2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC880
Submitter : Mr. michael centomani Date & Time: 09/14/2005 05:09:06
Organization : college of dupage
Category : State Government
Issue Areas/Comments
GENERAL
GENERAL
We encourage you to adopt a regulation on the use of 'gluten-free' on the product labels that is in line with that which has been used in Europe and other countries(including the USA via the Codex Alimentarius)for many years--20PPMfor productsthat containnaturally gluten-free ingredients,and 200 PPM for productsthat have been rendered gluten-free such as those that may contain
Codex Alimentarius quality wheat starch. Th formal adoption of these exsisting regulations will allow for the continued importation of the excellent,safe European products that are labeled 'gluten free'.

It is very important that you DO NOT adopt a 'zero tolerance' regulation in this matter baecuse doing so will cause many gluten-free food companies to discontinue their use of the term 'gluten-free' on their labels out of fear of litigation--which is counterproductive for all people with this disease (most, if not all,gluten-free food companies do not grow, transport or mill the gluten-free grains that they use as ingredients--a fact thatwill make them vulnerable to litigation if a zero tolerance level is adopted). Last, the inclusion of trace levels of gluten in the diets of those withceliac disease have been shown
to be safe in many scientific studies, for more details please see: http://www.celiac.com/st_main.html?p_catid=15.

In closing I just want to say that my daughter Victoria Centomani has Celiac disease. She is thirteen years old as is a precious gift from God to me. For Victoria, and all the wonderful children who have celiac disease, please help make their lives a most rewarding and joyous one.

Thank you,
Michael Centomani