Food Allergen Labeling, Part 1

When a family member has a food allergy, especially a life-threatening one, reading food labels becomes an obsession.  I don't think I purchase a single thing anymore without first reading the label.  Even if it's a product that I know to be safe, I still take a quick glance to make sure that the label hasn't changed to now include a cross-contamination warning.

I thought I'd spend some time discussing food allergen labeling. Even though, I've read labels faithfully now for almost 6 years, I recently learned something about the allergen labeling law that surprised me.

In January of 2006, the Food Allergen Labeling and Consumer Protection Act (FALCPA) went into effect.  Here's what it addreses:

• Food manufacturers must disclose "major food allergens" to include milk, egg, wheat, soy, peanuts, tree nuts, fish and Crustacean shellfish.

• The allergen must be identified by name, i.e., cashews, tuna, shrimp, etc.

• A scientific ingredient like casein may be listed, but a more consumer friendly term, like milk, has to also be included.

What it doesn't address:

• Allergens not considered major, for example, sesame seeds or cinnamon do not have to be listed and can be included in the terms "spices" or "natural flavors".

• Non-crustacean shellfish like clam and squid are not included.

• The "May Contain" advisory statement is voluntary.

That last one was the shocker for me.  For whatever reason, I've been under the impression for the last 6 years that labels had to include the "May Contain" statement and that a statement like "Manufactured in a Facility that also Processes Peanuts" was the voluntary one.

I didn't realize this until I recently contacted Pepperidge Farms about their products.  I was looking at one of their variety cookie products and was shocked to see that pecans was included in a very long list of ingredients, but there was no "May Contains" statement.  I e-mailed them questioning this, and they advised me that they were in complete compliance (I'll post their response at a later date).  Doubting them lead me to further research.

I can't believe all this time I thought a "May Contain" statement was a requirement.  In fact, as published in The Journal of Allergy and Clinical Immunology, an audit done in 2009 of 20,241 products showed that only 17% included an advisory statement.  Chocolate candy, cookies and baking mixes had the highest frequency.  Here's a chart (found in a report given to the FDA on the Use of Advisory Labeling of Allergens in Foods) indicating the products with the highest usage of an advisory statement.

A subset of this audit also indicated that there were over 25 different advisory terminologies, i.e., "May Contains", "Manufactured in a Facility", "Manufactured using the Same Equipment", etc.  No wonder we spend so much time reading labels at the grocery store.  And for me, contacting companies for clarification of their labels.  Wouldn't it be nice if there were some regulated standardizations!!

There is another study indicating consumers perceptions of risk associated with the various advisory terminologies which I will review in my next post.  In the meantime, I have a question for other parents of children with life-threatening food allergies.  What is your comfort level with food packaging labels?  Are you okay with products made on the same line?  What about in the same facility? And, if a manufacturer tells you it's safe, do you take their word for it without understanding their manufacturing process?  I've included a poll at the top of the blog for your answers.