|2005N-0279||Food Labeling; Gluten-Free Labeling of Foods; Public Meeting|
|FDA Comment Number :||EC1387|
|Submitter :||Dr. Betty Bernard||Date & Time:||09/20/2005 06:09:34|
|Organization :||USC Keck School of Medicine - retired|
|Category :||Health Professional|
| Edited version>delete previous one! FDA Docket No. 2005N-0279 9/18/2005
1. WHAT SHOULD GLUTEN FREE MEAN ON A LABEL. WHY? Gluten-free should be defined as NO Gluten, and it is not a product produced in a plant where airborne contamination could occur, or where the same equipment is used for Gluten containing products.
The less than 20ppm serves industry more than the patient - at what point is the cellular damage is tweaked by what level of gluten has as many answers as how many people respond to the same e.g. sunburn dose - due to multiple genetic factors present. State the <20 ppm gluten may be in product - as they do for peanuts now.
The risks for increased secondary manifestations of autoimmune disorders and malignancy are too great to be arbitrary about what gluten-free means. I will advise patients to only select Gluten-Free items. I am a celiac of 71 years and unwilling to have a " touch of gluten", or even a touch of pregnancy.
2. HOW TO IDENTIFY GLUTEN FREE FOODS? TIME SPENT/?
Reading labels is a constant past time at the markets - which doubles time spent shopping very often. When I cannot discern the gluten-free status of a vaguely labeled item, I leave it on the shelf. When dining out - simply broiled meats and vegetables are safest unless one can have a long talk with the chef before ordering. Fresh vegetables/fruits/meats and fresh frozen vegetables/fruits are the most used, but labels scrutinized carefully for products used to dust items to keep from caking or glazed in any way. If a stomachache/diarrhea occurs - then lesson learned and put it on the NO list. The latter is a dangerous way to determine gluten-free status of products.
Hospital dieticians are the most poorly informed - I have to have a snicky fit with them and the pharmacists again and again, and then supply to them my own regular medications, bread, broth, etc. items. Hospitalization is a real nightmare that the entire celiac community has had to deal with ? being poisoned in the hospital by gluten. The doctors and pharmacists are usually no better informed than the dieticians. They put/see gluten-free diet on the orders and they take away milk, butter, fruit, everything you might be able to eat, but they do not forget the roll or gravy ? or a slice of manufactured turkey, ham etc. which has been glued together with a gluten product. I order plain hamburgers to avoid that, or broiled chicken. Fake crab has gluten in it and most of the soy/terryaki sauces they use have wheat in them. It is a crapshoot at best to remain gluten free in the hospital ? so labeled foods/meds just might help the patient to survive while they are in the hospital to avoid becoming sicker because of sheer laziness and stupidity about a gluten-free diet/medications.. Personally, my arthritis flares nastily when in the hospital because of this. Please have all labels state mean Gluten-Free.
3. WHAT PERCENTAGE OF FOODS AND WHICH TYPES ARE MARKED GLUTEN-FREE?
Health food stores 2-3%, Safeway, etc., <0.05%.
Breads, corn, rice, bean pastas, cookies, flours are the most common with a gluten-free designation. Dairy products have none, but so many of the
| yogurts have food starch, cereals have malt and barley syrup, medications have coating on tablets, fillers, etc. Problem is that when you call manufacturers - you must ask what are ALL of the ingredients - not only those on the present label. You cannot ask if an item is gluten-free for they usually do not know what they are talking about.
4. DOES GLUTEN-FREE PRINTED ON A PRODUCT LABEL INFLUENCE YOUR DECISION TO PURCHASE PRODUCTS HAVING THE SAME INGREDIENTS? TO WHAT EXTENT?
100% influence to purchase the gluten-free labeled item.