As it currently stands, undeclared allergens are the number one reason for food recalls. There were already issues with labeling compliance before this.
While this supposedly doesn’t apply to the Big Eight allergens, this ignores the fact that a) there were already compliance issues, and b) numerous allergies, sensitivities, and intolerances exist beyond the Big Eight.
What FDA essentially did here was write a big check to the food industry, hoping for good faith adaptations in response to a precious supply chain.

But this is gonna just result in a different public health crisis.
I get that the supply chain is incredibly difficult, and that for smaller manufacturers with already razor-thin margins, revamping labels can be cost-prohibitive. But goddamn, manage the supply-chain issues while maintaining your duty to protect public health!
For example: what if FDA instead released labeling exemptions on a case-by-case basis after doing a risk assessment of both the supply chain and public health?
Let’s use the example they gave of flour vs. unbleached flour. That is predominantly a quality issue with minimal safety risks and a documented supply chain issue. Grant that highly specific exception, then publicize the hell out of it so consumers know.
FDA holds manufacturers to this level of scrutiny when evaluating HACCP/HARPC plans, I wish they would expect the same of themselves.
Ultimately though, FDA will never be able to do the individual exceptions or risk assessments because they are already grossly underfunded for what they are expected to do.
But that doesn’t mean we should settle. We need to advocate for better funding of public health agencies so that we can can provide thoughtful supply-chain management while protecting public health.
In short: stop funding imperialism and start funding public health

I will probably add to this thread with more thoughts later
You can follow @chromcatography.
Tip: mention @twtextapp on a Twitter thread with the keyword “unroll” to get a link to it.

Latest Threads Unrolled: