Girl Scout Cookies

It's that time of year.  I both dread it and look forward to it at the same time.  Probably because I can single-handedly consume a box of Thin Mint cookies in just a few days.  They are so good, but really...a whole box good?
 
This year, Abigail is in Daisy Scouts and will be selling cookies.  I admit that in the past, I've let her eat a few Thin Mint cookies.  And, it's not what you are thinking.  It wasn't because I didn't want to share, well maybe a little of that, but because according to the box label it is only one of two cookies that are safe for people with peanut/tree nut allergies. 

Here's what Little Brownie Bakers, the manufacturer of the Girl Scout Cookies in our region, says about food allergens:

On each of our cookie packages, we label for the top 8 allergens directly below the ingredient statement on the Nutrition Facts side panel. For peanuts and tree nuts, we have chosen to include cautionary labeling in the form of a "may contain" statement. This indicates that the product shares processing equipment with another product that contains peanuts or tree nuts.

If the allergen in concern is not listed below the ingredient statement, we are confident that the product is safe for consumption.

Since cookie time last year though, I've learned a lot. While the FDA has Allergen Advisory Labeling guidelines in place, a good portion of it is voluntary.  And according to a 2008 report by the FDA, cross-contamination can occur at almost any step of the manufacturing process.  "Cross-contact can occur due to allergens in raw ingredients or in processing aids, allergens in reworked product and allergen carry-over from the use of shared equipment. Such potential sources of unintentional allergen cross-contact exist regardless of the manufacturer's size or food product."

While a lot of food manufacturers do not have proper controls in place, a good many do.  By using dedicated facilities or production lines, they can prevent cross-contamination.  However, when I read a vague statement like the one above that "they are confident that the product is safe for consumption", I still question the product's safety.  Is it because they have a dedicated line or do they feel like they just do a good job cleaning the production line?  Part of me thinks that if Little Brownie Bakery is willing to go on record and make a statement like that then it must be okay.  Can you imagine what Legal would say if there was any question of safety at all?  I've contacted the company, and hopefully they will quantify their statement.

There's a whole other issue here though, and that's why does an organization like Girl Scouts not recognize the seriousness of food allergies and address the fact that out of 8 types of cookies, only 2 are safe for peanut/tree nut allergies when only 2 of them actually contain peanuts and none of them contain tree nuts.  Wouldn't you think that an organization the size of the Girl Scouts could require their cookie manufacturer to use dedicated lines so that there was no risk of cross-contamination for those cookies not containing peanuts/tree nuts?

I'm just thankful that Abigail is such a good sport.  She's willing to go out and sell cookies that she can't eat.  And, if it turns out that it's not safe for her to eat Thin Mints and Samoas, then she'll be okay eating a cookie that she can have.  Unfortunately, it happens all the time.

As for me, I've really got to show some restraint this year especially now that I'm advocating a healthier diet.  Luckily it's just one time a year....and besides....it's for a good cause!

Click to read follow up and reply from Little Brownie Bakers:
 
Post Update 1/9/10...There are 2 companies that supply Girl Scouts with their cookies.  The other manufacturer is ABC Smart Cookies.  The list of cookies on their site is a little different than Little Brownie Bakers and includes more that are safe for peanut allergies. They also appear to be pretty proactive in eliminating cross-contamination opportunities in their manufacturing process.  Makes me wonder if Girl Scouts are selling different cookies in different parts of the country, maybe even in different parts of the state.

1/11/10 E-mailed response from Kellogg in regards to my question about their allergen policies:

"Thank you for contacting Little Brownie Bakers.  Girl Scouts depend on great Moms' like you!

Scientific evidence has shown that consumers with peanut and tree nut allergies can have a severe reaction to amounts that are below the current detectable limits based on existing technology. For this reason, we have chosen to warn consumers allergic to peanuts and tree nuts of the potential for extremely low levels by using a may contain statement. A may contain statement indicates that a product is produced on a line that shares equipment with another product that does contain peanuts or tree nuts.

While we do not use facilities that are completely nut free, we take food allergies very seriously and use the following measures to prevent cross contamination:
- Raw materials and finished products containing allergens are isolated from receiving through packaging.
-Employee training is an ongoing process to maintain awareness of
allergens within the manufacturing facilities. Employees understand the consequences of unintentional allergens.
-When changing from an allergen-containing product to a non-allergen product, visual as well as analytical inspection of the cleaning takes place. An allergen clean requires that some equipment be disassembled and manually cleaned to ensure areas are free of allergen residue. The cleaning procedures are documented and a checklist is developed to ensure that the procedures are followed during each cleanup.

Again, thank you for supporting your daughter and the Girl Scouts in your community."