August 13, 2001

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# FAAN's Response to the FDA's Public Hearing on the

# Labeling of Food Products Containing Allergens

Close to 7 million Americans suffer from food allergies. For these
individuals, avoiding the food to which they are allergic is the only
way to prevent a reaction. Reading food labels is the primary means of
avoiding food allergens in packaged foods. Reactions can range from mild
to life-threatening or fatal. It is estimated that severe allergic
reactions to foods lead to 30,000 emergency visits to hospitals each
year and 150 to 200 deaths. Reactions occur when someone unknowingly
eats a food to which they are allergic. In other words, they are eating
a food they *thought* was safe but that contained a hidden ingredient
sometimes caused by confusing or misleading food labels.

FAAN's position is that food labels must be improved. For those with
food allergies, ingredient labels must be clear, consistent, and
reliable. FAAN supports all initiatives that address this important
issue.

# The FDA's public hearing on August 13^th^ in Washington, DC focused on three key areas of food allergen labeling: source or plain English labeling, advisory labeling (may contain...), and labeling of ingredients exempted from declaration (flavors, colors, spices; incidental additives).

**Source or plain English labeling**

Currently, ingredient labels are written for food scientists, not
consumers. They include technical or scientific terms that are foreign
to most of us. For example, ammonium caseinate and other chemical names
are used in lieu of "milk". For individuals with food allergies, their
family, friends, and caregivers, this poses a potentially dangerous
obstacle in avoiding certain ingredients to prevent a reaction.

FAAN's position is that labels should be simple enough so that even a 7
year old can read the label and begin to take the responsibility for
avoiding certain foods.

**Advisory labeling (may contain...)**

Allergens can inadvertently be present in a product due to cross
contamination in the manufacturing process. Companies have begun using
advisory statements, such as "may contain..." on the labels to warn
consumers of the potential presence of allergens.

Some companies have worked to follow good manufacturing practices to
prevent this from occurring. These companies use advisory statements
judiciously. FAAN applauds their concern for the safety of food-allergic
consumers.

However, a growing number of companies have begun to put these
statements on their products instead of improving their processes. The
indiscriminate use of these advisory statements is limiting the food
supply of food-allergic consumers. Additionally, the proliferation of
these statements has cast a doubt about the potential risk to the
food-allergic consumer. Some families are opting to ignore these
statements; a practice FAAN feels can be akin to playing Russian
roulette.

Currently, every company makes their own decisions about when to use
these statements. And each has a different understanding of what they
mean. FAAN's position is that we need consensus for the industry's use
of these statements so that we can educate food-allergic consumers as to
how decipher the meaning of these statements. Additionally, there are
currently over 15 versions of these statements in use, that number
should be reduced sharply.

# Labeling of ingredients exempted from declaration (flavors, colors, spices; incidental additives)

Current regulations allow companies to list ingredients which appear in
low levels under collective names, i.e. Natural flavors, spices, or
colors. Allergens may be present in these flavors, etc., and even at
these low levels, have caused reactions to children.

FAAN's position is that allergens should be listed on the label,
regardless of the low level in which they may appear in the product.
FAAN has brought these issues to the attention of leaders in the food
industry over the past few years. Recently, voluntary guidelines were
released, but much remains to be done.