This discovery began with the American College of Allergy, Asthma & Immunology (ACAAI) in 2018, when they made the following false claim on their website. [They have suspended this page at our request.]
“Most
corn-derived products, like cornstarch and high-fructose corn syrup, do not
contain corn protein. If you have a corn allergy, you do not need to avoid
these products.”
https://acaai.org/allergies/types/food-allergies/types-food-allergy/corn-allergy
Timeline:
March 15, 2018
Based on this claim by the ACAAI, I conducted an oral challenge of Argo cornstarch; and suffered a severe allergic reaction due to my IgE-mediated allergy to corn. I immediately called the ACAAI with the results of my oral challenge, and appealed to them to remove this false statement from their website.
Argo Cornstarch
Oral Challenge to Test Hypothesis Presented by the ACAAI
https://cornallergyadvocacyresources.blogspot.com/2018/03/argo-cornstarch-oral-challenge-to-test.html
March 27, 2018
Since the ACAAI made no attempt to correct this statement, I mailed them a certified letter of appeal. In addition, I also filed a petition against them; since they were clearly denying the allergenicity of cornstarch.
My March 27,
2018, Certified Letter to the ACAAI Re:
Cornstarch and Corn Syrup
https://cornallergyadvocacyresources.blogspot.com/2018/03/my-march-27-2018-certified-letter-to.html
Petition to
Demand that the ACAAI Remove False Statement Re: Cornstarch/High-Fructose Corn
Syrup
https://cornallergyadvocacyresources.blogspot.com/2018/02/petition-to-demand-that-acaai-remove.html
Early 2019:
Approximately one year after receipt of my certified letter, the ACAAI redacted their claim regarding cornstarch; however, I continued to appeal to them to redact their equally false claim regarding corn syrup.
October 18, 2020
I submitted the following inquiry to the Food and Drug Administration’s (FDA) Food and Cosmetic Information Center (FCIC)/Technical Assistance Network (TAN)
“The
ACAAI specifically declares: "Most corn-derived products, like
high-fructose corn syrup, do not contain corn protein." [They recently suspended this page at our request.]
https://acaai.org/allergies/types/food-allergies/types-food-allergy/corn-allergy
Since
the majority of the 12K+ members in our corn allergy support groups react to
corn syrup (and just about every other product derived from corn), we would
like to know what testing method is utilized to confirm that corn syrup
contains no allergenic corn protein. Thank you.”
October 19, 2020
I received the following reply from the Food and Drug Administration’s (FDA) Food and Cosmetic Information Center (FCIC)/Technical Assistance Network (TAN), case number 247714.
“Dear Sir/Madam:
Thank you for your inquiry regarding allergens in corn-derived products. You noted a statement from the ACAAI about allergen levels in such products.
There is no collaboration between FDA and the ACAAI, and FDA does not have records pertaining to their claims. Please contact the ACAAI for information about the testing procedures used to justify their claims. [emphasis added]
We hope this information is helpful. Please contact us if you have further questions.
Thank you for contacting FDA’s FCIC/TAN.”
October 20, 2020
I sent an email to the ACAAI with the FDA’s directive.
My October 20,
2020, Email to the ACAAI Re: Directive from the FDA Addressing the ACAAI’s
Claims Regarding Corn Allergenic Proteins
https://cornallergyadvocacyresources.blogspot.com/2021/02/my-october-20-2020-email-to-acaai-re.html
February 18, 2021
My
February 18, 2021, email exchange with Rick Slawny, Executive Director for the
American College of Allergy, Asthma & Immunology (ACAAI), is documented in
the following blog post:
https://cornallergyadvocacyresources.blogspot.com/2021/03/the-acaais-endangerment-of-corn.html
February 20, 2021
The
ACAAI suspended their page addressing corn allergies from their website;
however, I continued to appeal to them to suspend their "Infant Formulas
and Corn Allergy" page, since it clearly endangered the lives of
corn-allergic infants.
https://acaai.org/allergies/types/food-allergies/types-food-allergy/corn-allergy
Important Note: It appears that the ACAAI is erroneously equating “impurities” with “allergenic corn protein.” Would they apply this same theory to foods listed in the “Top 8” allergens, or are they just targeting corn?
[They have
suspended this page at our request.]
“The
corn component in the hypoallergenic formulae is corn syrup, derived from corn
starch [sic] which has been processed to remove any impurities. This corn starch [sic] does not have any
corn protein in it.” [emphasis added]
https://acaai.org/resources/connect/ask-allergist/infant-formulas-and-corn-allergy
FALCPA
establishes a process under 21 U.S.C. 343(w)(7) by which any person may file a
notification containing scientific evidence demonstrating that an ingredient
“does not contain allergenic protein.” The scientific evidence must include the
analytical method used and the ingredient must be derived by the specified
method. FDA has 90 days to object to a notification. Absent an objection, the
food ingredient is exempt from FALCPA's labeling requirements for major food
allergens.
https://www.fda.gov/food/food-labeling-nutrition/inventory-notifications-received-under-21-usc-343w7-exemptions-food-allergen-labeling
February 21, 2021
In response to the directive from the FDA to "contact the ACAAI for information about the testing procedures used to justify their claims," Rick Slawny used the following document published by the FDA as justification; since the ACAAI interpreted the FDA's "100% glucose" (blood sugar naturally present in all living organisms) claim as having no corn allergenic protein. HFCS is manufactured from allergenic cornstarch; so HFCS does, in fact, contain allergenic corn protein – “pure” or “impure.”
"High Fructose Corn Syrup Questions and Answers,” FDA
"Where does HFCS come from?
HFCS is derived from corn starch [sic]. [emphasis added]
When
corn starch [sic] is broken down into individual glucose molecules, the end product
is corn syrup, which is essentially 100%
glucose." [emphasis added]
The correct
term is “100% D-glucose.”
https://www.fda.gov/food/food-additives-petitions/high-fructose-corn-syrup-questions-and-answers
March 24, 2021:
I emailed my following blog post to Rick Slawny:
The ACAAI's
Endangerment of Corn-Allergic Infants (Documented)
https://cornallergyadvocacyresources.blogspot.com/2021/03/the-acaais-endangerment-of-corn.html
March 26, 2021:
For
the safety of corn-allergic infants, we are grateful that the ACAAI also suspended
this page from their website.
https://acaai.org/resources/connect/ask-allergist/infant-formulas-and-corn-allergy
Additional Documentation Confirming the FDA is Endangering Corn-Allergic Individuals
Again, let me reiterate that the FDA is fully aware that dextrose is corn sugar/D-glucose.
Pursuant to Code of Federal Regulation 21CFR184.1857:
Dextrose
= corn sugar manufactured from cornstarch = D-glucose
Dextrose
= D-glucose = corn sugar manufactured from cornstarch
Corn
sugar manufactured from cornstarch = dextrose = D-glucose
Corn
sugar manufactured from cornstarch = D-glucose = dextrose
D-glucose
= dextrose = corn sugar manufactured from cornstarch
D-glucose
= corn sugar manufactured from cornstarch = dextrose
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=184.1857
Since
dextrose (D-glucose) is corn sugar manufactured from cornstarch, it is an ADDED
sugar that is never naturally present in any other food products or in the
human body. Glucose (blood sugar) is
naturally present in all living organisms – NOT corn sugar! Glucose (blood sugar) is produced by the
liver – NOT corn sugar! Dextrose (corn
sugar) is a glucose (blood sugar)-elevating agent.
"The Liver & Blood Sugar,"
University of California, San Francisco
https://dtc.ucsf.edu/types-of-diabetes/type1/understanding-type-1-diabetes/how-the-body-processes-sugar/the-liver-blood-sugar/
"What is
Glucose?," WebMD
https://www.webmd.com/diabetes/glucose-diabetes
Dextrose (corn
sugar/D-glucose) is a glucose (blood sugar)-elevating agent.
https://reference.medscape.com/drug/d50w-dglucose-dextrose-342705
Dextrose
Equivalent (DE) is only derived from corn.
https://www.austradeinc.com/products/sweeteners/
Confirmation
that dextrose (corn sugar/D-glucose) is only derived from corn. Dextrin
(usually derived from corn) may be derived from food products other than corn.
https://cornallergyadvocacyresources.blogspot.com/2020/12/confirmation-that-dextrose-corn-sugard.html
Companies I
reported to the FDA’s Center for Food Safety and Applied Nutrition (Mislabeled
Food Product):
There
is no such thing as tapioca-derived dextrose, wheat-derived dextrose,
rice-derived dextrose, etc. Dextrose is
corn sugar manufactured from cornstarch/D-glucose; therefore, it is impossible
to derive corn sugar from any food product other than corn.
The following companies are falsely implying that dextrose (corn sugar) is derived from a food product other than corn; e.g., tapioca. The FDA’s reply to my complaint was to submit these mislabeled food products to my state FDA consumer complaint coordinator, since they lacked adequate staffing to address corn allergy claims. After supplying my state consumer complaint coordinator with indisputable documentation that these products were mislabeled, they told me they sent my complaint back to the FDA’s Center for Food Safety and Applied Nutrition; even though I supplied them with the requisite documentation of my severe allergic reaction to “Organic Tapioca Dextrose” from a complimentary sample sent to me by Ciranda. It was actually tapioca starch to which corn sugar, in the form of dextrose equivalent (DE), was added. The FDA has done nothing to address this critical issue.
TapiOK® Tapioca
Dextrose, Organic, Ciranda
https://www.ulprospector.com/en/na/Food/Detail/6025/206054/TapiOK-Tapioca-Dextrose--Organic
Certified
Organic Tapioca Dextrose, Parchem
[Documentation
forwarded to them via email, 12/15/2020.]
https://www.parchem.com/chemical-supplier-distributor/Certified-Organic-Tapioca-Dextrose-006117.aspx
Tapioca
Dextrose, Mike’s Mix
[Note
that they are also falsely claiming this
product is corn free, which endangers the lives of corn-allergic consumers.
I have exchanged over 40 emails with this company since September, 2020, and
they refuse to redact their corn-free/tapioca dextrose claims.]
https://mikesmixture.com/products/tapioca-dextrose?_pos=1&_sid=2b7cb53cb&_ss=r
Tapioca Starch
Dextrose, Alibaba.com
[Removed
from their website after I provided them with the requisite documentation.]
https://www.alibaba.com/product-detail/tapioca-starch-dextrose-fufeng-dextrose_62108273451.html?spm=a2700.7724857.normal_offer.d_image.3a3d1eb9747CbL
Tapioca Starch
Dextrose Monohydrate, Alibaba.com
[Removed
from their website after I provided them with the requisite documentation.]
https://www.alibaba.com/product-detail/tapioca-starch-dextrose-monohydrate-bulk-glucose_62108429284.html?spm=a2700.7724857.normal_offer.d_image.3a3d1eb9747CbL
Tapioca
Dextrose, A. G. Commodities, Inc.
[Sent
email 12/27/20, and they removed this reference from their website.]
http://www.tapiocadextrose.com/
Tapioca
Dextrose, Protein Muffins, Trader Joe’s
[I
was unable to notify this company of this mislabeled food product.]
https://www.traderjoes.com/home/products/pdp/068421
Organic Tapioca
Dextrose, Nature’s Flavors
[Sent
email 12/30/20.]
https://www.naturesflavors.com/organic-ingredients/63825-organic-dextrose-powder-kosher-vegan-gluten-free.html?search_query=tapioca+dextrose&results=4
Tapioca
Dextrose Monohydrate, Essex Food Ingredients
[Sent
documentation to them on 12/2/2020 via online contact form.]
https://essexfoodingredients.com/product/tapioca-dextrose-monohydrate/
Dextrose
(Tapioca Derived)
[Sent
documentation to them on 11/25/2020 via email.]
http://www.ffi-corp.com/products.asp
Why is this
important?
These mislabeled food products not only endanger the lives of corn-allergic consumers, but they also place the manufacturer/retailer at risk for liability. Corn may be exempt from FDA labeling requirements; however, no manufacturer/retailer can “imply” their product is free from corn, or make a “corn-free” claim, when the product actually contains corn-derived ingredients.
SUMMARY:
It
is incomprehensible that the ACAAI, a "professional medical organization
of more than 6,000 allergists-immunologists and allied health
professionals" would not know that cornstarch (which includes anything
manufactured from cornstarch) can prove deadly to anyone with an IgE-mediated
allergy to corn; since cornstarch contains allergenic corn protein. We are grateful that the ACAAI has finally
suspended both of the referenced pages from their website for the safety of
corn-allergic consumers.
https://acaai.org/about-college
The
FDA is fully aware of the critical difference between glucose (blood sugar) vs.
D-glucose (corn sugar/dextrose). If this was just a typographical error, we are
requesting that the FDA immediately correct this document from "100%
glucose" to "100% D-glucose."
If this was intentional, then we
are demanding that the FDA provide "information about the testing
procedures used to justify their claims" in equating HFCS with glucose
(blood sugar).
https://www.fda.gov/food/food-additives-petitions/high-fructose-corn-syrup-questions-and-answers
The FDA must also correct their errors in 21CFR182.1866.
"High fructose corn syrup.
(a) Product. High fructose corn syrup is a
sweet, nutritive saccharide mixture containing approximately 52 percent (dry
weight) glucose [correct to read: D-glucose], 43 percent (dry weight)
fructose, and 5 percent (dry weight) other saccharides. It is prepared as a
clear aqueous solution from high dextrose equivalent corn starch [sic]
hydrolysate by partial enzymatic conversion of glucose (dextrose) . . ." [correct to read: D-glucose (dextrose)]
https://www.govinfo.gov/content/pkg/CFR-1996-title21-vol3/html/CFR-1996-title21-vol3-sec182-1866.htm
The FDA must
immediately cease endangering the lives of individuals with an IgE-mediated
allergy to corn!
Diane
H., Corn Allergy Advocate
Corn
Allergy Advocacy/Resources
https://cornallergyadvocacyresources.blogspot.com/
Email: cornallergyinitiative@gmail.com
Twitter: @CornAllergy911
Additional Documentation/References:
If
“dextrose” is referenced on the FDA's Food Additive Status List, it refers to
21CFR184.1857.
https://www.fda.gov/food/food-additives-petitions/food-additive-status-list#ftnD
21CFR184.1857
defines corn sugar manufactured from cornstarch as dextrose/D-glucose
https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=184.1857
"FDA Rules Corn Syrup Can't Change Its Name To Corn Sugar"
"Also,
there's already something else on the market called corn sugar. It's the name
for the sweetener dextrose, and has been used by people who have trouble
tolerating regular sugar for 30 years, the FDA says."
https://www.npr.org/sections/thesalt/2012/05/30/154009682/fda-rules-corn-syrup-cant-change-its-name-to-corn-sugar
The Corn Refiners Association correctly identifies corn-derived sweeteners with the requisite “D-“ modifier (DE for dextrose equivalent). This critical modifier has been omitted from many published articles over many decades, which is the reason that corn-derived sweeteners are being erroneously equated with blood sugar (glucose); thus, endangering the lives of corn-allergic consumers and patients.
Nutritive
Sweeteners From Corn, Corn Refiners Association, 2006
https://corn.org/wp-content/uploads/2018/10/NSFC2006.pdf
The USDA and National Agricultural Library are complicit in the deception of equating blood sugar (glucose) with corn sugar (dextrose/D-glucose). Pg. 294, "They are composed of various proportions of glucose (dextrose)..." [emphasis added]
The correct
term is: D-glucose (dextrose).
https://www.nal.usda.gov/sites/default/files/fnic_uploads/265-338.pdf
The false narrative for equating corn sugar (dextrose/D-glucose) with glucose (blood sugar) was initiated by the corn industry decades ago. The propaganda is quite remarkable.
“Dextrose:
All-American Corn Sugar,” Candy Professor, September 29, 2010
https://candyprofessor.com/2010/09/29/dextrose-all-american-corn-sugar/#:~:text=But%20by%201866%2C%20someone%20figured,dextrose%20from%20that%20corn%20starch
"Conversion of Corn to Dextrose"
“Corn
must first be converted to corn sugar (dextrose, the common commercial name for
D-glucose) . . .”
https://polymerinnovationblog.com/from-corn-to-poly-lactic-acid-pla-fermentation-in-action/
The
America Heart Association defines HFCS as an ADDED sugar chemically manufactured
[from ALLERGENIC CORNSTARCH]; therefore, it cannot be equated with "100%
glucose" (blood sugar).
https://www.heart.org/en/healthy-living/healthy-eating/eat-smart/sugar/sugar-101
Administering
dextrose-containing IV fluids to corn-allergic patients is a critical medical
error equivalent to administering penicillin to patients with an allergy to
penicillin.
https://cornallergyadvocacyresources.blogspot.com/2019/12/lactated-ringers-in-5-dextrose.html
Corn
Sugar (Dextrose/D-Glucose) IV Solutions Contraindicated for Corn-Allergic
Patients
https://cornallergyadvocacyresources.blogspot.com/2020/08/corn-sugar-dextrose-iv-fluids.html
Glucose
(blood sugar) is produced by the liver; dextrose is corn sugar produced from
cornstarch/D-glucose, 21CFR184.1857. Therefore, they cannot be "one and
the same;" since our liver does NOT produce corn sugar
(dextrose/D-glucose).
https://dtc.ucsf.edu/types-of-diabetes/type1/understanding-type-1-diabetes/how-the-body-processes-sugar/the-liver-blood-sugar/
Glucose
(blood sugar) must NEVER be equated with dextrose (corn sugar manufactured from
cornstarch).
[This
petition does NOT solicit donations.]
PETITION:
Defund the NIH National Library of Medicine for Willful Negligence
https://www.change.org/p/united-states-department-of-health-human-services-defund-the-nih-national-library-of-medicine-for-willful-negligence
My
January 6, 2021, Open Letter to the FDA Re: Critical Difference Between Glucose
(Blood Sugar) and D-Glucose (Corn Sugar/Dextrose)
https://cornallergyadvocacyresources.blogspot.com/2021/01/my-january-6-2021-open-letter-to-fda-re.html
The following recipients have responded positively to our message addressing the conflicting molecular formulas between the FDA and the NIH National Library of Medicine.
Allergy Strong, Washington, DC, @allergystrong
American
Association of Surgical Physician Assistants (AASPA), @SurgeryPA
Arkansas
Department of Human Services, Little Rock, AR, @ARHumanServices
Baptist
Health, Northeast, FL, @BaptistHealthJx
Biology
Online, @BiologyOnline2
Health
New England, Springfield, MA, @HNEinc
Holy Redeemer Health, Meadowbrook, PA, @RedeemerHealth
Janice
L. Pelletier, MD, FAAP, Orono/Penobscot, ME, @DrJanPeds
Ohio
State University College of Medicine, Columbus, OH, @OhioStateMed
Primary
Care Progress, Boston, MA, @PCareProgress
Society
for Academic Emergency Medicine (SAEM), Des Plaines, IL, @SAEMonline
[Retweeted]
St.
Michael's Elite Hospital, Sugar Land, TX, @StMichaelsER
Stanford
MedicineX, Stanford, CA, @StanfordMedX
University
of Maryland Eastern Shore, Princess Anne, MD. @UMESNews
University
of Pittsburgh School of Pharmacy, Pittsburgh, PA, @pittpharmacy
University
of Saint Joseph, West Hartford, CT, @USJCT
Wolfson
Children's Hospital, Jacksonville, FL, @WolfsonChildren
Drugs.com corrected
their definition of dextrose!
PETITION: Demand
that Drugs.com correct their definition of dextrose (corn sugar/D-glucose) for the safety of corn-allergic
patients.
[This
petition does NOT solicit donations.]
https://www.change.org/p/drugs-com-demand-that-drugs-com-correct-their-definition-of-dextrose-corn-sugar-d-glucose
The
FDA should not be in the business of promoting corn-laden infant formulas. Parents
of corn-allergic infants are REQUIRED to make homemade infant formulas, since
there are NO corn-free infant formulas available for these struggling babies.
https://www.fda.gov/consumers/consumer-updates/infant-formula-safety-dos-and-donts
Corn
Allergy References, Surveys, Studies (“. . . Maize major allergen . . .”),
Statistics, & Petitions
https://cornallergyadvocacyresources.blogspot.com/2018/04/corn-allergy-reference-links.html
Blog Post Reference:
The FDA's
Endangerment of Corn-Allergic Individuals (Documented)
https://cornallergyadvocacyresources.blogspot.com/2021/04/the-fdas-endangerment-of-corn-allergic.html
