2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1289
Submitter : Mrs. Ann Marie Lipper Date & Time: 09/20/2005 05:09:51
Organization : Mrs. Ann Marie Lipper
Category : Individual Consumer
Issue Areas/Comments
I am writing regarding the Food Allergen Labeling and Consumer Protection Act pertaining to the definition of ?Gluten-Free.? I myself have been diagnosed with celiac disease (the condition requiring strict adherence to a gluten-free diet) for the past 22 years. Additionally, my three school age children also have the condition. Gluten-free foods are, therefore, very important to our household.

?Gluten-free? on a food label should mean that the food does not contain any traces of wheat, oats, barley, or rye grains, nor any derivatives of any of these grains. This should include, but not be limited to, any flavorings, vinegars, breakdown products( i.e. glycerides, or hydrogenated proteins), additives, or coatings. Additionally, these products should not be processed on equipment that processes gluten containing products or is coated with gluten (i.e. for separation purposes-such as grated cheeses). The presence of gluten in foods causes us to become ill because our bodies can not digest these grains. We become sick, miss school or work, and are at risk for developing cancer and other immune system diseases.

To identify ?gluten-free? foods, I and my children must regularly read all ingredient labels, even for foods we have previously identified as ?safe,? since companies periodically change their ingredients without otherwise indicating. Not only do we spend hours each month reading product labels, I personally spend 5-6 hours a month calling food companies and pharmaceutical companies (for vitamins, pain relievers, lotions, shampoos, etc.) to inquire about product ingredients to identify gluten-free items.

Most of the items which are currently labeled ?gluten-free? are found in health food stores. At health food stores, 80% of products that we purchase are labeled ?gluten-free.? Less than 0.5% of any products in regular grocery stores are labeled ?gluten-free.? At regular grocery stores, 2% of products that we purchase are ?gluten-free.? For example, the only ?gluten-free? breakfast cereals in a regular grocery store are puffed rice and grits, neither of which is so labeled. We would, of course, purchase more if they were available and we could be confident of the labeling. We would, of course, purchase more if they were available and we could be confident of the labeling. I contact all companies whose products I purchase that are not specifically labeled to determine if they are safe for our consumption.

Because of our need for gluten-free foods, we are very brand loyal. We frequently need to special order such basic items as breakfast cereal. Once we find a safe brand, we continue to use it and are not likely to try another brand. ?Gluten-free? labeling would increase our likelihood of trying new products. In England, where we lived from 1999 through 2003, as well as throughout Europe, many more products throughout the regular grocery stores are labeled ?gluten-free.? We found it is much easier to obtain safe products there.

We rely on fresh produce and meats and fish for much of our diet, since few processed foods are ?gluten-free.? However, since coatings of unidentified compounds are allowed to be present on fresh produce, even fresh produce can at times cause illness. Coatings on all food products, including fresh produce, should be required to identify gluten.

When ?gluten-free? is printed on a product label, I am much more likely to choose that product over a similar product that does not have the label. The presence of the label indicates to me that the company is aware of the need for consumers to avoid gluten. Requiring the appropriate use of the
?gluten-free? label will result in increased safe food options for my family.

I urge you to consider the careful definition of the term ?gluten-free? to provide safe food products and other consumer products for those people with allergies to gluten.