I'm one of 32 million Americans who suffers from food allergies. Of my 35+ food allergies, only two fall into the Top 8 allergens. In fact, 170 foods are known to cause food allergies.

The FDA recently released guidelines allowing food manufacturers to substitute ingredients without changing their product labels as a temporary measure to avoid supply chain disruption due to COVID-19. These guidelines do not cover food safety for millions of Americans who suffer from less common food allergies (the difference of prominence between the Top 8 allergens and other countries' Top 14, for instance, is small).

Food allergies are life-threatening. People with food allergies are now faced with a choice: risk consuming a product that may contain an allergen as a substituted ingredient and face death or avoid all pre-packaged foods. Personally, I am allergic to cottonseed oil, a likely substitute for canola, palm, or sunflower oil in most processed foods. People with corn or sunflower allergies have a similar concern, as do peanut or soy allergy-sufferers who react even to highly refined derivatives of those products (not considered allergens by the FDA). This is but one example of a food type currently protected by the substitution guidelines that can have a huge effect; many other foods fall into this category as well, like corn syrup, capsicum, spices, vegetables, and fruits. 

Let's call on the FDA to revise its policy and require label changes -- even with stickers -- to any products with substituted ingredients. We call on this for the safety of all those with food allergies. We call on this for those who cannot afford fresh ingredients and who do not have time to cook fresh meals regularly. We call on this for the children who will have to learn to be extra vigilant about sharing food and communicating their new restrictions to teachers when schools start up again. The FDA should protect food safety for all Americans and not leave vulnerable populations at risk.