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Addressing the Issue of Undeclared Allergens

Undeclared Allergens Still a Leading Reason for Recalls
If you took a random sample of recent food product recalls issued by the United States Department of Agriculture's Food Safety and Inspection Service, chances are good that a significant percentage of them would pertain to undeclared allergens.

The dangers of allergic reactions are well-documented, specifically those that occur in response to the eight major allergens: milk, eggs, fish, peanuts, shellfish, soy, tree nuts and wheat. In fact, the most extreme form of reaction, anaphylaxis, is described by the National Library of Medicine's Medical Encyclopedia as "severe" and "life-threatening." With so much on the line, why are products so frequently being recalled due to the undeclared presence of allergens?

The Problem of Cross-Contamination
As public health consultant Roy Costa explained in a recent piece published by the Food Safety & Environmental Health Blog, the food labeling laws currently in existence grant a certain amount of leeway. For instance, although products that contain allergens as an ingredient must declare this on their labels, allergens that may be accidentally introduced during the manufacturing or packaging process do not have to be indicated.

A recently released FDA Consumer Update that focused on the presence of milk in allegedly dairy-free dark chocolate delved deeper into this phenomenon, which is known as cross-contamination.

"Most dark chocolate is produced on equipment that is also used to produce milk chocolate," the report explained. "In these cases, it is possible that traces of milk may inadvertently wind up in the dark chocolate."

For individuals who are highly sensitive to dairy - or, indeed, any other allergen - a mere trace of it is enough to trigger anaphylaxis. In the interest of transparency, many manufacturers voluntarily include statements on product labels that point to the likelihood of allergens being present. However, because the inclusion of these warnings is not mandatory, their wording varies. In some cases, the phrasing chosen by the manufacturers downplays the potential for the products to include the allergens, leading to dangerous misconceptions on the part of the consumer.

Inconsistency Leads to Confusion
Among the 94 bars of dark chocolate tested by the FDA to form the basis of the consumer update, advisory messages included:

  • "made on equipment shared with milk"
  • "manufactured in a facility that uses milk"
  • "may contain milk"
  • "may contain dairy"
  • "may contain traces of milk"
  • "processed in a plant that processes dairy"

Despite the modifier "may," a significant majority - 75 percent - of all products with packaging that included one of these advisory statements was ultimately found to contain milk. At the very least, this suggests that more definitive phrasing should be used.

"Work is needed to make the format of these advisory labels more consistent so that it's easier to identify which products contain allergens," Costa asserted.

One way to align advisory statements would involve the FDA issuing a mandate to require all manufacturers to list potential cross-contamination risks. As part of these regulations, the FDA could specify the language that companies should use to get these warnings across in a realistic way.