2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1479
Submitter : Ms. Evelyn K. Cohen Date & Time: 09/20/2005 06:09:57
Organization : Ms. Evelyn K. Cohen
Category : Individual Consumer
Issue Areas/Comments
Comments from on ?Gluten-Free? food-labeling from
Evelyn K. Cohen
5220 E. Holmes St.
Tucson, AZ 85711

Sept. 19, 2005
1)?Gluten-Free? on a food label should mean that the product does not contain gluten and did not contact gluten in its manufacturing or packaging processes. It is, in the long run, a matter of life and death to persons with celiac disease to have this knowledge -- at least 133 per 1,000 people.
Persons with celiac disease are prone to multiple food sensitivities due to the damage caused by the disease over their life times. Therefore, all foods known to cause reactions also must be listed on the labels.
This is one disease where sufferers can have some control. Giving celiac patients full knowledge of food ingredients allows them to maintain their general health more efficiently. It is good for celiac people, and improved labeling will save health care dollars.

2) I study the ingredient list on every manufactured food I buy. I also phone the manufacturer and check on-line company websites. I would say that hunting for ?safe? products adds about two hours a week to my grocery outings. Frequently, even foods that claim to be ?gluten-free? are not, or they contain another irritant, not mentioned. Sometimes ingredient lists do not disclose all the ingredients, especially in ?secret recipes.? For example `Kettle Chips? did not mention on their ingredient label that wheat flour is used to crisp the chips! This caused me enormous physical damage until I narrowed my food culprits down to the Kettle-factor and forced Kettle to admit they use flour. I did not contact them before because their ingredients were listed as potatoes, salt, oil!

3) Very few foods are marked Gluten-Free, maybe .05% of the foods available. Types of foods marked ?Gluten-Free? include mostly hi-carb, hi- sugar deserts, salty snacks, and a variety of pastas. In addition, many of these products contain ingredients to which some people with Celiac disease are sensitive Some of these products may not be listed. I buy very few packaged foods.

4) I assume that a can without a ?Gluten-Free? mark on its label is telling me, ?Hey, Celiac Person, don't bother.? I definitely look for ?Gluten- Free? on the label, but use it only as a starting point for studying the ingredients. I would absolutely not pick up a can without a Gluten-Free marking on it. I don?t have time to be sick. I?d rather eat something boring, but safe.

Two-or-more levels of ?Gluten-Free? labeling would be helpful in that I would never buy anything but the top Level A. Why would I risk my life to eat a ?maybe?? I do everything in my power to avoid making gluten mistakes! Here?s a question for you: Would you ask a kid who is allergic to peanuts to accept anything less safe than ?Level A?? My reaction to Gluten is no less serious. The effects are cumulative over time, debilitating, and finally deadly.

Docket No. 2005N-0279
Division of Dockets Management
5630 Fishers Lane, Rm. 1061
Rockville, MD 20852