2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC280
Submitter : Mr. Jeffrey Natterman Date & Time: 09/01/2005 05:09:39
Organization : Mr. Jeffrey Natterman
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
Gluten free means no gluten...at all! Levels of contamination are meaningless for celiacs. Celiacs can suffer intestinal damage with miniscule amounts, so if the label says gluten free, the consumer must be confident that "zero" amount of gluten is present in the product.

To achieve "zero" gluten status requires that no basic grains (wheat, rye, etc.) are not used, but also that the product is made in a dedicated facility to ensure no cross contamination. Also, derivative ingredients containing any gluten must not be used in the final product. If a manufacturer cannot guarantee that subcontractor suppliers use no gluten containing products, then the product should not be considered gluten free at all.

It may be of some help to less concerned celiacs if a manufacturer states on their product that even though the product is gluten free, the facility is not and cross contamination may have occured.

BOTTOM LINE: IF THERE IS EVEN THE REMOTEST CHANCE A PRODUCT CONTAINS ANY GLUTEN, WAS EXPOSED TO GLUTEN WITH THE POSSIBILITY OF CROSS CONTAMINATION, OR WAS PROCESSED ON THE SAME EQUIPMENT AS NON- GLUTEN PRODUCTS THEN THE MANFUFACTURER SHOULD NOT PUT THE WORDS "GLUTEN FREE" ON THE PRODUCT.

THANK YOU FOR CONSIDERING THIS COMMUNICATION!