2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC695
Submitter : Dr. GEORGE KACHEN Date & Time: 09/12/2005 06:09:53
Organization : Dr. GEORGE KACHEN
Category : Individual Consumer
Issue Areas/Comments
First of all, thank you for doing this and for providing an opportunity for Celiac patients like myself to give you input--much appreciated.

I currently spend a lot of time reading labels. I am so happy when I see a product that says "Gluten Free"--it saves a lot of time reading the ingredients. In fact, I have been on business trips and will call my wife at her job asking her to check an ingredient on the web to see if it is gluten free! The ingredient listings that currently cause the most problem are those that say: Natural flavoring, Artificial flavoring, modified food starch, seasoning. Modified food starch, for example, can use wheat or corn. Seasoning often uses flour to prevent clumping--this is subtle, but very important. If these ingredients are listed (like modified food starch in some yogurts), I won't buy them!!

So, I recommend that all foods be labeled either as "Gluten Free" or "Contains Glutens". Gluten coming from wheat, barley, rye, oats and any of their derivatives. The specification should clearly state that each of the above items (modified food starch, etc) contains or does not contain glutens.

I also recommend that the label indicate whether or not the bottling/packaging facility also processes gluten-containing items. For example, I could see on a label of a salad dressing saying: "Ingredients are Gluten Free; however, Processing Plant also Processes Gluten Containing Items. We carefully clean our facilities before processing this product, but depending upon the sensitivity of the individual to trace amounts of gluten, there could be some health risk...." or words similar to this (less wordy than mine!!).

Also, it would be helpful if alcoholic beverages are so labeled. For example, if vodka is made from just potatoes, that is OK, but most vodkas also use wheat. But has it been distilled so that no glutens remain?? Similarly with scotch, etc. Also, Japanese beers are usually a combination of rice and wheat, not just rice as one usually thinks.

Candy is another issue--M&M's are OK, as are Baby Ruth bars, but I am uncertain about the others.

Thanks again for this opportunity and listening. I will be happy to provide other input as needed.

All the best,
George Kachen
Reading, MA