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Suggestion for FASTER Act Implementation Concerns

Food manufacturers intentionally add allergens to foods in response to FASTER. Why?
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Suggestion for FASTER Act Implementation Concerns. FDA Issues New Draft Guidance Regarding Allergen Labeling and Cross-Contact

While we are very happy the FASTER Act passed, implementation by food manufacturers continue to put food allergic consumers at risk. To that end, Dave Bloom of SnackSafely suggests aligning implementation requirements with developing research about the number and type of food allergens.

Suggestion for FASTER Act Implementation Concerns

By Dave Bloom
May 17, 2023

The US Food and Drug Administration (FDA) issued new draft guidance to FDA staff yesterday regarding allergen labeling and cross-contact. Spoiler Alert: the draft does nothing to help the food allergy community.

Instead, Sec. 555.250 Major Food Allergen Labeling and Cross-contact Draft Compliance Policy Guide guidance simply reiterates regulations established under the Food Allergen Labeling and Consumer Protection Act of 2014 (FALCPA), the Food Safety and Modernization Act (FSMA), and the FASTER Act of 2021 that took effect in January making sesame the ninth top allergen.

Does it clarify the ambiguity caused by allowing voluntary “Contains:” statements? No. Does it standardize and mandate the placement of precautionary allergen warnings like “May contain:”? No. Does it require the labeling of all ingredients instead of allowing some to be hidden under broad categories like spices or natural flavorings? No.

Does it prevent manufacturers from the abhorrent practice of adding trace amounts of an allergen like sesame or peanuts to a food product just so they can list the ingredient on the label and be freed from preventing cross-contact with that allergen in their facilities? You guessed it… No.

All-in-all, the draft guidance does nothing to move the ball forward for consumers concerned with food allergies, so chalk this up to another opportunity wasted.

Rather than continue to spin their wheels, we suggest the FDA focus on four simple changes to the current allergen labeling regime that would make shopping easier, safer, and far less confusing for the allergic community.

With the incidence of food allergies skyrocketing, the time is now.

David Bloom

Dave Bloom is CEO and "Blogger in Chief" of