Here's a hint: if you have to put that language in your press release, it's a sign that the status quo isn't quite working.
Don't get me wrong: FALCPA is a major step up from 2000, when I got a list of seventy-five or so synonyms for gluten from my doctor and was told in many more words, "um, memorize these." But there are two major steps that could improve allergen labeling tremendously. First, list -- in plain language -- the source of all ingredients used at all phases of the manufacturing process. Second, list shared manufacturing lines, at least down to the top twelve to fourteen allergens. I'm sure it's not feasible to list every single food that's been manufactured on a line, but surely it's possible to mention the presence of the current top eight plus corn, sesame, gluten, and anything else with similar prevalence.
The FDA is planning a hearing on food labeling for allergens next week, September 16. The hearing is public, so if you happen to be within striking distance of College Park, Maryland, you're welcome to attend. You can read more about the current standards and the proposed labeling at HealthLawProf Blog.
Further Reading About the FDA and Allergy Labels: