A Lesson in Food Labeling

Hi Owl,

Okay, yeah, so. I haven't been great about writing, have I? I second your proposal for optional weekend updates, because apparently I can't even handle five days a week, let alone seven.

I am almost done with my latest (and hopefully last) elimination diet, so I will soon be back to eating normally. This means not obsessively checking every label to see if a product contains soy (protip: it probably does) and turning down any and all invitations to go out to eat pretty much anywhere. That's pretty exciting, since I haven't been able to find bread that I can eat that lasts longer than two days before molding, and I really miss toast. (And have not had the patience to make my own bread, though my wonderful mother did bake me some whole wheat challah that has been seeing me through my otherwise breadless trial.)
This diet (and all of the diets that have come before this) has been quite a learning experience. A lot of the lessons are obvious (guys, Americans really like putting additives in their food) but some of them have been less obvious (turns out that olive oil is a terrible cooking oil and there are SO MANY better options. Save your olive oil for dressings and dipping bread into, and you'll be happy.)

I wanted to share some of these lessons with you, since I'm sitting in the Starbucks cafe at Barnes and Noble and food is on my mind. (At least I can have coffee still. Thank goodness.)

Lesson 1: Allergen information is surprisingly hard to find

According to FDA regulations, most food sold in the US must be properly labelled. Generally speaking, any packaged food must come clearly labelled with the following, according to 21 CFR 101.3(a): the common name of the food, or if no common name is available, or "an appropriately descriptive term, or when the nature of the food is obvious, a fanciful name commonly used by the public for such food"; what form it comes in if applicable (whole, diced, chopped); whether or not the food is an "imitation" of another food; an information panel with nutritional information, including serving sizes, caloric content, and content and percentage of daily values for fat, sodium, carbohydrates, proteins, etc; a complete list of ingredients, with allergens clearly labelled. The whole list of rules and regulations is muuuuuuch longer and more complicated than this, of course, and includes provisions for where the labels must be placed, when to include preparation instructions, exemptions for fresh meats and dairy products, and so on.

Of course, this just covers prepackaged food. There are separate provisions for food served at restaurants, sold in vending machines, or prepared at grocery stores. Broadly speaking, the rule is that all food should be properly labeled and when a label is not applicable, such as at a restaurant, such information must be otherwise made available.

In reality, however, this is not always the case. For instance, according to the FDA website's page on the Small Business Nutrition Labeling Exemption, "one exemption, for low-volume products, applies if the person claiming the exemption employs fewer than an average of 100 full-time equivalent employees and fewer than 100,000 units of that product are sold in the United States in a 12-month period." So, if I wanted to order a pizza from Bob's Pizza Palace*, for instance, and Bob's Pizza Palace is a small, locally-owned restaurant with twenty employees, plus Bob, that delivers to a 2-mile radius in Nowhere, Indiana, Bob could apply for an exemption through the FDA and would not be obligated to provide nutritional information for his food. Moreover, the provision for restaurants that stipulates that all waitstaff must provide nutritional information when asked assumes that we live in a world where everybody a) takes their job seriously and b) realizes that terms like "vegetable oil" or "flour" are not necessarily as descriptive as they think. If I ask a waiter what my chicken is cooked in and they tell me vegetable oil, I may assume that they mean canola or rapeseed oil, which is generally the default cooking oil in the US, when in reality the chef used a mixture of sunflower oil and soybean oil. I could ask, and they might go back and check, but the potential for misinformation is still high, and if you're a shy and unassuming Midwesterner like I tend to be around strangers the chances of you even asking in the first place are, let's face it, relatively slim.

So, despite the best efforts of the FDA, it's not a foolproof system. And keep in mind, this is one area in which the US is actually doing pretty well for itself. In many other countries, the requirements for food labeling are much less stringent.

In a perfect world, every food vendor would supply a full list of ingredients for every food product they sell. This means making readily available information for every component of every item, including condiments, beverages, dairy products, flours and spices, baked goods, and prepared foods. Preferably this information would be available with little to no human interaction to minimize the possibility for miscommunication or misinformation.

There are some places that are already doing this, and they might not be the places that you expect. Oddly enough, two of the places that I have found (pretty much by accident) to be particularly accommodating are Taco Bell and McDonald's. While I don't generally look to fast food giants for health information, I was pleasantly surprised to find that both companies had information on their products readily available online. This discovery came while wandering around the mall waiting for Owl to get off of work. Finding myself incredibly hungry and without any "allowed" food in easy access, I took out my phone and began Googling allergen information for the restaurants in the food court. To my surprise, Taco Bell's website went out of their way to provide a handy chart of common allergens and a list of every item on their menu, so that consumers could easily see which of their foods had what allergens in them. This list included a legend that had symbols to demarcate the gradient of contact each menu item had with each allergen, from "contains allergen" to "prepared in common equipment", with a separate symbol for foods which contain soybean oil and a stipulation that soybean oil is not considered an allergen (though for the purposes of my particular diet it is, so I was overjoyed to see this additional note). Of course, there were virtually no menu items that were allowed on my diet available, but the list made it a lot easier to say for sure, and helped me to feel a lot less alone. In a similar vein, a little bit of Googling will get you a searchable .pdf of virtually all of McDonald's menu items with every single ingredient in them, including what they were cooked or fried in and what all sauces, condiments, and dressings contain, with common allergens listed in boldface.

I would love to see either or both of these approaches taken up by other restaurants. I don't necessarily expect this of Bob's Pizza Palace, but it's aggravating to go to Starbucks (which lists ingredients for bakery items made specifically by Starbucks, but has no information available on their beverages and stocks a great variety of non-Starbucks baked goods, such as a chocolate mousse from the Cheesecake Factory, which is known for not providing any ingredient information whatsoever) and not know what I can eat without bothering a barista who is already juggling eight other customers.



Lesson one took a lot longer to discuss than I anticipated, but it is by far the most important, and most in need of addressing. Check back next time for some more Food Knowledge, brought to you by The Hungry Raven. Next week's episode: Learning About Food Substitutes.

*This name is made up (as far as I know), but I would totally order pizza from a pizza palace.