2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC478
Submitter : Mr. Barry Goldberg Date & Time: 09/09/2005 06:09:48
Organization : Mr. Barry Goldberg
Category : Individual Consumer
Issue Areas/Comments
To Whom It Concerns:

"Gluten-free" should not only mean that a product contains no gluten ingredients (e.g., that no wheat, spelt, rye, barley, oats, or products made from them were used as an ingredient), but also that the item is made on a product line that was free from Gluten-contamination. Both I and my son have celiac disease. If we ingest products made in a gluten-contaminated environment, we have terrible digestive difficulties (and my son errupts in a terible rash), despite the fact that the product did not list any glutenous ingredients. Invariably, we discover (after contacting a company) that the foods were made in a glutenous environment.

We mainly rely on gluten free product listings (such as from the Celiac Sprue Association) to identify foods that do not contain gluten. We have found too often that foods that do not list glutenous ingredients nevertheless have gluten or are contaminated with gluten. As such, my wife and I spend up to six hours a week trying to identify foods that are truly gluten free. My wife has taken to shopping with her cell phone during weekday business hours, so that she can contact the various companies using contact information on packaging to confirm whether products are truly gluten free, despite the fact that the products list no glutenous ingredients.

It is unfortune that so many foods which, from their ingredients would seem to be gluten free, are really contaminated. The problem is that if we cannot ensure that a product is truly free of gluten, we will not purchase it.

As a consequence, the vast majority of the foods we purchase have to have the words "gluten-free" printed on the label. Moreover, if there are two products of the same kind, both of which have identicle ingredients, but only one of which has "gluten-free" on the label, we will invariably purchase the product labeled gluten free.