2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC523
Submitter : Ms. Mary Courtney Date & Time: 09/09/2005 06:09:12
Organization : UCLA, Celiac Disease Fndt, Celiac Sprue Assoc.,
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
I'm a sensitive celiac and local celiac support group leader. I have adhered to a gluten-free diet for twenty years. I would like 'Gluten-Free' on a label to be safe enough for me and for newly diagnosed celiacs to eat with no danger of inflammation. In the past, when my body has reacted negatively to certain brands of rice crackers and rice flours, I've talked to the manufacturers and learned that the facility produces products with gluten in them. I would like to be protected from such products. Happily for me, the same manufacturers now claim that the products are made in the same facility with gluten products. That is a help for all celiacs--even those that don't react so overtly, but who want to stay inflammation- free and cancer-free.

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What should 'gluten-free' mean on a food label?
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I experienced a big health setback because celiac disease was not diagnosed for many years, so I still tend to fare better with products that claim to consistently fall far below 500 parts per million (PPM or mg/kg) (the current Codex Standard), such as Bob's Red Mill polenta and other products made in gluten-free facilities. 'Gluten-Free' should mean much less than the current Codex Alimentarius standard for gluten-free: some measurable value below 50 PPM might be considered a 'Gluten-Free' end product, and an end product with less than 200 PPM might be called 'gluten reduced.' Because the world is getting smaller, alignment with international standards makes sense as these standards change with better and more feasible testing.


In peer-advising newly diagnosed celiacs, I've learned how mind-boggling the diet is for someone who doesn't feel well yet. I'd like to be able to say to a new celiac, 'If you have to buy a manufactured product, stick with the ones that can claim to be 'gluten-free,'' and not have to worry about them having a reaction.

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How do you identify foods that do not contain gluten?
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I start with health food stores' shopping lists; some of them have researched the ingredients, secondary ingredients, and manufacturing processes that I can't collect. Then, I spend time spent studying the label for disclaimers about gluten or secondary ingredients such as tomato paste that may have hidden gluten. I have other food intolerances, so I?m screening for them. I've spent hours in a new store trying to find what I can eat. Sometimes I spend an extra half hour looking in my regular stores for new GF products.

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What percentage of foods and which types purchased are marked 'gluten-free'?
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Some of the manufacturers have already started voluntary labeling, so I would guess that of the few processed foods I buy, about a fourth of them say 'Gluten-free' and most of them are the expensive cereals and baked goods. The rest that I buy don't have additives, and/or I have researched them carefully. But, this limits what I can buy even in health food stores, and greatly limits what I might buy in a supermarket.

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Does 'gluten-free' printed on a product label influence your decision to purchase products having the same ingredients?
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A 'Gluten-Free' label influences me in a positive way. With special labeling on the horizon, I'll be looking for 'Gluten-Free' marked items that formerly had possible hidden glutens from the manufacturing process. Examples include corn tortillas, tomato products, chips/snacks and thickened foods.

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Would you consider a two or more level definition of gluten-free helpful?
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I wouldn't mind a multi-level definition of 'gluten-free,' such as I mention above, but my family members, rare dinner hosts, and others trying to cook for me might find it confusing. I prefer that 'Gluten-Free' mean only the presence of trace amounts (something less than 100 PPM) of gluten, that testing be at reliable intervals, and that disclaimers be present on labels when gluten products are manufactured in the same facility, especially if made on the same line.