2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1272
Submitter : Mrs. Lisa Krawczynski Date & Time: 09/20/2005 05:09:06
Organization : Mrs. Lisa Krawczynski
Category : Individual Consumer
Issue Areas/Comments
1. Manufacturers should clearly define if their products contain any hidden sources of gluten (such as malt flavoring, seasonings, starch fillers, etc.), they should be required to clean down their product lines before gluten-free products are run, they should not run other products simultaneously, and they should be required to test their products for any cross contamination. A company that produces a candy that does not contain gluten may be run on a product line that was dusted with flour to prevent any sticking. This manufacturer should not be allowed to list this product as gluten free.
2. Identifying foods that do not contain gluten is a time-consuming, expensive, and a discouraging process. I believe the first step to identify if foods contain gluten is to become knowledgeable through sources currently available. These sources may include reading specialty cookbooks, joining organizations such as Celiac Sprue Associtation, consulting with a dietician, and calling manufacturers directly. The time spent becoming educated varies depending on the individual. I was diagnosed as gluten-sensitive over nine months ago, and I am still learning how to be an avid label reader. Specialty cookbooks are not easy to find nor are they cheap. I've spent hundreds of dollars alone on my small collection of gluten free recipes and cookbooks. In addition, memberships in organizations that help educate gluten sensitive individuals are not free. What is the individual living on a limited budget supposed to do if finances do not enable them to obtain these sources so that they can identify which products are gluten free?
When calling manufacturers, the average wait time for a representative varies from immediate to 20 minutes to sometimes days. Many times, manufacturers are swamped with calls and leave consumers the only option of leaving a message. Some representatives are unfamiliar with the term gluten and are hesitant to make any statements. Other manufacturers get their supplies from many different suppliers that will not guarantee that the product is gluten free. For these companies, their legal departments have advised them to issue disclaimers so that the consumer has no way of knowing whether the items are safe or not. Still, there are companies that will not print their phone numbers or e-mail addresses on their products. What are consumers supposed to do then? If writing a letter is the only option to get information from these companies, then you can guess what the wait time would be to get a response by mail. Gluten sensitive individuals are faced with many challenges. Manufacturers should not add to their stress, but instead, aid such people in their struggle for a healthy life.
3. The percentage of foods that are labled gluten free is extremely low. I would estimate that less than 5% of food at a local grocery store is listed as gluten free. Cookies, pancake syrups, butter, and chips are the only products I have found to be listed as gluten free at my local grocery store. How long do you think you could survive on this type of diet? Therefore, in order to cook a well-balanced meal, I must shop at a specialty health food store or order food from an internet company. Time and money become issues again. It takes me over an hour to drive to the nearest health food store from my home. If the specialty store does not have the groceries I am looking for, then I am forced to order from an internet gluten free company. Ordering food by mail takes an average of 7-10 days to receive, unless I pay extra charges to Fed Ex my supplies.
4. The words gluten free printed on a product label definitely influences my decision to purchase it over other products. These manufacturers have taken the time and expense to become knowledgeable about the needs of individuals with gluten sensitive diseases. These companies should be rewarded for their efforts and I support them by buying their products.