His first reaction occurred while we were enjoying a snack of hummus and crackers. Quickly after his first bite, hives began forming all over his body. Being only 11 months old at the time, our son could not tell us what he was feeling, but his notable irritation and physical reaction were enough. We knew something was wrong. And we had a suspicion about what was causing it.
Four years later, our son was attending his last day of preschool and had just eaten a cup of ice cream. My wife received a call, letting her know that he had vomited due to what they believed was a stomach virus. Fifteen minutes later, she arrived at the school to find him continuing to vomit, but also having diarrhea, covered in hives, and starting to act incoherently. She quickly administered Benadryl and rushed him to the local Children’s hospital, where he had begun to go into anaphylactic shock. The team of doctors and nurses there promptly administered a dose of epinephrin, possibly saving his life that day.
These are only two of at least six serious allergic reactions to food my son has had in his first 10 years of life, each being traced back to a single ingredient: sesame. We have since become hyper-vigilant about understanding what foods may contain sesame and related ingredients, reading labels while standing in the grocery store aisles, and alerting family about which foods to avoid serving. He also carries an epi-pen everywhere he goes – baseball practice, the store, a friend’s house – it is a necessary burden.
But sometimes, even that is not enough. Part of the issue is that sesame can currently be labeled as obviously as “sesame oil” and the well-known “tahini,” or as benignly as “flavors” and “spices,” which you will find on hundreds of products. This makes it almost impossible to know when and where sesame could be included. In fact, we keep a watchful eye on labels for everything from panko to cookies, and salad dressing to crackers, but still cannot always be confident in our choices.
With the recent signing of the FASTER Act into law, this process should become easier for us and a little less stressful and potentially harmful for my son. This bill expands the definition of a “major food allergen” for purposes of certain food-labeling requirements to specifically include sesame. In effect, the law makes sesame the ninth major allergen here in the United States, requiring that packaging be labeled when the food contains sesame as an ingredient.
As a result, section 201(qq)(1) of the Federal Food, Drug, and Cosmetic Act will read “Milk, egg, fish (e.g., bass, flounder, or cod), Crustacean shellfish (e.g., crab, lobster, or shrimp), tree nuts (e.g., almonds, pecans, or walnuts), wheat, peanuts, soybeans, and sesame.”
For manufacturers, this means that sesame will need to be disclosed by name in the ingredient list or in a “Contains” statement starting Jan. 1, 2023, for foods that are introduced or delivered for introduction into interstate commerce. Regarding food safety, FSMA also requires a food allergen to be controlled for if it is identified as a hazard, which sesame will now be. As a result, manufacturers will also need to enact procedures, practices, and processes that minimize or prevent allergen cross-contact during the storage, handling and use of the allergen, while ensuring the finished food is properly labeled.
If you’d like to learn more, register to attend our Labeling of FDA Food Products virtual instructor-led seminar in September. Should you need more information on how to transition your labels to maintain compliance or how to minimize allergen cross-contact, please contact us at info@aibinternational.com.
Authored by Mark Crouser
Mark is the Senior Communications Manager for AIB International. Both his son and wife have tested positive for an allergy to sesame, among other food products. Their hope is that manufacturers utilize the FASTER Act as an opportunity to improve food safety, providing consumers with greater clarification on which foods are safe and offering a world of new foods for people with food allergies to enjoy.