Who gets to define a choking hazard?

More Cheerio messes this week. For  work . Best mom ever.

More Cheerio messes this week. For work. Best mom ever.

In Part I of The Couch Cheerio Series, we learned that if you’re going to eat couch food, your safest bet is the Cheerio dropped underneath it. Dry food + carpet = relatively safe for human consumption.

But what if that Cheerio has been sitting there for months, and your baby happens to crawl over and happens to reach under the couch and at that precise moment masters a pincer grasp? Will it be hard enough to pose a choking hazard?

While concern for infant and toddler choking isn’t new, the foods today’s parents fear seem rather…fluffy. After a viral story about a near-choking death on Gerber snacks first appeared in 2016, baby puffs and similar foods have been a perennial source of panic-googling, creating the perception that baby’s first finger foods pose hidden dangers and leading to calls for more rigorous standards.

So what are the standards for foods that pose possible choking hazards? Who writes them? Who enforces them?


If you had to guess who sets choke hazard standards, you’d probably say the Food and Drug Administration. But there are no FDA requirements for labeling possible choking hazards. Well, there is one, if you count psyillum husks as food, which I do not.

Parents might assume that the FDA is tasked with setting choke warning requirements because of the high-profile work of another group, the Consumer Product Safety Commission. If you’ve bought a toy sometime since 1994, or if you’ve purchased any item contained within a plastic bag since 1994, you’ve probably seen a choke hazard warning. The CPSC’s small parts regulation requires that any toy made for children under 3 years pass the tube test: if any piece of the toy can fit into a 2.25-inch long tube with a 1.25-inch diameter (the size of the expanded throat of your average 3-year-old), the toy cannot be marketed to children under age 3 and must feature a warning label.

Although the FDA does not require choke hazard labels on food, it does have requirements for toys included with food. Toys may be placed next to food (think Cracker Jacks), but not in food, which is why Kinder Eggs are way less cool in the US than in other countries. Those eggs must adhere to the CPSC small parts standard, which is why they, unlike other foods, feature a choke hazard warning.

Aside from candy-filled toys and toy-filled candies, then, foods in the US do not require choke hazard labels. The tube test is a reasonable standard for toys, but imagine trying to apply this standard to food. Nearly all foods served to babies would fit in the tube, and even those that wouldn’t—a crusty baguette, perhaps—could with little effort be chewed down to a choke-able size.


In the absence of any specific legislation requiring food-based choking hazard labels, pediatricians have developed their own standards. In its advice about starting solid foods, the American Academy of Pediatrics tells parents that food should be soft, easy to swallow, and in small pieces in order to prevent choking.

These guidelines are completely reasonable and totally unspecific, which has led some researchers to define choking hazards more clearly. Authors of a 2018 article in Clinical Pediatrics developed a dissolvability standard.

To test this standard, Nicol Awadalla and colleagues asked forty-one adults to eat like babies. Participants where offered nine different products, eight from Gerber and one from General Mills (Cheerios!). Seven of those nine products were tested both right of the container and after being exposed to air for at least one hour. Two of the products required refrigeration, so were not left exposed to air. Participants were asked to dissolve the products in their mouths without using their teeth and researchers measured the time it took to soften each food.

The study offers good news for those worried about the Couch Cheerio: the fresh and exposed Cheerios all dissolved in under fifteen seconds, as did Gerber’s Puffs and Lil’ Crunchies. Gerber’s Yogurt Melts melted in under twenty seconds.

The main concern of the participants seemed to be that some products were different when “fresh” vs. “exposed. Participants described one of the Gerber products exposed to air (Fruit & Veggie Melts) as “like a hard candy” even after attempted dissolution.

Although not particularly well-controlled (it’s hard to imagine that participants in a blind taste test cannot recognize the feel or taste of a Cheerio), this study offers one way forward in food labeling: using a dissolvability test to determine how quickly a product can dissolve, and then rating food designed for babies in terms of dissolvability.

Food Companies

Until such a standard exists, food companies are creating their own labels to alert consumers to possible dangers. A hunt through your own kitchen will turn up a surprisingly long list of choke hazards voluntarily labeled by food companies.

Hot dogs often include warnings like this one from Hebrew National: “When Serving Hot Dogs to Young Children, Cut Hot Dogs Lengthwise, Then Into Small, Easy-to-Swallow Pieces. Children Should Eat While Seated And Be Under Adult Supervision.” Popcorn kernels from Orville Redenbacher come with this warning: “While popcorn is a delicious snacking choice, it is never recommended for infants and toddlers, as the popped kernels can pose a choking threat to their safety.” Jell-O features a warning specifically targeted at parents with children under age four: "cut gelatin into bite-size pieces. Children should always be seated and supervised while eating.”

As my pantry inventory should make clear, we’ve graduated past Gerber in our household, so I took my four-year-old on an ill-advised trip to the grocery store that resulted in tearful demands for “those cool A-B-C cookies,” one of the many stratospherically-priced items in the baby food aisle.

Fortunately for him and my wallet, we also had to research for an upcoming piece on Valentine’s Day candy, which was conveniently located across the aisle. I bribed him with a box of SweeTart Hearts (“IMPORTANT: YOUNG CHILDREN (LESS THAN 4 YEARS) HAVE LIMITED CHEWING ABILITY AND COULD CHOKE ON SMALL CANDIES) and headed back to the puffs.

Four brands—Gerber Puffs, Happy Baby, Sprout Organic, and Plum Organic—all featured the same boxed warning: “THIS PRODUCT SHOULD ONLY BE FED TO SEATED, SUPERVISED CHILDREN WHO ARE ACCUSTOMED TO CHEWING SOLID FOODS.” A fifth brand, Tippy Toes, has a very similar version: “This product should only be given to children who are familiar with eating solid foods. Children should be seated and supervised while eating. Package not intended as a toy.”

In the absence of FDA labeling requirements, it appears that baby food companies as a group are recognizing the social media threat posed by a stale puff. Gerber, for example, unveiled all-new packaging for its baby food line in 2017. Although the stated aim was to compete with newer baby brands like Plum Organics, the company may have also seen an opportunity to redirect some consumer confusion and panic about its snacks.


It’s unlikely that we will ever have industry-wide requirements for food choking hazards, because the category of “choking hazards” is so broad. Is it a food? Then you can choke on it.

Keeping this broad definition in mind, you can proceed with solid foods slowly and cautiously, while acknowledging the baby will probably get ahold of a couch Cheerio. You can avoid introducing hot dogs and popcorn until age five while acknowledging your kid is going to find a way to eat these foods earlier. You can encourage your child to eat sitting down, while fully acknowledging that he’s going to eventually run around the table with a carrot or a candy cane. You can, in short, acknowledge that eating is both a risky and essential endeavor.