2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC110
Submitter : Mr. Richard Turner Date & Time: 08/19/2005 09:08:14
Organization : Member of Celiac Sprue Assn., also TCCSG
Category : Individual Consumer
Issue Areas/Comments
Ladies and Gentlemen:
This comment is in regards to Docket #2005N-0279 regarding Food Allergen Labeling, specifically as it pertains to the FDA defining 'Gluten- Free'.
As you may know people diagnosed with Gluten Sensitive Eneropathy or Celiac disease or the form of the disease that also manifests with an itchy skin rash--Dermatitis Herpetiformis must adhere strictly to a gluten free diet for life. Even miniscule amounts of the protein will cause a reaction in our small intestines that results in very unpleasant symptoms, including uncontrollable diareah and gas; and, leads to an increased risk of many other life-shortening diseases--not to mention the obvious near-term effects of the malabsorption of needed nutrients.
With the fairly recent advent of simpler and much more definitive blood tests and the acceptance of Dr. Alessio Fassano's statistical study proving the prevalence of the disorder to be much more common (1 in 133 people) than had traditionally been believed (1 in 3,000); the number of us diagnosed with Celiac disease will certainly increase many-fold in the near future. ALL of these newly diagnosed sufferers will benefit immediately and immeasurably from an understandable, consistent labeling pattern assuring us that products labeled 'Gluten-Free' really are, and that the words 'Gluten-Free' upon the label can be relyed upon to guarantee that fact.
No lower threshold has been found that will guarantee to avoid the 'gut reaction'; therefore we must avoid ANY FOOD THAT MAY CONTAIN ANY GLUTEN AT ALL!
So, 'Gluten-Free' must be understood to mean: 'conaining no gluten by the nature of the ingredients or thru any additives, preservatives, spices, flavorings, excipients or inadvertent cross-conamination'....in short as far as we can test the product is indeed free of any Gluten. If this can be assured the labeling will be of great value to Celiacs; if not it will be of less than no value since we'll be tricked into sampling products we might otherwise not try based only on those words: 'Gluten-Free', and the result may be the reaction we're trying to avoid.
With current labeling standards (no standard, really) we face a constant challenge in our modern markets, so full of processed foods, to find ones that won't make us sick. Indeed, many foods one might assume to be safe turn out to be contaminated, or additives used may make the food unsafe for us to even try. Foods you take for granted present us with a guess-work decision about puchase/consumption versus long-term health. If we can't trust the plain-language words: 'Gluten-Free' we will have accomplished nothing.
Even many alternative grain products used by celiacs are made in mills that also process wheat, barley or rye and, therefore may be contaminated if not tested and inspected; then so labeled. If that's assured by law we'll have come a long way!
At present we must pursue manufacturers (who usually don't want to commit for legal reasons) to tell us if a particular product is safe, yet some products are gluten-free but not so marked, and others that seem likely safe can't be guaranteed because of the inability of the makers to trace the source of some ingredient. It's VERY FRUSTRATING! Celiacs spend an average of 5-times the time shopping as others for these reasons...we have no choice!
At present about 1-percent or less of the products on market shelves are marked 'G-F'-- and we're not even certain about those without mandated rules and testing/inspecting procedures.
If we could have products that we can trust to be tested/inspected to really be 'G-F' before they're so labeled--WHAT A GODSEND that would be. That alone would be THE deciding factor in my grocery buying decisions--certainly in ALL the cases of products with same or similar ingredients.
If products containing gluten were labeled: 'contains gluten' or ' may contain gluten' that would relieve some anxiety as well, since we have no
way to home-test for gluten.