2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC71
Submitter : Mr. David Givers Date & Time: 08/16/2005 05:08:05
Organization : Mr. David Givers
Category : Individual Consumer
Issue Areas/Comments
I originally had to self diagnose myself, over five years ago, for gluten intolerance through self education and the diet challenge test. Great strides have since been made through research into celiac disease and education of physicians. One of the most serious barriers still existing to a healthy life is the lack of standardized, trustable food labeling. This is really true for people newly diagnosed. The diagnosis itself is shocking to most individuals. Finding the right foods quickly and easily is an extremely large hurdle for most people.

We need a standard label for domestic and foreign foods that Celiacs can trust. That is the FDA?s mission and your jobs as officials in the FDA is to make it happen for Celiacs and not to value corporate profits over people?s health.

1) What should ?gluten-free? mean on a food label? Why?
Simply put--it means no (that is, zero to the testable level) wheat, rye, barley or oats (WRBO) or their derivatives in the food. Why??--because there is no known threshold level for safe consumption of these products.

For the same reasons, prescriptions and over the counter medicines need the same label.

2) How do you identify foods that do not contain gluten? Time spent identifying foods?

I have to read every label of every product I purchase for ingestion. Even after reading the label, there is no guarantee that the product has not been contaminated somewhere along the line in the food web of production and distribution--because there is no one including the FDA to make the guarantee and enforce it.

My wife and I have basically have stopped shopping the center aisles of the grocery stores because I can?t trust the labels and it is too time consuming to constantly read labels. Product ingredients are subject to change when the recipes or the supply chain changes. We use the outer ring of the grocery store, fresh fruits, vegetables produce, meats more than 90 percent of the time.

3) What percentage of foods and which types purchased are marked ?gluten-free??

Less than twenty percent. The costs are too high for these specialty products.

4) Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent?

I really don?t understand he question. If I have a craving for that food, then I would buy it, but I would still read the label because some labels say wheat free, but they are not gluten free.