2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC308
Submitter : Mr. Sean Mooney Date & Time: 09/09/2005 05:09:34
Organization : Mr. Sean Mooney
Category : Individual Consumer
Issue Areas/Comments
Docket # 2005N-0279
1. "Gluten free" on a food label should mean there are no amounts (even trace) of wheat, barley, rye and oats in the product. Period. These are products that if they are processed, are done so on dedicated lines.
2. I identify foods that are gluten free by looking at the list of chemicals and other ingredients in various foods on the CSA web site and comparing that list to each item on a given product. I have spent hours doing this since my diagnosis in November 2005.
3. Only about 15-20% of the foods I purchase have the 'gluten free' label on them. These foods have been exclusively purchased at natural food stores or at special online stores and are prohibitively expensive, hence the smaller percentage of my intake. These types of foods are mostly gluten free breads, cereals & snack items.
4. Yes, having 'gluten free' printed on a label means that the manufacturer has taken the time to research the production means and has made sure the food is safe to one with my medical condition. It also saves me precious time reading labels. So it definitely influences my decision 100%. Even after almost a year with this diagnosis, reading labels is still a challenge, and I still miss from time to time certain chemicals or cross contaminated items that I didn't realize contain gluten. (a recent example is dyno-bites cereal. Some of their cereals contain no gluten on the product label but is processed on production lines with cereal containing gluten) Having the product labeled (like people with soy and peanut allergies) 'gluten free' would be a huge life enhancing action. Please Help us with this.
In the example of the tomato soup: If one is labeled 'gluten free', it eliminates any doubt as to possible cross contamination. Perhaps the tomato soup that is not labeled 'gluten free' contains tomatoes that were on a conveyer belt used to process semolina/pasta for chicken soup minutes or hours prior. And this conveyer belt was not properly cleaned before the tomatoes were put on it. This would have an adverse affect if one with my condition were to ingest such tomatoes. Therefore the clear label "GLUTEN FREE" means just that, absolutely no (even trace) amounts of gluten. Part of the problem with this condition is that one may look at a seemingly harmless label, purchase the product and ingest it only to have problems later because the product was used on the same production facility as another product that contains gluten. I know it seems trivial, and almost too specific, but believe me when I say some Celiacs are just that sensitive, and continued food production/labeling can lead to much more serious health problems if one continues to ingest these foods.
5. Since the current medical school of thought is to avoid gluten at all costs (even incidental/trace exposure), labeling the product in such a fashion that admits a trace amount of gluten means for someone like me that I will simply not purchase it. Why waste the energy making a level of how toxic a given product is? If it is at all toxic (and for a Celiac, gluten is just that...toxic at any level...again according to current medical thought) I won't purchase it. It is either gluten free or it is not gluten free, there is no in-between. Perhaps there is more current medical knowledge out there that suggests a Celiac patient can ingest a certain ongoing trace amount of gluten, but I am not aware of this, nor are many in various chat rooms and other forums I have taken part in during the last year of my life (to include my gastroenterologist).
Thank you for your interest and commitment to change the labeling process for Celiacs!
Sean Mooney