2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC255
Submitter : Ms. Rose Wilson Parvaz Date & Time: 08/29/2005 12:08:51
Organization : Ms. Rose Wilson Parvaz
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
1)"Gluten-free" on a food label should mean that the product is 100% gluten-free, made from unquestionably gluten-free ingredients and not cross-contaminated in any way BECAUSE not everyone with Celiac Disease has a clear and visible response if they ingest gluten. My 9yo daughter, who was finally diagnosed with CD when she was 4yo, had no easily discernible symptoms such as diarrhea. She had juvenile diabetes and was too short and underweight. Her bloodwork and biopsy revealed the CD. If she were to accidentally ingest gluten now, I would have no way of knowing it. Yet the damage would be done. It would take up to six months to recover from ingesting even a Cheerio. Her growth and brain development would be effected, as would her diabetes control. And I wouldn't even know why.

2)I identify foods that do not contain gluten by reading the label. First, I look for the words "gluten-free". If that fails me (as it usually does), I turn to my CSA Gluten Free Product Listing (hereinafter "Listing"). If the product is not in the Listing but its ingredient list appears to indicate that it might be gluten-free, I contact the company. (I start by checking the website. If that doesn't answer the question, I phone or e-mail.) Too often these days, a fairly uninformed company rep then states that if a gluten-containing ingredient were in the product, it would be clearly stated. I am not comfortable with this information. I want to hear "That product is gluten-free" stated loud and clear before I will consider feeding it to my daughter. I do not want to hear, "Our policy is that if the modified food starch [or whatever] contained gluten, we'd write wheat [or whatever] somewhere on the label." That's not definite enough for me. The stakes are too high. If they can't flat out state that the product is gluten-free, she's not going to eat it. Kraft (among others) now follows this policy; they used to product a gluten-free product listing, but not anymore... I spend on average an hour a week identifying gluten-free foods. We have our usual repertoire of foods, but something new always seems to come up, particularly when it comes to medication.

3)Exclusive of produce and dairy, nearly 100% of the foods I purchase for my daughter are expressly marked "gluten-free". (We are vegetarian, so that eliminates the meat group.) I purchase the food items generally either from a health food store or from Glutino, a company in Canada that makes its own gluten-free food and imports from Europe. These include bread, cookies, pasta, crackers, breadsticks, and the like. In addition, I purchase Amy's frozen foods that are clearly marked "gluten-free". Other than Amy's, most of the marked "gluten-free" food items I purchase are not available in a regular grocery store.

4)"Gluten-free" printed on a product label influences my decision to purchase the product 100%. I will ALWAYS choose the labeled product over the unlabeled one, even if both appear in the Listing or if I have assurances from the company. I like it when a company will stand behind its "gluten-free" assertion so much that it will print it on the label. (If the two products are not labeled as stated but only one appears in the Listing, I make the same decision.)

I WOULD SPECIFICALLY LIKE TO SEE GLUTEN-FREE PRODUCTS LABELED "GLUTEN-FREE", RATHER THAN HAVING TO RELY ON READING LABELS, WEBSITES, AND COMPANY ASSERTIONS. IT WOULD MAKE A HUGE DIFFERENCE IN OUR LIVES.

5)The only way in which a multi-level definition of gluten-free would help me is that it would enable me to avoid purchasing anything other than products that are absolutely 100% gluten-free.

Rose Wilson Parvaz
rose.parvaz@celebration.fl.us
201 Ficus Street
Celebration, FL 34747
407-566-0125