2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC223
Submitter : Ms. Julieanne Hensley Date & Time: 08/29/2005 11:08:10
Organization : Ms. Julieanne Hensley
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
The FDA has four main questions that they are trying to address:
1. What should "gluten-free" mean on a food label? Why?
It should mean there is no gluten in the food. It should be tested, and verified that it is uncontaminated with even trace amounts. Because even trace amounts make people sick - and those allergic to a gluten bearing grain, those celiac, and those intolerant to gluten WILL get sick from even trace amounts.

2. How do you identify foods that do not contain gluten? And Time
spent identifying foods?
I read labels EVERY TIME I shop for food. I make a point to know all the tricky terms the manufacturers use to describe foods that may have gluten - "modified food starch", dextrin, etc. I should NOT have to memorize chemical names to be able to eat safely. The labels should be clear and explicit - if there is "modified food starch" in something, it should say WHAT it is made from. And getting it from a secondary source is no excuse for not knowing or properly labeling what is in a product. Many manufacturers outsource oil or vitamins or whatever - which may or may not have gluten added to them - and as they don't know, they don't label them. This is unacceptable.

3. What percentage of foods and which types purchased are marked
"gluten-free"?
I don't buy anything unless it is gluten free. I have been made seriously ill by foods which are not supposed to have gluten but do - such as Quaker Rice Cakes, for example. The label says rice and salt, but independent labs have tested it and determined it is heavily contaminated with wheat. I read that AFTER I was sick for a month after consuming their supposedly safe product. To be fair, they do not claim their rice cakes are gluten free, but they only list rice and salt on the ingredient label.
Food labels MUST BE complete, understandable and accurate.

4. Does "gluten-free" printed on a product label influence your decision to purchase products having the same ingredients? And to what extent?
It does for products from the same company. If Amy's organic says it's gluten free, I will buy it, as I have had their foods before and have not gotten sick. If Quaker Oats says something is gluten free, I wouldn't touch it with a ten meter cattle prod - having paid the price for misplacing my trust in them before.
A universal standard for gluten free would go a long way to prevent accidental exposures - and the resulting hospital visits, doctor's bills, and lost productive time, not to mention the pure misery and even risk of death. But if the standard is set too low, it won't help at all. People will be getting sick and dying without knowing why.

Labels MUST be clear, consise, readable to those without a chemistry degree - and above all - HONEST and ACCURATE. Not only for gluten bearing foods, but ALL foods. There are more than eight food allergies - every food is an allergen for someone. Some people are so sensitive they react to the corn in Dixie Cups and in the detergent used to wash hospital gowns. If labels were complete, clear and accurate, almost all hospital visits, medical bills, and even deaths due to accidental exposures would be eliminated.

And whether you're talking about celiac or allergy - death is a very real risk. Anaphylactic shock kills hundreds of people a year in this country. As does colon cancer, and other complications of celiac which result from the damage done by ingesting even trace amounts of gluten.

Please set the standards for food labels at the very highest possible - to save lives, to save money, to help hundreds of thousands of people in this country who have to struggle every day simply to find something safe enought to eat.

Comments are due on or before September 19, 2005 and to be addressed to
FDA Docket #2005N-0279 to become public record.