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sesame seeds labeling: US specific page 3
sesame seeds labeling
Posted: Jan 21st, 2009 at 10:14 pm

Regarding hk's question in this thread
http://allergy.hyperboards.com/index.php?action=view_topic&topic_id=8745

Jan 21st, 2009 at 12:43 pm, hk wrote:
Hain Celestial just sent me this link to the FDA's wording about labeling for 'spices'. Yes, their labeling sucks and I don't use their products. I'm sending companies letters on a regular basis asking them to voluntarily label for sesame. I also ask Hain Celestial to disclose things so that I can resume purchasing any of their products that could be safe for us.

http://www.fda.gov/ora/compliance_ref/cpg/cpgfod/cpg525-750.html

According to this toward the bottom of the page:
NOTES:

1. Poppy seeds, sesame seeds, dried or dehydrated onions and garlic are not considered to be spices. When used as an ingredient in foods they should be declared on the label by common or usual names.

That has not been my understanding in the past 2 1/2 months of dealing with the sesame allergy. I was told that they often include sesame under the general term 'spices'. Does anyone else have any knowledge about this? Thanks.



ok ... here are my thoughts for what they're worth (generic disclaimer - I'm not an expert) ...

In the link they gave you, it states "In the absence of definitions and standards of identity for spices, the following descriptions provide guidance concerning acceptable names for use in labeling spices and foods in which they are used."

Guidance is not law, guidance is not regulation, and we can't risk our health or the health of our children on the chance that companies will choose to follow guidance.

Even if it were regulation (which, as far as I know, it's not), it would be a regulation buried among many, easy to miss, easy to ignore ... no attempt by FDA to connect the rule to life-threatening food allergies so that it is prioritized and emphasized.

From what I've heard, some companies DO label sesame as spice.
------------------------------------

The link they gave you also states that "After consultation with the American Spice Trade Association, the list has been brought up-to-date, and information from other sources has been added"

However, sesame is listed as a spice on this newer "American Spice Trade Association" link.
http://www.astaspice.org/i4a/pages/index.cfm?pageID=3723

It would be nice to know more about the ASTA/Government 2004 meeting they refer to.

------------------------------------

These links clearly suggest that sesame can be labeled as spice:


http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.4
"(b) The name of an ingredient shall be a specific name and not a collective (generic) name, except that:
(1) Spices, flavorings, colorings and chemical preservatives shall be declared according to the provisions of 101.22."

http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.22
"(2) The termspice means any aromatic vegetable substance in the whole, broken, or ground form, except for those substances which have been traditionally regarded as foods, such as onions, garlic and celery; whose significant function in food is seasoning rather than nutritional; that is true to name; and from which no portion of any volatile oil or other flavoring principle has been removed. Spices include the spices listed in 182.10 and part 184 of this chapter"

http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=182.10
Revised as of April 1, 2008
"Spices and other natural seasonings and flavorings that are generally recognized as safe for their intended use, within the meaning of section 409 of the Act, are as follows: .... Sesame ...."

------------------------------------

Trying to understand current FDA regulations seems to me an exercise in futile absurdity ... but now I know that I must contact manufacturers for info (versus just relying on the food label) .... and it is clear that better food allergen labeling is still needed.

-------------------

ETA - I did eventually call FDA about sesame & spice and the FDA employee told me that sesame could be labeled as "spice" if crushed. Who knows.

« Last Edited by Jul 11th, 2010 at 12:05 pm »

Posted: Feb 3rd, 2009 at 09:37 pm

Jan 21st, 2009 at 10:30 pm, hk wrote:
Thanks for your thoughts KP.


You're welcome Smiley .

Jan 21st, 2009 at 10:30 pm, hk wrote:

I may start harrassing them about the sesame again sometime soon.


Unfortunately, this is probably necessary if we are to push them to act. I think they actually forgot to exclude the non-big8 from the advisory labeling notice ... but it seems they tried to correct their "error" in the actual meeting by announcing in the beginning that:

Quote:

the purpose of the meeting today is for F.D.A. to gather information that will help us develop a long term strategy that can assist manufacturers in using allergen advisory labeling that is truthful and not misleading and conveys a clear and uniform message and adequately informs food allergic consumers and their caregivers to the potential presence of a major food allergen.


I do not believe that "major food allergen" language was in the original notice ... Smiley ... yep, look at the difference in the notice language ...

Quote:
II. Purpose and Scope of the Hearings FDA is developing a long-term strategy to assist manufacturers in using allergen advisory labeling that is truthful and not misleading, conveys a clear and uniform message, and adequately informs allergic consumers
and their caregivers. To that end, FDA is soliciting comments and information to assist the agency in determining how manufacturers currently use advisory labeling, how consumers interpret different advisory labeling statements, and what wording is most effective in
communicating to consumers the likelihood that an allergen may be present in a food. The agency is also interested in learning whether consumers find advisory labeling helpful for making food purchasing decisions.

The scope of this hearing is determined by this document.



Jan 21st, 2009 at 10:30 pm, hk wrote:

My new plan is to contact companies and request that they voluntarily start labeling for sesame.


This is good. Also, don't forget about writing to Congress.

Here is some general info:
http://www.foodallergy.org/advocacy/index.html

They probably aren't that interested in food allergies at this point, but they are interested in how the FDA is failing to protect the public ... and personal stories tend to be effective.

Jan 21st, 2009 at 10:30 pm, hk wrote:

I'm sure I won't get anywhere, but this plan is currently underway and at least I feel like I'm doing something.


No, don't say that! Just think about the difference you have already made ... didn't you say you got over 100 people to write in on the advisory issue regarding sesame?!? If everybody became active like you, the walls of resistance would fall down.


« Last Edited by Jul 11th, 2010 at 12:10 pm »

Posted: Feb 4th, 2009 at 08:33 am

FDA & HHS (Health and Human Services) news continued ...

"Daschle Ends Bid for Post; Obama Concedes Mistake"
http://www.nytimes.com/2009/02/04/us/politics/04obama.html?_r=1&th&emc=th

"Obama Says He Erred in Nominations"
http://www.washingtonpost.com/wp-dyn/content/article/2009/02/03/AR2009020304112.html?wpisrc=newsletter

"Old Ways Doomed New Job for Daschle"
http://www.washingtonpost.com/wp-dyn/content/article/2009/02/03/AR2009020300912.html?wpisrc=newsletter

------------------------------------------------------

"FDA = Failure to Do Anything"
http://www.huffingtonpost.com/kerry-trueman/fdafailure-to-do-anything_b_162620.html

"Not So Sweet: Missing Mercury and High Fructose Corn Syrup"
http://www.healthobservatory.org/library.cfm?refid=105026

"High Fructose Corn Syrup Meets Mercury"
http://voices.washingtonpost.com/mighty-appetite/2009/01/high-fructose_corn_syrup_meets.html

------------------------------------------------------

"Tainted food outbreaks won't go away: safety regulators"
http://www.google.com/hostednews/afp/article/ALeqM5j3WXxx4-AUav-1qkFIAs5v68CN8Q

"Governor Of Kansas Tapped to Lead HHS:
Sebelius Would Play Key Role In Health-Care Reform Plans"
http://www.washingtonpost.com/wp-dyn/content/article/2009/02/28/AR2009022801717.html?hpid%3Dtopnews&sub=AR

------------------------------------------------------

"Sen. Ted Kennedy Takes on the FDA"
http://www.qsrmagazine.com/articles/news/story.phtml?id=8206

"Obama orders agencies to work together on food safety"
http://www.ajc.com/services/content/2009/03/12/obamaga0312.html

"FDA Pick Was NYC Health Chief"
http://www.washingtonpost.com/wp-dyn/content/article/2009/03/11/AR2009031103570.html?wpisrc=newsletter&wpisrc=newsletter&wpisrc=newsletter

"Bipartisan Call for Food Safety Fixes"
http://www.nytimes.com/2009/03/12/health/policy/12fda.html?ref=health

"Obama: Food safety system is health 'hazard' --
President announces FDA picks and orders overhaul of troubled watchdog"
http://www.msnbc.msn.com/id/29691788/from/ET/

"GAO study: Fraudulent fish easily slip into the food stream"
http://www.usatoday.com/money/industries/food/2009-03-22-fish-fraud_N.htm

------------------------------------------------------

"FDA Commish to Employees: Take the FDA Back!"
http://invivoblog.blogspot.com/2009/04/fda-commish-to-employees-take-fda-back.html

Quote:

The FDA is now defined by others. You must speak up and take the FDA back. It is yours, not theirs. You do more good, day in and day out, than most others, inside or outside government.


« Last Edited by Apr 8th, 2009 at 12:55 pm »

Posted: Feb 4th, 2009 at 11:30 am

I was thinking about our situation with FDA and the movie "The Shawshank Redemption" came to mind ... particularly the scenes involving the letter writing campaign for books for the prison ...

http://www.411mania.com/movies/columns/92063

"After constant letter-writing for six years, we see various crates filled with books and records stacked up in the warden's office." ...

-----------

ANDY: "Dear Mr. Dufresne: In response to your repeated inquiries, the state has allocated the enclosed funds for your library project."

Andy reaches into the envelope again and pulls out a check.

ANDY: This is $200.

Suddenly realizing what this means, Andy continues reading.

ANDY: "In addition, the library district has generously responded with a charitable donation of used books and sundries. We trust this will fulfill your needs. We now consider the matter closed. Please stop sending us letters." .....

-----------

ANDY: Wow! It only took six years. From now on, I'll write two letters a week instead of one.

Smiley


Two words: Determination & Perseverance !!!


hk
Member


Posted: Feb 9th, 2009 at 11:00 am

I'm inspired to take up the sesame labeling mantle again! I recently started a local allergy support group and have a lot of women who are willing to write letters too. We are going to do something for Allergy Awareness Week that involves labeling laws, but haven't figured out the best thing to do yet. I will keep you posted.

« Last Edited by hk Jul 14th, 2010 at 07:21 pm »

7 yo DD - TN, PN, egg, sesame, avocado, flax, fish, cherry, mango
Posted: Feb 9th, 2009 at 08:48 pm

That's great that you started a local group!

I'll be interested to hear what you all decide to do for Allergy Awareness Week. Let me know if I can help.

KP

Posted: Mar 16th, 2009 at 01:22 pm

"Sesame Allergies on the Rise in U.S."
http://www.webmd.com/allergies/news/20090316/sesame-allergies-on-the-rise-in-us?src=rss_cbsnews

Quote:
“Sesame allergies have probably increased more than any other type of food allergy over the past 10 to 20 years,” says Robert Wood, MD


Quote:
“They’re now clearly one of the six or seven most common food allergens in the U.S.,” he tells WebMD.


Quote:
Yet, the FDA does not recognize them as such, as there are no well designed studies looking at how many cases occur each year, Wood says.

jenniferb
Member


Posted: Mar 16th, 2009 at 04:06 pm

oh you spotted this already. Oops I put the same link in Main Discussions

DS (age 6): allergic peanuts & tree nuts; asthma, eczema
DS (age 9): allergic amoxicillin; environmental allergies
Me: possible OAS to bananas, environmental allergies

http://www.foodallergybuzz.com
http://www.peanutfreebaseball.com

Posted: Mar 16th, 2009 at 05:03 pm

Mar 16th, 2009 at 04:06 pm, jenniferb wrote:
oh you spotted this already. Oops I put the same link in Main Discussions


No problem!!! The more people keeping an eye on sesame developments the better!!! Smiley

How did you come across the article so fast?


« Last Edited by Jul 11th, 2010 at 12:11 pm »

jenniferb
Member


Posted: Mar 25th, 2009 at 10:41 am

Ah, KP, I have countless Google Alerts--I am sure this must have come up in one of those! I am a news junkie.

DS (age 6): allergic peanuts & tree nuts; asthma, eczema
DS (age 9): allergic amoxicillin; environmental allergies
Me: possible OAS to bananas, environmental allergies

http://www.foodallergybuzz.com
http://www.peanutfreebaseball.com

Posted: Mar 25th, 2009 at 11:50 am

Mar 25th, 2009 at 10:41 am, jenniferb wrote:
Ah, KP, I have countless Google Alerts--I am sure this must have come up in one of those! I am a news junkie.


I had a hunch you were signed up Smiley .

So far I have resisted signing up ... I'm already on several news/health lists ... every once in a while, I just manually google "sesame allergy" Smiley

Keep us updated on anything interesting in your alerts!

Posted: Mar 28th, 2009 at 11:21 am

New commissioner aims to open FDA's 'black box'
http://findarticles.com/p/articles/mi_hb4365/is_12_42/ai_n32147623/

Quote:

The call for transparency comes at a time when the FDA already has a backlog of requests under the Freedom of Information Act. Asked how she planned to handle personnel needs at a time when the agency is behind in its work, Dr. Hamburg said, "When the recommendations come in, I will work with the task force and others on implementation. Some activity may result in more work, and some may result in decreased work. If we make more information available, there may be fewer Freedom of Information Act requests and citizen petitions."



« Last Edited by Jul 11th, 2010 at 12:12 pm »

Posted: Apr 28th, 2009 at 09:51 pm

I’ve gone through the FDA advisory comments and wanted to give a summary of those relating to sesame.

There were roughly 852 comments submitted in all. Of those, there were about 91 specifically mentioning sesame. Out of those 91, about 42 were based on hk’s comment.

Considering that pushing for sesame was strictly grassroots, 10% of comments mentioning sesame seems pretty respectable to me. There were many more comments requesting that all ingredients be labeled and a few requesting that seeds be labeled … which I didn’t officially include in my “sesame count”.

I say “roughly” because I didn’t double check for errors, wasn’t real consistent with handling duplicates (usually if I saw obvious duplicates, I combined them … or if one person wrote 2 sesame comments, I generally counted it as 1) … plus some of the submissions technically were considered something else like “testimony” but I didn’t differentiate.

I’m going to include a few quotes below from the comments.

I know this is public info, but if anybody feels uncomfortable with anything, contact a moderator, and they are welcome to edit or delete any of the below advisory comment quotes.


ETA - I didn't include consumer responses from the AAFA or KFA surveys in the figures above.

« Last Edited by Jul 11th, 2010 at 12:17 pm »

Posted: Apr 28th, 2009 at 09:51 pm

These are comments viewable at the FDA site (not all of these were included in my "sesame count"):
----------------------------------------------------

FDA-2008-N-0429-0015: Slide 9
American Dietetic Association

FDA-2008-N-0429-0019: Slides 10, 11
Allergen Bureau - Vital Allergen Risk Assessment

FDA-2008-N-0429-0022: Slides 4, 10, 17
Jaffe Food Allergy Institute - A Pediatric Allergist's Perspective of the Food-Allergy Consumer's Perspective

FDA-2008-N-0429-0043

FDA-2008-N-0429-0047

FDA-2008-N-0429-0055

FDA-2008-N-0429-0059

FDA-2008-N-0429-0066

FDA-2008-N-0429-0070

FDA-2008-N-0429-0086

FDA-2008-N-0429-0111

FDA-2008-N-0429-0134

FDA-2008-N-0429-0139

FDA-2008-N-0429-0150

FDA-2008-N-0429-0159

FDA-2008-N-0429-0162 - FDA-2008-N-0429-0172

FDA-2008-N-0429-0174 - FDA-2008-N-0429-0176

FDA-2008-N-0429-0178

FDA-2008-N-0429-0181 - FDA-2008-N-0429-0182

FDA-2008-N-0429-0196

FDA-2008-N-0429-0208

FDA-2008-N-0429-0212 (page 12)



« Last Edited by Apr 28th, 2009 at 10:22 pm »

Posted: Apr 28th, 2009 at 09:51 pm

Here is a sampling of quotes from comments submitted to FDA for the advisory effort:

Quote:

has a life-threatening allergy to sesame. Whether packaged food or restaurant food (they buy ingredients not labeled), everything that I give her is "Russian Roulette".



Quote:

As the parent of a child with life-threatening food allergies (milk, sesame and previously egg), I am writing to voice both my concerns and praise for current food labeling practices. While I am grateful for the enormous positive changes brought about by FALCPA (Food Allergen Labeling Consumer Protection Act), there is much more that can and should be done.

Sesame is a serious allergen. Current statistics rank it among the top 9 allergens. Sesame has been added to the list of major food allergens for use in food labeling in European Commission (EC) and Canada, but it is not yet included in the Food and Drug Administration’s listing of allergenic foods for labeling purposes in the United States. This is a serious deficiency in our labeling requirements.



Quote:

I recommend that a standardized "Allergen Facts" box be required for all packaged foods. It should include the top 8 allergens, PLUS sesame which is an increasingly diagnosed allergen.



Quote:

we ask that you give guidance to schools on allergy free menus regarding especially peanut, tree nut, and sesame.



Quote:

Add Sesame and Mustard to list of Big 8 Allergens



Quote:

I am writing to let you know that we regard all of the different types of advisory statements as meaning that there is the possibility of an allergic reaction and therefore we do not purchase/consume the product. We do not ignore them as my daughter's food allergies (nut, peanut, sesame, soy, egg, shellfish, and coconut) are too severe to risk any sort of a reaction. We would strongly encourage you to ensure that sesame is included in the US list of major food allergens as it is in the EU.



Quote:

I would like to see sesame included in the list of common allergens. Sesame allergy is a significant and serious problem found to be growing globally according to a report published in 2005 in Annals of Allergy, Asthma & Immunology, the scientific journal of the American College of Allergy, Asthma and Immunology (ACAAI). Sesame has been added to the list of major food allergens for use in food labeling in European Commission (EC) and Canada, but it is not yet included
in the Food and Drug Administration's (FDA) listing of allergenic foods for labeling purposes in the United States.



Quote:

A second issue for us is that both children are allergic to sesame, yet this is not one of the foods that is required to be called out on labels. It makes it so much harder to check for that ingredient when it is not called out separately anywhere.



Quote:

My daughter, who is 26 months old has an anaphylactic allergy to peanuts. At the advice of her allergist, we do not feed her peanuts, sesame, tree nuts, mangos or kiwi.



Quote:

Our 5 year old daughter is severely allergic to eggs, peanuts, and sesame seeds. Reading labels and knowing what types of facilities that foods are processed in are a life and death decision for us.





« Last Edited by Jul 11th, 2010 at 12:18 pm »