2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC84
Submitter : Mr. M Danke Date & Time: 08/19/2005 08:08:56
Organization : Mr. M Danke
Category : Individual Consumer
Issue Areas/Comments
A while back, I was a prospective juror. The prosecutor was trying to eliminate possible jurors by asking a how small an amount of illegal drugs would count toward a conviction. She was asking if 'Just a tiny speck' would count. This being Texas, she found her jurors. There being Washington, I'm not so sure that 'Just a tiny speck' might be allowed. So let me be clear - I'd prefer zero tolerance.

It takes me a lot of extra time to research packaged food and related supply chains. Many times, the ingredient label is inconclusive and requires a phone call, where I can be put on hold for 20 minutes or more, per product. I generally carry my cell phone while shopping for this very reason. Websites often do not carry ingredient information. The amount of packaged food I've purchased has plummeted as a result. It takes too long to pick my way through the minefield.

If you adopted a ruling that included some 'allowable' gluten in packaged products, I would consider the label 'gluten-free' useless, which would result in even more time spent researching products. In fairness, such a label, if widely adopted, might allow me to definitively rule out products that didn't carry the designation.

Although it's in your purview, you did not address in your call for comments a pressing problem with medications. So-called 'inactive ingredients' can include starch made from wheat. There are several (hundred?) medications that are regularly prescribed that Celiacs cannot knowingly safely ingest. Although clarity in medication is a most pressing need, the concept could be extended to vitamins and other supplements, as well.