The FDA Needs to Hear From PA Parents

Something very important in our quest to keep our PA kids safe will be happening next month at the Food and Drug Administration (FDA). As most parents of PA kids know, the current law regarding food labeling only requires that a company list if they have added a particular ingredient to a product (i.e. peanuts). (You can read that law here.)

Many companies label for cross contamination by letting us know if the product is processed in a facility with peanuts or on the same equipment as peanuts. This is strictly voluntary on their part. If you read a label and it does not have a cross contamination warning, it does not mean that it might not have occurred.

On September 16, the FDA is holding a hearing about developing a strategy for manufacturers to have a uniform allergy advisory labeling process.

What does this mean? On one level, it means those who do label simply need to agree on what language to use under what circumstances. As it stands now, companies put whatever they deem appropriate (if anything).

Another layer of these hearings involve the usefulness of these labels for those who read them. Here is what they say:

The 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 likely to be most effective in communicating to consumers the likelihood that an allergen may be present in a food. The agency is also interested in receiving comments about whether consumers find advisory labeling helpful for making purchasing decisions.

OK, this is where we come in. They want to know how useful these labels are. What wording is best? What will ultimately help us keep our PA kids safe?

Standing by to see what happens in these hearings is not enough for me. I wrote a letter to the FDA stating what my preferences are. Since this is not a formal letter but more of a "comment," I'm sending, I tried to make it short but to the point:

I would like to strongly encourage the FDA to adopt a policy that requires all manufacturers to label their products with an allergen warning if a food could possibly have a microscopic trace of a major allergen, such as peanuts.

I have a 3 three year old son who has a life-threatening peanut allergy. Even one of these microscopic traces of a peanut could kill him. His life depends on my ability to know if there could be a microscopic amount of a peanut in something he consumes.

The Food Allergen Labeling and Consumer Protection Act (FALCPA) that was passed is helpful in my quest to keep my son from consuming something that a manufacturer has added peanuts as an ingredient. However, this does not account for the traces that can be present in his food simply because it is processed on the same lines as a product containing peanuts or even in the same facility as peanuts, where the nut’s dust could settle onto a “peanut free” food.

As a result, if a company chooses to not label for such things, I must do further research beyond the FALCPA required label to ensure its safety for my son. This includes contacting companies and doing online research to uncover a company’s policies regarding labeling and food processing practices. This is not always easy, as many companies are not forth coming about their processing practices.

Requiring companies to label that something is processed in the same facility as peanuts would help me tremendously in my daily quest to keep my son safe. At a bare minimum, if the label could at least read whether the food is processed on the same lines as peanuts, I can assure you it would make my job protecting my son much, much easier.

Thank you for willingness to listen to a parent regarding these matters. I will be eagerly anticipating the results of these hearings.

I encourage you to let the FDA know how you feel. Many manufacturers will most likely be lobbying for less labeling since it will mean less work for them and a possible loss of business. We are our children's advocates. We need to let the FDA know how labeling practices can mean life or death for our children.

I encourage you to submit a similar comment to the FDA. Please feel free to plagiarize my letter as much as you want. It might seem a little intimidating to write the FDA but we can't be silent right now while we are on the verge of such big decisions.

*To educate yourself more fully on this issue, here is the complete document about the hearings that the FDA published last week.

*When your letter is ready for submission, you can submit your comment to the FDA here. I promise, this was super easy. Plus, I feel kinda cool knowing I wrote the FDA on Tyler's behalf!

I really hope my readers will contribute. I know everyone that reads this blog has been touched by PA in some respect. Most of you are parents and the "label readers" in your home.

If you do submit a comment to the FDA, I would love to know. Leave me a comment or send me an e-mail. We really are all on this journey together, aren't we?