2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1009
Submitter : Mrs. Deirdre Ward Date & Time: 09/20/2005 03:09:56
Organization : Mrs. Deirdre Ward
Category : Individual Consumer
Issue Areas/Comments
Dear Sir/Madam,

Below are my comments regarding Gluten-Free (GF) labeling.

GF on a food label should mean that the product was manufactured in a dedicated GF facility, that all of the raw ingredients as well as the final product have been tested to ensure that they are completely free of any traces of gluten or gliadin. My reasoning is any trace of gluten in a product will make me and those afflicted with celiac disease or other levels of gluten intolerance deathly sick, so GF labeling must mean zero gluten.

I currently spend several hours a day contacting manufacturers only to find that at least 99% of products listed as GF contain up to 30 PPM of gluten. And since manufacturers change facilities and recipes, this research is never ending because I must continually confirm the GF status of GF labeled products. And every time I go to the grocery store I have a bag full of GF labeled products to return because my research shows that they are not in fact GF.

Currently 100% of my purchases are labeled GF, these products include cold cuts, condiments, vitamins, supplements, beverages, cereals, desserts, chips, flours, spices, coffee/tea, skin care products, shampoos, toothpastes, all processed items. Although I am finding that this labeling is proving in most cases to be useless.

Currently I always choose items labeled gluten-free (in the hopes that I am protecting myself and my family from gluten associated illnesses) vs. choosing a similar product with the same ingredients w/o the GF labeling. As mentioned above the GF labeling is no guarantee that these products are actually GF and most often it is due to the product being manufactured in a non GF dedicated facility.

A multi-level definition of GF labeling would not be helpful. Either a product is completely GF or it isn't; it's that simple. People with gluten intolerance and associated diseases cannot consume any gluten containing grain or their derivates in any amount, trace or otherwise without having serious health problems. The Congress and the FDA have to understand that GF labeling must mean that absolutely no gluten in any form exists in the product or the labeling is useless.

My entire family, parents, siblings, nieces, nephews, cannot consume any gluten in any form or in any amount. The current GF labeling is useless as my research has uncovered. Currently a GF labeled product usually means that the raw ingredients as listed on the product are non- gluten. However, suppliers of the raw ingredients are not required to test their products to ensure that they have remained GF. Further, the manufacturing process can occur in a facility that processes gluten containing products. No matter how sanitary this type of facility is or the type of cleaning methods employed between product runs, there probably is gluten residue in the air, on surfaces or in crevices that cannot be reached during a cleaning process, etc. Even if the risk of cross contamination at these facilities is 1%, that is still too great for people who must avoid gluten completely. For celiacs and other gluten intolerant people, the amount of gluten that can cause adverse reactions is at the microscopic level.

Please help those of us (at least 1 in every 125 americans, and that number is increasing daily with new diagnostic tests) with gluten intolerance identify foods that are safe for us to eat by requiring strict guidelines for GF labeling. Please make GF labeling mean that the product contains 0 PPM of gluten and 0 PPM of gliadin, that the product has been processed in a dedicated GF facility, and that all raw ingredients are 100% free of gluten.

Thank you for your consideration.