In 2022, I wrote a piece for the National Provisioner (“Sesame gets called up to the majors”) about the 2021 Food Allergy Safety, Treatment, Education, and Research (FASTER) Act, in which Congress amended the Federal Food, Drug, and Cosmetic Act to require the inclusion of sesame among the list of allergens that manufacturers must identify on prepackaged food labels. For FDA-regulated foods, sesame then became one of the “Big 9” allergens.
In that article, however, I was able to report that the new law would apply only to foods regulated by FDA, and that all USDA-regulated foods were exempt — although meat companies were nevertheless permitted to declare sesame as an allergen voluntarily if they elected to do so.
Well, the times have changed. In January 2024, FSIS released a new Directive (FSIS Directive 7230.1 – Revision 3), in which FSIS now mandates that USDA-regulated food products declare sesame as an allergen on food product packaging. Sesame has thus now also become one of the “Big 9” allergens in USDA-regulated products as well.
And, the agency will be enforcing the new rule. So far this year, there have already been two recalls of USDA-regulated food products for the presence of undeclared sesame as an ingredient. FSIS has also issued one Public Health Alert this year for sesame in a product where it was not declared on the product label. Moving forward, we predict that FSIS will continue to ensure compliance by performing “Big 9” Formulation Verification tasks in regulated establishments.
Sesame allergy symptoms can vary widely from person to person, ranging from relatively mild to potentially severe. Common symptoms include skin reactions, such as hives, redness, and itchiness, and respiratory symptoms, such as coughing, wheezing, shortness of breath, nasal congestion, or a runny nose. Anaphylaxis is the most severe reaction and can be life-threatening. Symptoms of anaphylaxis include difficulty breathing, swelling of the throat and tongue, a sharp drop in blood pressure (shock), rapid pulse, dizziness, lightheadedness, or loss of consciousness. Finally, in some individuals, exposure to sesame can also cause gastrointestinal symptoms such as abdominal pain, nausea, vomiting, and even diarrhea.
So, moving forward, make sure that sesame is added to your hazard analysis and, if needed, added to your product labels. Indeed, FSIS has declared open season on sesame, and no company wants to be caught on the wrong side of a “Big 9” recall or public health alert.
