2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1314
Submitter : Mr. Lawerce Bowers Date & Time: 09/20/2005 05:09:43
Organization : Mr. Lawerce Bowers
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
I am writing this because of the changes on food labels you are considering. It is very desirable to have food marked as to whether or not celiac patients would be safe eating this product. It is not sufficient to just list the ingredients as they have questionable terms such as a ?malt? as it may or may not have gluten in it.

I have been asked if I have any comments on proposed labeling of food that is safe for celiacs to eat. I was very surprised to learn that the term ?gluten free? did not refer to foods that do not have any gluten in them. Therefore I feel that using the term ?celiac safe? instead of gluten free better describes these foods.

I am not sure how many parts per million of gluten should be allowed to be called celiac safe. My doctor told me that it would not be safe to eat foods that had gluten in them even though they did not cause a reaction because the agitation from these foods could cause cancer of the intestines over time. I feel that doctors in the field should determine the acceptable level of gluten in a product to be considered a celiac safe food. Different celiacs have different degrees of sensitivity to gluten. Perhaps different levels of celiac sensitivity could be assigned to a food depending on the PPM of gluten in the food if cancer is not a problem.

Celiac safe foods should be processed on machines that are only used for celiac safe foods or the manufacturer should be required to make tests for the amount of gluten in the product on a continuing basis because of the possibility of cross contamination.