Draft Review 1: Food Allergy Labeling

As part of my long term project (as well as a strong desire to have more eating out options) I am creating a detailed description of what people with food allergies really need to safely eat manufactured and restaurant food. Since the FDA seems incapable of getting it right I believe it’s time to take it into our own hands and create a standard. However one thing food allergies has taught me is no one person is an expert on all allergies. What works and is needed for one may be totally different for another. Because of that I think this should be a community effort.

Below I have put my first draft of a Guide for Selling to Customers with Food Allergies. I am looking for feedback and suggestions to make it complete for all allergies. What’s missing? What needs to be added? What needs more detail or less? I’m especially interested in feedback on the cleanliness and manufacturing process sections. Dealing with a corn allergy has made me sensitive to ingredients but since it wasn’t anaphylactic I’m weak on things like cross contamination in the air. Please make comments below and I’ll update the draft to be a reflection of what we all need. Just please keep in mind the following goals:

• Safety - Everything we need to keep people with allergies safe
• Simplicity - Keeping the safety goal how simple can we make it so manufacturers and restaurants aren’t too scared to even try.
• Inclusive - The rules need to be broad enough so they apply to all food allergies.

Once we have the draft sufficient to meet allergy needs I’ll be submitting it to review to some small scale food producers and/or restaurants. Once we have their feedback we can publish a final copy. I already have interest in the project from Idaho’s Bounty, a local food co-op with many small scale producers.

Thank you everyone for your help. Here is the draft:

Selling to Customers with Food Allergies

Why?

There are several excellent reasons to take the extra steps required to sell to customers with food allergies:

• Loyalty - The number one reason to care about customers with food allergies is loyalty. There is a limited selection of products that are safe for people with food allergies to eat. Experimenting and trying new products always comes with the risk of having a reaction. If you can create a safe product you will have a very loyal customer base.
• Word of Mouth Advertising – If you earn the loyalty of a food allergy customer you’ve most likely earned some free advertising. With so few options out there many people with food allergies share the safe foods they’ve found with each other. Winning over one customer can translate into many.
• Price – It can be hard for small-scale producers to compete with the price of large-scale producers. Customers with food allergies are used to having to pay a premium for quality food that meets their requirements. They will be more willing to spend extra dollars for a quality product then look for a cheaper and less safe substitute.

What’s the Big Deal?

Selling to people with food allergies is not as simple as adding a label that says no nuts. Even the smallest amount of an allergen accidentally transferred from one surface to another can be enough to cause a reaction. What is perfectly safe for most people can be deadly for others. One way to view it is someone’s allergen is the equivalent of arsenic to everyone else. If someone had just mixed arsenic in a bowl in your kitchen what would you need to feel safe eating food made there?

What’s Important?

Complete Transparency

The number one key thing people with food allergies need is knowledge. Ideally we want to be standing in your facility watching the entire process from start to finish. Since that isn’t practical we need complete transparency in the process, enough knowledge to feel like we are standing over your shoulder. It’s less important what you are doing then what you are explaining. Assume your food allergenic customer will know more about their allergy then you. If you give them enough knowledge they can tell if your food is safe.

One of the biggest dangers is when a manufacturer learns enough about allergens to think they know everything and so they try to think for the customer. For example a product labeled “Allergen Free!” because it doesn’t contain the top 8 allergens as defined by the FDA is useless for any of the many people allergic to something totally different. My daughter who was allergic to corn would have been sick all night if I’d served most “allergen free” food to her.

Cleanliness

The biggest worry after ingredients is cross contamination. It is critical that manufacturers follow strict cleaning procedures when switching from one product or flavor to another. Steps include:

• Completely cleaning all equipment and surfaces when ever switching ingredients

What to Share

To provide complete transparency customers need the following information:

Complete Ingredients List

Government regulations for ingredients lists are NOT sufficient for people with food allergies. Important elements of a complete ingredients list are:

• All ingredients listed – There is a very large loophole on ingredients lists. Foods used in the manufacturing process often do not have to be listed even if they end up in or on the food. For food allergies ingredients used in the manufacturing process count. The corn meal the bread was cooked on is an ingredient to the corn allergic person eating it. So is the oil used to shell sunflower seeds.
• No vague ingredients like spices, natural flavor, etc. - If you can’t read an ingredient and tell the exact plant it came from the list is too vague.
• Ingredients list for compound ingredients like mayonnaise, mustard, etc. - This is the same as the above point. It needs to be broken down to base plant. It matters a lot if that mayonnaise is made with soy oil, canola oil or olive oil.
• Full ingredient description – I have lost track of the number of foods I have not purchased because the ingredient list says “salt”. Is it iodized salt, kosher salt, sea salt? It may not seem like much but for someone avoiding either iodine or corn those distinctions make the difference between safe and not. If an ingredient can come with variations list which one.
• Ingredient brand or source – It matters how the ingredient manufacturer has processed the ingredient. For example using rice flour does not guarantee a food is safe for someone with a wheat allergy. It depends if the manufacturer ground that flour in the same mill as wheat. Even if you don’t know your customer may.

Manufacturing Process & Facility

After detailed ingredients the next most important step is what happens to the ingredients. Imagine again the analogy of someone working with arsenic. You would really care if they were using it in another building, another table, another bowel or the very same things that are touching your food. Details needed about manufacturing include:

• Shared equipment – What other foods are processed on the same equipment. This includes but is not limited to counter tops, grills, deep fryer, pans, mixers, etc. For each major piece of equipment like a grill or deep fryer it is important to maintain a list of all foods that come into contact.
• Cleaning procedures – When and how is equipment cleaned. Is the spoon used to stir the pecan chip cookies cleaned before being used to stir the regular cookies? How is it cleaned?
• Shared space – What other foods are made in the same area. Do you control the entire area or share it with other people? Is this a home environment, a private manufacturing facility or a shared manufacturing facility? Are there any foods that are banned from the facility.
• Special allergy precautions – Do you take any special precautions to prevent spreading general or specific allergens? For example some facilities that specialize in nut free have employees change clothing or put on protective gear before entering.

How to Say It Clearly

It would be impossible to meet the above requirements only on the ingredient label. To fully transfer the information there needs to be a two-part system. The first gives general details on the ingredient label. The second provides a source for more detailed specifics. Ideally a website with the details but alternatively an allergy information book located in the physical store or restaurant selling the product.

On the Label

The following information needs to be available on the label:

• Complete ingredient list with enough details to specify the source food. For example “citric acid from citrus”.
• Foods used in the manufacturing process. For example “May contain corn meal”
• Source of detailed information. For example “Please visit www.ourcompname.com for more details”
• Clear statements about specific allergy free claims.  Acceptable statements include:
  • Manufactured in a facility free of
  • Manufactured on a line free of
  • Tested to be free of
  • Detailed cleaning after handling ?

Detailed Allergen Information

• Contact information for asking specific questions
• Complete label information for each product produced (as described above)
• Ingredient brands or sources
• Ingredients that can be substituted or left out. (For restaurants or other custom food producers.)
• Lists of products produced on each piece of shared equipment
• Description of cleaning procedures
• Description of employee training in allergies and cleaning procedures
• Description of special allergy precautions or testing
• Description of type of manufacturing facility, in home, shared or private facility.

What Precautions are Needed

Who to Target

The previous steps will allow your customers with food allergies to know if your food is safe for them to eat. What if you want to take it one step further and actively cater to specific allergies to gain more customers? Who should you focus on?

First, the most important step is to let your customers know you are open to food allergy requests. A nice notice of “We are open to changes to meet our customers dietary needs. Please contact…” can start the dialog with your specific customers.

Second there are some allergies that are more common then others. Those include the top 8 allergens defined by the FDA:

• Dairy
• Egg
• Wheat
• Soy
• Peanuts
• Tree nuts
• Fish
• Shellfish

Many people believe several allergens are missing from that list. Other allergens that often make top lists include:

• Seseme
• Corn
• Gluten (Celiac Disease)