2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1402
Submitter : Ms. K Beane Date & Time: 09/20/2005 06:09:00
Organization : Ms. K Beane
Category : Individual Consumer
Issue Areas/Comments
Thank you for seeking comment on this topic. I don't want to see a zero tolerance policy on gluten free labeling because it would severely diminish the number of manufacturers that will even attempt to indicate whether or not a product is gluten free. I've been a diagnosed Celiac for 2 years and have seen a 'CYA' attitude among several manufacturers that were unwilling to say that their product did or did not contain gluten. OTOH, I do think a manufacturer should be required to confirm whether or not their product would contain wheat (or rye or barley) intentionally and if wheat flour is used on the production line (to prevent product sticking to the belt) even when it's not part of the official ingredients.

However, I feel that the 200 PPM standard for products that have been rendered gluten-free such as those that may contain Codex Alimentarius quality wheat starch is overly generous and does not sufficiently protect those of us that need to know more about our food.

I have been encouraged to see more manufacturers using rice, corn or potato starch instead of wheat in many products (grated cheese for example). I think the best step would be to require manufacturers to list _everything_ they deliberately put into a product, even when it is less than 2 % of the product. If it's listed, I can make an informed decision to purchase or not. If it's not listed, I can not make a good decision for healthy food. I would also like to see this applied to drugs that use wheat starch as a base for the drug. It is very difficult to determine whether or not some drugs contain 'traces' of wheat. I've already had an experience of an OTC drug making me ill and it took a week for them to confirm that it did contain 'a small amount of wheat'.

Again, thank you for looking at this subject that is so vital to my Mom, my sister, me and other people with Celiac or food allergies. It is a good step toward helping me make good choices for better health.


K. Beane