sesame seeds labeling
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Posted: Jul 9th, 2008 at 03:40 pm
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I know with the great US food labeling laws, some ingredients can hide under the the label of "seasonings" or something similar. Can sesame seeds ever hide under this?
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Northern CA - Allergic to shellfish, tree nuts, peanuts, and sesame
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Posted: Jul 9th, 2008 at 09:40 pm
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Sesame can hide under "spices" and "natural flavor(s)" ... I'm not sure if it can hide under "color" or "artificial flavor" so to be safe I would call a company when I see those. Lisa (Lakeswimmer) told me of at least one company that uses sesame as a processing aid (similar to us using cooking spray) without labeling for it at all. Also, be careful of derivatives of sesame like tahini. Cross-contamination is a big issue for sesame ... some companies treat it as an allergen, but others do not take special precautions like cleaning equipment for sesame.
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This link has some info I collected on sesame & labeling:
(Edited - took out link for privacy reasons)
At one point in that thread, you'll find the FDA's explanation to me on how sesame can be labeled (at least for FDA regulated food).
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Also be careful of sesame oil ... a leading allergy expert told me that he is unsure whether sesame oil is ever safe for someone with a sesame allergy (he wasn't sure if it could ever be refined enough to remove the proteins). A lot (not all) peanut allergic folks can have highly-refined peanut oil ... from what I understand, that may not hold true for sesame.
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« Last Edited by
Jul 11th, 2010 at 11:55 am »
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Posted: Jul 9th, 2008 at 10:50 pm
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Thanks for the info. I had a feeling it could hide under those labels, but wasn't positive. The information in your link was fabulous. I cannot get over the quote of "We’ve got enough to deal with right now with the eight major allergens." Gotta love the bureaucrats.
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Northern CA - Allergic to shellfish, tree nuts, peanuts, and sesame
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Posted: Jul 10th, 2008 at 09:29 am
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It is all VERY bureaucratic!
If you'd like some pretty good summaries of what you need to know about sesame & labeling, I'd recommend the following:
http://www.kidswithfoodallergies.org/resourcesnew.php
http://www.kidswithfoodallergies.org/resourcespre.php?id=1&title=Grocery_shopping_for_a_child_with_food_allergies
http://www.kidswithfoodallergies.org/resourcespre.php?id=50&title=FALCPA
http://www.kidswithfoodallergies.org/resourcespre.php?id=8&title=Careful_label_reading_for_food_allergens
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For a very detailed analysis of the FALCPA:
http://allergy.hyperboards.com/index.php?action=view_topic&topic_id=4438
There is a draft of the FDLI paper here (it is not the final version of the paper):
http://leda.law.harvard.edu/leda/data/730/Derr05_FINAL.html
Please don't quote from that paper ... I believe it's open for anyone to read for personal use ... but I'd ask everyone to respect the copyrights on it.
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For the most bureaucratic explanation, see the FDA's explanation to me:
Dr. Y has asked me to respond to your questions. I have attempted to answer as completely as I can. For general information The Code of Federal Regulations, represents the primary body of rules that apply. Here are links to the relevant sections of FOOD FOR HUMAN CONSUMPTION, Part 101, Food Labeling (http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=101&showFR=1), and specifically, Section 101.3 Identity labeling of food in packaged form, http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.3 and Section 101.4 Food; designation of ingredients, http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.4.
As you are aware the Food Allergen Labeling and Consumer Protection Act (FALCPA), http://www.cfsan.fda.gov/~dms/alrgact.html also addresses allergen labeling. Through this link, you can access the full law. I have addressed information on food labels other than the 8 major allergens. I believe you have asked if the labels of foods made from two or more ingredients still required to list all ingredients by their common, or usual, names? Under the 21 Code of Federal Regulations Part 101.4(a) If the ingredient is a major component of a food it will be listed in the ingredients list by it's common or usual name. Always list the common or usual name for ingredients unless there is a regulation that provides for a different term. For instance,use the term "sugar" instead of the scientific name "sucrose".
"INGREDIENTS: Apples, Sugar, Water, and Spices"
It depends on whether the trace ingredient is present in a significant amount and has a function in the finished food. If a substance is an incidental additive and has no function or technical effect in the finished product, then it need not be declared on the label. An incidental additive is usually present because it is an ingredient of another ingredient. Sulfites are considered to be incidental only if present at less than 10 ppm. 21 CFR 101.100(a)(3)
You have also asked what are all of the exceptions to this rule?
All other ingredients must comply with current labeling regulations for foods and food additives. These are found in 21 Code of Federal Regulations Parts 100 to 169. Regulations specific to ingredient labeling are Sec. 101.4 Food; designation of ingredients.
You have asked for more specific information about the labeling of �vegetable oil� as opposed to a �vegetable oil blend�. The label for a �vegetable oil blend�, does the label then have to include exactly what oils like sesame make up that blend, or is a manufacturer not required to state the exact ingredients of the blend? In answering your question I asked the Office of Nutrition Labeling and Dietary Supplements and they gave me the answer provided to you in my email addressing this specific question. From reading the regulations it appears that the following applies to your question:
"INGREDIENTS: . . . Vegetable Oil (contains one or more of the following: Corn Oil, Soybean Oil, or Safflower Oil) . . . ."
21 CFR 101.4(b)(14) Here is the section of the regulations that deal with vegetable oil blends. Sec. 101.4 Food; designation
of ingredients:
(14) Each individual fat and/or oil ingredient of a food intended for human consumption shall be declared by its specific common or
usual name (e.g., "beef fat", "cottonseed oil") in its order of predominance in the food except that blends of fats and/or oils may be
designated in their order of predominance in the foods as "___ shortening" or "blend of ___ oil
« Last Edited by
Jul 11th, 2010 at 11:58 am »
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Posted: Jul 10th, 2008 at 09:30 am
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designated in their order of predominance in the foods as "___ shortening" or "blend of ___ oils", the blank to be filled in with the word
"vegetable", "animal", "marine", with or without the terms "fat" or "oils", or combination of these, whichever is applicable if, immediately
following the term, the common or usual name of each individual vegetable, animal, or marine fat or oil is given in parentheses, e.g.,
"vegetable oil shortening (soybean and cottonseed oil)". For products that are blends of fats and/or oils and for foods in which fats
and/or oils constitute the predominant ingredient, I.e., in which the combined weight of all fat and/or oil ingredients equals or exceeds
the weight of the most predominant ingredient that is not a fat or oil, the listing of the common or usual names of such fats and/or oils in
parentheses shall be in descending order of predominance. In all other foods in which a blend of fats and/or oils is used as an
ingredient, the listing of the common or usual names in parentheses need not be in descending order of predominance if the
manufacturer, because of the use of varying mixtures, is unable to adhere to a constant pattern of fats and/or oils in the product. If
the fat or oil is completely hydrogenated, the name shall include the term hydrogenated, or if partially hydrogenated, the name
shall include the term partially hydrogenated. If each fat and/or oil in a blend or the blend is completely hydrogenated, the term
"hydrogenated" may precede the term(s) describing the blend, e.g., "hydrogenated vegetable oil (soybean, cottonseed, and palm
oils)", rather than preceding the name of each individual fat and/or oil; if the blend of fats and/or oils is partially hydrogenated, the term
"partially hydrogenated" may be used in the same manner. Fat and/or oil ingredients not present in the product may be listed if they
may sometimes be used in the product. Such ingredients shall be identified by words indicating that they may not be present, such as
"or", "and/or", "contains one or more of the following:", e.g., "vegetable oil shortening (contains one or more of the following:
cottonseed oil, palm oil, soybean oil)". No fat or oil Ingredient shall be listed unless actually present if the fats and/or oils constitute the
predominant ingredient of the product, as defined in this paragraph (b)(14)
Finally, you have asked if there are any other intentional ways sesame could be introduced into a product where it is not required to be labeled, such as through “processing aids” (which I understand the FDA puts in a separate category than “ingredients”). 21 CFR Part 178 designates "production aids". I have given you the link for this section so that you can see what is permitted. This is where you can find the information on production aids you have requested PART 178--INDIRECT FOOD ADDITIVES: ADJUVANT, PRODUCTION AIDS, AND SANITIZERS http://www.access.gpo.gov/nara/cfr/waisidx_07/21cfr178_07.html.
I understand you frustration and the need for you to protect your child. The Food Allergy and Anaphylaxis Network (http://www.foodallergy.org/) might be able to assist you more than I can. In an attempt to keep my answers simple and to the point I may not have assisted you as well as you might have needed. All this being said, sesame is not one of the major allergens and does not have any special designation. It is considered a food under the Act and is treated as a food. When it is added to a conventional food or dietary supplement "in significant amounts and has a function" it will be labeled in accordance with 21 Code of Federal Regulations 100-169. I can't provide you with any specific list of foods that might have sesame proteins in them as such a list does not exist. Manufacturers can use Generally Recognized as Safe foods or approved food additives in their product in accordance with the regulations. They are not required to provide the Food and Drug Administration's Center for Food Safety and Applied Nutrition with "lists" specific to products. To the extent possible ingredients are require to be listed so that consumers know what they are eating. The combination of ingredients under "flavors, colors and spices" is specific to minimal amounts that do not serve a "function" in the food. As described previous "function" is not a flavor or color in the food but rather deals with processing such as binding ingredients together. You can email me directly at xxx with any further questions about 21 CFR Part 101 or the Allergen Labeling Act. I can be reached by phone Tuesday through Thursday 10am to 1pm xxx or private line xxx until 4pm.
X
Center for Foo
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Posted: Jul 10th, 2008 at 09:54 am
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Here is some more sesame info:
http://www.kidswithfoodallergies.org/resourcespre.php?id=107&title=sesame_allergy
http://www.medicinenet.com/script/main/art.asp?articlekey=52926
http://www.allergicchild.com/sesame_allergy.htm
http://allergies.about.com/od/otherfoodallergies/a/sesameallergy.htm
http://www.inspection.gc.ca/english/fssa/labeti/allerg/sese.shtml
http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=182.10
http://www.immunocapinvitrosight.com/dia_templates/ImmunoCAP/Allergen____28360.aspx
http://www.ctv.ca/servlet/ArticleNews/story/CTVNews/20050902/sesame_allergies_050902/20050902/
http://www.faiusa.org/?page=seeds
http://www.allergymedsites.com/article.php?id=96&from=PS&s_doctor_id=53
http://www.anafylaxis.nl/uk_sesame
http://www.liebertonline.com/doi/abs/10.1089/pai.2005.18.177?journalCode=pai
The best paper I have read about sesame is "Sesame allergy: a growing food allergy of global proportions?" by Dr. Gangur, Caleb Kelly, and Lalitha Navuluri.
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This link has some cross-reactive info
http://download.journals.elsevierhealth.com/pdfs/journals/0091-6749/PIIS0091674901632950.pdf
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The foods most likely to cause anaphylaxis are peanuts, tree nuts, shellfish, and sesame.
Ref - Robert A. Wood, MD and Joe Kraynak, Food Allergies For Dummies (Hoboken: Wiley Publishing, Inc., 2007), p. 49.
Sesame may be one of the top five most prevalent allergies in the United States. Ref - Wood, p. 56.
« Last Edited by
Jan 11th, 2009 at 11:41 am »
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Posted: Jul 12th, 2008 at 02:26 pm
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Posted: Jul 12th, 2008 at 07:13 pm
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Good stuff, KP! Basically, anything I can't recognize I know can be a non-top 8 allergen. And even if I can recognize everything on a label, my DS reacted to Green Mountain Gringo corn chips (a piece the size of my pinky nail!) so I try to call all companies about the possibliilty of x-contam, too.
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Posted: Jul 12th, 2008 at 10:52 pm
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Jul 12th, 2008 at 07:13 pm, lakeswimr wrote:
Good stuff, KP! Basically, anything I can't recognize I know can be a non-top 8 allergen. And even if I can recognize everything on a label, my DS reacted to Green Mountain Gringo corn chips (a piece the size of my pinky nail!) so I try to call all companies about the possibliilty of x-contam, too.
Thanks Lisa!
In my opinion, the label is useful for alerting those of us dealing with a non-big8 allergy of a food we MIGHT be able to eat, but for those dealing with a severe allergy, there are too many loopholes to be able to confidently determine whether a food is safe from the label alone. I agree with you that finding companies with a good allergen policy regarding sesame is very helpful ... you were right when you said there is a huge difference in how different companies treat sesame. I wish more companies would put their allergen policies on their websites ... I wish more companies would create allergen policies. I'm thinking of starting an online list of allergen-unfriendly companies that refuse to share info  .
Whenever you get a chance, can you either post or PM me what the FDA told you about efforts to improve labeling for sesame?
Also, if you get a chance, are you interested in working on this with me ... I know you were more interested in focusing just on sesame (no hard feelings if you'd rather go that route):
(Edited to take out link for privacy reasons and some other info)
« Last Edited by
Jul 11th, 2010 at 12:01 pm »
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Posted: Jul 15th, 2008 at 09:07 pm
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Hi KP,
What I learned from the FDA is that they do not create the laws about this--they only enforce them. Only Congress can make the laws regarding this stuff. So, if we want to make any change we have to go though congress, not the FDA unless it is a matter of *interpretation* or enforcement of existing laws.
FAAN-level support would help a lot. currently FAAN isn't going to work on anything like this IMO. I could be wrong. But I wouldn't give up. I think you are looking at something *big*, though. Maybe this change can happen but it will be a long, hard thing, IMO.
I'm certainly happy to write letters in support of something like this. I would also recommend you talk with one of the members at KWFA. I am not sure if she posts there anymore as her son outgrew egg allergy but I can PM you there with her screen name. I *believe* she is one of the people who penned the current top 8 labeling law and worked to get it passed so she might be a good source of info for you.
What I still want to know is who raised the money for the other frequency studies and why FAAN is asking members to do this privately rather than paying for the sesame study themselves. I still have not heard back from the woman at KWFA who was talking with FAAN about the sesame study about this question. I had a couple other questions, too that I'm waiting to hear about.
I almost don't even care anymore! I know that even if they label for sesame I have to call companies anyway due to x-contam and hemp and amaranth allergies. But it would be nice. It would be wonderful if I could just go by labels alone.
Best wishes!
Lisa
« Last Edited by
lakeswimr
Aug 22nd, 2008 at 05:30 pm »
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Posted: Jul 16th, 2008 at 10:09 am
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Congress has already given the FDA clear authority to deal with other allergens in some areas (like the spices & flavors loophole) ... in other areas, it is a matter of interpretation but can probably be dealt with through regulation .... still other areas would need Congressional action. Some things would take years (if they ever happen) while other suggested steps could be put into place without much of a wait if the FDA had the "will" & resources to take action. It'd be great if you could PM me the name of that woman that was involved in the top 8 labeling law. I totally understand where you are coming from - being ok with calling companies ... I'll let you know when I hopefully write a draft ... maybe you can give it a quick read at that time.
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I like FAAN & they have done LOTS of great work, but their focus is & has been on the "big 8" :
1) Their educational material doesn't tell those of us with a non-big8 allergy what we need to know about avoiding those allergens:
http://allergy.hyperboards.com/index.php?action=view_topic&topic_id=4896
and they haven't corrected the mistake in this yet
http://www.foodallergy.org/downloads/wysk.pdf
2) Postition stated at the pre-FALCPA FDA public meeting:
http://www.fda.gov/ohrms/dockets/dockets/00p_1322/tr00001_02.pdf
"DR. WILCOX5: I'd like to address a
question to Ms. Munoz-Furlong. Much of the
industry discussion on good manufacturing practice
and labeling focus on the eight major allergens.
Does your organization agree that at this time
that's the appropriate focus or do you think
additional efforts also need to be placed on the
less common allergens?
MS. MUNOZ-FURLONG: My belief is that if
we focus on the eight major allergens, we've
covered 90 percent of the problem, and once we
clear that up, we should start looking in other
areas, but keep it to the eight so that we can
focus there."
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Whereas this is another view expressed by DR. JACOBSON:
"We urge the FDA to require disclosure not
just of the major eight allergens but others as
well. To someone with an allergy to corn or
carmine, it's no satisfaction that wheat and shrimp
are disclosed.
The cost and inconvenience to companies of
providing disclosure is a small price to pay for
protecting the health of sensitive consumers.
Therefore, as a general policy, the FDA
should require, not just strongly encourage, labels
to disclose allergenic ingredients in the
flavorings, colorings, and spices. Labels should
simply declare something like colors includes
carmine or natural flavoring includes peanuts, and
then in the allergy information section of the
label, the presence of the major allergens should
be highlighted.
Moving now to incidental additives. Those
are substances that are present at insignificant
levels in food and that don't serve any technical
or functional effect. Incidental additives have
never been disclose,d on labels, but in 1996, the
FDA told the food industry that such additives are
not insignificant if they might cause serious
allergic reactions and that they had to be labeled.
And that was incorporated into the FDA's
compliance policy guide earlier this year. While
incidental additives are present at low levels, and
to my knowledge have not caused known allergic
reactions, it's worth noting that the EPA recently
expressed concern about the allergenicity of
StarLink corn. It banned--it banned the presence
in food of any amount, even under 20 parts per
billion, of StarLink even without proof that it
ever caused an allergic reaction.
Today, no one is talking about banning
wheat, corn or other allergin, but only requiring
label disclosure. The FDA's policy concerning
allergenic incidental additives should be
incorporated into a regulation that states
explicitly that any incidental additive that may
cause a serious allergic reaction should be
presumed to pose a risk and be declared in
ingredient list."
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I understand the need for political compromise, but the remaining labeling deficiencies should not be neglected as they needlessly increase the risk of serious injury for those of us dealing with less common allergens.
« Last Edited by
Jan 2nd, 2009 at 01:31 pm »
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Posted: Sep 11th, 2008 at 08:52 am
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For those who would like better labeling for sesame, here is another way to have your voice heard by the FDA:
FDA accepting comments regarding Food Advisory Labeling
ETA - Thanks to all who wrote "sesame" comments!
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To all who are wondering why their comments have not been posted ...
This is the response that I got from FDA today (1/22/09) regarding comments that have not been posted:
Quote:
According to the Division of Dockets Management, comments from the type category “individual consumer†will not be posted in http://www.regulations.gov website. Therefore, if you identified the comment as “individual consumer,†the comment is not available at http://www.regulations.gov. However, all comments including “individual consumers†comments are available to the FDA staff for review.
I wanted to read all comments ... I am disappointed in this policy ...and I think it makes FDA less accountable & less responsive to the public.
--------------------------------------------------
Here is more on this policy:
http://www.fda.gov/ohrms/dockets/
Quote:
(NOTE: Documents NOT published include: copyrighted material, confidential, and individual consumer comments.)
« Last Edited by
Jan 23rd, 2009 at 10:39 am »
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Posted: Sep 20th, 2008 at 10:14 pm
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I don't know why I haven't seen this until today - unless it's because this week has been murder!
Anyhoo, I'll try to get to this tomorrow. As it happens I had two really frustrating sesame issues this week. I tell ya, this darned allergy just might be the straw to break this camel's back.
Amy
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USA
Mom to two boys:
DS #1 - Age 20, Superbad OAS
DS #2 - Age 17, PA, TNA, Soy, Sesame and Chick Pea
"Speak out against the madness." -- David Crosby
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Posted: Oct 10th, 2008 at 05:50 pm
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I have some good news. I emailed FAAN and they confirmed to me that they got the funding and have started a sesame prevalence study!
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Posted: Oct 11th, 2008 at 03:35 pm
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Wow! Thanks for posting! Oct 10th, 2008 at 05:50 pm, wrote:
I have some good news. I emailed FAAN and they confirmed to me that they got the funding and have started a sesame prevalence study!
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