2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1374
Submitter : Mr. Phillip Keller Date & Time: 09/20/2005 06:09:06
Organization : Mr. Phillip Keller
Category : Individual Consumer
Issue Areas/Comments
This is input in response to defining 'gluten-free'
Question #1: Gluten-free should mean that there is no gluten in the product and or any chance that it has been cross contaminated during production of the product even though the product has no gluten in it. The reason why is that those with celiac disease for the most part cannot tolerate even small amounts of gluten in their diet.
Question #2: I identify foods that do not contain gluten by refering to a published gluten free products list that is published by the national Celiac Association or the Denver Support Group CSA Chapter. I also quickly scan the ingrediants list. This can add 30 minutes to an hour for a seasoned celiac's weekly grocery shopping trip. For a newly diagnosed person it can add several hours to their grocery shopping experience.

Question #3: I would estimate that less than 5% of all processed foods are labeled Gluten Free and less than two percent of the those that are highly likely to contain gluten but don't are labeled gluten free.

Question #4: Certainly, because you assume they are honest about it and do not have to look it up in the product list or read the label if it is not marked Gluten free. To what extent is in all cases unless I have researched the other product before and can rememeber it. Even then they are likely to make changes and add gluten to the product if it is less expensive of readily available on the open market.

Question #5: I do not think that two or more levels of labeling should even be considered. Either it is Gluten Free or it isn't and if you start labeling it on levels, there will be those who will try it and maybe not have any obvious effects and keep using it, and in the meantime because it is not readily apparent it has done some serious damage to their small intestine that they will not be able to detect until it causes serious damage to other functions of the body because of lack of proper absorbtion of needed nutrients. The only way one can confirm that damage is being done is with a Small Bowl Biopsy, which not a cheap procedure but not something that is not real pleasant to have done on a periodic basis.