FDA Citizen Petition

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This petition is no longer valid; it has been left online for educational purposes.

Feel free to print out and distribute to friends, support groups, health food stores, and allergists. Once completed, send to the FDA at: Dockets Management Branch, HFA-305; Food and Drug Administration; 5630 Fishers Lane, Rm 1061; Rockville, MD 20852

Please note that changes might be made to this petition, per FDA request.
Citizen Petition

The undersigned submits this petition under Title 21 Food and Drug  regulation 21CFR 101.4(a)(1) Food Designation of ingredients, and regulation 21CFR 101.22 (h)(1)(2) Spices and Natural flavors to request the commissioner of Food and Drugs to amend the above regulations.

A. Action requested

Regulation 21CFR 101.4(a)(1) Food Designation of ingredients, states: Sec. 101.4  Food designation of ingredients. Ingredients required to be declared on the label or labeling of a food, including foods that comply with standards of identity, except those ingredients exempted by Sec. 101.100, shall be listed by common or usual name in descending order of predominance by weight on either he principal display panel or the information panel in accordance with the provisions of Sec. 101.2

Regulation 21CFR 101.22(h)(1)(2) states: (h) The label of a food to which flavor is added shall declare the flavor in the statement of ingredients in the following way: (1) Spice, natural flavor, and artificial flavor may be declared as ``spice'', ``natural flavor'', or ``artificial flavor'', or any combination thereof, as the case may be. (2) An incidental additive in a food, originating in a spice or flavor used in the manufacture of the food, need not be declared in the statement of ingredients if it meets the requirements of Sec. 101.100(a)(3).

I, ___________________, suffer from food allergies, which makes it very difficult for my family and me to purchase manufactured products.

In the regulations listed above, the FDA states that spices, natural flavors, and/or artificial flavors may be listed in a vague manner. An example of this problem would be that most commercial products on the market contain ingredients such as modified food starch and/or natural flavorings. It is not possible to tell by this type of labeling what ingredients the product actually contains (such as corn, potato, or wheat, which are common allergens).  This type of labeling can have serious ramifications to an individual with food allergies, the most serious consequence being asphyxiation from undisclosed ingredients. I, along with many other individuals who suffer from food allergies, urge the FDA to require manufacturers to list all ingredients, including trace amounts. My recommendation would be simply to add a line after the words modified food starch, natural flavorings, artificial flavoring, and/or any ingredient that is not listed in a clear manner, by telling what it is derived from. An example of this would be "modified food starch (derived from wheat);" or to substitute the vague term with a more specific term. An example of this would be "modified wheat starch" instead of "modified food starch," or "garlic oil" rather than "spices."
Possible environmental impact: None known.
Possible economic impact: We believe that initially this may cause some economic strain, as manufacturers may be required to investigate more into what ingredients are present in their products. Individuals with allergies may also refrain from purchasing products that they discover, via more indepth labeling, contain their allergens.

The undersigned certifies, that, to the best knowledge and belief of the undersigned, this petition includes all information and views on which the petition relies, and that it includes representative data and information known to the petitioner which are unfavorable to the petition.


Melissa Taylor
angelfire.com/mi/FAST
Food Allergy Survivors Together Co-founder
Contacts:

Lucy Shriver
gfkitchen.server101.com
The Gluten-Free Kitchen Founder/Petition Author

Also, Melissa of FAST (listed previously).

Please add your own comments to the FDA. They are interested in your suggestions and experiences.
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This website is for personal support information only. Nothing should be construed as medical advice.