2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1255
Submitter : Mr. Jerry Sullivan Date & Time: 09/20/2005 05:09:27
Organization : Mr. Jerry Sullivan
Category : Individual Consumer
Issue Areas/Comments
1. Gluten-free on a food label should mean no wheat, rye, barley, or oats, or any ingredients derived from them (i.e. modified food starch, malt flavoring, distilled vinegar, etc.). This is the strictest definition of a gluten-free diet. There is a current controversy about oats (and to some extent vinegar) and whether they can be safely eaten by a celiac. For celiacs who choose to eat oats, they can read labels and identify what foods they want to eat. The majority of celiacs could then depend on a food label to protect them.

2. I use two methods to identify foods that do not contain gluten. First, I use the Celiac Sprue Association's Food Guide because these are foods that the manufacturers are willing to commit to as being GF. With the current environment of suing anyone and everyone in court for anything, I feel confident that these foods are as advertised by the mfg. Beyond that, I read food labels. Anything suspect - modified food starch, oats, etc. is reason to skip the food.

3. I purchase approximately 40% of my foods that are marked gluten-free. The remainder are foods that have been identified in the CSA Food Guide as being GF although they are not labelled as such. I almost never eat suspect food because it is not worth it to me. I know what products I can eat and which ones I can't, but I have been a diagnosed celiac for over 10 years. Newly diagnosed celiacs that I meet are overwhelmed by what it takes to find acceptable food. Food labeling that was accurate and dependable would be a great service to these people.

4. I do not read as many food labels after 10 years as I once did. I have identified foods that I can eat and basically stick with them. I do not compare GF and non-GF ingredient lists to determine if I should buy a product. I depend on the manufacturer themselves committing to it being GF. For example, if Product A is GF and Product B has the same ingredients, I will not buy Product B unless the mfg. has stated it is GF. Why? There are many issues in the mfg process, like common equipment, airborne particles, etc. that could contaminate a product. If the mfg is not willing to certify a product as GF, I will skip it.

5. Allowing multiple levels within the definition of Gluten Free would be a major mistake and cause unnecessary confusion for celiacs. There are enough issues today with educating consumers on what they are buying that adding an additional level is ridiculous. My knowledge of the current science is that there is no way to determine what level of "trace amounts" would not cause harm to a celiac. How would a person who is a celiac determine if they could eat Level A food but not Level B food? The medical community today is still not educated to the level where your local doctor knows enough about it (although it is definitely better than 10 years ago when I knew more about the diet I needed to be on than the dietician I was referred to). I see no justification for needing two levels. If there were only 2 products in the whole world that were GF and all celiacs would starve without Level B food I might be able to understand needing it. That is not the case. Creating confusion for consumers is not necessary. I also do not believe it is necessary for the food industry to be able to produce sufficient quantities and varieties of GF food. Would allowing trace amounts mean lower prices for consumers? Maybe, but there is no guarantee. Will the big food businesses (Conagra, etc.) stay out of the GF market without Level B? Maybe, but today there are many companies that specialize in GF food that I'm sure will continue.

Requiring GF labeling, and requiring that no oats be present as a condition of the GF definition, is the safest way for celiacs to be protected. The strictest definition will protect all celiacs to the maximum degree possible. Those celiacs who choose to eat oats can still do so but no celiacs
would be exposed to them unknowingly.