Getting Things Done with CFP
New Allergen Committee and Letter to the FDA to Look into Sesame Issue
I am a proud member of the Conference for Food Protection. It is an organization that “brings together representatives from the food industry, government, academia, and consumer organizations to identify and address emerging problems of food safety and to formulate recommendations. Though the Conference has no formal regulatory authority, it is a powerful organization that profoundly influences model laws and regulations among all government agencies and minimizes disparate interpretations and implementation.”
I attended the Conference for Food Protection Biannual Meeting in Houston April 26-29, 2023. I spoke on behalf of people with sesame allergies who are now unable to find safe bread products to eat due to the manufacturers’ addition of sesame flour to their products to get around the labeling requirements of the FASTER Act. I presented 7 issues on this topic which ended up being merged into two issues.
Throughout the conference, I interacted with several key players in the retail industry and regulatory agencies. I was told several times that the sesame issue was the talk of the conference, so there was definitely lots of awareness.
I made a connection with Mitzi Baum who is the founder and CEO of STOP Foodborne Illness, a non-profit dedicated to preventing sickness due to contaminated food. Mitzi, as a council member, was instrumental in helping to pass the issues and was a true ally. Mitzi also spoke with a representative from Walmart asking them to find bread suppliers who do not add sesame to their products. I also worked with Michelle Hill who was also a council member. Michelle was co-chair of an allergen committee who was at the conference to present the results of the committee’s prior work. Michelle worked closely with the other committee co-chair, and she was helpful to the cause as well.
I had a long talk with the Food Safety Representative from the National Restaurant Association. She told me that restaurants are also frustrated that their suppliers are changing their ingredients to contain sesame and that she would encourage restaurants to try to find suppliers that were not adding sesame. She also said that she would alert the Association about the ingredient changes so that the Person in Charge will be aware of the change when they serve a sesame allergic customer. I shared with her the story of a woman in Utah who had to go to the ER after eating at Olive Garden because she was not made aware that the once safe breadsticks now contain sesame flour.
I also had conversations with Greg Abel who works with the FDA and consults with the allergen committee. He explained that bakeries have a difficult time cleaning sesame from their lines because they cannot use water in the cleaning process. He explained that sesame seeds are very small and tend to go everywhere (including airborne) in the facilities. He had predicted that bakeries may start adding sesame to products because it would be too onerous for them to clean the facilities enough to avoid cross contact. I explained that Canada has labeled for sesame for a long time and companies there did not resort to adding sesame.
I presented my issues the first day, where they were tabled. I was then asked to attend an informal meeting that night to help hammer out language that would be acceptable to the council. We worked for about an hour or so to tweak the language.
The second day, both my issues passed. The Conference decided to do the following:
1) The Executive Committee will send a letter to the FDA requesting the acknowledgment of the practice on the part of the commercial bread industry's addition of sesame and sesame flour into bread and similar products consequence for industry to comply with FDA allergen label. FDA should work with commercial manufacturers towards additional solutions. [1]
2) Re-creation of the Allergen Committee with the following charges:
1. Provide clarification and guidance on 2022 FDA Food Code Section 3-602.11(B)(5), 3- 602.11(C)(2), related to major food allergen labeling in bulk food available for consumer selfdispensing and 3-602.12(C) informing consumers of major food allergens in unpackaged foods via written means.
2. Using existing research and resources to expand upon the "Major Food Allergen Framework" to include: a. If determined to be needed, provide continued guidance on how to control
major food allergen cross-contact, including during receiving, storage, holding, preparation (including knowledge of preparation methods), and service.
b. Identify and gather existing research and resources to form an "Allergen Control Toolkit", (which could include checklists, infographics, allergen matrix for all products, etc.) that can be used by food workers to better understand allergen control.
c. Identify and establish tools (such as SOPs, standardized menus, ingredient lists, quality assurance, etc.) to support the PIC when training food workers around notifying a Consumer about food allergens.
d. Update the document "Major Food Allergen Framework" to include the gathered information from steps a - c.
3. Recommend changes to the Food Code that support retail food establishments to operationalize framework to prevent and control food allergic reactions.
4. Examine if allergen cross contact can be defined and if so, propose a definition.
5. Create best practices and consumer messaging for when and how to disclose when major food allergens are used on shared equipment within retail establishments. Include recommendations for scenarios that include "may contain" or "made in a facility that also processes" statements and potentially addresses tolerance levels.
6. Report back findings and recommendations to the next Biennial Meeting of the Conference for Food Protection
It is likely that I will serve on the new Allergen Committee. I was told that I should be proud that both my issues passed on the first try. We are definitely raising awareness and getting things done!
[1] The bolded language represents the two issues I presented