2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1353
Submitter : Ms. Robin Watters Date & Time: 09/20/2005 05:09:57
Organization : Ms. Robin Watters
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
Ladies and Gentlemen-
Our son Rob was recently diagnosed with Celiac Disease. Six years ago he was diagnosed half way into his freshmen year of high school with Type I diabetes and manages it with an insulin pump, exercise and carbohydrate counting. We are familiar with reading labels for carbohydrate/fat content. Now we have more information to look for in order to rule out products that contain Wheat, Rye, Oats and Barley(WROB). We have been told to watch for wheat in labels that contain "mondified food starch & natural flavoring" which then requires us to call manufacturers to determine if the basis is wheat/gluten based. A the age of 20 and a student this places even more stress on his daily life.
Please help our son by simplify this process with clearer more susinct labeling and decrease the complications he must live with every day. IN addition see the request below-
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

Thank you,
Your Name
Robin Watters