2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC204
Submitter : Mrs. Cheryl Phillips Date & Time: 08/29/2005 11:08:03
Organization : Mrs. Cheryl Phillips
Category : Individual Consumer
Issue Areas/Comments
In response to the 4 questions published in the Federal Register Vol 70 No.137:

1) Gluten Free should be just that. Free from detectable gluten. Consider a two-tier system and put 'Low Gluten' items containing up to your 200ppm. Then consumers can make the decision for themselves as to how much they would like to consume. The accumulative effect of more than one product containing 200ppm would cause symptoms in most people I have had contact with. If minute amounts from cross contamination is such a huge problem for us with gluten intolerance/celiac, allowing food processors to put in that high an amount would be disasterous for us. Allowing this amount only perpetuates the loophole that food producers glide through making foods untrustworthy for those of us with food intolerances.

2) We identify first by looking at the ingredients listed. We cannot always rely on the allergen listing, because they only list items that that particular processor has put it - they are not held accountable for the ingredients their suppliers add in. So if we see items suspicious of containing potential hazards for us, we need to check further. Often times we have to try to phone the company and run through the hoops put forth by that company. I (and many others I know) have stopped calling all together. We often run up against people who give us answers without verifying the accuracy, get defensive claiming that their products are indeed wholesome, or just flat out refuse to give the information citing 'proprietary information' priviledges. I will not risk my health or the health of my family on these premises. If I cannot find accurate information within a reasonable amount of time (5-10 minutes per item), I just will not use that item. Imagine spending half an hour per phone call on each item you need to check and then still not get the info you need. Then be told you have to do that every time you purchase that product, to make sure things haven't changed. For EACH ITEM IN YOUR KITCHEN!

3) Currently, only about 10% of the foods in our kitchen are actually labeled gluten free. I have had to start cooking from scratch in order to be certain of the ingredients going into our meals and to do so within our budget. It is good that I have the freedom to not have to work outside of the home; if I had to work, I do not know what we would do. Either we would not be able to afford it, or there would be a breakdown in our family because of the time involved.

4) Items labeled gluten free make a huge influence on whether or not I buy a product. If I have two brands in front of me, 1 marked gluten free and 1 not, I will most always choose the gluten free labeled one (as long as the quality is good). These tend to be companies who are committed to actually checking their products and catering to the consumer. They realize that they save me time by not making me hunt for information they know.

Ultimately, I would suggest this:
-- jump onto an internet celiac support group or visit some in person and actually listen to how much trouble people have from things like cross contamination.
-- create a 2 tier system for gluten free and low gluten items - let the individual make the choice for their own health (most will choose truely gluten free I will bet)
-- CLOSE THE LOOPHOLES that allow companies to not be accountable for what their suppliers put in, or who try to hide behind 'proprietary information' -- if we state we are asking for health/allergy reasons, why allow them to get off with out telling us?