2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC831
Submitter : Mr. Steven Hall Date & Time: 09/13/2005 07:09:26
Organization : Mr. Steven Hall
Category : Individual Consumer
Issue Areas/Comments
Gluten-Free labeling should indicate the absence of all traces of gluten. This is the only way to ensure Celiac Sprue sufferers will not encountering damage to their small intestine. This is especially true for me since I do not have any symptoms. The only way I can be sure that gluten is absent from my diet is to do a biopsy of my small intestine via an EGD or through blood work.

Currently I read every item in the ingredients list on every product I purchase. If it contains non-descript items like natural flavors, or artificial flavors I contact the manufacture to find out if these items contain gluten. I spend 1-2 hours per week researching food ingredients. This is complicated by the fact that most manufacturers state that they can change the ingredients any time without notice. Therefore, I have to re-read the labels each and every time I purchase their products.

I have found that less than .01% of all foods are marked gluten-free. I have observed that only those food items specifically manufactured as substitutes for wheat based products (e.g. gluten-free rice bread) are marked gluten-free. Some manufactures currently list at the end of the ingredients if it contains Allergens. This is nice, but it lacks clarity. For example: If a product states that it contains soy allergens does this imply it does NOT contain any other type of allergen? I feel gluten-free would be much clearer.

While shopping, if I compare two identical products where one is marked gluten-free while the other is not, I would purchase the one marked gluten-free over the product without this labeling because gluten-free implies that this product was produced on separate facilities. This eliminates the chance of cross-contamination.

A multi-level definition for gluten-free is acceptable to me ONLY on the condition that the FDA sponsors a study to determine which levels of gluten are low enough to prevent small intestine damage. Without this information, a tiered level approach for gluten labeling would be meaningless to me. Again, this is due to the fact that I do not have any symptoms to gluten and I have no way of knowing which levels would be acceptable.

As you can imagine living without wheat products is bad enough. Add to that complicated and inconsistent labeling on food products that can change without warning and life becomes miserable.

Thank you for your consideration.

Steven Hall