Isn't it about establishing a framework that people can trust, and closing loopholes? Just because the specifics are about sesame seeds, isn't that how the law works? Some stupid specific case forms the groundwork for the entire system?
- "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.