2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1264
Submitter : Mrs. Ellen Winkler Date & Time: 09/20/2005 05:09:19
Organization : Mrs. Ellen Winkler
Category : Individual Consumer
Issue Areas/Comments
1) What should ?gluten-free? mean on a food label? Why?
Gluten free must be free of wheat, rye and barley including their derivatives. It is essential that a person with Celiac disease not ingest gluten to maintain optimal control of the disease and its associated symptoms. "Lumping" ingredients together such as "spices", "flavorings", etc. are misleading and can be damaging for a celiac. Dietary control is the best means a celiac has for preventing disease complications.
2) How do you identify foods that do not contain gluten? Time spent identifying foods?
I read labels. I have had to learn what ingredient names really are. It is very confusing to read a label and understand exactly what is contained in the scientific name. I initially spent 2 hrs to complete my grocery shopping while learning to read labels. I also would call the manufacturer for any product with "hidden" or "undefined" ingredients such as modified food starch. This was very time consuming. Celiacs have been instructed to continue to call manufacturers as they frequently change ingredients. I still read every label but now better recognize forbidden ingredients. I prefer to shop in "regular" grocery markets due to pricing of products. Health food stores are pricey and many of the specially prepared foods are not tasty. For this reason, I try to buy as many products as I can at a store such as Krogers. Proper labeling of gluten free would greatly enhance my ability to purchase foods at a reasonable cost.
3) What percentage of foods and which types purchased are marked ?gluten-free??
Approximately 25% of my grocery purchase is marked gluten-free. As stated above, I prefer to shop in regular grocery stores so I read labels and identify gluten free foods in that manner. Gluten free labeled foods that I purchase from a health food store include: bread products; pasta; baking mixes; bouillon; canned and dry soup; and crackers/cookies.
4) Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent? Example:Two cans of tomato sauce on the shelf both contain only tomatoes and salt and only one is marked gluten-free.
I am an RN and work in a hospital with dietitians available to me. I have been very fortunate to have ready education related to reading labels that the general celiac population would not have. For this reason, I would not be influenced by the presence of "gluten free" on the label of 2 similarly prepared products. I would buy based on taste in this instance.


5) Would you consider a two or more level definition of gluten-free helpful?

Example: If Level A meant the absence of any wheat, barley, rye, oats and any of their derivatives and level B meant the presence of trace amounts, less than "X" parts per million, of wheat, barley, rye, oats and any of their derivatives and level C meant the presence of small amounts, less than "Y" parts per million, wheat, barley, rye, oats and any of their derivatives. (Using "X" and "Y" to identify quantities to be determined by the FDA.)

Iwould find this labeling very helpful. A physician specializing in the treatment of celiac disease spoke at a conference I attended last year in Columbus Ohio on Celiac. He cautioned celiac patients to not "overreact" to labeling rules requiring manufacturers to list "this product processed in a plant that also processes wheat". The concern is that celiacs must avoid gluten in their diets to maintain optimal health. This limits the foods we
can eat. Nutrition becomes a concern when celiacs do not intake proper nutrients. Labeling the quantities of gluten contamination would take the guess work out of deciphering the processing statement. It is very important that celiac patients strictly comply with dietary restrictions while maintaining proper nutritional intake. I would welcome this type of labeling.

Thank you for the opportunity to share my input.