Product adulteration requires the application of a recall strategy as defined in 21 CFR § 7.42. The first step of this strategy is to conduct a health hazard evaluation. For allergenic substances, Congress put in place the Food Allergen Labeling and Consumer Protection Act (FALCPA) in 2004, which requires that food labels clearly identify the food source names of all ingredients that are or contain any protein derived from the eight most common food allergens—eggs, milk, fish, crustac…