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FARE is especially pleased that the FDA specifically identifies food allergens in the proposed requirement
for a hazard analysis.

Me, too!!   

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We encourage the FDA to specify, and communicate, what constitutes a hazard that is "reasonably likely to occur." FARE is concerned that inadequate analysis on the potential for cross-contact could result in an inadequate approach to hazard evaluations and the subsequent preventive controls.  Consequently, FARE recommends that the final rule stipulate that food allergens are deemed a hazard that is reasonably likely to occur anytime food allergens are present anywhere in the food manufacturing or processing facility. Such a determination should require the preventive controls and recall procedures identified in §117.135 and § 117.137.
The presence of allergens in production facilities
should require the development of food allergen control plans by manufacturers

Yes, yes, yes!!   

http://www.foodallergy.org/document.doc?id=251

Recently, FARE submitted its comment to the U.S. Food and Drug Administration in response to its request for comments on the proposed rule for preventive controls. This proposed rule would establish new food safety requirements for those engaged in the manufacturing, processing, packing, or holding of human food in two fundamental ways.

First, the proposed rule would update, revise, or otherwise clarify certain requirements of the Current Good Manufacturing Practice regulations, which were last updated in 1986.


Second, it would add new preventive controls provisions as required by the FDA Food Safety Modernization Act.
Noting that undeclared food allergens are a leading cause of recalls, FARE commends the FDA for looking at food allergens within the preventive controls framework and recognizing them as hazards that can have lethal consequences if ingested unintentionally. FARE endorsed the proposed rule, with some noted recommendations, which you may read here. http://www.foodallergy.org/document.doc?id=251