2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC814
Submitter : Mrs. Norma Daniel Date & Time: 09/13/2005 07:09:28
Organization : Mrs. Norma Daniel
Category : Individual Consumer
Issue Areas/Comments
RE: FDA Docket # 2005N-0279

1) What should 'gluten-free' mean on a food label?

As the only treatment currently available for celiac disease is avoidance of all traces of gluten,it follows that the only meaningful definition of 'gluten-free' on a food label must mean: none of the ingredients in the food contain any gluten at all, none of the additives in the food contain any gluten at all, no gluten at all has been used in processing that food, and all equipment used in the product processing line has been kept free (or thoroughly cleansed) of all traces of gluten-containing cross-contamination.

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

I look on the label for the term 'gluten-free'.
If I do not see that term stated on the label, I check the current Gluten-Free Product Listing' manual published by the Celiac Sprue Association, and see if the product is listed. (This manual costs me about $35 each year.)
If the product is not listed, I read the list of ingredients on the food label and compare it with a lengthy list of naturally gluten-free, gluten- containing, and ambiguous ingredients.
If I still am unsure whether the product is safe or unsafe for me to consume, I call the manufacturer's contact number (if available) for gluten information.
If I still cannot determine that the product is gluten-free, I do not buy it.

I spend approximately 6 hours a week in researching and identifying foods that are safe for me to eat.

3) What percentage of foods and which types purchased are marked 'gluten-free'?
Of the foods I am familiar with, I would estimate that 2-3% are marked 'gluten-free'.
These foods are usually soups, puddings, and beverages. Of the foods I purchase, 100% are either marked 'gluten-free', listed in a reference as being 'gluten-free', or the manufacturer has assured me that the item is 'gluten-free'.

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

Yes. I must avoid all traces of gluten, so if I cannot determine if a product is gluten-free, I cannot consume it, and therefore I do not buy it.

5) Would you consider a two or more level definition helpful?

It would be helpful, in that any labeling is better than no labeling at all. However, as I must not consume any gluten at all, I still would buy only 'gluten-free' products.

It is also important that the 'gluten-free' label designation be extended to pharmaceuticals as well, as persons with celiac disease must not consume any gluten at all, from any source at all.