2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1362
Submitter : Ms. Allison Reid Date & Time: 09/20/2005 05:09:32
Organization : Ms. Allison Reid
Category : Individual Consumer
Issue Areas/Comments
I suffer from celiac disease, so I have an interest in your definitions of gluten free. Overall, it should be treated like a peanut allergy where gluten free means absolutely no gluten, not even trace amounts from contamination (we get sick from trace amounts). So, if food is prepared in a non- gluten free facility, it should be tested for trace amounts (with the best available technology, suggested technology updated with the development of newer methods).

I spend so much time trying to id gluten free food, both calling and emailing companies. Some companies never get back with me, others tell me that they cannot answer my questions (is that even possible or legal - if not, Bali Spice soy sauce people need to be dealt with). Ingredients such as "natural flavoring", "modified food starch", "HVP", mono- di-glycerides, distilled white vinegar, etc....all of these may or may not involve gluten, either through distillation or directly. It is inappropriate and unfair to have such generic labeling and it prevents me, as a consumer, from being an independent individual capable of making informed decisions. All questionable/generic ingredients should have in parentheses (sp?) where it was derived. Example: "modified starch (potato)" I buy from companies that do this in support of their efforts and avoid companies that do not (obviously, by not doing so, they don't appreciate me, my condition, or my ability to make decisions, so they don't deserve my money). In addition, many people with celiac disease have other allergies, for example, I cannot tolerate corn. These allergies are not necessarily one of the 8 common allergens, and yet many celiacs have them (whether to potato, rice, corn, whatever). So specifying the source of ingredients is absolutely necessary and would improve the quality of life for everyone involved.

The allergen issue brings up something else - I noticed that only 8 allergens are considered, and, as relating to gluten, only wheat. We can get sick from so much more than just wheat (barley, rye, oats, wheat relatives), that gluten free labeling is necessary. I also would like to see the word "gluten" or "gluten as pertains to celiacs" under the line which states whether the product was manufactured in a facility that processes other products. Ex. Manufactured in a facility that also processes tree nuts and gluten (or gluten as pertains to celiacs).

The majority of the food I buy is from trusted companies (they test their foods) and marked gluten free. For example, Edward and Sons miso soups (they post on their website which are tested and passed for gluten content), Enjoy life makes food in a dedicated gluten free facility. I would say, marked and trusted food make up 85% of my purchases (the rest are veggies or raw meat and these are nearly 100% of the time GF).

The label of gluten free does influence my decision, even if it has exactly the same ingredients as another product (this is especially important when something like "natural flavorings" occurs on the label - I will always buy the labeled GF version). I buy the GF version over an comparable product b/c they have made the effort to respect me as a consumer and are trying to make my life easier (at least, that is how I prefer to think of it, or I could be cynical and consider that they may be lying).

A two or more level definition of gluten free would be helpful - see my allergen concerns above and what type of facility it was processed. Trace amounts can make people with celiac disease sick (I know, I've been there). So testing of products wishing to put "gluten free" on their label should be mandatory. However, I will be honest and tell you that I will not be purchasing a product with trace amounts. Ultimately, knowing whether traces are present empowers me as a consumer and allows me to better protect my health.