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Shocked After Modified Food Starch Comment
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Ok, just when I think I have this thing figured out!!!!  I just called the Atkins hotline since I had bought some frozen dinners for my daughter.  No gluten ingredients listed but I just wanted to make sure since I had the horrible experience with Campbell's hiding barley in their 2% of "secret recipe".  The lady answered and said no, they were not gluten free because of the modified food starch.  She told me she herself had celiac.  I told her that in all the info, MFS in America has to be declared if it was wheat and should be on the label.  It was not.  She immediately told me that yes for the FDA but not the USDA. They do not have to declare it. So apparently the meat must have it?  She told me that she herself did not learn that until starting to work for Atkins.  Does anyone know if this is true? I am stunned.  For a whole year, I have thought I was keeping her safe.

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How do you know if a food contains a major allergen?

All food products containing two or more ingredients are required by Federal regulations to bear an ingredients statement listing all ingredients by common or usual name in descending order of predominance. In addition, on January 1, 2006, FALCPA), passed by Congress in 2004, became effective. The FALCPA applies only to consumer packaged foods regulated by the Food and Drug Administration (FDA). FDA regulates all foods except meat, poultry, and egg products, which are regulated by the Food Safety and Inspection Service (FSIS).

Wheat is an allergen as a result it must be listed. It cannot be hidden what so ever.

 

From the USDA website:

http://www.fsis.usda.gov/Fact_Sheets/Allergies_and_Food_Safety/index.asp#9

 

Meat does not have gluten (unless of course it is breaded or what have you).

 

Does the Food Allergens Labeling and Consumer Protection Act (FALCPA) apply to meat, poultry, and egg products under FSIS jurisdiction?

No. The FALCPA passed by Congress did not amend or implement regulations and policies for meat, poultry, and egg products in the acts related to them: the Federal Meat Inspection Act (FMIA), the Poultry Products Inspection Act (PPIA), and the Egg Products Inspection Act (EPIA). FSIS encourages the use of allergen statements, consistent with FALCPA, and other statements that highlight the presence or absence of ingredients of public health concern; particularly the "big eight" allergens. FSIS will consider rulemaking to require allergen statements if it does not continue to observe, through its prior label approval system, widespread voluntary compliance with the use of allergen statements on meat, poultry, and egg product labels. The Agency's compliance policy guide on the use of allergens statements can be found at http://www.fsis.usda.gov/Regulations_&_Policies/

Labeling_Allergens/index.asp.

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She immediately told me that yes for the FDA but not the USDA. They do not have to declare it.

 

Yes, this is a very little known loophole from USDA that the food manufacturers love to exploit, when they think it is in their favor. I looked at the ingredients lists for several of the Atkins frozen meals, and they had the word "flavorings,"  such as "modified starch product, ingredients dah, dah, dah, etc, flavorings." listed as a separate ingredient. 

 

Remember, in the United States, "flavorings" or "natural flavorings" can be made out of anything. 

 

Example, the Atkins frozen Beef Merlot has broccoli, seasoned cooked beef and "modified food starch product" (beef, water, modified food starch, salt, flavorings ) water, canola oil, onion, ....  etc

and there are "flavors" or "flavorings" mentioned several other times on this list of ingredients.   http://www.atkins.com//Products/Frozen-Meals/Atkins-Frozen-Meals/Lunch---Dinner/Beef-Merlot.aspx

 

Even this list for the Crustless Chicken Pot Pie, which only has the warnings "contains milk,soy"  has the word "flavorings" as the next to last ingredient.   http://www.atkins.com//Products/Frozen-Meals/Atkins-Frozen-Meals/Lunch---Dinner/Crustless-Chicken-Pot-Pie.aspx

 

Also seeing "natural flavorings" listed on the Roasted Turkey Tenders with Herb Pan Gravy, along with "flavorings" listed in the "turkey base" ingredient subgroup.

 

Here's the USDA faq  on "natural flavorings." link:   http://www.fsis.usda.gov/help/faqs_flavorings/index.asp

 

You will see that they talk about spices, spice extracts, essential oil, oleoresins, vegetable powders.  Substances derived from MEATS have to be labeled.  MSG (monosodium glutamate)  has to be labeled most of the time, but there is another loophole for that, if a food is naturally high in MSG proteins (free glutamate) it doesn't have to be labeled.  Hydrolyzed animal or vegetable proteins are supposed to be identified by source.  Autolyzed yeast is supposed to be identified.

 

You will notice there is one category missing in the USDA list of things they "care" about in ingredients added to meat for product labeling. That's the modified food starch.  That is because, technically, a starch is not a protein, and is, in theory, not containing the protein. Because it is so highly processed that the protein is not supposed to be there.   Voila !   WE HAVE THE LOOPHOLE. :ph34r:  "Starch" doesn't come from animals with a central nervous system and a pulse, proteins do, so the USDA official attitude is, "not ours to worry about, FDA, it's yours if you want it."   FDA says, "we don't do meat. we're really busy.  See the USDA."   USDA: "we're busy. this is voluntary. we believe it's adequate."  

 

Celiacs and Gluten Intolerants = screwed !  & at the mercy of those companies which are vigilant about their voluntary standards. Be nice to those who do fully disclose hidden proteins on labels. 

 

And this is one of the reasons why the bad food labelers got upset about that CA proposition 37, because it had a clause about not allowing the generic "natural flavorings" anymore. That certainly would have put a crimp in somebody's practices. 

 

I've had some interesting discussions with people on the internet who swear up and down this can't be so, the USDA would never be so mean to us consumers, as to omit an entire category.  Guess again.  :rolleyes:

 

__

I thought I had better add, to the above, that it is possible that proteins can come from vegetable and nut sources as well as from meat, and did not mean to imply that they can only come from meat.  But this is about whether or not the USDA rules care if they are in the same package as the meat, so they would require a manufacturer to disclose it. 

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If modified food starch contained wheat, it would have to say modified food starch (wheat).  Most all food starch in the US is derived from corn but wheat can still be used. Then you would see the wording as above.  I have seen a few instances where imported food contained starch with wheat and it was labeled as such.

 

Natural flavorings are so low on the radar for gluten, it is not considered unsafe for Celiacs. There may be instances of barley malt used in flavorings but that is rare and usually will be labeled as barley malt under the ingredients list.

 

I would think it wise to not eat a product that was not labeled gluten free but no gluten ingredients, especially if it were a processed meat dish. There is probably no gluten in the food but processed meat stuff is kind of risky.  If it takes this much effort to figure it out, I bag it.  But modified food starch has to label wheat in the US if it's there.

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Sigh.  Not if it is the USDA "rules" they claim to be using.  "Loophole."  Barley not on the official allergens list. So nobody has to list this if it is a barley derived natural flavoring. Barley's got gluten.  Sorry.  Claiming barley is scarce when this nation brews so much beer from it...  not really.  

 

Can't wait until we get stuck with the new rules, possibly Codex wheat starch crap being imported, and a few manufacturers/packagers/distributors will try to get away with labeling it "gluten free," people will react, will be told it's not possible, and more fun will ensue.   

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Despite all the hand wringing and fear, I have not seen a verified case of modified food starch actually being derived from a gluten grain in almost thirteen years on the gluten-free diet. It is just not something that I worry about.

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Despite all the hand wringing and fear, I have not seen a verified case of modified food starch actually being derived from a gluten grain in almost thirteen years on the gluten-free diet. It is just not something that I worry about.

 

I agree, Peter.  I have never run across any barley in natural flavoring in 8 years gluten-free.  Even in candies where barley may be used as a sweetener, it's never in natural flavorings and always listed in the ingredients.  Beer is something where barley may be used but any reputable beer manufacturer who is brewing gluten-free beer does not use barley. There was an exception I saw with a new gluten-free beer and supposedly they distill/refine it to the point where the barley content is minimal but my husband passed on that one.  But they did label the beer in detail about the process.

 

I always feel that if you want to not eat something with modified food starch out of fear of wheat being in there and not declared, that's fine.  But you cannot argue that point correctly when people give good evidence that natural flavors and food starch are not a concern in the US or Canada.  Even most Celiac foundations that I have checked into view these products as safe.

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I would be cautious in accepting 'modified food starch' as an ingredient listing in foods that are imported as there is no regulation requiring them to list allergens.  It is encouraged but not required.  At least in Canada.  Furthermore, in the recommendations of listing possible allergens, wheat is listed but not barley and rye.  I stumbled upon this when I looked at the ingredient listing from a product from China that listed 'modified food starch' without the source.  I checked the government of Canada's "Food Inspection Agency - Guide to Importing Food Commercially" website and found the following:

 

  Food Allergens

A variety of foods can cause adverse reactions in hypersensitive individuals. These reactions can vary from minor to life-threatening. Most adverse food reactions are caused by the following foods or their derivatives:

  • peanuts
  • tree nuts (e.g., almonds, Brazils, cashews, hazelnuts, macadamias, pecans, pinenuts, pistachios, walnuts)
  • sesame seeds
  • milk
  • eggs
  • fish
  • crustaceans (e.g., crab, crayfish, lobster, shrimp)
  • shellfish (e.g., clams, mussels, oysters, scallops)
  • soy
  • wheat
  • sulphites.

If these foods and their by-products or derivatives are not labelled or are incorrectly labelled, or if inadvertent carry-over occurs during manufacture, the results can be serious and sometimes fatal.

Importers are encouraged to identify these ingredients on food labels when they appear as ingredients or components. It is also recommended that the plant source of all forms of hydrolysed plant proteins, starches, and lecithin be identified (e.g., hydrolysed soy protein, modified wheat starch, soy lecithin).

Experience has shown that undeclared ingredients may occur as a result of:

  • carry-over of product through incomplete cleaning of food contact surfaces and utensils, sometimes because of poor equipment design;
  • inappropriate use of rework materials containing ingredients causing adverse reactions;
  • ingredient changes, substitutions or additions not reflected on the label;
  • product in wrong packages because of mix-up of packaging material;
  • printing error or omission from list of ingredients;
  • unknown ingredients in raw materials;
  • use of incorrect common names to describe products/ingredients (e.g., mandelonas for reformed peanuts);
  • labelling exemptions.

Despite all possible precautions, the presence of allergens cannot always be avoided. Consequently, a policy on precautionary labelling has been developed, which allows industry to voluntarily label products that may inadvertently contain substances capable of causing severe adverse reactions (e.g., "May contain peanuts").

 

Taken from:  http://www.inspection.gc.ca/english/fssa/imp/guide1e.shtml#d3

 

Further, I have more trust in domestic products as there are more stringent regulations than say foods that are produced and exported from China where regulations are not as stringently followed as seen for example in the recent use of melamine in baby formula (2008) http://www.guardian.co.uk/world/2009/jan/22/china-baby-milk-scandal-death-sentenceand melamine used in wheat gluten in pet food (2007).  http://en.wikipedia.org/wiki/2007_pet_food_recalls

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I would be cautious in accepting 'modified food starch' as an ingredient listing in foods that are imported as there is no regulation requiring them to list allergens.  It is encouraged but not required.  At least in Canada.  Furthermore, in the recommendations of listing possible allergens, wheat is listed but not barley and rye. 

 

Wheat is one of the ten top allergens, as well as being one of the gluten-containing grains.  It is required to be listed because of the allergen factor, not because it contains gluten.

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Yes, mushroom.  I find this glaring omission in Canada's Food Importing guidelines to be disturbing.  To not require the listing of but 'recommend and encourage' listing of food allergens as well ignore barley and rye food sources is totally at odds with what we require of domestic food producers.

 

I am a bit boggled by this.  My understanding is that as of 2012, we required all food labelling to list allergens and gluten containing food sources to be listed.

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Kamma, your information regarding Canadian labels seems to be out of date. Food and beverages packaged on or after August 4, 2012, are subject to expanded disclosure rules.

 

The list above, which has included wheat for many years, was expanded. All gluten sources must now be explicitly declared.

 

Read about it here.

Note in particular, the last sentence:

When the CFIA becomes aware of a potential serious hazard associated with a food, such as undeclared allergens, the CFIA investigates and takes all appropriate action to protect consumers, which may include a recall of the food product.

This labeling is required and is enforced. It applies to all products offered for sale in Canada, regardless of country of origin.

(For the sake of completeness, I will note that there is currently an exemption for alcoholic beverages, due to some beer having the label molded into the glass of the bottle, rather than being pasted on.)

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Yes, Peter, which is why I am boggled.  The information that I used is from the current G of C, Inspection Agency web page of "Guidelines for Commerically Imported Food".

 

I have just sent an email to Canada Food Inspection Agency asking them to clarify this apparent discrepancy.  I will post the answer when I receive it.

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