<<Disclaimer: Verify this information before applying it to your situation.>> (part 2 of 2, continued from part 1)(maybe length wasn't the problem) B) Advisory labelling: I agree with the statement "FDA believes advisory labeling should not be the norm, and manufacturers should strive to eliminate the presence of allergenic materials that are not intentionally added to a specific food product." I worry that the wording "May contain traces of ...." could be used by manufacturers to protect themselves, and might eliminate potential food products that might in actuality be safe. I would prefer to see labelling as follows: wheat in all its forms clearly labelled in the ingredients list. Otherwise: "wheat free; made in a wheat-free environment" "wheat free; made on shared equipment or non-dedicated lines" "wheat free; manufactured in a facility that processes other wheat containing products." Symbols could be devised as a shorthand for this terminology. I'd like to look for the labeling statements next to or below the ingredients list. C) Labeling of Ingredients Exempted from Declaration 1) Common or Usual Names of Flavorings, Spices and Colors Natural Flavors - Our concern is mainly with the following in the FDA defined list of natural flavors (*see below): "protein hydroylsate, distillate, or any product of roasting, heating or enzymolysis that contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice." The problem is the ambiguous "vegetable" origin of these flavors. We would like this to be disclosed, in the ingredient list, with a generally applicable policy, not on a voluntary basis. Another concern is herbs and spices, also categorized as "natural flavors" ("herb, bark, bud, root, leaf, or similar plant material"), which might have flour added as anticaking agent (see incidental additives below). Just listing "natural flavors" doesn't tell us what is included. 2) Labeling of incidental additives 1) What minor ingredients would manufacturers be unlikely to recognize as containing food allergens? a)Incidental wheat from cultural practices: growing crops on the same fields where wheat was once grown, using the same trucks and manufacturing facilities. Oatmeal in this country is considered to be contaminated with wheat from these sources and should be so labelled. If there's a wheat free source of oatmeal, we would like to know about it. This may be the case for other grains, such as millet, quinoa, and others. b) Flour used for anticaking or sticking might be derived from wheat. As noted above, this can be true of many herbs and spices and mixes, where one might not expect wheat flour to be present. Or flour may be used on a conveyer belt or other equipment. Or simply processed in the same room, and therefore in the air. If so, it is a contaminant in the final product and should be labelled as such. c) Enzymes of microbial origin may have been grown on wheat containing substrates. d) One method of creating caramel color is to extract it from fermented grain by-products. e) Emulsifiers (mono and di-saccharides) might have wheat origin f) Vegetable broth might have wheat origin or thickening 2) When products that contain food allergens are further processed, is food allergen labelling sufficent? Emphatic "NO." This is a big problem. The inclusion of wheat in the intermediate products should be clearly labelled. A couple of examples: Labels for tomato paste may or not show the inclusion of wheat flour. If tomato paste is an ingredient in another product, one doesn't know if it has wheat flour added or not unless the ingredients of the tomato paste are included in parentheses (this is sometimes done). The same is true for soy sauce and soy sauce as an ingredient. 3) Should the agency codify its policy that incidental additves are not exempt from labeling and must be declared in the ingredient statement? YES, please codify the labeling to include all the minor and intermediate ingredients. Not on the agenda is the issue of testing for gluten in foods, but if there's time I'd like to speak to this issue. Thanks for your input- Mary Thorpe *"At the present time, the terms "natural flavor(s)" and "natural flavoring(s)" may include: "essential oil, oleoresin, essence of extractive, protein hydroylsate, distillate, or any product of roasting, heating or enzymolysis that contains the flavoring constituents derived from a spice, fruit or fruit juice, vegetable or vegetable juice, edible yeast, herb, bark, bud, root, leaf, or similar plant material, meat, seafood, poultry, eggs, dairy products, or fermentation products thereof, whose significant function in food is flavoring rather than nutritional"; WITHOUT DISCLOSURE OF ANY OF THOSE INGREDIENTS."