2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1037
Submitter : Mrs. Rebecca Davis Date & Time: 09/20/2005 03:09:31
Organization : Mrs. Rebecca Davis
Category : Individual Consumer
Issue Areas/Comments
1. 'Gluten-Free' on a food label should mean that NO INGREDIENT has gluten or even POSSIBLY gluten. For example, dextrin can be made from corn, potato, arrowroot, rice, tapioca or wheat. Major dextrin-producing companies in the US say they use corn. However, imported dextrin could be made from wheat. Companies should be required to state which ingredient the dextrin is made from. The FDA requires this type of detail with Hydrolyzed vegetable protein (HVP) or Hydrolyzed Plant Protein (HPP). Ten years ago the FDA said food processors had to identify the vegetable or plant by name. So, food labels might list ?hydrolyzed wheat protein? (unsafe) or ?hydrolyzed soy protein? (safe), for example. This should be require for all ingredients if it is going to be 'gluten-free.'

2. I identify gluten-free foods by research on the internet and calling the companies directly. Its very time consuming and extremely frustrating if I am hungry and the only thing to eat that is available has a 'questionable' ingredient like DEXTRIN where it is possible this ingredient doesn't have gluten but it still might. If in doubt, I can't eat it.

3. Very little food in the regular grocery store have anything labeled gluten-free so therefore I cannot buy very much unless previous research has been done.

4. If I had to choose between one food package labeled with 'gluten-free' and the other doesn't have the label and the ingredients are exactly the same, I would choose the package labeled with 'gluten-free.'

5. I think a two or more level definition would be very useful. It would allow me to have an even greater control of the amount of gluten I would eat. It allows there to be a 'grey area' instead of just a 'black and white area' which might allow me to choose a trace gluten food to eat during a celebration. If there was not label like this, where I didn't know the exact amount gluten, I would most likely abstain from eating.

I believe by creating a standard or labeling system, you are improving people's quality of life on a daily basis. This system would provide security and a 'free-ness' that most people with Celiac's don't experience. I believe this should be a federal decision instead of state so that no matter where a constituent travels in the US, the confidence in the food labeling will provide security. This security will take away an unnecessary stress that comes with wondering, 'If I run out of food while I am traveling, am I going to be abble to find anything to eat, that I will no for SURE, doesn't have gluten.'
I also think, because of the seriousness of celiac's, in regards to negative impact on the body, this labeling system will help provide a tool and an additional resource for people to be as healthy as they can.

I hope this labeling system will be approved.

Thank you for your time.

Rebecca L. Davis
Olathe, KS 66061