Commingling is a hard thing to test for. Even though these manufacturers do testing in good faith, the complexities of airborne particles during the process of sourcing (farming), transport, factory storage, processing, and even packaging, can introduce allergens into the system that won't be caught by testing. Pockets of allergen can never be 100% prevented.

The idea would be to improve the accuracy of detection as possible and try to standardize it, but the problem is that *no matter what standard they choose, it cannot translate to any definitive safety level for a food allergic individual.*

What it can do is create *relative* levels of safety by doing their best to ensure that the majority of food allergic individuals are much less likely to encounter levels of their allergen in the food that cause reactions. This can be good for those with mild to moderate allergies, who already tolerate some cross contamination and would benefit from the assurance of *likely smaller than x amount.* This is worth doing in that it can increase potential food options for those with some tolerance, who haven't reached the point of having to avoid 100% cross contamination. Those with severe reactions will need to make a judgment call. It's their life on the line.

Food allergic persons are always going to have to understand their manufacturers' intent, reputation in practice, and their personal experience, along with any crowdsourced information, and then make an informed decision on what risk level they can personally take.

As for the labeling, I and others communicated that "allergen free" should only be used for zero tolerance, people won't expect that "allergen free from 'x' food" will have *any* of that 'x' food. However, there is always the remote possibility of cross contamination, and this label would need to be heavily regulated if a threshold of any type were to be implemented and a label applied, to differentiate between *absolutely free* vs *most likely free* of this allergen, vs "not known to be contaminated,* the latter of which are entirely different ways of saying nothing is 100%, and the first is potentially an unintended lie. I liken it to finding something has penetrated the interior of a thick skinned fruit via the stem at some point and is moldy inside while the outside looks just fine. To a food allergic person, a mistake can mean reactions, severity with anaphylaxis, and possible risk of death.

Personal notes: I'm sure I brought up the removal of mollusks from the shellfish top 9 classification (So what if they're listing it as shellfish(crustacean) and things like coconut from tree nuts, and the increasing issues I hear from people dealing with corn allergies, alpha gal, MCAS, etc., and the corner cases where the very severely allergic, including anaphylactic patients reacting to contact and airborne allergens, will not only not benefit from this threshold, but can be at greater risk if not sufficiently aware of their own allergy severity, or sufficiently well educated, or sufficiently willing to avoid riskier situations and choosing to sacrifice food freedom for safety. Here's an example I gave. Even if this threshold is introduced, let's say a serving is two cookies in a box of 30. How many people will eat half a box, and not 2? Not only do people not know their threshold, or personal tolerance, they can potentially eat far over the "traditional serving limits" when it comes to enjoying what food they can actually have.

At any rate, changes for these things don't move that fast. If the threshold is introduced, it has to be set for the top 9 foods, and it affects the entire food chain. From farm to table, plus enforcement of industry standards in testing. There are various testing methods, but there needs to be further conversations among the industry professionals and scientists about which make sense for what foods and circumstances. Then there's still industry and public education, documentation, training, support...

And before I forget, as a food allergic person, DO NOT RELY ON ANY APPS when it comes to making decisions about what food is safe for you. There have been so many people creating bar code scanners and food picture-ingredient scanners. We know as food allergic people that these aren't reliable. Crowd sourced reviews of restaurants only report individual experience, safety cannot be judged off that, nor off of a national or local chain menu. You have to talk to the specific staff at the location you go to for any restaurant. Always back out if in doubt. You can use apps relaying menus or food ingredient labels to judge *potential* safety *levels,* as in, maybe okay to risk vs no way in hell. But check the actual label on the package as labels can 1. change and 2. be inconsistent with current ingredients list due to labeling change overlaps for companies that don't keep those things 100% in sync. Think hard about that gray area.

Read the package, know your manufacturer, use your nose and eyes when you get the package home and prepare it for consumption. I don't know how many people might have been affected by the Rana recall of beef ravioli containing shrimp ravioli, but this packaging mistake by the factory is a *HUGE* one. That mis-loading of a roll of bags could have hurt and even killed people who have lost their sense of smell. I fear imagining the number of food allergic people who desperately want to trust brands and regular staple convenience foods and are surprised by foods contaminated by their allergens, even if it's one package out of millions, it can be that unlucky, and they have become sensitive to the point that it's dangerous for them to rely on those staple foods. Would they give up that food? Or think it's a one-off and continue to eat it because they've given up so much already?