2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC274
Submitter : Mrs. Sharon Casper-Williams Date & Time: 09/01/2005 04:09:05
Organization : North Raleigh Celiac Support Group
Category : Individual Consumer
Issue Areas/Comments

1) What should ?gluten-free? mean on a food label? Why?
It should mean that a product does not contain wheat, rye, oats, barley, triticale, spelt, kamut, semolina any products made with these grains. (millet, buckwheat, amaranth, quinoa and teff could also be contaminated in milling or transport so they should be included in the above list).

2) How do you identify foods that do not contain gluten? By doing a TON of research. If the ingredients are straight forward like wheat, barley, oats etc, it is an easy decision that the product is not gluten-free. If the product label contains modified food starch then I am forced to call the manufacturer to determine if the food starch is corn or wheat based etc. I have also joined a Celiac support group to learn and share gluten-free products with the group. It is a good way to expand the list of "Allowable" foods for this gluten free diet.

Time spent identifying foods? Hours. This is a constant struggle and constant complaint our Celiac Group has. We purchased the CSA Gluten- Free product listing guide but it does not contain all foods in our area that are gluten free. We have taken tours with one of our older members through grocery stores that carry gluten-free products to learn how to read labels. We have shared the names of foods locally that we purchase that are gluten-free. It is an absolute nightmare to have to live like this. My motto is "If in doubt, don't eat the food in question". I rather be safe and hungry then full and ill for the next week by guessing the contents of a food label.

3) What percentage of foods and which types purchased are marked ?gluten-free??
In a regular grocery store, there are less then 10% of the foods marked gluten-free. Most of us have to buy our foods at health food stores which have a section of foods labeled Gluten-free or from a web based gluten-free shopping site like gluten-free pantry (www.glutenfreepantry.com) or gluten solutions(www.glutensolutions.com).

4) Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent? Example:Two cans of tomato sauce on the shelf both contain only tomatoes and salt and only one is marked gluten-free.

The label "Gluten-free" absolutely influences my decision. I would 100% buy that over a food not labeled gluten-free. That gluten-free label indicates I do not have to spend the next 5 minutes dissecting a food label and can continue on with my shopping. It also means a person who is entertaining me for dinner can safely buy this product and will have piece of mind that they are serving my dietary needs instead of guessing like I have had a number of folks do!


5) Would you consider a two or more level definition of gluten-free helpful?

No. Not for a gluten-free product. By definition, a celiac should not ingest any gluten. That means either the product is 100% gluten free or it is contaminated. Trace amounts of gluten can be just as detrimental to some celiacs as eating a full meal contaminated with gluten. I think here it should be an all or nothing approach.

Thank you!
Sharon Casper-Williams