2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC227
Submitter : Ms. Catherine P. Lund Date & Time: 08/29/2005 11:08:42
Organization : Ms. Catherine P. Lund
Category : Individual Consumer
Issue Areas/Comments
Gluten-free should mean that there is no gluten in the product, which means no wheat, rye, barley, oats, and their derivatives. There should be no traces of gluten.

I identify foods that do not contain gluten through labels that specifically say gluten-free, from the product book of CSA or Clan Thompson or other celiac newsletters, and by calling or e-mailing the company that makes the product. This is a time-consuming process because except for a clear gluten-free label, all the others involve research not only of companies that manufacture the product but also of area stores that may or may carry the product.

The food that I purchase that has 'gluten-free' on its label is about ten percent of the total food that I buy. The other 90 percent consist of products that are by nature gluten-free: fruits/vegetables, meats that the CSA product book says are gluten-free or that butchers guarantee are gluten-free, products that I conclude are gluten-free from the product book/ newsletters, or calls or e-mails.

I trust a gluten-free label over a label with the same ingredients without a gluten-free designation, because often not all the ingredients are on a label. If a product says gluten-free, with rare exceptions I have found that to be so. Also, if a company has gluten products that they manufacture along with non-gluten products, the gluten-free label usually has an asterisk which explains that.

Finally, I believe that a gluten-free label should mean no gluten even in trace amounts. I am sensitive to any gluten and have gotten sick when a label's ingredients show no gluten products. In these cases I have eaten the product and discovered by calling/e-mailing the company that the product has 'traces' of gluten.

I strongly urge that all labels list all ingredients and their /derivates/sources. That means that modified food starch on the label has details describing what starch is used, natural flavors and artifical flavors have labels that detail the exact derivatives.

When at least one in every 133 people in the U.S. have celiac disease, we need to have accurate labeling because our health depends upon it. A set of labels with A meaning totally gluten-free and B meaning traces could be misleading to many who think that a trace won't cause damage to a celiac. Having reacted to .002percent barley in Rice Dream, I know traces make a difference. I'm one of the lucky celiacs that has a gastro- intestinal reaction to gluten. Others have no discernable symptoms except for blood tests. These people can have much damage to their small intestine without any warning sign from the product doing the damage.

Thank you for your consideration. I hope that the FDA will take these comments to heart.