Understanding food allergy labeling laws and what cross contact and cross contamination really mean.

Being that my family has food allergies, the holiday season is always a strong reminder of the importance of understanding food allergy labeling laws. If you’re a food allergy family I’m sure this is something you’ve spent a great amount of time making sure you understand as well! This is also the time of year I find myself spending more time calling manufacturers to ensure the holiday foods I’m preparing are safe for my daughter.

It often surprises me when manufacturers use the terms cross contact and cross contamination incorrectly. After all, one would assume that the manufacturer has got this food allergy thing down pat (because they’re in the business of food) but it’s important to keep in mind that we need to do our due diligence as consumers as well. We first must educate ourselves on food allergy labeling laws, and put that knowledge into practice when reading labels, calling manufacturers, etc.

So this blog post really focuses on defining a few terms for everyone in hopes that it’s either a good review if you’re a seasoned food allergy family, or a good tutorial if you’re new to our community. First, let’s discuss an FDA-regulated food allergy labeling law.

FALCPA

The Food Allergen Labeling Consumer Protection Act (FALCPA) was enacted January 1, 2006. FALCPA mandates that food labels containing major food allergens (i.e. the big 8- fish, shellfish, wheat, soy, peanuts, tree nuts, milk and eggs) be called out in plain language (easily readable/understandable) and must be listed in either the ingredients statement OR in a “contains” statement. So it’s important for someone with a food allergy to any one of these foods to read BOTH sections on the label (as it’s applicable).

Additionally, if the label includes a generic descriptor such as “spices” or “natural flavors” it must list if one of them contains even trace amounts of a “big 8” allergen. If you have an allergy to a food not included in the “big 8” a bit more detective work with manufacturers may need to be done (as example- sesame seeds, mustard seeds and corn are fairly common allergens in the US that are NOT required to be labeled for).

Further, it is VOLUNTARY for a manufacturer to include a statement on their package regarding the manufacturing facility. Some manufacturers will voluntarily list that certain food allergens are processed on a shared line or in a shared facility, while others don’t list any sort of statement. It is up to the consumer to decide how they proceed with these (if they call a manufacturer to verify, if they don’t eat foods when they see a statement like this that includes their allergens, etc.)

CROSS CONTACT vs. CROSS CONTAMINATION

So this is one that I will admit used to throw me off before I considered myself an educated food allergy mom. So many people in the food allergy community (my past-self included) use the word cross contamination when discussing food allergens, when really what they’re talking about is cross contact. Let’s define them with examples below:

Cross contact: this occurs when the food protein in one food (let’s say cheese) touches another food (let’s say a burger) therefore transferring some of the food protein from one food to another (the food proteins mix). In this example, let’s assume I have a severe milk allergy. If the cheese touches the burger, it has experienced cross contact and there is a high likelihood the unsafe food protein from the cheese (my allergy) has touched the burger. Even if the cheese is removed from the burger, trace amounts of the milk protein could still be on that burger therefore making it unsafe for me (AKA risking an allergic reaction). Huge note: food proteins CANNOT be cooked out of foods.

Cross contamination: the important note here is that cross contamination is really more of a food term in general, not necessarily a food allergy term. This occurs when bacteria is unintentionally transferred from one food product to another, making it unsafe. A couple examples: you cut raw chicken on a cutting board before you put it on the grill. You then cut peppers on the same cutting board that you don’t have intent to cook. The raw chicken juice touches the peppers, therefore posing a risk for bacteria. Or, let’s say you purchase a melon that unknowingly has listeria on it. You cut it at home with a knife, and the knife slicing through the melon’s flesh transfers the bacteria into the melon, therefore making it unsafe.

I hope this helps to clear up any confusion, and navigate the food allergy waters with a bit more confidence. Feel free to reach out to me directly at meg@myfoodallergypartners.com if you want to discuss further!

Until next time,

Meg