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A blog about all things allergen-free and delicious

Entries in labeling laws (5)


Organic? All Natural? GMO’s? What’s Happening to Our Food?


As seen in Women's Lifestyle Magazine's April 2012 EditionRead the Full Magazine.


Photo Courtesy of Women's Lifestyle Magazine


It's Not Just About Food Allergens Anymore

When you become a Tender Foodie, you start to read labels.  As entertaining as this sounds, it is a necessary and regular exercise that helps keep people with food allergies safe.  Labeling gives us important information, and it helps build trust with manufacturers.  But as you apply this label-reading practice to your daily life, you begin to see how essential each ingredient is to your overall health.  It is as important to read what’s ON the label as it is to understand what is NOT on the label.  ‬

‪In this article, I’ll help decipher some of the labels you see every day, and then outline important events that are happening off- label, so you can better understand your choices.  It isn’t just about food allergens anymore. ‬


Organic is a labeling term that indicates that the food or other agricultural product has been produced through approved methods that integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. Synthetic fertilizers, sewage sludge, irradiation, and genetic engineering may not be used.

‪~USDA National Organic Program‬

The label “Organic” is important for the many reasons stated in the above quote.  One of the most important issues of our time, however, is that it’s one of the only ways to know that your products do not contain Genetically Modified Organisms (GMOs).  You could also get to know your farmers and vineyard owners, learn about their practices, and trust them.  It’s not scientific, but there are responsible farmers out there who grow organically, even bio-dynamically (above and beyond organic), but who do not use the USDA certification process.  We’ll get into GMOs in the next section.  ‬

‪First, let’s roll up our sleeves, get out our magic decoder rings, and review organic labeling.  ‬

‪“100% Organic” / USDA Certified Organic Seal‬

‪Only manufacturers who have met the USDA requirements and who have been certified by a licensed agent may use this claim and use the USDA Certified Organic Seal.  All agricultural aids and processing agents must be 100% organic, must not be irradiated, and may not contain GMOs, or anything (including chemicals) from the National List of Prohibited Substances.  ‬

‪“Organic” / USDA Certified Organic Seal‬

‪At least 95% of the product must be composed of certified organic agricultural products.  The remaining 5% must consist of organically produced agricultural products if commercially available. If not, the product may consist of certain non-organic agricultural ingredients or non-agricultural or synthetic ingredients listed in the regulation.  No genetically modified organisms (GMO), sewage sludge or irradiation are allowed in the remaining 5%.  ‬

‪Food producers can use the above terms (“Organic” & “100% Organic”) anywhere on the package, as long as it doesn’t interfere with other legal labeling requirements.‬

‪“Made with Organic Ingredients”‬

‪Up to 3 organic ingredients can be highlighted anywhere on the package.  This practice is often used as a marketing tool to underscore that the product contains organic ingredients.  An unlimited number of organic ingredients can be marked as such in the ingredient list.  For a food producer to use the “Made with Organic Ingredients” label, however, at least 70% of the ingredients must be certified organic.  The remaining 30% may be substances from any non-organic product produced without GMO, sewage sludge, or irradiation.  ‬

‪What Happens When a Product is Less Than 70% Organic?‬

‪If a product is made with less then 70% organic ingredients, the manufacturer is not permitted to use the term “organic” anywhere on the label, EXCEPT in the ingredient list itself (such as “organic carrots, peas, organic tomatoes”, etc.)  The USDA Certified Organic Seal may not be used.  The label must, however, identify the certifying agent, identify which ingredients are organic, and may include a statement or organic percentage in the ingredient information panel.‬


‪. . . Ah, the wild west of food marketing.  I hear people say, “But the label says that it’s All Natural?  How could that be bad?”  ‬

‪Steve Kluting, an attorney with Varnum, who focuses his practice on food industry issues, including product labeling, explains:  ‬

‪While the use of "organic" and its related terms is strictly regulated, the use of "natural" and "all natural" on food labeling is much more loosely dictated under the law.  To label a product as "natural", a food business does not have clear and straight-forward rules to comply with so, as a result, the grocery aisle is filled with "natural" products that a consumer might purchase despite that consumer having a definition of "natural" that's vastly different from the FDA, the USDA, or the food processor that labeled it.

‪In short, the FDA does not consistently define this claim, nor regulate it.  It’s policy (not law) is that natural foods contain no added color, synthetic substances or flavors, and that nothing artificial or synthetic has been included in, or added to, a food that would not normally be expected to be in food.  But what is considered “synthetic”?  High fructose corn syrup is one example of an inconsistency and is under scrutiny by a number of courts.  GMO products are also allowed with this label.‬


‪According to the USDA Economic Research Service, 90% of soy crops produced in the United States, 86% of corn and 93% of cotton are genetically modified.  About 80% of our processed foods contain GMOs (think soy lecithin, sugar from GM sugar beets, and high fructose corn syrup).   At least 30 countries (including Japan and the entire European Union) have either banned, demanded labeling, or have greatly restricted GMOs.  According to Reuters in February 2012, China, the 2nd largest corn consumer in the world, is considering approval for GMO corn for 2013.  ‬

‪The U.S. has been using GMO crops since around 1996 without any labeling.  There is also no standard definition of “Non-GMO” labeling.‬

Photo Courtesy of Women's Lifestyle Magazine
‪Petitions created by consumer and farmer groups raise important questions about the wisdom and safety of GMO crops.  In March 2012, 45 Congressmen and women and 10 Senators have recognized that GMOs are a critical issue and have prompted the FDA to look at GMOs much more closely.  ‬

‪In January of 2000, a group of 828 concerned scientists from 84 different countries have issued an open letter to all governments, urging them to immediately suspend all release of GMO crops:‬

‪We urge the US Congress to reject GM crops as both hazardous and contrary to the interest of family farmers; and to support research and development of sustainable agricultural methods that can truly benefit family farmers all over the world. ‬

‪We, the undersigned scientists, call for the immediate suspension of all environmental releases of GM crops and products, both commercially and in open field trials, for at least 5 years; … and for a comprehensive public enquiry into the future of agriculture and food security for all.

‪  ~ From an open letter to all governments Signed by 828 scientists from 84 different countries, including Majory U.S. Universities.‬

‪What is a GMO?‬

‪A GMO food contains genes replicated in a lab from other plants, animals, bacteria or even viruses that give these foods different characteristics – such as a resistance to insects, increased yield, or drought resistance.  This is not crossbreeding.  GMO crops are specifically engineered to withstand the direct application of herbicide, and /or to produce insecticide.‬
‪ ‬

‪What’s Wrong with GMOs?‬

‪Some of these new characteristics sound noble and helpful.  GMO manufacturers have made claims that genetic engineering will “feed the world”.  However, they have released new genes into our food supply without knowing how these genetic alterations would affect human, animal or farming health.  ‬

Independent, long- term studies have exposed serious health and farming concerns.  The Non-GMO Project, a non-profit organization dedicated to preserving non-GMO foods, has compiled an impressive, but frightening list of scientific research using large and small animals.  According to these studies, GMOs have caused problems with immune, reproductive, and gastrointestinal systems; and have also caused organ damage and accelerated aging in these animals.  ‬

‪In one of only a handful of human studies performed at the University of Sherbrooke Hospital in Quebec, Canada, 93% of pregnant women had traces of insecticide present in their blood, namely, the bacterial toxin, “bacillus thuringiensis”, or Bt, found in GMO Corn.   The health effects were beyond the scope of this study, but significant, none-the-less.  ‬

‪GMOs are an experiment, plain and simple.  It is not the consumer’s responsibility to prove that GMOs are safe or to put their health on the line in the name of science.  GMOs must be removed from the market and then be properly and independently tested.  Until then, we have the power to act.  We can demand labeling of GMO foods.  The FDA has until mid-April to respond to the petition to label GMO’s.   Go to to learn more.‬

‪7 Simple Actions You Can Do Now‬

‪1.    Read every label – every time‬
‪2.    Know your brands‬
‪3.    Stay away from the top GMO 8:  corn, soybeans, canola, cottonseed, sugar beets, Hawaiian papaya, yellow squash and zucchini (buy these organic, but be aware that cross-breeding between GMO & Organic can easily occur for certain crops, like corn)‬
‪4.    Go Organic whenever possible‬
‪5.    Look for the “Non-GMO Project” Seal‬
‪6.    Shop using the “Non-GMO Shopping Guide”‬
‪7.    Ask the FDA for Labeling.  Nearly one million people have sent their comments to the FDA through the “Just Label It!” campaign at  The FDA has until mid-April to respond to the petition to label GMOs.  ‬


‪The Institute for Responsible Technology (‬

‪Just Label It!  (‬
‪ ‬
‪The Non-GMO Shopping Guide  (‬)


About Elisabeth

Writer, owner of Blue Pearl Strategies, and lover of all culinary delights, Elisabeth is a Tender Foodie. She started The Tender Palate, a website for foodies with food allergies where she consults with experts from every area of the Tender Foodie life. She believes that everyone should live deliciously and have a healthy seat at the table. Find her at



INTERVIEW: Bob's Red Mill on Gluten-free Processing, Testing and GMO's


This is an interview with Cassidy Stockton, the Social Media Specialist for Bob's Red Mill.  Through the interview, she takes us behind the scenes at Bob's, and gives us insight into their practices and philosophies, and some of the challenges in the allergen-free food market.  The above video opens the door to the plant and their testing facility, so we can see how things are done.



TF:  How & Why did Bob’s Red Mill get started? 

Bob’s:  Bob's journey began in the mid 1960’s after running across a book about old, stone-grinding, flour mills.  The book really struck him.  He became so enthusiastic, in fact, that he began to search the U.S. for stone mills that were still usable.  High-speed, steel, roller mills were quickly dominating the market, so any stone mill was a rare find.  Bob is pretty persistant, so when he procured millstones from an old water-powered flour mill in North Carolina , Bob and his wife, Charlee, began their first mill in Redding, California.

In 1978, Bob and Charlee decided to pursue others interests and moved to Oregon City, Oregon. On an afternoon walk, Bob came across yet another, beautiful, old mill.  As luck would have it, the mill was for sale.  In a few months, Bob was producing stone ground flours and cereals for local customers. Word quickly spread and Bob's Oregon City based mill enjoyed much success until 1988 when a fire destroyed the building.

Bob knew he owed it to his family of employees and loyal customers to rebuild.  He spent many years growing the business to where we are today. Our current site, located in Milwaukie, Oregon is a 320,000 square foot facility covering some seventeen acres and produces thousands of products each day.  Our products are all made with the same good old-fashioned techniques our customers have come to love and trust since our beginning.



Bob's Whole Grain StoreTF:  How does Bob’s keep their GF flours truly “gluten-free” when also processing other products that contain gluten grains?

Bob’s:  Our gluten free process begins at the farm. We source from suppliers who can deliver clean, gluten free grains.  We do not use suppliers who cannot provide us with grains that are mostly clean from gluten-containing grains. Once we receive a shipment, it is tested in our on-site gluten-free laboratory for gluten before it is released into our gluten free facility. If an ingredient does not test gluten-free, it does not go into that facility. All products and ingredients are tested to be under 20 ppm.

Within our building we have two manufacturing facilities- one that is entirely gluten free and one that is for everything else. The gluten free facility has dedicated storage areas, manufacturing lines, employees, and even a separate ventilation system. Customers can learn more, here: (links to a tour of our GF facility). All gluten free products are tested when they come in (as ingredients), during and after production before being released to the public.

Our entire facility is HACCP certified, which means that we practice Good Manufacturing Practices and all of our employees are well-versed in preventing cross contact between allergens.

Link to HACCP

Link to GMPS


TF:  Do you use a particular process for cleaning machines and your facility?   If so, why did you choose this particular process?

Bob’s:  Yes, we have a full procedure for cleaning machines. All lines are cleaned between runs using air and 30 lbs of the new product is flushed through the system before packaging begins. Production is scheduled with allergens in mind so that cross contact is minimized, for example if a soy product is to be run on a line, only products containing soy are run after it.


TF:  What certification organization(s) do you use?

Bob's:  We are certified organic by Quality Assurance International and certified kosher by Kehilla Kosher. Our HACCP certification is done by Randolph Associates, Inc.


TF:  Do you source your gluten-free grains from farms that do not rotate their gluten-free crops with wheat, rye or barley? 

Bob’s:  Yes, all of our gluten free oats are grown by a farming cooperative in Canada who is committed to only growing oats. No oats can be grown on those farms within the last 3 years prior to joining the coop. Additionally, while I don’t know the exact mileage, all of those farms are located a certain distance from farms growing wheat/rye/barley or other gluten-containing grains to prevent cross contamination due to weather/ birds/etc.  


Bob's Gluten-free LogoTF:  To what ppm do you test for gluten?  Why have you chosen that particular number?

Bob’s:  We test products down to 20 ppm, which means nothing over 19 ppm goes out- period. We chose 20 ppm because we felt that was low enough for the mass majority of people and high enough for us to produce the wide variety of gluten free products that we carry. At the time, this was the standard used in Europe. People should know that while we do test to below 20 ppm, most of our products fall much lower than that.


TF:  You also process nut flours.  If someone has both gluten and nut allergies, is it safe for a nut-allergic person to eat your gluten-free flours?  What is your advice?

Bob’s:  Yes, we package hazelnut and almond meal in our gluten free facility. We do not grind these flours, as stone grinding cannot produce flour and instead turns nuts into butters. We do package those flours and as we stated above, use good manufacturing practices to prevent cross contact. We have many people with nut allergies who eat our gluten free products with no problem, but it really comes down to the comfort level of the individual. There are several companies that specialize in allergen-free and nut-free products and we recommend customers look to them if they are not comfortable with our practices.

TF:  Do you test for other top allergens? 

Bob’s:  No, we do not.


TF:  Are you considering testing for other allergens to help more people with multiple food allergies?

Bob’s:  No, there have been no plans to do so.


TF:  Why are some of your gluten-free grains, like whole grain millet, not labeled “gluten-free”?

Bob’s:  All of our gluten free grains that are tested, including millet, are labeled gluten free. Some products, such as the millet, are sold to all sorts of customers. Those products have a small symbol on the front of the package to indicate gluten free, while the products that have been specifically designed for gluten free eaters display a more prominent gluten free label. We do have some products that are inherently gluten free, such as Buckwheat Flour and Soy Flour, but are not packaged or tested to be gluten free. This typically happens when we cannot secure a supplier who can provide the commodity in a reliable, gluten free manner in a sufficient quantity for our needs.


TF:  Oats are another fairly common allergy for people with gluten allergies or celiac disease.  Do you also test for oats in your gluten-free flours?

Bob’s:  No.



TF:  While on the subject of gluten, what are Bob’s thoughts on the proposed gluten testing  & labeling law?  Do you think 20 ppm is enough? 

Bob’s:  As a leader in the gluten free industry, Bob’s Red Mill was asked in the original hearings. We fully support this labeling law and eagerly await its release. We have been very active in pushing this law through by working with our US senator, Ron Wyden. (

We support 20 ppm because we feel it is a reasonable level for most manufacturers to attain. When you start getting into 10 and 5 ppm, many companies won’t be able to meet that threshold and will not be able to produce gluten free foods.


TF:  Could you see the law going further in any area?

Bob’s:  One area that begs more consideration is regarding the use of the gluten free claim on foods that are inherently gluten free. The spirit of the law is to prevent people from putting gluten free on things such as milk and eggs- things that would not ever have gluten. However, it will cause problems for foods that are inherently gluten free, such as oats, but need to be produced in a way that makes them fully gluten free. It does not help the consumer to say that all oats are gluten free- they simply are not.

TF:  Could you clarify what the labeling law means for foods that are "inherently" gluten-free?

Bob's:  It’s kind of a tricky wording on the proposed law. It says that if a product is inherently gluten free, you must state that. So for things like Quinoa, for example, even if we go above and beyond to ensure that the product is gluten free (through sourcing, production, and testing), we’ll have to put “quinoa is inherently gluten free” on the labeling if we want to call it gluten free. What worries our company is that people might assume that all quinoa is safe for consumption because it’s "inherently gluten free", (when it could be sourced or processed with gluten grains, and is not tested for gluten). That’s just an example, by the way. It’s just scary with the foods that really do have a high chance of cross contact- like oats- and if customers are not as savvy about what something like "gluten free oats" really means, they might think that all oats are inherently gluten free, so safe to eat even if the label doesn't actually say "gluten free".

TF:  What is the most difficult thing for food manufacturers to deal with when serving people with food allergies (Tender Foodies)? 

Bob’s:  Cross contact and keeping our ingredients clean through the entire process. It’s hard when you’re trying to source grains and your suppliers don’t know enough about allergens to work with you.



TF:  I see on your web site that Bob is a big supporter of health and wellness.  In fact, he and his wife recently gave to Oregon Health and Science University.   What inspired this interest and the gift to OHSU?

Bob’s:  The donation to OHSU and the two given last year to Oregon State University and the National College of Natural Medicine are all working to create and bolster nutrition research and education. The OHSU donation is the largest and will create the Moore Family Center for Whole Grain Foods, Nutrition and Preventive Health. Bob and Charlee want nothing more than to help end childhood obesity and educate people about proper nutrition.


TF:  I also noticed that Bob’s site has a section dedicated to Autism.  I know that a gluten-free diet has helped many people with Autism.  What is Bob’s interest in this condition?

Bob’s:  Our gluten free products have always been free from dairy/casein and we started hearing from our customers about their success following a GF/CF diet to mitigate the symptoms of autism. We care about our customers, so we listened and started trying to get more involved in the autism community.


TF:  Do you have any new products coming to market, or any events coming up that you would like my readers to know about?

Bob’s:  We have a few new gluten free products coming in 2012, but we cannot divulge what they are at this time.



TF:  What is your position on GMO's?

Bob’s:  All of our products come from identity preserved seeds. This means the seed planted in the ground is non-GMO. We simply can't guarantee against cross-pollination due to natural occurrences such as wind drift, so we do not label our products GMO-free.



TF:  How can Tender Foodies help manufacturers serve them better?

Bob’s: By increasing education and awareness (in the community).


TF:  If you were to give the Tender Foodie Community one piece of advice, what would you like them to know?

Bob’s:  Be an advocate for yourself. You are your biggest ally in eating allergen-free.


My warmest thanks to Cassidy Stockton and to Bob's Red Mill for the information they provided for this interview. 



Labeling Laws: How Much Gluten is Safe to Eat?

Since the FDA re-opened the comment period on the 2007 proposed rules for gluten-free labeling, the question on everyone's mind is, "Is the allowed 20 ppm really safe?"  According to The University of Maryland's Center for Celiac Research, the safety limit ceilings out at 10 mg.  This allows quite a large amount of gluten-free labeled foods that contain the FDA's recommended allowable amount of 20 ppm during processing.  In plain English, 20 ppm allows most people with celiac disease to eat 18 slices of gluten-free bread or 9 servings of gluten-free pasta before they reach the limit of 10 mg of gluten in your food.  The Center for Celiac Research has also been studying the rise of gluten intolerances.  In addition to the 1 in 133 people with celiac disease, there are more than 18 million people have gluten sensitivities which range from mild to severe reactions. 

Read more specifics on The Center for Celiac Research's guidelines.

Lend your voice to the comments on the FDA's website

Read The Center for Celiac Research's initial reaction to the proposed law.


“This standard has been in use in Europe for almost two decades,” says Fasano, “and the science supports its adoption in the U.S.” says Alessio Fasano, M.D., director of the University of Maryland (UM) School of Medicine’s Center for Celiac Research and an internationally renowned expert on celiac disease.




FDA Wants to Hear From You About Gluten-free Labeling

Thanks to, a group of folks who built a giant cake for Congress in May of this year, the celiac community and other great organizations, The Food and Drug Administration (FDA) has re-opened the comment period for the proposed rule on the "gluten-free" labeling of foods.  This rule was originally published in 2007, but nothing has been done about it (i.e., no laws have actually been passed).  How important is this?  Very.  As the gluten-free community grows, so does the marketing of so-called "gluten-free" products.  Currently, it is up to each company to set their own standards.   Some are doing a really good job.  They go above and beyond the FDA proposed requirements of 20 ppm of gluten allowed in products after testing.  Others, however, are not. Those who have Celiac Disease or gluten allergies cannot tolerate even a trace of wheat, rye, barley or other products derived from gluten-containing grains (like soy sauce or some anti-caking agents, etc.).  We need proper labeling so that Tender Foodies in the U.S. can be sure that gluten-free labled products are being processed properly.  Gluten-free labeling could also influence the laws around other allergen labeling as well.  As the gluten-free community, and as the Tender Foodie community as a whole has grown, we have also learned.  Lend your experience and voice to this bill.  Do you think it should be more strict?  Have you had experiences with reactions to foods labeled "gluten-free"?  Do you think it is a good rule as is?  Are you super happy that this proposal is resurfacing?  Let them know.  Those with Celiac Disease comprise 1% of the population, or  1 in 133 people.  The gluten intolerance community (those with sensitivities to gluten) is expected to be around 18 million people.  Add those with a true gluten allergy, and you have a large group of folks that need to know if gluten is in their food.  If you are one of them.  Let the FDA know what you want to have happen.

Go to between now and October 3, 2011.  The docket number is FDA-2005-N-0404.


On Cookies, Cravings & Mis(taken) Labelings.

The Cravings Made Me Do It

When I started this post, I was about to extol the taste and virtues of these Dark Chocolate, Chocolate Chunk Cookies.  I was about to say how delicious and satisfying they are (and they are); and how much I admire the company who made them for going the extra mile to include multiple allergies. But when I double-checked the ingredients to be sure I was writing about them accurately, I realized why I had such a rough couple of nights after eating them.  Until then, I simply could not pinpoint the reason for my body's allergic reaction.

Before I go on, let me add that If gluten is your only allergy and you love chocolate, these cookies from Pamela's Products are some of the yummier G-free cookies out there.  Go get 'em. 

But they are not yet "dairy-free", even though the label says, "Non-Dairy".  Since I have an allergy to all dairy products, even traces of dairy can cause a reaction.  I'm embarrassed to say that my craving for chocolate coupled with the sound of the word "cookie" just drove me to the shelf without doing my usual ingredient-reading homework.  This mistake plus an FDA approved, but outdated labeling technique, led me down a path that was painful, but interesting.  So, I'm going to use this experience to discuss a few very important things:

  • Non-Dairy & Vegan vs. Dairy-free labeling
  • Why it is important to call the manufacturer if you have a clear allergic reaction to their product
  • How a responsible company/manufacturer should and did respond
  • The possibility for allergen-free product companies and factories to expand their mutual markets if they cooperate on a larger scale. 


My Conversation with Pamela's Products

Usually, I am a fastidious ingredient checker -- even if I've used a particular product before.  You never know when the manufacturer of a product might change their recipe.  Sometimes, one producer of just one ingredient could add nuts, dairy or some other allergen to their facility.  But when I picked up this box,  I let the little snack devil in my head make my decisions for me because of this label:


I was sure it wasn't the cookies that made me miserable.  But an empty box (it had been a long time since I ate a cookie) and a couple of long days later, I turned said box over just to be sure.

On the back of the box it states in smaller letters:  "ALLERGEN INFORMATION:  CONTAINS EGGS, SOY, AND MAY CONTAIN TRACES OF MILK."

I picked up the phone immediately and called Pamela's customer service department.  I was upset.  The customer service rep had their marketing director, Stephanie call me back within minutes.  We had an intelligent discussion about several things.


The Real Meaning of "Non-Dairy" & "Vegan"

"Non-dairy" means that there are no dairy ingredients listed in the product.  But the FDA does not define the term "non-dairy", each state does.  This adds complicaton for the consumer.  Also, "Non-Dairy" doesn't take into account that the product, or any ingredient in the product, could be manufactured on the same equipment that also handles an allergen like dairy.  Incidentally, neither does the label, "Vegan".  Traces of milk or any of its derivatives (casein, whey or lactose) left on equipment from another product can be quite significant.  Significant enough to cause a serious reaction.

In researching this article, I found that I am not alone in my mis-interpretation of "non-dairy".  I am allergic to gluten and all forms of dairy - with a slow onset, or IgG reaction (i.e. not an IgE or anaphylaxis) that causes one or more of the following (for me): dull to sharp stabbing pain in my head, dizziness, stuffed nose, swelling (that's attractive), abdominal pain, a digestive standstill, flu-like symptoms, anxiety, numbness and sometimes a racing heart.  These symptoms take several days or more to clear.  I probably won't end up in the hospital because of a mistake, but some people will.    

In a open letter to the FDA encouraging them to change this labeling tactic, The Food Allergy & Anaphylaxis Network (FAAN) describes another twist to the non-dairy labeling:

Many of our members have told us they have purchased “non-dairy” products for their milk-allergic children because they believed these items to be safe.  Individuals often interpret “non-dairy” to mean “no dairy” and therefore do not feel it necessary to read the ingredient statement on the back of the package. In fact, doctors often advise parents of milk-allergic children to avoid “milk”, without informing the patient/parent of technical ingredient names such as casein.  However, FAAN has learned of situations in which “non-dairy” items (such as whipped toppings, imitation cheeses, and soft-serve frozen desserts) have caused milk-allergic reactions in children because it was later discovered that the item contained a milk-derived protein.


Pamela's Products Takes Quick Action

In short, according to labeling laws, Pamela's Products was not wrong for labeling this product, "Non-Dairy".  Plus, they specialize in gluten-free products, not products for multiple allergens.   My phone call was apparently a first for Pamela's, which surprised me and yet didn't surprise me.  I've learned that people are embarrassed.  They are used to just sucking it up and moving on because they feel they "have no choice".  Or perhaps others were just smarter than I was. 

However, Pamela's recognizes that with the increase in the numbers of people with food allergies, as well as the increase in people with multple allergies - they need to evolve more ahead of their customer base.  So they immediately went to work.  Stephanie asked for my email address so she could keep me apprised of her conversations with Pamela herself and their managment team. 

Here is what they have done so far:

  • They Stopped the Presses on cookie boxes for their new "Wherever Bars" as they were being printed.  This was at no small expense.  When you see this new product (launched this spring) in stores, you will notice an asterisk (*) next to "Non-Dairy".  This is a temporary change while they consider making more changes to the box design to accommodate better labeling. Rest assured, I'll be looking to see how the change turned out.

  • They are Considering Changing Chocolate Factories.  I put them in touch with Barry-Callebaut Chocolate, a fair trade, high quality company and the only dairy-free bittersweet chocolate factory line in North America.   Callebaut also does not produce nuts or gluten products in their factory, but right now, they only test for dairy.

I appreciate the concern and action from Pamela's Products and have great respect for their immediate response.  In fact, I called them on April 8, 2011 and received these results on April 12, 2011.  They very kindly made it clear that they want to hear from their customers (so give them feedback!), so they can "strive to be the best".


An Expanding Food Allergy Market

Perhaps it is the marketer in me, but I see a huge mult-beneficial opportunity here.  If Callebaut agrees to test also for gluten and nuts, both Pamela's and Callebaut could theoretically expand their markets - possibly significantly.  

Here's some quick data for the United States alone:

  • Over 12 million Americans have some kind of diagnosed food allergy - that's 1 in 25 people (FAAN)
  • Over 3 million (1 in 133) have celiac disease (
  • Millions more have diseases that require a restricted diet (some resources say 3 million, others closer to 11 million)
  • Peanut allergies have tripled from 1997-2008 (FAAN)
  • There are 4 times more people with celiac than there were 50 years ago (March 2011, University of Maryland study)
  • 18 million people suffer from gluten-sensitivity (March 2011, University of Maryland study)
  • Many people are developing multiple allergies (data not conclusive)

More data on this expanding market is coming out every day.  My hope is that more Tender Foodies with nut, dairy and gluten allergies (and more?) can experience the products of great companies like Pamela's and Barry-Callebaut.  If my greatest wish could become true, all ingredients would be organic and non-GMO.  Eutopia would be if we could find the cause of food allergies and make them disappear.

While there are some real limiations that need to be acknowledged, something close to Eutopia could be only a few decisions away. 

Enough of us just have to ask for it.  Tell me what you think.



Recommended Reading:  The Wall Street Journal Article on the Gluten Study

How do I get tested for Celiac?