Fatal food allergies are on the increase, making comprehensive labelling on processed foods a matter of life or death. Yet many US food manufacturers fail to comply with recommended labelling requirements. To improve standards, the FDA has published a new compliance policy guide. Nevertheless, the Food Allergy and Anaphylaxis Network is calling for greater government enforcement of ingredient labelling and more specific label wording. Pam Ahlberg takes up the story:

The number of consumers in the US with serious food allergies appears to be growing. Experts attribute this to changes in food habits, the introduction of known allergens such as peanuts at an earlier age, the use of milk and soy as a protein supplement in prepared foods, and the availability of more exotic seafood and fish. Whatever the reason, current estimates suggest that 1.5% of the US adult population and 5% of children younger than three years old have some form of food allergy. Furthermore, according to the Food Allergy & Anaphylaxis Network (FAAN), these allergies are suspected of causing 30,000 emergency room visits, and between 150 to 200 deaths each year.


The eight most common allergens, which cause 90% of allergic reactions, are peanuts, milk, eggs, fish, crustaceans, tree nuts, wheat and soybeans. Of those, peanut allergies are the most life threatening. More troubling is that as little as one-fifth to one-five-thousandth of a teaspoon of the offending allergen can cause death. For consumers with food allergies, ingredient labelling can mean the difference between life and death.


Recent study sounds the alarm


In response to an increased number of food allergen-related recalls across the US, the Food and Drug Administration (FDA) recently conducted a study in which it reviewed 85 food manufacturing companies in Minnesota and Wisconsin. The study looked for the presence of peanut and egg allergens on food processing lines in ice cream, bakery and candy plants. Label verification, rework procedures, cross-contact prevention, and general allergen-control procedures were reviewed. The study found that 18 out of 73, or 25%, of final food product samples tested positive for peanut allergens even though peanuts were not declared on the product label.


In 1996, FDA had issued a notice to the food industry alerting manufacturers of the public health problem of undeclared allergens in food, noting the importance of declaring allergens even when present in very low amounts. However, the increase in food recalls as well as the results of this latest study indicate that current manufacturing practices and labelling requirements need improvement.

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To that end, FDA in April delivered a new compliance policy guide (CPG) entitled ‘Statement of Policy for Labeling and Preventing Cross-Contact of Common Food Allergens,’ which identified issues related to undeclared allergens not clearly covered by existing label regulations. Those include:



  • Products containing one or more allergenic ingredient, but the ingredient not declared in the ingredient statement;

  • Products contaminated due to a firm’s failure to exercise adequate control procedures, for example, improper rework practices, allergen carry-over due to use of common equipment and production sequencing, and inadequate sanitation;


  • Products contaminated due to the nature of the product or the process; that is to say, use of common equipment in chocolate manufacturing where interim wet cleaning is not practical and only dry cleaning and product flushing is used;


  • A product containing a flavour ingredient that has an allergenic component, but the label of the product only declares the flavour;

  • Products containing a processing aid that have an allergenic component, but the label does not declare it.

FDA said the new guide was to provide guidance “on the Agency’s policy on allergens and actions that the Agency may or may not take under the Federal Food, Drug, and Cosmetic Act (the Act) and regulations based on the Act.”


At the same time, the National Food Processors Association (NFPA) released a ‘Code of Practice’ for managing food allergens, consistent with FDA’s guide.


In putting together these guides and codes, FDA and NFPA worked closely with the consumer group FAAN, which has been the mouthpiece for US food allergy issues. While acknowledging the efforts of FDA and industry groups, FAAN is asking for greater government enforcement of ingredient labelling and more specific label wording.


“When a doctor makes a diagnosis of food allergy, the patient is told to avoid milk, or eggs, or wheat. Current labels list these foods in a number of scientific or technical terms including caseinate, albumin, or semolina,” notes FAAN founder and CEO, Anne Munoz-Furlong. “Labels should be written for consumers, not scientists.”


In addition, FAAN takes issue with food manufacturers who voluntarily label their products with statements that begin, “May contain.” The group claims that this “maybe, maybe not” phrase undermines the integrity of food labels, further confuses consumers and reduces the number of foods available to those with allergies.


Thanks to the efforts of FAAN, as well as FDA and industry associations, US food manufacturers have been made much more aware of the problem of food allergens. However, increased product recalls and the results of the Minnesota/Wisconsin study suggest that awareness alone does not change behaviour. Whether policy guides and codes of practice will reduce the recall numbers waits to be seen. But for those with life-threatening food allergies, the matter is dead serious.


By Pam Ahlberg


Pam can be reached by email at: pahlberg@bellatlantic.net