2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1481
Submitter : Mrs. Kristy Figlar Date & Time: 09/20/2005 06:09:38
Organization : Mrs. Kristy Figlar
Category : Individual Consumer
Issue Areas/Comments
1) What should ?gluten-free? mean on a food label? Why?

Gluten Free should mean no gluten containing materials were used in the formulation of the product and also that the manufactured food product was not contaminated with gluten during the processing/packaging. This is important because persons afficted with Celiac Disease are required to eliminate (NOT reduce) gluten from the diet to overcome deleterious affects of this disease.
2) How do you identify foods that do not contain gluten? Time spent identifying foods?

Reading labels is just the beginning. Often follow up phone calls to the manufacturers are required to confirm the status of the food product. This is very time consuming and oftern difficult for many reasons including: 1) manufacturer availability. Food shopping and preparation for the employeed consumers often occurs during non-operating hours for the manufacturer making contact for information nearly impossible and 2) many food items are distributed by distribution centers as opposed to the actual manufacturer. Repeat or return phone calls are often required further delaying notification and/or purchase of food items.
3) What percentage of foods and which types purchased are marked ?gluten-free??

Although all of the food items purchased are gluten free, less than 10% are labeled gluten free. Labeled foods include some cereals, snack bars, bread crumbs, bread, bagels, pizza crust, assorted flours, crackers, etc. A majority of these items are not available in traditional supermarkets but in health food stores or by mail order/internet (often at increased prices). Many items are imported.
4) Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent? Example:Two cans of tomato sauce on the shelf both contain only tomatoes and salt and only one is marked gluten-free.
Gluten free labeling absolutely influences decisions. There is absolutely no question in my mind as a consumer that the food item will not make me sick and that the precautions have been taken by the manufacturer not to cross-contaminate the food item. I will always buy the labeled item over the non-labeled item and will often look for other items manufactured by the same company. This can cut down on excessive amounts of time spent reading labels and attempting to contact manufacturers.
5) Would you consider a two or more level definition of gluten-free helpful?
Example: If Level A meant the absence of any wheat, barley, rye, oats and any of their derivatives and level B meant the presence of trace amounts, less than 'X' parts per million, of wheat, barley, rye, oats and any of their derivatives and level C meant the presence of small amounts, less than 'Y' parts per million, wheat, barley, rye, oats and any of their derivatives. (Using 'X' and 'Y' to identify quantities to be determined by the FDA.)

No since complete elimination of the food items is required for good health and recovery.