Mandell cited further evidence that current advisory labeling does not provide useful and clear information for consumers. Almost 50 percent of food-allergic people have reported having serious problems using food labels to help them avoid eating certain foods (source: FDA). It's no wonder, as the Food Allergy and Anaphylaxis Network (FAAN) has documented over 30 different advisory warnings on food products. Mandell explained that in the absence of clear standards for advisory statements, consumers are making their own risk assessments based on the various warnings. For example, some food-allergic shoppers may incorrectly assume that one food is safer than another based on its label and accompanying advisory warning. Others may unnecessarily avoid eating a particular food due to the advisory statement. Yet others may assume that the warning is added due to liability or legal reasons and not due to real safety issues.
In his comments, Mandell commended the FDA on its commitment to develop labeling that is truthful, not misleading, clear and uniform, and that adequately informs special diet consumers; however, he explained that he strongly supports the development of consistent, risk-based guidelines for the use of advisory statements by food manufacturers. He also said that he:
Supports more stringent enforcement for manufacturers who do not comply fully with FALCPA regulations Recommends the development of a free, comprehensive consumer database of mislabeled or misleadin
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