Under FDA labeling rules adopted into California Retail Food Code §114091 practice, which of the following lists the 9 MAJOR FOOD ALLERGENS that must be controlled to prevent cross-contact?

a.Milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, gluten, corn
b.Milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, mustard
c.Milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, sesame
d.Milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, sulfites

Explanation

As of January 1, 2023, sesame became the 9th federally recognized major food allergen under the FASTER Act, expanding the Big 8 to the BIG 9. The complete list adopted into California Retail Food Code practice under §114091 is: (1) milk, (2) eggs, (3) fish, (4) Crustacean shellfish, (5) tree nuts, (6) peanuts, (7) wheat, (8) soybeans, (9) sesame. Option A incorrectly includes 'gluten' (gluten is a wheat protein, already covered under wheat) and corn (not a federally recognized major allergen). Option B incorrectly includes mustard (mustard is a major allergen in Canada and the EU but not in the U.S.). Option D incorrectly includes sulfites (sulfites are required to be declared but are a chemical preservative, not a protein allergen, and they appear under a separate FDA labeling rule). Knowing the exact 9 matters because each must be (a) declared on packaged foods, (b) disclosed to customers on request, and (c) controlled in prep through dedicated utensils, surfaces, and time/space separation.

Law Reference: HSC §114091

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