**Food Allergy Support Group of Northern Virginia**

**Food Labeling Testimony Presented to the Food and Drug Administration,
HHS**

**September 16, 2008**

Thank you for the opportunity to speak today.

My name is Anne Cass Carter and I am the mother of a 9 year old with
multiple food allergies. I am here representing thousands of people in
Fairfax County, Virginia who either live with or care for people (mostly
children) who live with life-threatening food allergies. I present this
testimony on behalf of the Food Allergy Support Group of Northern
Virginia. We are a new group, just one year old, with a member base of
more than 120 families.

We are but one of several new and established support groups in the
Washington DC metro area. Leesburg County and Arlington also have their
own support groups. As we grow and continue to network with one another,
it is our hope to become an organized information source for families
and individuals throughout the region who are managing food allergy
lifestyles.

We thank you for the years of work, research and study that have been
conducted to help us avoid life-threatening allergens whenever possible.
And we thank you for recognizing that there is potential for continued
improvement in how manufacturers clearly communicate with consumers
about these issues.

As you are aware, ingesting an allergen can result in a trip to the
emergency room, or worse, a fatal reaction. Through our testimony we'd
like to provide you with a glimpse of the wide range of real-life
experiences with the confusing inconsistency of labeling:

One member writes: *An example I find amazingly frustrating is where the
manufacturer does not label the cross contamination issues clearly.  My
husband purchased flour from Bob\'s Red Mill and read the label
carefully before buying it.  Upon arriving home I double checked the
label.  I found a cross contamination warning in tiny print, in a
different color ink (red, which was very difficult to see let alone
read), in an entirely different location from the ingredients list. *

*   *

> *This is not an isolated occurrence from one manufacturer.  These
> problems in varying degrees are quite common.  As an allergy family
> it\'s scary to think this may have slipped past us.  It is also a
> grave concern when children start going out into the world where
> others (teachers, other parents, counselors, babysitters, restaurant
> personnel, etc) must be relied on to read labels for an allergic
> child.  If an experienced parent like me misses these things how in
> the world can I expect an inexperienced label reader to do an adequate
> job of protecting my child?  Even the best intentioned person will
> fail at some point. *

*  *

> *I would like CLEAR, CONSISTENT warnings.  It is extremely difficult
> to convey the basic pertinent information to keep your child safe
> without overloading the recipient.  Must I also explain the multitudes
> of different language a manufacturer may choose to use and that the
> warning could be just about anywhere on the package?  It\'s already
> asking a lot for busy parents and professionals to read labels for
> allergens without asking them to go on a scavenger hunt for warnings
> and then further have to play the guessing game of what does* this
> *particular warning mean.  *

*     Thank you for any help, it would be truly appreciated.*

Another member writes: *During a shopping trip at Whole Foods I was
being pestered by my food-allergic daughter for a new type of cereal
directed at children. We stopped and read the label together and I
victoriously showed her the part of the label that said "manufactured in
a facility that processes nuts." As I turned back to the shopping cart,
a Whole Foods employee interrupted me to say he had overheard our
conversation and that I didn't need to avoid that particular brand of
food because of nut allergies. He went on to explain that Whole Foods
has close working relationships with its suppliers and manufacturers,
often conducts its own facility inspections, and knows that this
particular manufacturer is fastidious about separating allergens in its
facility.*

> *Between pressure from my daughter -- who more often than not must
> skip eating the foods her friends enjoy -- and the safety blessing of
> a store employee, I bought the cereal. And we did not have an allergy
> incident. But who am I to believe? The manufacturer? The store
> employee?*

A few months ago on our online discussion board, a member wrote that
Hershey's Kissables, which for many of our families are the "safe"
answer to M&Ms, contained an ingredient derived from shea. None of us
knew that shea is a type of nut. None of us had noticed a "Contains
nuts" warning on the Kissables labels.

And yet another member writes: *Popsicles were handed out at school
orientation with the following label: **Does not contain peanuts or tree
nuts.  Processed on equipment that also processes peanuts or tree
nuts.***

* *

> *My son, who reads his own labels, was debating about what to do \--
> he finally asked me and we discussed and decided to forego. His
> growing independence is a wonderful thing to watch **but I can see him
> already willing to take chances \-- or consider it \-- and taking a
> chance two or three times with no consequences makes him MUCH more
> likely to take a chance the next time and maybe with a different
> outcome. How do we teach them the shades of gray when it feels like
> Russian roulette? This inconsistent labeling will lead to risky
> choices and decisions for pre-teens and adolescents who are making
> these choices alone for the first time.***

* *

> *Also, Duncan Hines cake mixes, right after the labeling laws were
> changed, altered their ingredients to include dairy \-- the very last
> item on the list.   Now, it\'s gone \--so, did they change their
> processing or merely the labeling?  The manufacturer could not answer
> that question.. *

There is another component to the food labeling issue that we ask you to
consider; that is consumer education. We realize that through your
consumer research you already understand the risks we take when we
depend on labels. And yes, many of us have assumed that labeling more
often than not is included on packaging simply to protect against
liabilities. In fact, many of our members were ignoring labels stating,
"Manufactured in a facility that also processes peanuts," until Anne
Munoz Furlong from the Food Allergy and Anaphylaxis Network spoke at a
meeting and explained why and how trace amounts of peanuts and tree nuts
can still make it into "safe" foods.

While things are starting to change, the majority of people diagnosed
with food allergies receive little or no support once they leave the
doctor's office. One doctor simply told a mother, "Your child is
allergic to peanuts. He could die. Don't let him eat peanuts." After
surveying our members we've found dramatic variances of what allergists
advise. There is no consistent advice on how to embark on a lifestyle
free of allergenic foods.

So to many of us, it does matter how manufacturers label their products.
But just as importantly, consumers like us need context. We don't
understand how foods are processed and produced. We don't understand the
risks we're taking when we ignore a label. Those of us who are hyper
vigilant about obeying label warnings suspect that we are unnecessarily
missing out on favorite foods, or more importantly, foods needed for a
nutritious, balanced diet because of food limitations due to multiple
food allergies.

We urge you to consider a consumer education campaign when you prepare
to roll out updated food labeling standards. We desperately need the
consistency for which you are striving. But people who, unlike me, have
not been advised by their doctors, or do not know about one of the new
support groups springing up, are simply left on their own to interpret
the safety of myriad foods. Therefore, clear, consistent, meaningful
labeling is absolutely imperative to keep our children safe from
accidental exposure to potentially life-threatening allergens

Again, thank you for the opportunity to speak today, and on behalf of
our families and children, thank you for working toward better, safer
food labeling.

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