Food Allergy Cross Contamination: In the Trenches

I want to write a quick follow up to the article about the FARE survey and food allergy thresholds. I assumed people knew there are unlabeled allergens in our food. Based on the article comments, however, that doesn't appear to be common knowledge.

A study done several years back by Sicherer showed that 2% of the samples they tested contained some level of milk, egg, or peanut, even though the foods did not mention them on the label at all. The reality is that, if you use manufactured foods, you have most likely used a contaminated food at some point without knowing it.

Yes, this is technically out of compliance with FALCPA. BUT (and this is an important but), the food actually has to cause a problem before the FDA will take action. That means the allergen has to be at a threshold high enough to cause a reaction, a reaction has to occur, it has to be reported, and the FDA has to decide it's important enough on which to act. Since the process can break down at any of those points, the reality is that not many food recalls happen in the real world. (The FDA is so stressed and food inspections so infrequent that the chances of a company proactively being cited are slim to none.)

We have gotten burned by cross-contaminated foods so many times over the years that I assumed this was a common experience among FA parents. I've always assumed no food is 100% guaranteed to be safe, despite the label. (That's why we used to have our son try a little of everything before we went on camping trips.)

Scratch an "old timer" like me and you'll probably find a bunch of subjective coping strategies to try to avoid cross-contamination in foods. Not all of them probably make total sense. But, I'm going to note them here because they can at least add to the discussion about how very bad U.S. food labeling laws currently are.

1. The Liquid, Creamy, Sticky Rule.

Precautionary labels ("may contain", "made in a facility", made on a shared line") are completely voluntary on the part of manufacturers. There's no consistency at all to how they're used, or whether they're used. While I don't ignore them if they're there, I also try to think beyond them and consider the product being made:

Manufactured items that start out as creams or sticky dough are more likely to be contaminated. 

Over the years, we've had two really memorable incidences of reactions from cross-contamination. One involved a sticky candy (where the QA director told me the peanut dust "hangs in the air in the factory) and the other involved a small cookie manufacturer. These experiences have caused me to be very nervous about sticky.

2. Shared Product Lines. 

Sharing a manufacturing line is not always a big deal. After all, most of the small manufacturers in our country essentially rent time on manufacturing equipment. Even many large companies shift manufacturing operations, depending on open capacity.

However, there's sometimes an issue when a company carries two brands that are manufactured on shared equipment, where one of the brands contains an allergen. Examples of this would include almond and soy milks, different flavors of soups, or milk chocolate and dark chocolate. Because the products are similar, the companies will often run one manufacturing process in the morning, and the second manufacturing process in the afternoon. While all companies give lip service to "good manufacturing practices" and clean lines, the reality may be that the new batch is poured into the line after not-good-enough cleaning.

3. Small Companies.

When my son was little, we were excited to find a wholesome cookie that listed safe ingredients for him. However, I also noticed they carried a peanut variety so I called the company. The person I talked with assured me that the lines were thoroughly cleaned between batches and there would be no issue.

There was. My son suffered a pretty dramatic reaction that time. It made me extremely wary of small companies, both because the controls on information can be so poor and because of the issue I mentioned before: they tend to rent time on lines and may cut corners on cleaning.

I see a lot of folks who complain about the labeling practices of various large manufacturers. However, there's simply less likelihood of issues with larger manufacturers because they do not switch lines as often. National brands have enough business to run the same manufacturing batches over and over. The less switching, the less risk.

4. Country of origin.

This one's always a bit of a game because it can be difficult to tell what's really going on in any country. However, consumers protections tend to go hand in hand with economic development.

I am leery of products manufactured in China or Mexico. I trust products manufactured in Canada much more than US-made items. We do use many canned imports, but since many of these products are likely processed at a dedicated facility (i.e., coconut milk), the risk seems minimal. Others I know won't use any products processed outside the U.S.

One important warning: European chocolates have an entirely different labeling standard that U.S. chocolates. We completely avoid these and I highly recommend you do as well.

I'm sure there are other useful rules (and if you'd like to share yours, please add them in the comments). It's a shame we need these at all. But, once bitten, twice shy as they say. Hopefully my rules will help someone in the future to avoid the bite of a reaction from poorly-labeled food.


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