<<Disclaimer: Verify this information before applying it to your situation.>>

The suggestion was made that we send a letter to FDA on food allergen
labeling before the August 13, 2001 meeting (Jerly Cordell, May 31,
2001).  But I can't find anything about that meeting anywhere on the FDA
website or the "Docket OOP-1322" that we are supposed to refer to in our
comments.

I definitely plan on sending comments to FDA on food allergen labeling,
but I want to read what is being considered so I can make my comments as
specific as possible. I sent the FDA food labeling office an email
asking for the proposed changes and I'll let you know if I get a
response.

All I could find is an FDA Notice to Manufacturers on label declaration
of allergenic substances.  This notice shows clearly why we need to make
detailed comments.  FDA urges voluntary labeling on allergens, including
wheat (but not gluten).  FDA tells the companies that any "significant"
quantity of an ingredient must be on the label, but there's obviously a
lot of wiggling room on what is significant.  FDA states that any
quantity that causes an allergic reaction is significant but that
specificity is not in the regs.  The notice shows that the regulations
are too weak and I think we should make specific recommendations.

I'd be happy to draft a sample letter to FDA, but I need more
information.  The sample letter to Congress sent to the list is
certainly one avenue of advocacy, but in my opinion, FDA regulations are
more important, because regs are more detailed than legislation, and
also, FDA does the enforcement.

If anybody knows how to find out what the FDA is considering at the
August 13 meeting, please tell us.

Also, we can email comments, but we've got to have the exact docket #
and title of the docket, and I can't find the number given on the email
anywhere on FDA's website.


Diane