3 ms·

At this point it seems like it might be more effective to mandate the opposite: labels that indicate that the product is allergen free for X class of allergen.

by umvi 2y ago

At this point it seems like it might be more effective to mandate the opposite: labels that indicate that the product is allergen free for X class of allergen. That way the default (no label) = might contain allergens, and the presence of the label guarantees your safety. Companies that take allergen cross contamination seriously can tout the label (and win the business of the allergic), companies that don't won't resort to purposefully including allergens in their product to avoid having to overhaul their cross contamination practices.

NoMoreNicksLeft 2y ago
This makes sense from a practical standpoint, but from a litigative standpoint not having the warning label on those products with allergens exposes the company to liability. I also suspect that if there is an incident, this company might be able to have the government found liable for preventing it from warning customers.
- underseacables 2y ago
  the government found liable for preventing it from warning customers. Very interesting idea. I wonder if there is a similar situation in which the government prevented a company from alerting customers to something. The only thing I can come up with is FISA warrants.
- umvi 2y ago
  Seems to have worked for gluten, at least. i.e. Consumers look for "gluten free" labelling rather than "This product contains gluten" labelling. If I were the FDA I'd standardize the nutrition label to have a clearly labelled allergen section in which you can reliably use to check that the product is free of X allergen. Of course a naive implementation of this would mean that water bottles and stuff will have a big long list of "gluten free, peanut free, dairy free" so it probably requires a bit more thought.
  - john01dav 2y ago
    It's fine to have such long lists because the alternative is more complicated rules that might even be subjective. Clarity from subjectivity or mistakes with complicated rules is more important when safety is at risk than having less text on a label.
  - nsilvestri 2y ago
    As someone who can't eat gluten, we look for that label because gluten isn't included as one of the mandatory allergens in the US. I would prefer if things were simply labelled as "contains gluten" because instead I have to evaluate the ingredients of things without a GF label to see if it's suitable.
  - samtho 2y ago
    “Gluten free” is a little different because gluten is a protein not only found in wheat, but also wheat derivatives like spelt, semolina, graham, and other grains like barley, rye, and malt. This is different from a wheat allergy, in fact, its also not an “allergen” in the same way that peanuts are (digestive problems vs anaphylaxis), and would probably be better classified as an intolerance similar to lactose (which is covered by milk but is also an indirect indicator of lactose that can be a false positive because lactose free milk exists).
    - Miner49er 2y ago
      Gluten is an allergen for people with celiac, just not IgE-mediated. Celiac shouldn't be classified with lactose intolerance, it's much more serious, arguably more dangerous then even IgE-mediated allergies.
      - zackbrown 2y ago
        ^ This is correct. > (digestive problems vs anaphylaxis) ... and would probably be better classified as an intolerance similar to lactose is misinformation — "digestive problems" and "intolerance" drastically understate the seriousness of celiac disease, and contribute to the educational challenges surrounding the condition. The chronic impact of gluten exposure to a celiac patient include: permanent damage to the small intestine, malnutrition, reduction of lifespan, and significantly increased risk of comorbid autoimmune diseases (MS, diabetes, and more) and cancer. The acute symptoms span from gastrointestinal symptoms to neurological issues, systemic pain, and cognitive impairment. The reason for all of this is gluten causes the celiac patient's immune system to mobilize and attack the patient, i.e. "autoimmunity." Not anaphylactic, correct, but not a digestive problem nor an intolerance.
Miner49er 2y ago
It's an interesting idea, but the end result would probably be less options for people with allergies (unless they risk foods that appear to be safe, but lack the label.) We already have this type of labelling for gluten free foods, and one common complaint in the celiac community is that gluten should also be a major allergen. This would help greatly in deciding if a product is safe for people with celiac, since many products are but manufacturers don't bother putting GF labels on them.
- zackbrown 2y ago
  > one common complaint in the celiac community is that gluten should also be a major allergen As a point of interest, most of the developed world already requires labeling gluten as a major allergen. The US is the outlier / laggard.
forgetfreeman 2y ago
This position makes perfect sense in a setting where there's broad competition and incumbents that put quality of product ahead of shareholder value. I don't feel like current market conditions meet either of those criteria so you'd in effect just be giving manufacturers an out at the expense of folks with allergies.
Asooka 2y ago
The whole problem is that putting any sesame in might kill somebody with a severe enough allergy. There should be some gradation to the labelling, because "contains absolutely no sesame" is extremely hard at industrial scale, but "certified to contain less than Xg of sesame per 1kg of product" would be pretty easy to test and still useful for people who don't die from ingesting a single grain.

by umvi 2y ago

NoMoreNicksLeft 2y ago

This makes sense from a practical standpoint, but from a litigative standpoint not having the warning label on those products with allergens exposes the company to liability. I also suspect that if there is an incident, this company might be able to have the government found liable for preventing it from warning customers.

underseacables 2y ago
the government found liable for preventing it from warning customers. Very interesting idea. I wonder if there is a similar situation in which the government prevented a company from alerting customers to something. The only thing I can come up with is FISA warrants.
umvi 2y ago
Seems to have worked for gluten, at least. i.e. Consumers look for "gluten free" labelling rather than "This product contains gluten" labelling. If I were the FDA I'd standardize the nutrition label to have a clearly labelled allergen section in which you can reliably use to check that the product is free of X allergen. Of course a naive implementation of this would mean that water bottles and stuff will have a big long list of "gluten free, peanut free, dairy free" so it probably requires a bit more thought.
- john01dav 2y ago
  It's fine to have such long lists because the alternative is more complicated rules that might even be subjective. Clarity from subjectivity or mistakes with complicated rules is more important when safety is at risk than having less text on a label.
- nsilvestri 2y ago
  As someone who can't eat gluten, we look for that label because gluten isn't included as one of the mandatory allergens in the US. I would prefer if things were simply labelled as "contains gluten" because instead I have to evaluate the ingredients of things without a GF label to see if it's suitable.
- samtho 2y ago
  “Gluten free” is a little different because gluten is a protein not only found in wheat, but also wheat derivatives like spelt, semolina, graham, and other grains like barley, rye, and malt. This is different from a wheat allergy, in fact, its also not an “allergen” in the same way that peanuts are (digestive problems vs anaphylaxis), and would probably be better classified as an intolerance similar to lactose (which is covered by milk but is also an indirect indicator of lactose that can be a false positive because lactose free milk exists).
  - Miner49er 2y ago
    Gluten is an allergen for people with celiac, just not IgE-mediated. Celiac shouldn't be classified with lactose intolerance, it's much more serious, arguably more dangerous then even IgE-mediated allergies.
    - zackbrown 2y ago
      ^ This is correct. > (digestive problems vs anaphylaxis) ... and would probably be better classified as an intolerance similar to lactose is misinformation — "digestive problems" and "intolerance" drastically understate the seriousness of celiac disease, and contribute to the educational challenges surrounding the condition. The chronic impact of gluten exposure to a celiac patient include: permanent damage to the small intestine, malnutrition, reduction of lifespan, and significantly increased risk of comorbid autoimmune diseases (MS, diabetes, and more) and cancer. The acute symptoms span from gastrointestinal symptoms to neurological issues, systemic pain, and cognitive impairment. The reason for all of this is gluten causes the celiac patient's immune system to mobilize and attack the patient, i.e. "autoimmunity." Not anaphylactic, correct, but not a digestive problem nor an intolerance.

Miner49er 2y ago

It's an interesting idea, but the end result would probably be less options for people with allergies (unless they risk foods that appear to be safe, but lack the label.) We already have this type of labelling for gluten free foods, and one common complaint in the celiac community is that gluten should also be a major allergen. This would help greatly in deciding if a product is safe for people with celiac, since many products are but manufacturers don't bother putting GF labels on them.

zackbrown 2y ago
> one common complaint in the celiac community is that gluten should also be a major allergen As a point of interest, most of the developed world already requires labeling gluten as a major allergen. The US is the outlier / laggard.

forgetfreeman 2y ago

This position makes perfect sense in a setting where there's broad competition and incumbents that put quality of product ahead of shareholder value. I don't feel like current market conditions meet either of those criteria so you'd in effect just be giving manufacturers an out at the expense of folks with allergies.

Asooka 2y ago

The whole problem is that putting any sesame in might kill somebody with a severe enough allergy. There should be some gradation to the labelling, because "contains absolutely no sesame" is extremely hard at industrial scale, but "certified to contain less than Xg of sesame per 1kg of product" would be pretty easy to test and still useful for people who don't die from ingesting a single grain.