2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1513
Submitter : Mr. Bryan Flint Date & Time: 09/20/2005 06:09:45
Organization : Mr. Bryan Flint
Category : Individual Consumer
Issue Areas/Comments
From: Bryan Flint
431 Broadway #511
Tacoma, WA 98402

Date: September 19, 2005

RE: Docket # 2005N-0279 Food Labeling: Gluten-Free Labeling of Foods.

Thank you for the Opportunity to provide comment on this important topic. After fifteen years of symptoms I was diagnosed one year ago with Celiac disease. This has lead to a new adventure of food choice and label reading. In narrative form I will be addressing questions posed in the federal register Vol No. 137 on July 19, 2005. Specifically Section III Questions D. 8. and E. 9. and 10.

How I shop for food

I have seen the diagnosis of Celiac decease as an invitation to eat a whole foods diet. I have increase the whole fruits and vegetable in my diet. I try to eat unprocessed meats and dairy products. When I do purchase processed products I look for products with a minimum of processing, additives, and ingredients. I am best off when the ingredient list has less then 6 items listed. I almost never buy products with dozens of ingredients - unless the package is labeled ?gluten-free?.

I most often find suitable products at health food and specialty stores. I find more products listed ?gluten-free? at such stored. Right now I am down to three stores I shop at, with a fairly narrow list of products I purchase on a regular basis. This is easy since I live alone at the moment. This shortens my shopping time, because I do not need to reread labels from products i have already determined are gluten-free. If i pick up a new product I always read the label.

Most of the time I am left to my own devises to figure out if a product is gluten-free. sometimes this is easy by the nature of the ingredients. Some ingredients are extremely frustrating because I cannot tell if they do include gluten in the product. Examples of these are spices, artificial flavoring, carmel color, and other similar ingredients. for the most part I exclude these products from my diet, unless the label has ?gluten-free? on it.

If similar products or similar ingredient list are present I will always trust and often choose the product labeled ?gluten-free?. I will often try a new product labeled ?gluten-free? that was not on my shopping list, in order to find products I enjoy and know are safe.

My assumption when I see a ?gluten-free? label is that the product does not have any increadiants derived from wheat, rye, oats or barley. I also assume that the manufacture has put some controls into place to ensure that the raw material does not include these items or that the manufacturing process does not contaminate the product. I do not assume that the manufacture test batches or go to great lengths to ensure there is not gluten. I do assume if the company is dedicated to all gluten free products that they take more care with their manufacturing process.

I have customer loyalty to those companies that take the effort to accommodate my dietary need. I seek out those companies that label their products ?gluten-free?, not only to have safe products, but to support those companies with my consumer dollar. I appreciate companies like Bob?s Red Mill, who actually batch test their product to ensure that their products are gluten-free.

One of the hardest places to deal with this subject is visiting family and friends for extended periods. Because gluten can be hidden in so many places, it is hard for ones host to deal with your diet restriction. Without good labeling it is difficult for people who are not used o shopping for gluten-free to sort out the hidden gluten. The result is potential poisoning or awkward situations.

Not having good labeling can also effect restaurant staff. If restaurant grade packaging labels ?gluten-Free? it would be easier for a staff person to assure that the food being served is gluten free.