The Problem with Precautionary Allergen Labels

We’re almost three years into our food allergy journey and while I’ve gotten good at quickly reading food labels, there’s still one thing I just don’t know what to do with. Precautionary allergen labels (PALs) including “may contain,” “made in the same facility as,” and “made on shared equipment with” are everywhere in the grocery store. And I just can’t get a straight answer on what information they actual provide. Things we do know about these statements:

• They are voluntary- just because you have peanut dust floating around your facility doesn’t mean anybody has to know about it. Companies can remove them at any time even if their facilities haven’t changed.
• There are no regulations- to me “made on shared equipment” and “may contain” sound a lot more serious than “made in the same facility as”. But, really, there’s no differentiation between the statements. They carry the same risk and shouldn’t be looked at any differently!

May contain peanuts, tree nuts, milk, and wheat! What do you do when you make these zbars? Take the oats and mix in everything you can find?

When I asked our allergist about it, she said that the statements are usually just a CYA situation that the companies take to remove the risk of accidentally causing an allergic reaction. But, people have reported reactions to foods with PAL statements and research studies have found detectable amounts of allergens in foods with precautionary labels (a study in 2013 found peanut in 8.6% of products with PALs).

The problem is, there’s no way to know the actual risk from a precautionary statement because they don’t tell us anything about the manufacturing process. Is this protein bar made right next to the peanut one? Is it made on the other end of the facility, never coming in contact with peanuts? How much is the manufacturing line cleaned between runs? PALs don’t differentiate.

Even if the statement is just to protect companies from being sued, all of the advice that I have seen from FARE, Allergic Living, the FDA, Food Allergy Canada is to avoid foods with PAL statements. As with all food allergies, it seems like better safe than sorry is the way to go. In that 2013 study, the amount of peanut varied significantly- 3 to 510 ppm. But I have no way to know what my kid's threshold is and in the end, it’s just not worth it. She can eat other safe bars while we wait to try a new brand.

Even without a "may contain" statement (remember, it's completely voluntary), there are a couple of places that are very likely to have cross contact with the Top 9 Allergens. The most common:

• Dark chocolate: even without a PAL statement, dark chocolate usually contains traces of milk because it’s made on the same lines as milk chocolate. Apparently, the equipment is hard to clean because rinsing with water can cause bacteria to grow. So if you are allergic to milk, avoid dark chocolate!
• Oats: if they aren’t specifically labeled as gluten free, typically contain gluten because of how oats and other grains are handled during processing.