Docket Management
Docket: 00P-1322 - Food Safety and Food Labeling; Presence and Labeling of Allergens in Food
Comment Number: EC -3

Accepted - Volume 17

Comment Record
Commentor Ms. Barbara Erb Date/Time 2001-08-08 14:47:09
Organization Ms. Barbara Erb
Category Individual

Comments for FDA General
1. What plain English terms would be understandable for the eight most common food allergens? Milk Seafood Soy Nuts Peanuts Wheat
2. What source or plain English labeling format or formats would be most informative to consumers? Are the formats from the Food Allergy Issues Alliance appropriate and sufficient? Are the recommendations in the petition from the Attorneys General of nine states warranted and beneficial? Are multiple formats confusing to consumers, and if so, is there a single format that would be preferable? If so, why? May contain [name of specific allergen] Made on shared equipment Manufactured in a facility that also processes [name of specific allergen])
3. Should source or plain English labeling be voluntary or mandatory for the eight most common food allergens? Mandatory
6. Where should advisory labeling statements be located on the food label? How prominent should advisory labeling statements be on the label? Should the location and prominence of advisory labeling statements be prescribed? In bold below, near the ingredient list.
7. Should the agency continue to address the labeling of individual allergenic flavorings, spices, and colors on a case-by-case basis, or should there be a generally applicable policy? Should the information on allergenic components of flavorings, spices, and colors be included in the ingredient list? Is there a better location or format for this information? Explain. For individual flavorings, spices, or colors that contain one of the eight most common allergens, should listing the common or usual name of the individual flavoring, spice, or color on the product labeling be voluntary or mandatory? There should be a general policy stating that the common or usual name of individual flavorings, spice, and colors be listed in the ingredient label.
8. What, if any, minor ingredients would manufacturers be unlikely to recognize as containing food allergens and therefore not include on the label, and what kinds of manufacturing processes would manufacturers be unlikely to recognize as introducing unintended food allergens? When products that contain food allergens will be further processed or repacked, is food allergen labeling sufficient on such intermediate products or is it necessary to have clearer labeling on intermediate products to ensure that food allergens are appropriately declared on the retail packaging of the final product? Should the agency codify its policy to specifically state that incidental additives that are food allergens are not exempt from labeling and must be declared in the ingredient statement on the label? Each and every ingredient should be listed individually, in plain english, on a label. My son is extremely allergic to garlic, and a friend is very allergic to cinnamon. Under current labeling, these can both be listed as 'spice', even though the allergic reaction of an individual can be deadly!

EC -3