2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC13
Submitter : Mr. Michael MacCartney Date & Time: 08/03/2005 02:08:22
Organization : My Family
Category : Individual Consumer
Issue Areas/Comments
My children are allergic to Cows Milk, Chicken Eggs, Shellfish, Scalefish, Tree Nuts, and peanuts. Thanks to President Bush and others food labeling for the 8 common allergens will be required for foods manufactored starting Jan 1, 2006. This is great, but does not address cross contamination, which can be deadly for my son who is peanut allergic, nor does it address gluten from rye or barley. I am Celiac, and my 1st son is Celiac. Without any labeling requirement for rye or barley grains, there may as well be no requirements for food labeling. If a product is labeled such that I can ascertain that it does not contain the 8 common allergens it is meaningless to us as that product can still contain gluten from rye or barley grains. As such, for us, without knowing that a product is "gluten free" we still must contact manufactorers, or risk being sick. Since there isn't any requirements for companies that claim a product is "gluten free", how can we trust a companies statement? Imagine if you will, what it would be like to get into an automobile that a manufactorer claims is safe only to have the seat belt fail during a crash becuase there was no standard on seat belt testing. Gluten ingestion by Celiacs not only makes us sick, it can cause a slow painful death due to damage to intestines, inability to digest food and/or abosrb nutrients. It can cause osteprosis, and many other health ailments.

If I were the one making the decision I would require that any company that wishes to claim their product is "gluten free" must either

a) Obtain legally binding certification from their suppliers that their products are gluten free, certify that their factories and product lines contain no gluten. This would satisfy my requirements.

b) If they have gluten containing products in their factory, and/or on the same product lines, require batch testing using an ELISA test for gluten.

Thank you for listening, and thank you for addressing this issue. I am a US Citizen, and have lived here since I was born here 32 years ago. This is the best place on the planet to live, and our gov't is the best on the planet. However I must state that due to my food health issues, and my childrens food health issues I am considering relocation to a country with stricter food labeling requirements such as Australia...I do not want to do this, but our health must come first....