2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC149
Submitter : Mrs. Jennifer Lee Date & Time: 08/24/2005 04:08:58
Organization : Mrs. Jennifer Lee
Category : Health Professional
Issue Areas/Comments
Gluten free should mean there is not any amount of gluten in a product whether it is naturally gluten free or made from gluten free products. It is to my knowledge that the consumption of any amount of gluten is just as harmful to a celiac person as an entire plate of gluten. Celiac disease is an autoimmune disease which can lead to other autoimmune diseases if a celiac does not follow a strict gluten free diet. Many more people will be diagnosed in the years to come as Dr. Alessio Fasano found that 1 out of every 133 people have celiac disease however are undiagnosed due to varied symptomology. Doctors have also been taught that Celiac disease is a European disease. We now know different. It is important for proper food labeling of gluten free items to begin now as many more celiacs become diagnosed. It is imperative for a Celiac to be gluten free so that other nutrients (iron, vitamins, and minerals)will be asorbed. If celiacs mistakenly get gluten in their diet, some have untoward symptoms but others do not. However, the silent side effect is the loss of small intestinal villi which can silently cause celiacs to become unknowingly anemic and osteoporotic. My husband was diagnosed with Celiac disease almost 2 years ago. It was only by chance after many tests that he was diagnosed by his yearly military flight physical. He was an asymptomatic celiac with underlying anemia. After thorough testing, he was diagnosed with celiac disease.

I have spent many hours reading ingredient labels in the grocery stores every time I go. If the item is labeled gluten free, I tend to believe them and buy it. Otherwise, I need to read to be sure the manufacturer has not changed what they have put into their products. Many change the ingredients and it doesn't say so on the label so celiacs and their food preparers need to read them every time. If one can imagine it makes grocery shopping a very long chore.

Every celiac has to learn what foods are gluten free. Our foods are no longer made of a few ingredients but many preservatives and additives which mostly contain gluten. I shop the outer isles in a regular grocery store. Most of the prepared frozen items I buy are at health foods stores such as Whole Foods, Wild Oats, and Trader Joes. Amy's frozen entree's are labeled gluten free. All gluten free items are very expensive as well which may cause low income people to less likely follow a gluten free diet.

I would say about 50-60% of the groceries I buy for my husband are labeled gluten free. Fresh fruits, vegetables, and fresh unprocessed meats should be gluten free naturally and are never marked. Gluten-free items I buy that are marked as such include baking mixes, occasional snacks, and frozen items. Otherwise, I have the Celiac Sprue Association Commercial Product Listing Guide for 2005 as guide to buying acceptable gluten free items.

Take into consideration that 'about twice as many people suffer from celiac disease as do Crohn's, ulcerative colitis, and cystic fibrosis combined' as stated by Dr. Fasano, however there is not enough funding for research on celiac disease which hopefully will change in the future as more people are diagnosed and physicians educated that it is an American disease as well.

Yes, 'gluten-free' labeling does influence my purchasing an item. If it states 'gluten-free', I don't feel the need to read the label everytime. Hopefully, labeling it as such ('gluten free') is regulated by FDA government guidelines to mean that the product is really gluten free, meaning NO

I hope you consider that this disease not only affects adults but also affect children and senior citizens. At all ages, celiacs would benefit having items marked as gluten free so they would not paying for food that is harmful to their health. Just because celiacs don't have anaphylactic reactions to gluten, does not mean that gluten will not harm them.

Thank you,

Jennifer Lee, RN, BSN