2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1018
Submitter : Mr. John Regan Date & Time: 09/20/2005 03:09:13
Organization : Mr. John Regan
Category : Individual Consumer
Issue Areas/Comments
Thank you for your attention to this important matter. Our response to relevant questions regarding the importance of 'Gluten-Free' Labeling are as follows:

1) What should 'gluten-free' mean on a food label? Why?

'Gluten-Free' labeling according to the Food and Drug Administration should mean: Absolutely NO chance of any of gluten present through food processing, flavoring, food coloring, cross contamination, etc. - without exception. Diets free of gluten are essential to the well being of millions of Americans who can suffer long term effects from even trace amounts of gluten. The cure is simple - No Gluten - period. The roadmap to this cure is also simple - provide clear, concise and accurate labeling. Those afflicted with Celiac Disease can do the rest.

2) How do you identify foods that do not contain gluten? Time spent identifying foods?

We rely almost exclusively on product labeling to ensure our well-being. We estimate that we spend 1 hour per week identifying foods free of gluten.

3) What percentage of foods and which types purchased are marked 'gluten-free'?

Approximately 5% of the 'conventional' foods we purchase are labeled 'gluten-free'. Most of these products are dry goods such as cereal, pasta, crackers, etc. These are mainly found at high-end grocery stores which cater to natural or organic shoppers or through mail orders. Very few meats, deli products, etc. are labeled gluten free although many may actaully be free of any wheat products.

4) Does 'gluten-free' printed on a product label influence your decision to purchase products having the same ingredients?

Yes, but not without caution. For example, many products are made using modified food starch, which is usually made from corn and is, therefore, gluten-free. Modified food starch, however, may also be made from wheat. Ambiguous labeling such as 'Modified Food Starch' may result in the inadvertent ingestion of gluten. Such inadvertant ingestion, even on the smallest scale, may result in long term expose to gluten which can result in terminal illness (i.e. cancer). This type of exposure is easily avoidable with accurate labeling.

5) Would you consider a two or more level definition of gluten-free helpful? No.

Thank you for your consideration.

Respectfully Submitted,

John E. Regan
Chelmsford, Massachusetts