Supporting Coconut Labeling

Posted on: Tue, 01/30/2007 - 6:24pm
Greenlady's picture
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I'd like to put in an impassioned plea to the PA community as a whole to throw our collective support behind FDA's recent decision to include "coconuts" in the list of tree nuts.

Yes, at first it looks strange. I've had many conversations with DS, his teachers and other caregivers that "coconut" on the label is okay because it's not really a nut. This will cause some initial confusion.

But the FDA scientists aren't stupid. They knew when they did this it would cause controversy - I'm sure the food manufacturers are howling about this decision. FDA will have a clear scientific argument to support their decion, but more importantly, it is a good public health policy for the allergic community. It casts the net of FALCPA protection as wide as possible.

Bottom line, FDA's decision to include coconut in the list of tree nuts will have [b]only one direct effect[/b]: if a food has coconut as an ingredient, the word "coconut" will need to be on the label.

This will make the lives of children who are allergic to coconut safer. Including children of some families who are also PA.com members.

Yes, there are some possible unintended consequences that could inconvenience PA families who aren't allergic to coconut, like the impact on "Nut-Free" labeling and CYA "May contain nuts" labeling. FDA doesn't have control over either of these.

But aren't we always the ones to argue that protecting a child's life is more important than a little inconvenience? Shouldn't we model the behavior that we'd like to see from the non-allergic community?

I think that there are practical solutions that will allow coconut to be covered by FALCPA and still minimize the confusion. Hopefully, we can throw our energy behind making this descion work for everyone.

[This message has been edited by Greenlady (edited January 31, 2007).]

Posted on: Tue, 01/30/2007 - 9:19pm
BS312's picture
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"Bottom line, FDA's decision to include coconut in the list of tree nuts will have only one direct effect: if a food has coconut as an ingredient, the word "coconut" will need to be on the label." Is this accurate?
Consider this please: If a facility has no other "tree nuts" besides coconut on the premises, manufactures foods containing coconut on the same equipment, but does not have coconut as an ingredient in a product, wouldn't we expect that product to have the label "may contain tree nuts" without specifying which tree nut? People who avoid tree nuts but are not allergic to coconut would need to avoid this product unnecessarily. I would hope the warning would say "may contain coconut", but "may contain tree nut" labels do not specify walnut, cashew, etc.

Posted on: Tue, 01/30/2007 - 10:01pm
krc's picture
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Quote:Originally posted by BS312:
[b]"Bottom line, FDA's decision to include coconut in the list of tree nuts will have only one direct effect: if a food has coconut as an ingredient, the word "coconut" will need to be on the label." Is this accurate?
Consider this please: If a facility has no other "tree nuts" besides coconut on the premises, manufactures foods containing coconut on the same equipment, but does not have coconut as an ingredient in a product, wouldn't we expect that product to have the label "may contain tree nuts" without specifying which tree nut? People who avoid tree nuts but are not allergic to coconut would need to avoid this product unnecessarily. I would hope the warning would say "may contain coconut", but "may contain tree nut" labels do not specify walnut, cashew, etc.[/b]
This is what I am afraid would happen. My dd is PNA and TNA. If it says "made on the same equipment/ or same facility as Tree nuts" WE do not buy it.
We are not allergic to coconut and her allergist has said this is safe for us.
I'm afraid this new change will limit even more of the items we consider "safe" by changing the labeling to include "tree nuts" when it is in fact coconut.
I can think of a few items we use currently that have coconut oil in them.
If it will be directly labeled as coconut- GREAT! I have no problem w/ it. But if it will in fact put it under the tree nut umbrella, I am going to be making a whole lot more phone calls to manufacturers or eliminating more foods possibly.
I'm still confused as to why this was added when FOR YEARS everyone has said this was NOT a tree nut!

Posted on: Tue, 01/30/2007 - 10:08pm
2BusyBoys's picture
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Quote:Originally posted by BS312:
[b]"Bottom line, FDA's decision to include coconut in the list of tree nuts will have only one direct effect: if a food has coconut as an ingredient, the word "coconut" will need to be on the label." Is this accurate?
Consider this please: If a facility has no other "tree nuts" besides coconut on the premises, manufactures foods containing coconut on the same equipment, but does not have coconut as an ingredient in a product, wouldn't we expect that product to have the label "may contain tree nuts" without specifying which tree nut? People who avoid tree nuts but are not allergic to coconut would need to avoid this product unnecessarily. I would hope the warning would say "may contain coconut", but "may contain tree nut" labels do not specify walnut, cashew, etc.[/b]
From [url="http://www.cfsan.fda.gov/~dms/alrguid4.html"]http://www.cfsan.fda.gov/~dms/alrguid4.html[/url]
[b] #5 Does FALCPA provide any specific direction for declaring the presence of ingredients from the three food groups that are designated as "major food allergens (i.e., tree nuts, fish, and Crustacean shellfish?") [/b]
Yes. FALCPA requires that in the case of tree nuts, the specific type of nut must be declared (e.g., almonds, pecans, or walnuts). The species must be declared for fish (e.g., bass, flounder, or cod) and Crustacean shellfish (crab, lobster, or shrimp).
and
[b]#16 Does FALCPA require food manufacturers to label their products with advisory statements, such as "may contain [allergen]" or "processed in a facility that also processes [allergen]?" [/b]
No. FALCPA does not address the use of advisory labeling, including statements describing the potential presence of unintentional ingredients in food products resulting from the food manufacturing process. FALCPA does require FDA to submit a report to Congress, a part of which assesses the use of, and consumer preferences about, advisory labeling. In earlier guidance, FDA advised that advisory labeling such as "may contain [allergen]" should not be used as a substitute for adherence to current Good Manufacturing Practices (cGMPs). In addition, any advisory statement such as "may contain [allergen]" must be truthful and not misleading.
If a company chooses to use the may contain or processed in (which is not required) and chooses not identify which treenut then we will need to be vocal with that company.
[This message has been edited by 2BusyBoys (edited January 31, 2007).]

Posted on: Tue, 01/30/2007 - 10:12pm
2BusyBoys's picture
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Quote:Originally posted by Greenlady:
[b]
But aren't we always the ones to argue that protecting a child's life is more important than a little inconvenience? Shouldn't we model the behavior that we'd like to see from the non-allergic community?
I think that there are practical solutions that will allow coconut to be covered by FALCPA and still minimize the confusion. Hopefully, we can throw our energy behind making this descion work for everyone.
[This message has been edited by Greenlady (edited January 31, 2007).][/b]
Well said. Thank you!

Posted on: Tue, 01/30/2007 - 10:24pm
krc's picture
krc
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Joined: 01/16/2007 - 09:00

Quote:Originally posted by 2BusyBoys:
[b] From [url="http://www.cfsan.fda.gov/~dms/alrguid4.html"]http://www.cfsan.fda.gov/~dms/alrguid4.html[/url]
[b] #5 Does FALCPA provide any specific direction for declaring the presence of ingredients from the three food groups that are designated as "major food allergens (i.e., tree nuts, fish, and Crustacean shellfish?") [/b]
Yes. FALCPA requires that in the case of tree nuts, the specific type of nut must be declared (e.g., almonds, pecans, or walnuts). The species must be declared for fish (e.g., bass, flounder, or cod) and Crustacean shellfish (crab, lobster, or shrimp).
and
[b]#16 Does FALCPA require food manufacturers to label their products with advisory statements, such as "may contain [allergen]" or "processed in a facility that also processes [allergen]?" [/b]
No. FALCPA does not address the use of advisory labeling, including statements describing the potential presence of unintentional ingredients in food products resulting from the food manufacturing process. FALCPA does require FDA to submit a report to Congress, a part of which assesses the use of, and consumer preferences about, advisory labeling. In earlier guidance, FDA advised that advisory labeling such as "may contain [allergen]" should not be used as a substitute for adherence to current Good Manufacturing Practices (cGMPs). In addition, any advisory statement such as "may contain [allergen]" must be truthful and not misleading.
If a company chooses to use the may contain or processed in (which is not required) and chooses not identify which treenut then we will need to be vocal with that company.
[This message has been edited by 2BusyBoys (edited January 31, 2007).][/b]
Thanks 2BusyBoys! That really helps!

Posted on: Wed, 01/31/2007 - 12:03pm
PurpleCat's picture
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Joined: 01/28/2006 - 09:00

Thank you Greenlady!

Posted on: Wed, 01/31/2007 - 1:26pm
AuntAmanda's picture
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Joined: 01/20/2007 - 09:00

How do we support this?

Posted on: Wed, 01/31/2007 - 8:09pm
Greenlady's picture
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If you would like to write FDA a letter in support of their new guidance (or, to be fair, complaining about it), here is the address:
Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852.
The reference would be:
Inclusion of coconut in the list of ingredients considered "tree nuts" for purposes of section 201(qq), per question #25 in the FDA guidance document "Questions and Answers Regarding Food Allergens, including the Food Allergen Labeling and Consumer Protection Act of 2004 (Edition 4)", October 2006
(FDA writes a lot of guidance documents, so it helps the people in the docket direct your question if you write it all out).
Here's the link to the document: (it's pretty interesting reading)
[url="http://www.cfsan.fda.gov/~dms/alrguid4.html#update"]http://www.cfsan.fda.gov/~dms/alrguid4.html#update[/url]
The list of "tree nuts" is under question #25
Thanks for your support!

Posted on: Thu, 02/01/2007 - 6:11am
Carefulmom's picture
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But what 2BusyBoys posted doesn`t change what BS312 posted. According to what 2BusyBoys posted, if the item contains a tree nut it must state which tree nut. However, that does not refer to may contains like shared equipment. The company does not have to state shared equipment, but might choose to. In that case, the company can now state "warning: made on shared equipment with tree nuts" when the tree nut is actually coconut. Same thing with the optional warning of "this product is made in a plant that processes tree nuts" which does not require that the manufacturer state which tree nut. Now that tree nut can be coconut. So basically any time we see a may contain stating "may contain tree nuts" or "manufactured in equipment that processes tree nuts" or "manufactured in a plant that processes tree nuts", we will now need to call and see if it is actually only coconut. This is a big problem for me. Dd is milk allergic and pa, so at this point the majority of products are ones we cannot buy. Anything that says may contain tree nuts is off limits too. I hate to have something be off limits when the "tree nut" is actually coconut.

Posted on: Thu, 02/01/2007 - 7:22am
2BusyBoys's picture
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Joined: 09/03/2004 - 09:00

Quote:Originally posted by Carefulmom:
[b]But what 2BusyBoys posted doesn`t change what BS312 posted. According to what 2BusyBoys posted, if the item contains a tree nut it must state which tree nut. However, that does not refer to may contains like shared equipment. The company does not have to state shared equipment, but might choose to. In that case, the company can now state "warning: made on shared equipment with tree nuts" when the tree nut is actually coconut. Same thing with the optional warning of "this product is made in a plant that processes tree nuts" which does not require that the manufacturer state which tree nut. Now that tree nut can be coconut. So basically any time we see a may contain stating "may contain tree nuts" or "manufactured in equipment that processes tree nuts" or "manufactured in a plant that processes tree nuts", we will now need to call and see if it is actually only coconut. This is a big problem for me. Dd is milk allergic and pa, so at this point the majority of products are ones we cannot buy. Anything that says may contain tree nuts is off limits too. I hate to have something be off limits when the "tree nut" is actually coconut.[/b]
Right- the product would remain "off limits" if you choose not to call to clarify which type of tree nut the product may contain. But if you choose to call the company to inquire you can also let the company know how you feel about their labeling [img]http://uumor.pair.com/nutalle2/peanutallergy/smile.gif[/img]

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