2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC878
Submitter : Mrs. Andrea Bankston Date & Time: 09/14/2005 05:09:46
Organization : Mrs. Andrea Bankston
Category : Food Industry
Issue Areas/Comments
1)What should ?gluten-free? mean on a food label? Why?
Gluten-Free should mean exactly what it says: FREE OF GLUTEN!! Why? Because if the food contains any gluten at all, then it is NOT GLUTEN-FREE. My health depends on being able to trust what I read. There is no excuse for labels to be vague or untrue.

2)How do you identify foods that do not contain gluten? I read every word on the label. If I don't recognize an ingredient, I look it up. If I can't look it up at the moment, I don't purchase the food. I can't afford to risk my health.

Time spent identifying foods?
A trip to the grocery store takes me twice as long, or more, than the 'normal' person. I would say 30-60 seconds per product I'm not already familiar with. That adds up fast.

3)What percentage of foods and which types purchased are marked gluten-free?
Maybe 5%... this question makes no sense. Either something is missing or it is just poorly written. What percentage purchased by me? What products? Various. Still not enough.

4)Does ?gluten-free? printed on a product label influence your decision to purchase products having the same ingredients? To what extent? Example:Two cans of tomato sauce on the shelf both contain only tomatoes and salt and only one is marked gluten-free.

Of course being marked gluten-free influences my decision. It means (or should mean) that I don't have to look at the ingredients at all.


5) Would you consider a two or more level definition of gluten-free helpful? 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.)

If there are going to be levels, call them something other than 'gluten-free'. It wouldn't make sense to use the term 'gluten-free', which means free of gluten. Some Celiacs can handle trace amounts, but I am not one of those. Even one crumb makes me feel ill and triggers an outbreak of Dermatitis Herpetiformis. Where do people get the idea that they can completely change a definition? If something says it is GF, then IT SHOULD BE GF!!!!! Why not simply refer to the levels as 'levels of gluten' or 'gluten levels'. How can something be called gluten-free if there is even a trace amount of gluten?!?!?! LET'S USE COMMON SENSE!!!!!!