2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC50
Submitter : Miss. Nancy Ann Pelini Date & Time: 08/15/2005 05:08:30
Organization : Celiac Sprue Association Omaha, Nebraska
Category : Individual Consumer
Issue Areas/Comments
Gluten-free on a food label should mean that a food excludes wheat, oats,
barley or rye either in its composition or preparation. Wheat, oats, barley
and rye are the known sources of gluten in foods, either by including these
sources in food ingredients or by contacting foods in their preparation.
This definition of the term is essential to an individual with celiac disease.
The medical community has recommended the elimination of all gluten from
the diets of individuals with celiac disease regardless of that person's
symptoms because there is no definitive amount of gluten known to be tolerable
to these individuals. Therefore the strict adherence to a "gluten-free" diet
is known to be most beneficial to individuals with celiac diseas in their pursuit of health.
I identify foods that do not contain gluten primarily by reading the
list of that food's ingredients on the food label. If in those ingredients
I am unsure if the product excludes all wheat, oats, barley or rye I
will either contact the manufacturer of that product or the supplier to
provide me with the assurance that the food is "gluten-free".
I spend on an average of between one and five minutes reading the
food label ingredients of any one food. This varies greatly between products
and applies primarily to processed, canned, frozen or pre-packaged foods. This
time in reading food labels has varied for me over the sixteen years I have
been adhering to a gluten free diet as an individual diagnosed with celiac
The percentage of foods labelled gluten-free varies considerable between
food sources. In those establishments that seek to provide foods and dietary recommendations to individuals based on a specific dietary requirement my estimate is up to 50% of their food products are labelled gluten-free.
However, in those establishements that cater to individuals with more
varied dietary guidelines (over 99% of individuals in the US), I would
estimate that less than 1% of all the food is labelled as gluten-free.
As an individual with celiac disease, the term "gluten free" on
a food label does influence my decision to purchase that product. When
I have a choice between similar products that do not contain wheat, oats,
barley or rye or have not been contaminated with these grains I almost
always choose the product labelled gluten-free.
Thanks for the opportunity to provide my comments.