Industry, sanitation and trade groups tell FDA thresholds could expand safe choices but raise implementation challenges

Manufacturers, sanitation leaders and trade associations attending the FDA meeting described practical implications of adopting population reference doses for allergen management.

Sanitation and manufacturing presenters said thresholds can help shift attention from a near-zero detection mindset to risk-appropriate controls. Scott Hagenbart (Conagra) illustrated how a reference dose can be translated into a percent carryover and a batch-mass calculation so companies can determine whether cross-contact would be visible or require specific controls. Nathan Mirdamati (global sanitation director) warned that absent thresholds, many firms choose wet cleaning to reach near-zero results—sometimes increasing microbiological risk for low-water products—and that thresholds could enable safer, product-specific sanitation choices.

Trade groups from the baking and spice sectors described concrete problems under the FASTER Act’s sesame requirement: some bakers added sesame to products or removed seeded items because they judged cross-contact risk and recall likelihood unacceptable. The spice industry presented an agricultural commingling example (peanut detected at 135 ppm in garlic) and a consumption-based exposure calculation showing the contaminant level would be far below a 2 mg peanut protein reference dose at typical use levels.

Panelists outlined operational gaps that must be addressed: harmonized methods for quantitative exposure assessment across supply chains, analytical-method calibration to action-level ranges (not just LOQs), sampling and measurement uncertainty, and clear criteria for exemptions and dossiers. Ben Remington reviewed existing guidance (FDA, EFSA, FAO/WHO) and noted FAO/WHO’s suggested RFD/30 benchmark for exemption consideration.

Industry requested predictable, transparent benchmarks so firms can design prospective controls, avoid forced reformulation, and reduce unnecessary PAL that limits consumer choice. Panelists urged FDA to pair thresholds with guidance on sampling, verification and enforcement expectations.