2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1100
Submitter : Mrs. Nadine Ernst Date & Time: 09/20/2005 03:09:53
Organization : Mrs. Nadine Ernst
Category : Individual Consumer
Issue Areas/Comments
Dear Decision-Makers at the Food & Drug Administration:

I am writing to ask you to adopt and enforce regulation(s) requiring the use of 'gluten-free' on product labels. Specifically, in the interest of time and consistency in today's global marketplace, I encourage you to look at and model what has been used in Europe and other countries, where people are far more aware of this disorder, and whose societies have more experience coping with it.(While known in Europe for nearly 100 years, Celiac was not documented by the NIH until the late 1990's)

The formal adoption of these existing regulations will allow for the continued importation of excellent, safe European, Australian and Canadian products that are labeled 'gluten-free.'

It is also important that the FDA not adopt a 'zero tolerance' regulation in this matter. A Zero-tolerance regulation would open the doors to voluminous litigation, which would result in fewer producers of these products so vital to the survival and well-being of so many people.

As the mother of a 12-year old with Celiac, I can speak first-hand of the difficulties of feeding this child, both from trying to shop in a traditional food store, to the expense of the alternative, health-food stores. Celiacs face more difficulties than sufferers of many other single food allergies, because wheat, rye, or barley are more common ingredients in foods than nuts or dairy, or soy.

To fully understand the importance of this issue, the next time you shop in a grocery store, imagine you cannot eat anything containing 'food starch', 'modified food starch', 'vinegar' (which must be avoided because labeling does not indicate the source grain). You must also avoid anything containing wheat, rye, barley, or their derivatives (e.g. barley-malt), including beers, ales, and malted beverages.

Things that one wouldn't think are problematic include certain flavored potato chips, honey-roasted nuts, all commercial cereals, most commercial salad dressings, all vinegars except apple cider vinegar, condiments, most commercial soups, canned broths, even some popular ice cream brands such as Ben & Jerry's, nearly all brands of vitamins, some critical medications.

Please help Celiacs be healthy by adopting regulations to more clearly detail the sources of the ingredients of foods, cosmetics, and drugs.

Nadine Ernst