On one hand, I love them...
In 2011, Lucy's lips swelled up to several times their normal size after a salad dressing touched her mouth. I just knew this was because the vegan Caesar dressing had been cross-contaminated with eggs or milk. I called the FDA at 8pm. They called me back at 10pm. What? Seriously? The nice man on the line said, "we care very much about food safety, in particular when it comes to kids." Nice work, guys. The next morning, an FDA case worker was at my house, interviewing me at length and taking samples. I was shocked. I felt comforted. My government is awesome!
Oops. My bad.
Turns out, it was all for nothing. No cross-contamination. Lucy had developed a mustard allergy and the dressing had mustard in it five different ways. My bad. Thanks anyway, feds. I am impressed.
FALCPA
In 2006, because of FAAN's relentless legislative advocacy work, one of the most important pieces of food allergy legislation was passed. This act, known as The Food Allergen Labeling Consumer Protection Act, or FALCPA requires that packaged food labels have ingredients of the eight most allergenic foods declared even if they are spices of flavorings. These eight foods are: peanuts, tree nuts, milk, eggs, fish, shellfish, soy and wheat. Lucy is allergic to the first four, and outgrew a soy allergy at 2-years-old.
This is tremendously helpful. Pre-2006, any of those ingredients could be hiding anywhere and there was no way to know if a pre-packaged food was safe or not. Also, any of those ingredients could have been listed as anything. Milk, for example, could have been labeled as, "casein," "whey," "lactoglobulin" or any of the other scores of milk proteins, enzymes or lipids. In thos dark olden days, you needed a PhD and faith in manufacturers to get through a trip to the grocery store. Except, that you still do.
On the other hand, I hate them...
FALCPA is very limited in scope. It does NOT cover the following. In parenthesis, I've put common allergens found in these products. How do I know about these? Personal experience, research and phone calls. Those parenthesis represent reactions that could have prevented if only labels were accurate.
- deli or bakery foods at grocery stores
- restaurants
- raw meat (marinades, binders and fillers often contain milk and/or egg)
- medicine (most chewables contain milk; many gummy vitamins contain nut oils)
- alcohol (not that we have to worry about this for a while, but liqueurs and beers often contain nuts)
- lotions/soaps/toothpastes/cosmetics (nuts and milk are in many skin and hair products; peanuts are in Chapstick and lipsticks; most toothpastes contain milk and/or eggs)
- vaccines (the virus in the vaccine is often grown in egg and milk is often used as a binder. Lucy gets vaccines at the allergist's office and has to stay four hours for observation. In 2009, she reactive with full-body hives to a vaccine that used milk as a binder. Several hihg-profile cases of anaphylaxis later, the manufacturer admitted this.)
- dentist office cleansers/adhesives (braces, fillings, caps and crowns contain wheat ingredients, which thankfully doesn't impact us. Whiteners often contain milk.)
- products containing food that are not intended for consumption, such as paints and glue (tempura paint contains egg and until recently, Elmer's glue contained milk)
- foods used in manufacturing that are not technically an ingredient (raw seafood is often soaked in milk to reduce the odor; the wax put on raw produce contains milk; milk is used in the tumbling process of many candies).
It also doesn't cover foods that are very similar to the eight foods that are required to be labelled. For example, goat and sheep milk have 96% of the same proteins as cow's milk and are just as allergenic. A product could use another mammalian milk and not have to label it.
"This product manufactured on equipment shared with anthrax"
You've probably seen that some foods have statements like, "May contain peanuts." Or, "manufactured on equipment with food containing eggs." Those statements are completely voluntary. If a fork was used to stir cyanide soup and then used to serve your mashed potatoes, I'm guessing you'd want to know that. I saw a Halloween Snickers bar that said, "Contains peanuts." Following that logic, one might assume that it did not also contain any of the other top eight food allergens. Except that it did contain milk and wheat. Tricky.
The trickiest part is that foods are made on the same equipment as other foods. Bits and pieces of those foods stick and get co-mingled. This has happened in my own kitchen. Mixers, blenders, spoons, frying pans - food residue sticks. Lucy threw up once after taking a wooden spoon out of my clean dishwasher. She immediately vomited. The spoon had been used to stir cheese sauce the night before.
There have been several studies on this phenomenon with peanuts. In candies and baked goods where peanuts were not an ingredient, but where the foods were made on equipment shared with peanut-containing foods, up to 1.5 peanuts were found in the "peanut-free" foods. Lucy experienced anaphylaxis at 1/60th of a peanut. So not requiring "shared equipment" labels on foods is a major failure. We do buy some foods that are made on shared euipment because the manufacturers follow really tight guidelines about cleaning the lines between productions. Some brands, like Tofutti ice cream sandwiches are recalled nearly every year due to cross contamination,
And then there's mustard and roach poop...
Mustard, et al. In other words, the 80 bizillion foods that are not the eight foods required to be labeled. The manufacturers have (and exercise) their legal right not to tell you what is in their patented, propritary spice blend of death. And, since these other ingredients do not have to be labelled, a recipe can change at any time without consumers knowing. Just because a food was safe in July doesn't mean that a new box of it purchased in August has the same ingredients. Worried about GMOs, gluten, MSG, HFCS, roach droppings? Too bad, consumers.
Hey, thanks, Jews.
I'd be remiss if I didn't give a shout out. Where the FDA has failed me, Jewish dietary law has not. Foods labelled as Parve are safe for Lucy. This is not an FDA label, but rather a rabbi's seal of approval that the food does not contain meat or milk. This is not a 100% method for guaranteeing a safe food, but I'd like to see the FDA take this businesses as seriously.
Total Recall
Several times a week, I get a notice like this in my inbox, "Clif Bar & Company is initiating a voluntary recall today of a small amount of 12-pack Blueberry Crisp CLIF® Bars and individual mislabeled Blueberry Crisp CLIF Bars in Chocolate Chip CLIF Bar Wrappers." They put the wrong food in the wrong wrapper. What you thought were Allergen-Free Yum Yums are actually Extra Crispy Anaphylaxies. I'm so glad the FDA recalls these foods and makes us aware, but come on, manufacturers! Really?!?!
My Evil Plans
You do not know what's in your food, and food manufacturers' rights are protected by law, whereas yours are not. And this is good because I want nothing more in the world than to start my own ketchup-making business and bring down Heinz. I want to know their secret blend of tomatoes, high fructose corn syrup, mustard and roach poop so I can convert my garage into a condiment-producing empire. MWWWAAAA HAAA HAAA. Except that all I really want to do is put a dollup of ketchup on my kid's plate to enjoy the safe sweet potato fries that it took us three years to find.
Oh Canada!
The FDA takes this business seriously. They came to my house for a false alarm, for Pete's sake. And I don't hate them. I am just endlessly frustrated that they don't do more. FAAN is advocating for label laws to become more strict and to include more foods. Canada does include mustard as per their food allergy labelling laws. (They made this decision after just 44 cases of reported mustard anaphylaxis.) So, thanks to the internet, I can often figure out which brands hide mustard, so long as a change my search criteria to be Canadian sites.
On a daily basis, this labeling stuff makes life easy and makes life hell. We've pretty much honed in on the safe manufacturers for toothpaste and medicine and lotion and several foods, but keeping a list of brands, ingredients, recall notices, 800 names for milk/eggs/peanuts/tree nuts, etc., can be a real challenge. Grocery and drug store trips take half a day and cost a ridiculous amount of money.
So please peeps, support FARE. You have a right to know what you put in and on your body and the 15 million people with food allergies deserve to eat and brush their teeth and paint their walls without having to worry about dying.
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