2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC898
Submitter : Ms. Jennifer Dodd Date & Time: 09/14/2005 05:09:05
Organization : Ms. Jennifer Dodd
Category : Individual Consumer
Issue Areas/Comments
GENERAL
GENERAL
Dear FDA:

I was diagnosed with ciliac disease when i was 3 years old. I am now 27, and living on my own. PLEASE consider making 'gluten-free' labeling a manditory regulation. I support companies which have begun to label foods with the warnings 'contains gluten'', etc. I have had a lot of practice reading labels, but many newly diagnosed or less trained patients are not and either eat glutenous foods unknowingly, or overly restrict their diet in fear of doing so due to confusing labeling of ingredients. Also, often times friends and family members, unaware of the complexity of ingredients containing gluten, buy items thinking they are safe, simply b/c they do not say 'wheat' or 'gluten' on the label. Eating at someone's house is then always limited, b/c you cannot trust that they have correctly interpreted the ingredients of the meal. Living with Celiac is hard enough, but imagine going to a dinner party and being limited to the salad, minus the dressing...

I have often attempted to buy frozen meals for lunches at work. I challenge anyone, even with a firm knowledge of what ingredients to look out for, to search the frozen food isle for gluten free items. The result is usually one item in 45 minutes of searching....

Please, make labeling a mandatory regulation.

Thank You,
Jen Dodd
(Edison, NJ)

In addition, please take into account the following statement:
We encourage you to adopt a regulation on the use of 'gluten-free' on 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--20 PPM for products that contain naturally gluten-free ingredients, and 200 PPM for products that have been rendered gluten-free such as those that may contain Codex Alimentarius quality wheat starch. The formal adoption of these existing regulations will allow for the continued importation of 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 because 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 that will 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 with celiac 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