Petitioning The US Food and Drug Adminstraton FDA

Add Sesame Seeds as an allergen to US Product labeling laws (Require them to be disclosed on US food labels)

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Sesame seeds were estimated to be the number 9 top allergen in the US.  By law, only the top 8 allergens need to be disclosed on food labels in the US.  

This needs to change ASAP and sesame seeds need to be added to our food labeling laws, requiring disclosure on our food labels, just like we do for nuts.

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It is estimated that about half a million people in the US have severe sesame allergies.  If you include poppy seeds, sunflower seeds and other similar seeds (like we do with "tree nuts" as a category), the numbers are much higher.  The US lags behind other countries which already require sesame disclosure on food labels, including Canada, and most countries in Europe, Israel, Australia, New Zealand, and many others.  UK study determined that, of people allergic to sesame, one in six (17%) had suffered potentially life threatening symptoms, including 65% of severe reactions on the first known exposure! 

The logic used to cut off the list after the "top 8" allergens was because one old study found that 90% of all food allergies in the US were covered by the top 8 allergens at the time.  This logic needs to be revised now for many reasons, including without limitation:  

(1) This study is severely outdated.  It was released in 2004, using data collected even before that time.  Sesame seed allergies are growing, estimated with over half a million affected people in the US alone, not counting poppy seeds, mustard seed, caraway seeds, sunflower seeds, and other seeds (much like we treat “tree nuts” as a broad category).  For comparison, there are roughly 3 million people in the US allergic to peanuts or one or more tree nuts.  The number of peanut and tree nut allergies in the US literally tripled in just 10 years, so it is reasonable to assume that a 2004 study can be vastly outdated about other allergens, like sesame, as well.  

(2) Seed allergies can be severe, leading to anaphylaxis, while the number 10-15 allergens typically cause much less severe reactions. Some people argue that if you add the number 9 allergen, then people affected with the number 10 allergen will argue that their #10 allergen should be added, and so on, causing a never ending "slippery slope".  But many of these other allergens merely cause stomach discomfort and are not life threatening.  Seed allergies can be life threatening.  Thus, it makes sense to “draw the line” at number 9 (if not later), but not stop at number 8, since allergen #9 can lead to life threatening reactions.   A UK study in 2005 determined that of people allergic to sesame, one in six (17%) had suffered potentially life threatening symptoms, including 65% of severe reactions on the first known exposure! See the additional reading items below for the citation to this research.    

(3) Sesame allergies are even more prevalent worldwide, and other countries (such as Canada, most countries in Europe, Israel, Australia and New Zealand) already require disclosure of sesame in their food labeling laws.  Sesame is the #3 allergen in Israel (above peanuts!), #3 in Canada (right on our border!), #4 in Australia, and one of the top few allergens throughout Europe and in New Zealand.  In Canada, the top 11 need to be disclosed, including both sesame seeds at number 3 and mustard seed at number 11.  Canada is also working on standardizing "may contain" or cross contamination disclosures, with even more strict requirements than what we have currently in the US, even for nuts.  We lag behind other countries, and it it time for us to become a world leader again, especially on this important safety issue.    

(4) Very, very low doses of sesame can cause serious reactions, including death.  These can be from levels as low as might be expected in mere cross contamination from the same facility.    

It is time to add sesame (supposedly the #9 food allergen in the US according to an old study, now likely even higher), to the list of food allergens that must be disclosed on all US food labels, even when merely made in a factory with, or in a facility containing, sesame seeds or sesame oil, etc. 

This issue is personal for me.  My son recently had to be rushed to the ER in an ambulance after just a couple bites of a meal from a restaurant, even though the restaurant assured us there was no sesame in his meal.  We later found out that the restaurant did not add any sesame to the meal, but they used a premade packaged sauce that had sesame oil.

Silence on a label does not mean a product is safe - and many people with severe allergies do not know this, and rely on that silence.  Most prepackaged breads, buns, rolls, bagels, and other baked goods do not say anything about sesame on the label.  Many people with sesame allergies are unaware of the law and assume that this means they are safe to eat and sesame free.  But they are not.  By law, any cross contamination of sesame currently does not need to be disclosed.  If you call any of the major bread manufacturers or packaging plants, they will almost all tell you that they use the exact same equipment to process and/or pack sesame and non-sesame versions of their products.  But they do not disclose this because they do not have to.  I have spoken with many employees at several of these companies and they all tell me the sesame seeds are pervasive and the machines are impossible to clean.  The seeds get everywhere (even in the employees' shoes!), and there are often stray seeds on the non-sesame breads.  It only takes a fraction of a seed to be life threatening.  So a person with a sesame allergy can have a life threatening reaction from eating a non-sesame seed bun that is not properly labeled!     

I don’t want my son to die from eating a hot dog bun.  As a parent of a child with serious, potentially anaphylactic allergies, I need to know if the buns or breads I’m buying were made on shared equipment with sesame seeds.  

As one mom said in the comments below (paraphrasing) "while other parents are teaching thier kids to carefully read food lables, I have to teach my kids with allergies that they cannot trust our food labels."  This is a sad but true statement in the USA.

I recommend that

     (1) sesame be added to the list of FDA regulated allergens, required to be disclosed on packaged food labels,

     (2) disclosure of cross contact / cross contamination should become mandatory, not voluntary, and

     (3) there should be more stringent regulation on restaurants with regard to food allergen disclosures and practices.

Additional reading on this issue:  

http://www.medicineonline.com/news/12/1230/Sesame-Allergies-May-Be-a-Growing-Problem.html

http://www.suntimes.com/lifestyles/23680924-423/hard-to-uncover-sesame-seeds-for-those-with-the-growing-allergy.html#.U-ebc1bWLgI   http://www.annallergy.org/article/S1081-1206(10)61181-7/pdf   http://www.livingwithout.com/issues/4_8/sesame_seed_allergy-2025-1.html   http://beta.freefromuk.com/condition/40

http://www.ncbi.nlm.nih.gov/pubmed/15787876 

http://www.foodsafetymagazine.com/magazine-archive1/december-2008january-2009/adverse-reactions-to-allergens-the-importance-of-labeling-and-cross-contamination-control/

http://www.kidswithfoodallergies.org/resourcespre.php?id=122

http://foodallergybitch.blogspot.com/2013/02/food-allergy-cross-contamination-in.html

http://www.wilmerhale.com/uploadedFiles/WilmerHale_Shared_Content/Files/Editorial/Publication/SC%20roses.pdf 

http://www.wholefoodsmarket.com/blog/shopping-food-allergies-101

http://www.fda.gov/Food/ResourcesForYou/Consumers/ucm079311.htm

http://www.foodallergy.org/cross-contact

 http://www.fda.gov/downloads/Food/GuidanceRegulation/UCM179390.pdf

http://www.loudounallergynetwork.org/label-laws.html

http://home.allergicchild.com/less-common-allergies-sesame/

http://multiplefoodallergyhelp.com/?page_id=502

http://www.canadianliving.com/health/prevention/canadas_9_most_common_food_allergies.php

http://www.shiftfrequency.com/stephanie-whiteside-peru-bans-genetically-modified-foods-for-ten-years-minimum/cartoon_fda_gmo/

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