The confusion people have between the two petitions is pretty widespread - in a sense, the CSPI petition is submitted and being reviewed but people signing the change dot org one may believe that is being seen by the fda when the contents need to be uploaded to the docket if they haven't already been.
I want to give concrete information on what we can do - going to get it soon! I will say the Canadian argument did not impress, the fda seems to think that it doesn't tell them what US consumers need. Because borders are magical, right?
I do like the idea of trying to get allergic families in the top 8 to understand what it is like. But I see conflict between even nut allergic folks and milk allergic ones in terms of the latter feeling the former group isn't compassionate on their plight since nut free classes exist but milk free is a harder battle.
I asked allergy eats about sesame labeling and the reply was that restaurants don't even want to disclose the top 8. Which we all know, but labeling benefits them so they can offer customers labels to review instead of potentially having to have a chef guess.
The argument for sesame labeling with the FDA is different than what I would argue to FA organizations and maybe different than I would argue to other people dealing with FAs.
To the FDA I think the argument is to address their question--how does not having it label affect people. Well, it causes anaphylaxis like it did in my child because sesame was in a food and not listed on the label. I found I had to call companies or email them to learn if foods contained sesame but couldn't get companies to give me this information. It made buying packaged and processed foods other than from a few companies that did label for sesame something that meant going without or taking a risk at the unknown. What can sesame allergic people do in this situation when companies don't have to label and won't disclose needed info?
Also at issue is the super potency of sesame. Along with peanuts and other seeds, sesame is the most potent of allergen and according to The Peanut Allergy Answer Book it takes 1000 times less sesame to cause a reaction than other allergens.
There is also the frequency issue. While the study by Mt. Sinai tagged onto the peanut study found sesame to be a somewhat low % of the population, Dr. Wood has stated that the % of sesame allergic people in his practice is higher than that and higher than a bunch in the top 8. So, CSPI could poll the allergists who already support sesame labeling to get the % of their patients who deal with sesame allergy. We could also do an informal poll at KWFA, which while not scientific, would give some indication. I believe these would show sesame allergy to be much more common than the frequency study showed.
So, the arguments are that it is super potent and that it is increasing in prevalence and prevalence on par with the top 8 (pending that info from allergists, etc), and that companies often are not aware it is an allergen and often will not disclose any information about sesame as an ingredient or potential cross contamination. (Most companies will give information about the risk of xcontam with the top 8.) When you combine all these factors, not requiring sesame to be labeled is a very dangerous situation. It's super potency means trace exposure can cause reactions. But companies are not nearly as aware of sesame as an allergen as they are of the top 8 and many still do not take precautions to keep sesame from cross contaminating other foods. And it can be in foods and not listed on labels and companies often will not give any information about this to consumers.
As for an argument for other FA people, I would just politely and positively ask for their help in supporting this new FA legislation. Give simple, easy, directions on something they can do (sign the CSPI petition) and have it be something that doesn't take much time in their busy days to do.
Seriously, I want to support this and I'm not 100% certain if I signed both or only one of the petitions and if so, which one. If even someone like me is confused the average person who would support this might not even realize all this is happening.
As for food allergy orgs, I would let them know that top allergists are not supporting this, that the FDA is listening to CSPI and is going to consider the petition and here is what they can do to help make this happen. I would let them know as soon as any one org gives a written statement that that is the case to help encourage all of them to support it as well.