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OK, now what about the language that you often see below the ingredient listing that says something along the lines of,
"May contain __," "May contain trace amounts of __",
"Manufactured in a facility that also manufactures products containing __" - what about that kind of language? What does that mean? OK, well
that is the food manufacturer disclosing to you, the consumer, that
the food in the package might have inadvertantly have come in contact with
(fill in the blank) - wheat, eggs, peanuts, whatever it happens to be. Now
does the FDA require a food manufacturer disclose that kind of a "risk" to you? No.
OK, why not? Well
because there really shouldn't be a risk, number one. OK, and why shouldn't it be a risk? The food manufacturers are required by the FDA to
follow what are known as Good Manufacturing Practices, or GMPs. GMPs
basically deal with making sure that the food manufacturing facility is as clean as possible and making sure that the
food that is delivered to the consumer is as fresh and healthy as possible.
A food manufacturer is supposed to make sure that your food is not contaminated by anything, and "contaminated" is expanded to include ingredients
that are not actual ingredients in your product. So
technically, the FDA has already covered this for us as consumers, so that's why it's not part of FALCPA, because the truth is
accidental exposures are not really supposed to happen. But
I guess I should say the truth is that they sometimes do. So the FDA calls this "cross contact" or "cross contamination." On our website and in various
parts of this checklist you've heard us refer to this as "exposure." It's just easier to say. You know, your food has accidentally been exposed to
something that you're allergic to. OK, so how can this happen? OK I'll just give you a quick example. Let's say that your
plain chocolate candy bar is also produced in a facility where chocolate-plus-almonds candy bar is also produced.
This food manufacturer might say on the label of the plain chocolate
candy bar: "Produced on equipment that also produces products containing almonds." But
they don't have to say that! If they are following the protocol that is outlined by the FDA for keeping their facility clean, and cleaning the equipment
in between each run, you shouldn't have a problem with cross contamination or exposure, and they don't have to tell you on the label.
So it's a little bit tricky, and the best way to get comfortable with this is to
you know, do some more research on your own and see what you feel like you're comfortable with.
Since the FDA does not require a food manufacturer to disclose to you if they use some of the Top 8 food allergens in their facility,
even if it's not an ingredient in the product you are eating,
and the food manufacturer decides anyway to go ahead and disclose that information to you, we believe that that represents a real risk. It might be
that the production lines are so close together that even with the most responsible food manufacturer and the best steps in place
something could still accidentally happen. The peanut could come flying over from production line B
and accidentally land on production line A. Some of these things are just unavoidable. So it would be nice if they were avoidable
but the only way they are completely avoidable is if there are dedicated facilities where there are
none of the Top 8 food allergens in the facility that's producing your food.
Hopefully we're headed in that direction, but not all food manufacturers are quite there yet, so we would like to suggest to you that
when you find a label that discloses to you that there is a risk of exposure to your food
allergen, please don't buy that product because we believe that it probably is a true risk. So just be really careful and read
those labels, and if you have more questions - this is a big topic so we're going to give you a couple of websites to check out
so that you can do your own research. And also please do visit our checklist to learn a little bit more. We've got some direct links on our
website to the FDA so you can learn more about this really important topic because it's crucial to managing your or your child's food allergies.
Thanks.