2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC437
Submitter : Mrs. Susan Pierce-Ruhland Date & Time: 09/09/2005 06:09:40
Organization : Mrs. Susan Pierce-Ruhland
Category : Individual Consumer
Issue Areas/Comments
#1- Gluten Free should mean NO wheat, barley, oats or rye or any derivatives from these grains.In addition, it should mean the product is not produced in the same facility as those grains. Tiny amounts of gluten can make a celiac sick for weeks!

#2-I identify foods that are GF by looking at the label for the words 'gluten-free' if I know from a Celiac Sprue Asso. list or from calling the manufacturer that the manufacturer reliably labels foods by my definition of Gluten-free. This research takes hours to establish my 'safe' shopping list. I never deviate from this list until I research the new item (or an old one that seems to have changed).On evenings and weekends, it's impossible to contact manufacturers!

#3- 100% of all grain products are labeled Gluten-free. 100% of vitamins; 100% of condiments; 100% of frozen convenience foods are labeled gluten-free. about 50% of meats are labeled, while the rest are researched. All dairy products are researched, none are labeled. Frozen or canned vegetables and fruits are researched, as are juices; none are labeled...it would be helpful if they were. Fresh produce is taken as GF, assuming it is not genetically modified.

#4 - I will ALWAYS buy a product labeled Gluten-free if it means it is truly GF (no disclaimers about shared equipment, for example).

#5- More than one definition of Gluten free would be confusing. By defining Gluten-free in the strictest terms (no cross-contamination, no ingredients derived from gluten-containing sources, and no oats), the product is truly safe for all celiacs as well as people with allergies to wheat, barley, oats, or rye. The gluten-free diet does not harm the general population, but the general population's diet (or contamination from it) can potentially kill a celiac.

The medical profession insists on 'first, do no harm.' The FDA should insist on labeling that will do no harm to those who are unable to eat gluten-containing foods. After all, every product that is made with Aspartame is additionally labeled for Phenylkentonurics with the warning that it contains Phenylalinine. The incidence of celiac disease is much greater than that of PKU; labels should address this, not only on foods, but on pharmaceuticals as well!