2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC888
Submitter : Mrs. Kathy Brazelton Date & Time: 09/14/2005 05:09:21
Organization : Mrs. Kathy Brazelton
Category : Individual Consumer
Issue Areas/Comments
1) "Gluten-free" should mean completely free of: wheat, rye, oats, or barley malt, any ingredient derived from these sources, and any trace of gluten not on the ingredient label that is incidental to processing. This would confirm to the consumer that the product is safe for their consumption, lifting an incredible burden from the consumer's shoulders in trying to read between the lines to ascertain if a product is truly gluten-free. Please note that it would be incredibly helpful if food service products were also labeled gluten-free, as there is less information available to consumers about these products, which increases our risks in dining away from home.
2) We identify foods not containing gluten by reading the labels, confirming with the manufacturer and referring to gluten-free listings published within the celiac community. We often resource websites of manufacturers and restaurant chains, email manufacturers or call them with questions. We spend significant effort on this when we wish to try new things. Additionally, when either of my children is headed to a camp or group outing, a huge effort is put in by myself and those involved in the food preparation (if they are willing to help) to communicate what the menu is, and to determine what ingredients and cooking methods are used to prepare each item on the menu and then to determine what substitute menu items they should prepare or what we should send with them to be prepared specially. This is always an enormous ordeal, but worth the effort to have our children live as normally as possible and still be safe and healthy.
3) About 5% of the products we purchase are labeled gluten-free, including products from Amy's, Thai Kitchen and Hormel in the general market, and cookies, crackers, pastas, and mixes specifically designed for a gluten-free diet in the specialty marketplace.
4) Having gluten-free on the product label is extremely reassuring, and definitely influences our decision to purchase these products over others. We know that the proper homework has been done on the product, and we can just relax and enjoy the product without any time-consuming research or worries about hidden sources of gluten. Even if a label appears to be gluten-free, we attempt confirm this with the manufacturer for those products we plan to use regularly, just to be certain.
5) The idea of different levels of "gluten-free" doesn't make sense to me, as I would think that a product either is or is not gluten-free. In raising my celiac children, I want to be sure that they are completely gluten-free while their bodies are needing to grow and mature fully, so that their growth and health is not impeded in any way. Since there is debate and differing opinions about the acceptability of certain types of ingredients such as vinegars, extracts and flavorings originating from gluten-related sources or the acceptability of some of the ancient grains, it could be helpful to have these types of items either defined more specifically on the label or have a separate category of gluten-free when these "questionable" items are present, but the product is otherwise gluten-free.