2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC254
Submitter : Mr. Timothy Gehring Date & Time: 08/29/2005 12:08:41
Organization : Mr. Timothy Gehring
Category : Individual Consumer
Issue Areas/Comments
RE Docket # 2005N-0279
"Gluten Free" on a food label should mean that it is free of any ingredients harmful to those impacted by celiac sprue disease, and further that the food has not been processed in a way that might contaminate it with such ingredients from other foods. This would ensure that the user could be confident in buying the product and not consuming anything harmful to their Celiac condition.
I identify foods that do not contain gluten by reading over the labels of every thing that I could possibly eat. I have had to learn and continually update myself on the types of ingredients that are harmful so I can know what to look for on the labels. I spend several minutes per day on average reviewing labels, however the time is not as concerning as the stress of not knowing what is in some products.
About 10% of what we purchase is marked Gluten Free. These are mostly breakfast foods, and some alternative pastas.
If a product is marked "Gluten Free", it greatly influences my decision to purchase that product. Where there are seemingly identical products which would inherently be gluten free, where one is labeled as "Gluten Fee", I will most definitely purchase the product labeled as "Gluten Free" just to be on the safe side (i.e. contamination).
I would consider a two or more level of Gluten Free labeling to be very helpful, only because my condition is not severe enough that trace amounts impact my health. This would mean that I could buy many products that contain "trace" amounts of Gluten knowing that the amount of Gluten is below an acceptable level. I feel strongly that this would help a substantial majority of people affected by Celiac Sprue, since some statistics show that roughly 80% of those with the disease do not exhibit severe symptoms, and reducing the diet to trace amounts of Gluten is sufficient to keep symptoms in check. I would strongly encourage the FDA to come up with such "trace" standards in consulation with professionals in the field of Celiac research.

Thank you very much for your work on this important initiative!

Timothy B. Gehring