2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC891
Submitter : Mrs. Azalyne Skye Date & Time: 09/14/2005 05:09:52
Organization : Mrs. Azalyne Skye
Category : Individual Consumer
Issue Areas/Comments
1) What should 'gluten-free' mean on a food label? Why?
ANSWER: Gluten free on a food label should mean 100% gluten free, made on equipment that does not handle gluten containing foods...so as to avoid cross contamination for the many people who are gluten intolerant/sensitive.
2) How do you identify foods that do not contain gluten? Time spent identifying foods?
ANSWER: I read labels, do mass amounts of research online, and make phone calls/emails to many manufacturers. When a food label states 'gluten free', but then states (usually in small obscure print) processing on equipment shared with wheat, I then identify that item as not being gluten free, as their is cross contamination! I find this labeling misleading and deceiving! I spend way too much time identifying what is safe and not safe due to misleading labeling/advertising.
3) What percentage of foods and which types purchased are marked 'gluten-free'?
ANSWER: 50% of the foods I purchase that are non produce, ie. bread mixes, cereals, milks, etc... are purchased if labeled as truly-authentically gluten free. The remaining foods that appear to have no gluten containing ingredients I make phone calls on, half the time I am assured the product is gluten free, the rest of the time they are not 100% sure.
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.
ANSWER: Yes, it most definitely does. My children are extremely sensitive and I need to be sure that the foods I am feeding them are not contaminated for any reason, especially through shared equipment and manufacturing procedures. For example, research has shown that cows who are fed mass amounts of gluten containing grains before slaughter have a gluten content to the meat. It would appear that meat is gluten free, but this is not always so. In addition, farm raised salmon are also fed large amounts of gluten containing grains, they too have a gluten content.
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.)
ANSWER: No, I would not. If it is labeled as gluten free then it should be 100% gluten free no cross contamination. If you are to create 2 more levels of labeling in regard to gluten content, the label absolutely should not read as 'gluten free', but rather 'contains x% gluten', in large print!