2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1188
Submitter : Ms. Ann Petersen Date & Time: 09/20/2005 05:09:50
Organization : Spirit of the Healing Heart
Category : Other Organization
Issue Areas/Comments
GENERAL
GENERAL
Dear FDA:

We encourage you to adopt a regulation on the use of "gluten-free" on product labels that is in line with that which has been used in Europe and other countries (including the USA via the Codex Alimentarius) for many years--20 PPM for products that contain naturally gluten-free ingredients, and 200 PPM for products that have been rendered gluten-free such as those that may contain Codex Alimentarius quality wheat starch. The formal adoption of these existing regulations will allow for the continued importation of excellent, safe European products that are labeled "gluten-free."

It is very important that you do not adopt a "zero tolerance" regulation in this matter because doing so will cause many gluten-free food companies to discontinue their use of the term "gluten-free" on their labels out of fear of litigation--which is counterproductive for all people with this disease (most, if not all, gluten-free food companies do not grow, transport or mill the gluten-free grains that they use as ingredients--a fact that will make them vulnerable to litigation if a zero tolerance level is adopted). Last, the inclusion of trace levels of gluten in the diets of those with celiac disease have been shown to be safe in many scientific studies, for more details please see:
http://www.celiac.com/st_main.html?p_catid=15

Also, please make it law that restaurant and other retail food and drink businesses MUST DEVULGE the contents of such ingredient umbrella terms as: "Natural Flavors" or "Artificial Flavors" or "Modified Food Starch", or any other additive that can potentially contain gluten or has been processed with it. I am a part-time employee of Starbucks and have been unable to get this information from them concerning the natural flavors their white mocha sauce and their caramel sauce, both of which cause reactions. They claim that only the java chips contain gluten, but I think that they may not know about all the ways that gluten can hide. Most people don't seem to know. They say that they can't devulge the contents of their natural flavoring as it is proprietary information, regardless of my health concerns and the potential health threat to many other people. This is morally wrong. PLEASE MAKE IT ILEGAL!
Thank you,

Ann S. Petersen