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Specific Food Allergies > Seed Allergy

sesame seeds labeling: US specific (laws, loopholes)

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LinksEtc:
FARE
http://www.foodallergy.org

I love things like your FAAP/ECP, but unless I'm missing it, I can't find a
"How to Read a Label for a Sesame-Free Diet" or other "non top 8" diet.

http://www.foodallergy.org/document.doc?id=133


Why?


LinksEtc:
Anaphylaxis and Food Allergy Association of Minnesota (AFAA)

ID: FDA-2012-N-0711-0047


--- Quote ---Adding Additional Allergens. In addition to the traditional “8 major allergens” in the U.S. (milk, egg, wheat, soy, fish, shellfish, treenut, peanut), it behooves the FDA and the food industry to begin recognizing other allergens that are becoming increasingly common rather than keeping the list of major allergens static. (Recognizing this, other countries label for additional allergens such as mustard, sesame, and other foods.)2 For example, in the 2011 study3 among children with food allergies, strawberries and wheat and soy were equally prevalent. Deciding what additional allergens to include on U.S. labeling should be based on medical and statistical information, and possibly also including items showing increases that are likely in the future to be significant.

--- End quote ---


--- Quote ---Uncommon Allergens. Consumers allergic to foods that are not of the “major 8” are at a distinct disadvantage in determining whether manufactured food products are safe for them or not. Manufacturers should be able to provide answers to consumers about product ingredients even if labeling for those ingredients is not mandated. All consumers deserve easy-to-find company contact information and clear answers when inquiring about the safety of food.

--- End quote ---

LinksEtc:
Food Allergy Research & Education (FARE)

ID: FDA-2012-N-0711-0059


--- Quote --- Although the “major allergens” include 8 foods/food groups accounting for most of the allergic reactions affecting consumers, many persons with food allergies must avoid additional foods. It is also recognized that over 170 foods have triggered allergic reactions, including anaphylaxis caused by many foods not considered “major allergens” (e.g., seeds). Additional foods should be considered in discussions about thresholds.

--- End quote ---

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"Why isn’t Sesame a Top Allergen in the U.S.?"
Dr. Scott Sicherer
https://allergicliving.com/index.php/2013/11/13/why-isnt-sesame-a-top-allergen-in-the-u-s/

--- Quote ---Sesame allergy can be a severe and it certainly could be argued that it should be regulated. We should continue to advocate for improvements in the laws.
--- End quote ---




LinksEtc:
Hmmmm, I can't seem to find an equivalent FDA document ...

"The Canadian Criteria For The Establishment of New Priority Food Allergens"
http://www.hc-sc.gc.ca/fn-an/pubs/label-etiquet/crit/index-eng.php

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

Well, yeah ...

http://fdatransparencyblog.fda.gov/2009/06/04/the-transparency-task-forces-first-question/

--- Quote ---1) The 2005 Policy Advisor to CFSAN’s Director of the Office of Regulations and Policy stated that “We’ve got enough to deal with right now with the eight major allergens.” (Reference: Laura E. Derr, When Food is Poison: the History, Consequences, and Limitations of the Food Allergen Labeling and Consumer Protection Act of 2004, 61 FOOD & DRUG L.J. 65, 141 (2006).)
--- End quote ---





--- Quote ---October 12, 2009 at 1:36 pm Reply | Quote

I read the 6/15/09 article “New commissioner aims to open FDA’s ‘black box’”, http://findarticles.com/p/articles/mi_hb4365/is_12_42/ai_n32147623/ , where Dr. Hamburg was reported as saying “If we make more information available, there may be fewer Freedom of Information Act requests and citizen petitions”.

I am writing as a citizen who has already filed a FOIA request and is considering submitting a petition asking FDA to regulate the allergen sesame. I know FDA is not considering individual issues like the regulation of sesame here in this blog, but I am using this issue as an example of how FDA could better explain its operations, processes, and decision making.

From a scientific standpoint, it is clear that sesame should be regulated:

1) The foods most likely to cause anaphylaxis are peanuts, tree nuts, shellfish, and sesame. (Reference: Robert A. Wood, MD and Joe Kraynak, Food Allergies For Dummies (Hoboken: Wiley Publishing, Inc., 2007), p. 49.).

2) Sesame is “clearly one of the six or seven most common food allergens in the U.S.”.
(Reference: Sesame Allergies on the Rise in U.S.: Sesame Seed Allergy Now Among Most Common Food Allergies, by Charlene Laino, available at http://www.webmd.com/allergies/news/20090316/sesame-allergies-on-the-rise-in-us ).

3) The European Commission (EC) and the Canadian Food Inspection Agency both include sesame in their allergen lists. (Reference: Gangur V., Kelly C., Navuluri L. (2005). Sesame allergy: a growing food allergy of global proportions? Annals of Allergy, Asthma and Immunology. 95, 5.).

Looking in at the FDA from the outside, it appears that FDA has not decided on standardized criteria that will be used to determine when additional allergens will be regulated using the authority granted in the FALCPA. Instead, from the references below, it seems that FDA is not prioritizing the risk that different allergens pose to the public health, and is too overworked and underfunded to do so.

1) The 2005 Policy Advisor to CFSAN’s Director of the Office of Regulations and Policy stated that “We’ve got enough to deal with right now with the eight major allergens.” (Reference: Laura E. Derr, When Food is Poison: the History, Consequences, and Limitations of the Food Allergen Labeling and Consumer Protection Act of 2004, 61 FOOD & DRUG L.J. 65, 141 (2006).)

2) In the prepared remarks of Dr. Eschenbach’s March, 2008 FDLI conference speech, it is explained that there are significant problems at FDA like a lack of “planning, precision, or prioritization”, a workforce that is “aging, volatile, overextended, and equipped with inefficient tools”, and that FDA may “fail in its mission to protect and promote the health of every American”. (Reference: Andrew C. von Eschenbach, M.D (Commissioner of Food and Drugs), Prepared remarks for “The FDA Amendments Act: Reauthorization of the FDA” speech, Annual Conference of the Food and Drug Law Institute (March 26, 2008), available at http://www.fda.gov/NewsEvents/Speeches/ucm051550.htm ).

In many cases in which FDA is given authority by Congress, it would be both possible and helpful for FDA to explain to the public the criteria and decision-making processes FDA plans to use as it decided decides whether and when to use such authority.
--- End quote ---




LinksEtc:
https://www.facebook.com/KyleDineMusic/posts/10151447134802267

--- Quote ---What allergen would you like to see become a priority allergen?
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http://www.linkedin.com/groups/My-son-is-allergic-Sesame-166193.S.128673496?_mSplash=1

--- Quote ---How can we get the US Government to join Canada and the EU in recognizing this
--- End quote ---



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