LAS VEGAS — For Americans with food allergies, label reading is a way of life. And for commercial baking companies, the term “Top 8” — referring to allergens — is quite the same. So, when the FASTER Act was signed into law in April to recognize sesame as the ninth allergen on the list, those in both camps took notice.

During the International Baking Industry Exposition (IBIE) — which took place Sept. 18-21 in Las Vegas — Nathan Mirdamadi, senior food specialist for Commercial Food Sanitation, addressed the operational implications of understanding and managing the risks associated with producing baked goods with sesame.

When it comes to recalls for American food manufacturing, nearly a third of food allergy recalls were initiated from bakeries, many of which were due to labeling issues or omission.

“Those of us who work in food manufacturing know that the labeling aspect of [food allergens] is problematic,” Mirdamadi said. “The entire intent of the law was to inform consumers. But I also think we’ve learned that labeling — and controlling labels — is not nearly as easy as we had hoped.”

While some food manufacturers rely on precautionary or defensive labeling, Mirdamadi warned that not only is such reliance insufficient, but it also does little to reduce liability.

Across an entire grocery store, roughly 6% of all products contain sesame.

“That’s much higher than I think people appreciate,” Mirdamadi said, noting that other allergens such as tree nuts, which can garner a similar reaction in terms of severity, looks more like 3% of total grocery.

But addressing sesame as the ninth allergen in some ways introduces just as many questions as answers. For Mirdamadi, the safest protocols begin proactively, not defensively.

In looking at how sesame is used in baked goods specifically, it’s often applied topically to a product post-bake, such as with hamburger buns. Because it’s a very fine particulate used as more of a topping than inclusion, controlling sesame as an allergen is like “trying to remove sand from the beach,” according to Mirdamadi, especially when most post-oven equipment sanitation employs dry methods.

“It’s a very serious challenge,” he said. “Then we take into consideration supply chain issues and sanitation departments struggling to find, train and retain employees. We’re pushing ourselves into a corner trying to create a scenario where we can successfully remove sesame.”


“The entire intent of the law was to inform consumers. But I also think we’ve learned that labeling — and controlling labels — is not nearly as easy as we had hoped.” — Nathan Mirdamadi | senior food specialist | Commercial Food Sanita


There are options, Mirdamadi said, and knowing the right strategy will depend on the level of disruption to the operation. It could be as simple as scheduling runs with sesame as late in the process as possible or going as far as investing in equipment that’s dedicated specifically to sesame. The most important strategy, though, is validating through sanitation.

“You’ve got to do a risk assessment to understand how you’re going to manage potential sesame seed cross-contact,” he said. “What are the cost considerations for a duplicate piece of equipment, and what does it actually cost if you’re going to manage it through cleaning?”

Some middle ground could be found in modifications to the existing line, such as with dedicated pans, a modified pan return or modular belt systems.

“You can set up modular belts that aren’t too large,” Mirdamadi said. “You can put them on casters or wheels, so you can slide it into or out of place.”

Another option is dedicating a depanning belt for seeded products and another for unseeded.

Some equipment manufacturers are putting in the R&D to find solutions for sanitation, especially with belts, where those little sesame seeds can find great gathering (and hiding) places.

sesame presentationSome manufacturers are developing a brush with vacuum attachments that can minimize the migration of seeds. Other technologies include driving belts from the edge rather than the center shaft to eliminate transfer points on the line.

“Then you could put some of these cleaning apparatuses directly on the line for a dry CIP that’s automated,” Mirdamadi said. “That could be pretty impactful.”

In looking at equipment overall, hygienic design has never been more important — not just for today but also tomorrow. While sanitary equipment design has been a priority for years, Mirdamadi noted that what’s addressing today’s concerns won’t necessarily cover tomorrow’s issues.

Bakers must always be thinking ahead when it comes to food safety, whether in how they schedule runs or how they’re investing in equipment and sanitation.

The FASTER Act added a layer of complexity with the addition of sesame as the ninth top allergen. How will it all change when the 10th is added later on?

“Bakeries sometimes have trouble grasping the concept that the equipment we’re buying today will have to comply with future regulations,” Mirdamadi said. “We’ve seen that with not only allergens but also pathogens and all the other concerns. The bar is only going to get higher.”