The most underserved part of the food allergy community are the people who get life threatening reactions to foods that are not on the short list of 8 federally protected ingredients. Those most common allergens account for 90% of anaphylactic food allergies — but what should the people in that other 10% do? Most publications change the subject at that juncture, which is not much help if you or someone you know is managing one of those other life threatening food allergies.
The relevant law for top 8 food allergens is known as FALCPA in the United States. Other food allergens fall under the Food Additives Act of 1958, specifically a provision called Generally Recognized as Safe (GRAS). This is a very old law but theoretically a well written one: Congress was aware that advances in science might change medical understanding of food safety so they gave the FDA authority to update regulation as new information becomes available.
An example of the FDA using this discretion is the ingredient lupin, which is botanically related to soybeans and to peanuts. Lupin is included in the European Union’s list of protected food allergens but is less commonly used in North American foods. The FDA requires lupin to be mentioned by name on ingredient lists (either as “lupin” or “lupine”). So although this allergen does not get special warnings in large print, US residents who are allergic to lupin can look for it by name in the fine print.
A few things to bear in mind: as mentioned in a previous piece here, factory cross-contamination is another risk factor. Cross-contamination information can be difficult to obtain even for the most common allergens and is even more scarce for rare allergens. Yet the FDA’s ruling on lupin does offer a reasonable option for people who are willing to read all the fine print. Unfortunately lupin is the exception; most other food allergens might not be recognizable anywhere on the label.
The FDA classifies most of the other foods known to science as causes of life threatening anaphylactic allergies as GRAS, which means those foods could be present in products under a variety of misleading names such as natural color, natural flavors, or spices.
A different allergen that takes serious effort to avoid is maize, commonly known as corn but also present under a variety of other names such as dextrose and maltodextrin. The University of Rochester Medical Center publishes an extensive set of charts about maize-laden foods that includes such unlikely sources as vinegar, powdered sugar, and wine. Most commercial baking powder has maize, which makes many baked goods dangerous to a person who has a severe corn allergy — so raisin bread and oatmeal cookies may be off limits regardless of whether corn oil or corn meal is in the recipe. People who have this allergy may need special substitutions for many foods.
Most of the roughly 150 other foods known to science as causing anaphylaxis but not covered under FALCPA are stuck in a similar morass as maize allergy. Yes, minute quantities would cause a life threatening medical emergency in certain people — yet the FDA still deems them safe. Although consumers are often advised to contact a manufacturer with questions, results can be spotty at best.
In 2014 a food allergy parent wrote to Heinz to ask whether their ketchup’s unspecified “spices” included sesame. Sesame is not a protected allergen under US law although the laws of many other countries do cover sesame including Canada, Australia, and the EU. According to that parent Heinz wrote back demanding a letter from a physician’s office before disclosing whether their product had sesame, and also cautioning that the product formulation was subject to change at any time.
In an effort at verifying that parent’s claim I wrote to Heinz; their customer service department never replied. The Heinz website now includes the following statement:
We do not issue letters/lists regarding this subject because letters are only as good as the day they are written.
The Food Additives Act of 1958 allows manufacturers to change formulations of unspecified “spices” at any time with no further notification to the public as long as the ingredients are Generally Recognized as Safe. The same flexibility applies to unnamed “natural colors” or “natural flavors.”
So the only way a US consumer can keep reasonably safe with this type of medical condition is to avoid all food products whose ingredient lists use vague catchall phrases, then search for reliable information about other ingredient names that might conceal their allergens.
One of those hidden allergen names — for certain types of anaphylactic Oral Allergy Syndrome — is pectin. My next piece will delve into pectin.