2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC644
Submitter : Ms. Amani Ahrens Date & Time: 09/12/2005 06:09:05
Organization : Ms. Amani Ahrens
Category : Individual Consumer
Issue Areas/Comments
1) What should gluten-free mean on a food label? Why?
As someone who has had Dermatitis Herpetaformis for 9 years and needs Gluten-Free foods for long-term health free of taking Dapsone medication or possibly having to have part of my small intestine removed later in life, it is absolutely crucial that gluten-free on food labels means exactly that - no gluten whatsoever - in the food, in the manufacturing process, and absolutely no cross-contamination since that will be harmful to my body and health.

2) How do you identify foods that do not contain gluten? I read constantly read labels whether it's in the grocery store, talking to waiters and cooks in restaurants, and talking about and reading labels when eating at other people's house for dinner. Time spent identifying foods? About 30 minutes per 1 hour a week at the grocery store and 5-10 minutes in restaurants and eating at other people's homes.

3) What percentage of foods and which types purchased are marked gluten-free?
Maybe 5-10%. Anything that's marked gluten-free can be baked goods, baking products, ketchup, soups, frozen dinners, sausages, etc.

4) Does gluten-free printed on a product label influence your decision to purchase products having the same ingredients? To what extent? Absolutely. If something is marked gluten-free, I know for certain that it is something that isn't detrimental to my health which is not only good for me but doesn't make me worry that I'm eating something that will harm me. Since the slightest amount of gluten (including cross- contamination) prevents absortion of nutrients and deposits gluten into my small intestine, it is absolutely vital that I know for sure a product is gluten-free because trace amounts of ingredients aren't required to be reported on a food label.

5) Would you consider a two or more level definition of gluten-free helpful?
No. While there are only a small number of people with Dermatitis Herpetaformis (DH), there are many children and senior citizens who have Celiac Disease (CD). Since people with CD and DH shouldn't have ANY gluten, it is absolutely critical that products be labed simply as gluten- free (GF). Gluten intolerance can also be a problem for people with Rheumatoid Arthritis and is generally not very helpful for people with Diabetes either. Therefore, it seems quite simple that most citizens wouldn't have a need for products labeled with varying categories of gluten but it is absolutely necessary for people with CD and DH to know which products are or aren't detrimental to their health. If the FDA is truly worried about how much food manufacturers will complain about the cost of having to identify and label gluten-free foods, it is simply sufficient to put GF on those products that are gluten-free for those of us whom it is crucial to live a gluten-free life.