2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC1514
Submitter : Ms. Susan Bailhache Date & Time: 09/20/2005 06:09:58
Organization : Ms. Susan Bailhache
Category : Individual Consumer
Issue Areas/Comments
As a US citizen and consumer who has Celiac Sprue, the way that food products are labeled is a matter of high concern and has enormous potential impact on my long-term health. Gluten free on a food label should mean that the product does not contain any oats, barley, wheat or rye, or any products that have oats, barley, wheat or rye as ingredients.

I determine whether foods are gluten-free primarily by reading the ingredients on the label, by using food product guides issued by Celiac support groups and through labels that specifically indicate "gluten free" clearly on the label. On average I spend an extra 30 minutes per shopping trip, searching for gluten free foods, or driving to specialty stores where I know I can buy a specific gluten free food product.

With the exception of fresh produce and fresh meats, approximately 30% of the grocery items I purchase are marked gluten free. An example of items marked gluten free include salad dressings, condiments, bakery items, snack foods, prepared frozen meals, frozen fish sticks & chicken nuggets, cereals, spices and flour. When an item states that it is gluten free on the label, I am much more likely to purchase it over a similar item that doesn't carry the gluten free label. In some cases the gluten free label indicates that the item is produced in a facility that doesn't allow oats, rye, barley or wheat, so there is no concern about cross contamination issues.

The long term health issues that can arise from Celiac Sprue are widely misunderstood, even by the medical profession. The good news and the bad news are one in the same. The cure is in maintaining a gluten free diet. It sounds easy, however, in today's world of processed, canned and packaged foods, it can be an enormous challenge. Without careful and judicious lists of ingredients on food labels, it's impossible to know if a product is safe. It takes extra time, patience and experimenting to find safe food to eat.

More specific food labeling relative to gluten contents would save Celiacs time, and would potentially reduce national health costs and insurance claims for those of who experience health complications as a result of accidentally ingesting gluten.

Thank you for requesting our input. I highly encourage you to develop stringent specification for products that are allowed to carry a gluten free label.