2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC777
Submitter : Dr. Julie Dunn-Morton Date & Time: 09/13/2005 06:09:57
Organization : Dr. Julie Dunn-Morton
Category : Individual Consumer
Issue Areas/Comments
Docket # 2005N-0279
Gluten-Free Labeling of Foods mandated by the Food Allergen Labeling and Consumer Protection Act.

As a recently diagnosed celiac, I am very concerned with the accuracy and consistency of labeling related to the use of gluten-containing products in prepared foods. Although my degree of intollerance is not life-threatening, I do find that any amount of gluten product will cause serious and life-disrupting physical symptoms. I also have found that the time I have invested in learning about gluten sources so that I can identify any possible items on food labels has been extensive, and even so the labels are not always clear. I have also found that foods listed as "no gluten added" are then produced on machinery which uses flour on the conveyor belt during the packaging process - adding a dangerous ingredient to the "finished" product which, although not technically part of the recipe, is still present in levels that could be life-threatening to many individuals. Like other celiacs, I currently spend more than twice my usual time grocery shopping due to the need to meticulously scrutinize every label of every item I buy, including dairy products which use modified food starch for thickening. I generally avoid most canned, boxed, or processed food unless it is sold on the "gluten free / health food" aisle of the grocery, and even then I must still carefully read the labels, as the terminology is not consistent. For example, I was recently given a "gluten free" dinner roll on an international airline "gluten free" dinner that stated it was gluten free but actually contained a small portion of wheat flour - apparently within some guideline (perhaps British) for an acceptable level of this potential poison. I avoided eating it because I have learned that for me, any level of gluten product is a problem.

For these reasons, I respectfully submit the following recommendations for food labeling:

1) ?gluten-free? on a food label should indicate that this product contains no gluten-containing ingredient, either by virtue of their recipe or their packaging process. The product should not be exposed to a gluten-containing ingredient at any time.

2) Companies should be urged, although not required, to add the term "gluten free" to their labels if their products meet that requirement. If there were consistent and enforced guidelines for what "gluten free" meant, it would greatly assist celiacs in shopping safely. For example, if a salad dressing does not contain any gluten product, even if the recipe is only oil, vinegar and spices (that is, even if there is obviously no reason for a gluten-ingredient thickener) the company should be urged to add the gluten-free label.

3) Please consider a two or more level definition of gluten-free as this might be helpful to those who tolerate some level of gluten.

Example: If Level A meant the absence of any wheat, barley, rye, oats and any of their derivatives and level B meant the presence of trace amounts, less than "X" parts per million, of wheat, barley, rye, oats and any of their derivatives and level C meant the presence of small amounts, less than "Y" parts per million, wheat, barley, rye, oats and any of their derivatives. (Using "X" and "Y" to identify quantities to be determined by the FDA.)

Thank you for considering my request.