be nice if life was a non-risk enterprise?")as a basis for a field of law, that we elevate and wipe out whole sectors of the economy with this bong-fueled dreaming, shocks me. The comments about KFC going around killing people are simply amazing. "Yep, yer honner, that chicken wing just drug me inna that KFC, and made me eat it. Yep, sure, there was a big sign with all the nutritional stuff on it. But the chicken made me eat it because it was tasty."

This is insane. The logical end of this type of reasoning is that our parents inflicted great harm upon us by giving birth to us - after all, they set into motion a chain of events that is often terribly traumatizing, painful, and which inevitably results in death. They are therefore liable, and should be subject to punitive damages.

I know, I know. It's been done before. In New Jersey.
6.15.2006 2:52pm
Splunge (mail):
Well, that's trickier. It turns a great deal on what sort of implied contract you have. For example, if you see a metal box with knobs and ask: "Is that an FM radio?" and he says "Yup!" and you buy it, and it explodes when you turn it on and kills your cat, then, yes, you have an implied contract that it is an "FM radio" in the professional engineer's understanding of that phrase and the engineer has broken the contract. But if you decide without asking any questions that it's an FM radio in working condition instead of a bomb disguised as a radio, and you buy it, and the engineer says nothing but just takes your money, then caveat emptor and you're screwed. In other words, the answer turns on whether you have been the victim of a mistake or your own ignorance, wilful or not, or whether you have been the victim of a fraud.

The question of what kind of contract, exactly, you have when you go into the store, and how precisely that depends on what you do, and what the storekeeper does -- this is exactly the stuff I as a scientist would leave to the lawyers, the relevant experts in the field. I trust that you've worked out good principles of what is, and is not, a contract over the centuries, and it's my job as an amateur to learn as much as I need to know to survive about how it's properly done, and then (if necessary) take advice from a professional if and when I need it.

What goes wrong in the torts case, if I understand you correctly, is that now the state is modifying definitions in the contract without the prior consent of both parties. It's saying "Ho there, engineer, we are going to redefine what is meant by 'FM radio' so that it excludes bombs disguised as radios."

Why is this a problem? Because maybe there's a very good engineering reason why bombs should look like radios, and lawyers don't understand this, because they didn't take Advanced FM Radio and Bomb Design in college. If so, the socially productive solution is for people to learn to ask whether a given "radio" is a real radio or a bomb, and for the law to make clear that this is part of what you must do to have an enforceable contract, implied or not, about buying radios. For amateurs to forceably modify engineering best practise about what a radio should look like is not socially productive, any more than it would be for (as noted in another thread) non-lawyers to define what contract legal language should look like.

In the case in point, the question of whether or not trans fats should be used in frying fries is not, or should not, be a legal question decided by judges or legislators. It's perfectly reasonable for the law to say you cannot lie or shrug your shoulders and say 'I dunno' when someone asks whether your fries are fried in trans fats, or lard, or used motor oil. But which frying medium to actually choose should be a food-science question or business decision.

Whether to buy the fries is a decision properly made by each consumer without outside interference, in very much the same way as each consumer must decide how much alcohol to drink, whether to smoke or not, how much to exercise, whether to take pills for high cholesterol or not, whether to have children to help in old age or not, whether to save for retirement or unexpected illness or not, and whether to look both ways before crossing the street.

And my reason for that general principle is that legislation and the law are simply too blunt an instrument -- not reliable, precise or wise enough -- to make anything even remotely approaching the best decisions for each and every individual case. I suggest the best the law can aspire to in practise is to make sure parties to any contract don't defraud each other. I suggest the best government can do is try to make sure the parties to any contract are as informed as reasonably possible about what each other means, through education, state-sponsored testing and certification, and information exchange. All else is fool's gold that saps time and money from achievable goals.
6.15.2006 3:33pm
Medis:
Splunge,

I have good news for you--what you want is usually exactly how the law works. Your general complaints about the legal system, in other words, appear to be based on a misconception about how the legal system resolves these issues.

The law, for example, has attempted to lay out a series of default rules for commercial exchanges which make it possible for people to engage in such exchanges with minimal transaction costs. Those rules are precisely about defining what the buyer and seller can both expect without requiring them to go through elaborate exchanges of information and long bargaining sessions leading to detailed written contracts. Of course, people can vary their contracts from these default rules in all sorts of ways if they so choose, but the law gives them the option not to go through all that effort as long as they are content with the default system.

Frequently, those default rules refer to industry standards and practices, and the general commercial law typically makes no attempt to define exactly what those standards and practices should be in advance. That is precisely why in these cases, the parties would bring in expert witnesses to testify--they need the experts to analyze and explain how these general rules should apply to the specific case.

So, for example, this KFC case is partially based on a DC statute which specifies that: "Unless excluded or modified (section 28:2-316), a warranty that the goods shall be merchantable is implied in a contract for their sale if the seller is a merchant with respect to goods of that kind. Under this section the serving for value of food or drink to be consumed either on the premises or elsewhere is a sale."

The statutory definition of "goods which are merchantable" includes that the goods must "pass without objection in the trade under the contract description."

So, in your radio/bomb case, if the thing is called a "radio" during the sale, the question would be whether this thing would "pass without objection in the trade" under that description ("radio"). And to get an answer to that question, the parties would call in industry experts to testify.

In that sense, the general commercial law doesn't try to define in advance "the best decisions for each and every individual case" (eg, it wouldn't try to define in advance what a merchantable radio was). And in fact, the application of the general commercial law to most informal exchanges is never even considered by the courts, because both parties comply with the default rules and are happy with (or at least resigned to) what happens as a result.

But in a case where one party believes that the other party has violated these general default rules, the courts may play a role. Nonetheless, given the nature of the default rules, the courts will look to actual experts to define exactly what those rules mean in the context of the particular case.

So, be happy. It turns out that the legal sytem generally works the way you want it to.
6.15.2006 4:14pm
therut:
I just got a hair style which needed a styling apparatus that gets hot to make hair straight. I was reading the instructions less than an hour ago and was not impressed with the warning to not use in bed. Good Grief. How stupid. Who would try to straighten their hair in bed? Tonight I am pulling all the tags off my pillows and matresses. Better than pulling my hair out.
6.15.2006 7:39pm
Kev (mail) (www):
I am curious as to how you could have "had" to eat food. Did the food hold a gun on you demanding that you eat it?


Perhaps Houston Lawyer grew up with parents who told him that he had to finish all the food on his plate because there were "starving children in Korea" or wherever. (This is sometimes blamed for the fatness of those same people in their adult years, though I'm not recommending that they sue their parents...or the starving Korean kids, for that matter.)

Also, there was a great Bizarro comic this week about fast-food chicken and the fear of bird flu. I'd post the link, but King Features Syndicate doesn't allow complete archives now.
6.17.2006 5:51am