Food Allergen Labeling, Part 2

In my last post, I wrote about how, not too long ago and much to my chagrin, I was surprised to learn that the "May Contains" statement on a food package is voluntary.  As long as the Top 8 Allergens are listed in consumer-friendly terms somewhere in the ingredient list, then food manufacturers are following the laws as outlined in the Food Allergen Labeling and Consumer Protection Act.  When a food manufacturer does include information, they do so in good faith but without any type of industry standardization.

So, while us consumers who purchase food for ourselves or for someone with an allergy are very appreciative of this labeling, we are also very, very confused!  In Part 1, I discussed a recent study that found over 24 different advisory terms with the major ones being some form of "May Contains", "Manufactured/Processed in a Facility/Plant", or "Made on the Same/Shared Equipment". I posed a question to you readers. Which allergen advisory labels prevent you from purchasing a food?

A study was published in 2007 in the Journal of Allergy and Clinical Immunology regarding that very question.  At both a 2003 and a 2006 FAAN conference, participants (625 and 645, respectively) from all over the US were asked whether they heeded advisory labels, and if so, which ones.  This graph was included in a report by Dr. Scott Sicherer and presented to the FDA regarding the Use of Advisory Labeling of Allergens in Foods.

 

In 2006, consumers were less likely to heed precautionary warnings (75%) than in 2003 (85%).  From the graph, you can see that they are more likely to not purchase products with a "May Contain" statement than products manufactured or packaged in the same facility as products containing the allergen.  There is also caution exercised with products made on the same equipment.

As part of this study, the Department of Food Science and Technology at the University of Nebraska tested various foods containing advisory allergen labels for traces of peanuts using Veratox, a peanut allergen test.  Accordingly, peanut protein was detected in 10% (20/200) of the foods they sampled, foods such as cereal bars, snack items, frozen foods, desserts, instant meals, bakery goods and baking ingredients. They found clinically significant levels of peanut (>1 mg of peanut or >0.25 mg of peanut protein) in 13 of those 200 products.  Their conclusion was because food products with advisory allergen labeling do contain detectable levels of peanuts, a risk exists to consumers choosing to eat such foods. This is important. They found that the type of labeling statement did not influence the likelihood of finding detectable peanut (except for products listing peanuts as an ingredient).  However, as we can see from the chart above, the wording of those advisory allergen statements did influence the types of foods that consumers purchased.

In looking at another graph from that presentation to the FDA in 2008, it appears that of those 13 products that had clinically significant levels of peanut protein, 2 had a "May Contain" statement, 3 were labeled  "Manufactured using Shared Equipment" and an astounding 7 had labels stating "Manufactured in a Shared Facility."  That's huge...that's the label that many consumers think is probably okay and not so much a risk!

I know it was just one study with 200 items, and I know that everyone has to make up their own mind and follow their own gut instinct as to what they feel comfortable eating.  We've never given Abigail anything that has the word peanut on it's label unless it ends with "free" as in peanut-free facility.  This isn't a game-changer for us.  But, if I was purchasing foods that had advisory warnings and thinking some were less risky than others...than I might consider the possibility that there's a bigger risk than I original thought!

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.

Nature's Path Foods

We're a fan of the Nature's Path Toaster Pastries, i.e. an organic Pop Tart.  Recently I contacted the company regarding their labeling policy and was pleased by not only their response, but also the Canadian government's stance on product labeling (I've put that section in bold).  Here's their e-mail:

Thank you for your query regarding the use of nuts in Nature’s Path products. We endeavor to always provide a good quality product.  Nature’s Path is committed to producing quality organic foods, using the best ingredients available, while adhering to strict quality control procedures.

Nature's Path Organic Toaster Pastries are made in a nut free facility.

Government regulators have advised us that because we utilize peanuts, nuts, soy or dairy in some of our facilities we are strongly recommended to put the disclaimer "may contain traces of peanuts, tree nuts, dairy or soy" on Nature’s Path products made in those factories. Government regulator opinion is that if there is a remote chance of cross contamination that the consumer should be advised of this possibility.

At Nature's Path we have an extensive planning and cleaning schedule which includes protein testing, for all our production facilities in order to prevent any cross contamination of our products with non-declared ingredients. All of our products that do not contain peanuts, nuts or soy  or dairy – as listed on the ingredient label are theoretically dairy, soy, peanuts & nut-free. However because of the remote chance of contamination from machinery or peanuts, nuts & soy or dairy in the plant we can not imply that there is no possibility of minute amounts of these allergens in our products.

No matter how small the chance, we feel it is our obligation to inform customers of this possibility. Our main concern is the health risk to any of our customers who may have a life-threatening allergy. We feel that consumers must make the final choice in consultation with their healthcare provider about eating Nature’s Path products.

Nature’s Path does manufacture some of its products in a dedicated nut free facility. Here is the list of Nature’s path products made in a peanut & tree nut free factory

Nature’s Path Frozen Waffles – all flavors- Share equipment with dairy, egg.
http://www.naturespath.com/products/waffles?tid=9&brand=All&nutri=All
Nature’s Path Puffed Bagged cereals – Puffed Rice, Puffed Corn, Puffed Millet, Puffed Kamut- Share equipment with wheat. No egg or dairy in facility.
http://www.naturespath.com/products/cold%20cereals?tid=5&brand=All&nutri=All
Envirokidz Animal Cookies –vanilla –Share equipment with egg. Contain soy. Casein/ dairy free.
http://www.naturespath.com/products/cookies?tid=94&brand=All&nutri=All
Nature’s Path Toaster Pastries- Frosted Toaster Pastries contains dairy. Unfrosted Toaster Pastries share equipment with dairy. No egg in facility.
http://www.naturespath.com/products/toaster%20pastries?tid=All&brand=All&nutri=All
Nature’s Path FlaxPlus Flax Seed and Flax Seed Meal
http://www.naturespath.com/products/vegetarian/flaxplus-flaxseed-meal
Nature’s Path Buttermilk Pancake Mix
Nature’s Path Flax Plus Pancake Mix
http://www.naturespath.com/products/baking%20mixes%20and%20ingredients?tid=All&brand=All&nutri=All

Please also check our website www.naturespath.com for more info on all of these including ingredient lists and store locations. (Updated & valid as of August 2009)

NB: people with life threatening peanut & nut allergies, it is still advisable to check back periodically with food companies over time because recipes can change.

Your email tells us that you are passionate about your health and wellness. If you would like to get more involved and share your opinion with us, please accept our invitation to join our research panel, The Cereal Bowl, at https://www.naturescerealbowl.com/R.aspx?a=23

Kind Regards,
Consumer Service

Wow, to have a government make such a suggestion as to protect the well-being of the consumers as opposed to catering to the large corporation.   How much easier it would be for parents with allergic children if we could look at the food packaging and have it tell us the whole story.  I've not purchased any of the other Nature's Path brands, but I've added them to my shopping list.  I also joined their research panel.  I'm not sure what that will entail, but the more I research the food we eat, the more I'm leaning toward going all organic.  I will say, there is one positive to Abigail's allergy.  Her allergy forced me to take a close look at the food our family is eating, and I'm appalled.

Like my other posts regarding food manufacturers, it's been my choice to endorse the company.  I've not been compensated for my review.

Note:  Wal-Mart has the best price for the Nature's Path Toaster Pastries.  They come in 6 or so varieties and are less than $3.00 a box.

Now for Some Good News!

I thought I'd post some good news for a change.  The last couple of posts have been troublesome first with the news of ConAgra and their "proprietary" manufacturing information and second with the telling of how bogged down I was getting over our trips to Duke.

It's time to shout out praise for General Mills.  I hate to even mention ConAgra in the same sentence, but like ConAgra, I sent an e-mail to General Mills asking about their allergy labeling policy.  Again, trying to find out how they label for products manufactured in the same facility or using the same equipment as products containing peanuts.  Here is their response:

Thank you for contacting General Mills concerning ingredients in our products.  As manufacturers and consumers, we understand your concern about potential allergens in the foods you eat.  Our primary goal is to provide accurate information; and we believe this is best accomplished by referring to the specific ingredients listed on each product package.  This is the most current information for your needs.

If one of our products contains any of the top 8 allergens (peanuts, tree nuts, dairy products, eggs, soy, wheat, crustaceans, and fish) or if it contains sesame, sunflower or mollusks, that ingredient is always listed in the ingredient panel, and also in bold letters just below the list of ingredients.  If a product is exposed to any of these allergens in the manufacturing facility the allergen will be listed in bold in the ′Contains Statement′ just below the list of ingredients.  This list is your ingredient assurance for that package.  It is not intended for other packaging of the same product.  Ingredients may vary from one package to another due to product reformulation.  If you have allergy concerns, please read each package ingredient panel.

This means I'm now a huge fan of General Mills.  Not only do they include a few additional allergens over and above the top 8, but if a product is manufactured in a facility with an allergen, the allergen is listed in the "Contains" statement.

We're all familiar with their cereals, Cheerios, Trix, Lucky Charms, Chex, but also Cascadian Farms, Fiber One and Nature Valley.  Some of their other brands include Betty Crocker, Pillsbury, Bisquick, Fruit Roll-Ups, Progresso, Green Giant, Old El Paso and Haagen-Dazs.  Now, if we could get them to drop the high fructose corn syrup, artificial sweeteners and partially hydrogenated oils we could enjoy even more of their products.

Our next visit to Duke is this coming Wednesday.  Be thinking about us.  Abigail has to have blood drawn and another skin prick test performed.  And me, I have to be rock solid keeping her brave and distracted through each procedure.

Bad News from ConAgra Foods

I received a very disturbing e-mail today.  In a previous post, I wrote that I was in the process of contacting major food manufacturers regarding their product labeling.  By law, food manufacturers must include a "Contains" statement if their product has any of the top 8 food allergens in the ingredients.  They do not have to include a statement regarding whether their product is manufactured in a facility or on the same equipment with a product that contains these allergens.  Given the risk of cross-contamination, people with severe food allergies should not consume foods processed in either of these conditions.

One of the companies I contacted was ConAgra Foods.  It's a huge conglomerate of highly popular, highly consumed brands.  The list of their brands is too long to include them all, but here are a few:

• Chef Boyardee
• Healthy Choice
• Kid Cuisine
• Hunt's
• Van Camp's
  
• Orville Redenbacher's
• Marie Callender's
• Banquet

We really try hard to avoid all foods with high fructose corn syrup, trans fats, partially hydrogenated oils, artificial sweeteners or high sodium content.  This eliminates a lot of their food from our shopping list.  However, we do still purchase quite a few of the ConAgra products.

I received a response from ConAgra today regarding my inquiry into their labeling policy.  Here it is:

Thank you for your request for more information about the ingredients in our products.

We comply with Federal regulations for allergen labeling.  These regulations require all major food allergens to be listed in plain language on the ingredient list, and/or be noted in plain language in a 'Contains' statement appearing just after the ingredient list. For consistency, ConAgra Foods always uses the 'Contains' statement. The allergens we list will include any of the eight major food allergens that are used in ConAgra Foods products. The major food allergens as defined by regulation are Crustacean Shellfish, Egg, Fish, Milk, Peanut, Soy, Tree Nuts, and Wheat.

Allergenic ingredients will be listed in the ingredient statement and will be noted in the Contains statement if they are included in flavorings or spice mixes. Please keep in mind that product formulas do change occasionally, so it is important to read the ingredient statement each time you purchase the product.

ConAgra Foods would like to help you with this request to the best of our ability. However, because the information you have requested is considered to be proprietary and a trade secret of ConAgra Foods, we are unable to supply this information.

If you have any allergen concerns outside of the Top 8 Food Allergens, we recommend you do not consume the product and consult your physician.

We appreciate your patronage and value our consumers.  We hope you will continue to enjoy our line of quality food.

Proprietary information, trade secret....really???  You can't tell your allergic consumers if the food they are eating is safe??  I understand that ConAgra is a really big company and that their food is probably manufactured in facilities around the world.  I also understand that it would take tremendous effort to document every food manufacturered on every line in every one of their facilities and then coordinate their package labeling to reflect their processes (although other manufacturers do).  Why not just say that?  How is telling a consumer with a peanut allergy that the food they are eating was made with equipment also used to make a product containing peanuts a violation of a trade secret?  I feel one of my infamous "soap boxes" coming!  Is it possible to boycott this company and not purchase any of their brands?  I'm about to find out!  Poor Abigail, it was a really big treat for her to be able to have a "fast meal", i.e., Kid Cuisine.

Follow up to Post:   I had someone recommend Ian's as an alternative to Kid Cuisine.  I went on their website, and they do have a very healthy, nut free kids meal.  It doesn't come cheap though.