Fish Allergen | The U.S. Big Nine Allergens

Fish is commonly eaten worldwide, including in the U.S., where Food Allergy Research & Education (FARE) estimates that 1% of the country is allergic to finned fish in particular. While this may seem like a small number, millions across the country would experience an allergic reaction and are at serious risk when shopping and eating out if businesses have undeclared allergens. As a result, fish is considered one of the nine major allergens in the U.S. and is subjected to certain labeling requirements. 

Food businesses need to be aware of relevant food safety legislation, the consequences of incorrect allergen information, and how their food safety processes can minimize these risks. Our article will detail everything you need to know, along with important resources to learn more.

What is a Fish Allergy?

place of food containing fish

A fish allergy allergy, like other food allergies, occurs due to an immune system response. Proteins from fish are mistakenly identified by the body as harmful foreign substances known as antigens, and in response, the body releases a protein known as immunoglobulin E (IgE), which is meant to protect the immune system. As part of this process, IgE releases several chemicals, including histamine, which causes most of the typical allergy symptoms. 

Please Note: LiberEat’s content is not intended to be a substitute for professional medical advice. You should always take precautions and use appropriate judgment to protect yourself and others under your care concerning food allergies.

While a variety of fish proteins can trigger an allergic reaction, parvalbumin is mainly responsible. 

Parvalbumin is a type of protein commonly found in the muscles of various fish and some amphibians. It is known as a major allergen that can trigger allergic reactions in people who are sensitive to fish. When an individual with a fish allergy consumes fish containing parvalbumin, their immune system can mistakenly identify the protein as harmful, leading to an allergic response.

One of its unique characteristics is that it is heat stable, meaning it retains its function after the cooking process. As a result, both raw and cooked fish can trigger an allergic reaction. This protein is more abundant in some fish species than others, such as cod, salmon, and carp.

It’s important to note that as a significant allergen, ‘fish’ only refers to “finfish such as flounder, tilapia, grouper, and other vertebrate fish with fins.” Shellfish is a separate major allergen, as different proteins are responsible for causing an immune system response. Parvalbumin triggers reactions in finned fish, while tropomyosin is the cause in shellfish. This means that it’s possible to be allergic to finned fish and safely eat shellfish and vice versa.

Symptoms of a fish allergy are typical of other food allergen symptoms. They can vary widely and range from mild to life-threatening, with no way to predict the severity of a reaction, demonstrating exactly why it’s so crucial for businesses to provide accurate allergen information to consumers. Common symptoms include: 

  • Tingling or itching in the mouth
  • Hives or rashes
  • Swelling, particularly of the lips, face, or throat
  • Difficulty swallowing or breathing
  • Gastrointestinal issues like stomach pain, nausea, vomiting, or diarrhea
  • Anaphylaxis: a severe reaction that can cause breathing difficulties, shock, and even fatalities if not treated promptly with epinephrine

A more detailed overview of anaphylaxis can be found at the Mayo Clinic website.

Food Labeling Requirements for Fish

 

In the United States, the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA Act) and the Food Allergy Safety, Treatment, Education, and Research Act (FASTER Act) identified nine allergenic foods as being the cause of the majority of allergic reactions stemming from food in the country. As a result, they were collectively known as ‘the big nine allergens’, and comprised of the following:

  1. Crustacean shellfish allergy
  2. Wheat allergy
  3. Soybean allergy
  4. Fish allergy, referring to Finned Fish
  5. Milk allergy, referring to domesticated cows’ milk
  6. Tree nut allergy
  7. Egg allergy
  8. Peanut allergy
  9. Sesame Allergy

These pieces of food law mandate that any packaged food and dietary supplements containing fish as an ingredient must clearly label its presence on the packaging and identify the source name of the ingredient. This can be done by listing the specific fish in parentheses following the ingredient (e.g., “anchovy (fish)”) or by using a “contains” statement such as “contains fish” immediately after or next to the ingredients list.

While catfish is a finned fish, it is exempt from FALCPA labeling requirements as it is regulated by the Food Safety and Inspection Service (FSIS), an agency under the United States Department of Agriculture (USDA).

Meat, poultry, and egg products are under FSIS jurisdiction under the Federal Meat Inspection Act (FMIA), the Poultry Products Inspection Act (PPIA), and the Egg Products Inspection Act (EPIA).

In an attempt to combat imports that were growing in popularity by introducing stringent inspections, domestic catfish farmers successfully pushed for catfish to be included as an amenable species to the FMIA through the Food Conservation and Energy Act of 2008 (known simply as the 2008 Farm Bill) and its 2014 iteration. Nonetheless, the USDA encourages the use of an allergen statement consistent with FALCPA requirements and correctly declared allergen labels.

The Cost of Food Recalls

Failure to declare the major allergens regulated by the FDA can lead to costly and time-consuming food recalls for businesses.

The FDA enforces recalls for products that are mislabeled or may pose a health risk for consumers. These recalls are usually initiated by the FDA and carried out voluntarily by the responsible parties following guidance supplied by 21 CFR 7 of the Code of Federal Regulations. Additionally, Section 423 of the Food, Drug, and Cosmetic Act, as amended by Section 206 of the Food Safety Modernization Act on January 4th, 2011, grants the FDA the power to issue mandatory recalls if voluntary measures are not taken.

Managing a recall can be a formidable challenge for businesses. When a food recall occurs, the operation must notify regulatory agencies, affected manufacturers, businesses throughout the supply chain, and consumers about the product in question. Companies also face a considerable burden in public relations efforts to mitigate damage to their reputation while shifting their focus away from critical tasks to manage this crisis. 

Food recalls are the most common consequence of incorrect allergen information. In some cases, businesses may receive criminal penalties such as fines or even jail time under the Federal Food Drug and Cosmetic Act (FD&C Act).

By following FDA regulations and implementing best practices in allergen management, food manufacturers and retailers can significantly reduce the risk of allergen exposure and ensure the safety of their customers. 

If you’re interested in learning more, take a look at our Recall page to learn more about why food recalls occur. Our dedicated U.S. Allergen page will also direct you to pages where you can learn about the rest of the Big Nine allergens and relevant legislation. 

For businesses looking to avoid undeclared allergens and reduce the risk of recalls, contact us to learn how LiberEat’s Food Safety Technology can support you.

LiberEat Allergen Detection Software

LiberEat’s food safety software helps prevent errors in allergen data on supplier specifications, website and app data, food packaging, and menus. This can help protect your customers from the major allergens—find out more about these with our allergen information hub.

Correctly managing and reviewing your allergen data is essential for keeping you and your customers safe. 

Errors in allergen data can cause potentially devastating allergic reactions and expensive product recalls. Give yourself peace of mind, and contact us to learn more about how LiberEat can help protect your business.