I think this is a sham and the FDA is overstepping. 0.2% of the population have sesame allergies. Maybe its higher the recent numbers I saw from a government study gave this number.
- "FDA officials indicated that allergen labeling is a “not a substitute” for preventing cross-contamination in factories."
- "some companies began adding small amounts of sesame..FDA officials said that violated the spirit, but not the letter, of federal regulations"
Hence my open ended question, how do you legally and with the spirit of the law not serve the allergy market? If you allergen labeling is not a substitute for preventing cross-contamination...what if I as a baker/factory don't care about cross contamination?
Seems like "may contain trace xxx" is a factual statement if they don't ensure otherwise.
Math doesn't check out.
> If you hosted an event of 500 people, you could expect around 10 people to have a sesame allergy.
Same.
> 65,000 [...] ~1,300
Again.
sesame: 0.7 million
FARE citation: https://www.foodallergy.org/sites/default/files/2020-06/FARE...
US Population: 341mm
341 * .002 = 0.682mm
Some rounding errors but I think math stands.