2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC933
Submitter : Ms. Patricia Sharp Date & Time: 09/14/2005 05:09:04
Organization : Ms. Patricia Sharp
Category : Individual Consumer
Issue Areas/Comments
Item 1.
A. Gluten-free should identify totally G-F rather than 'no gluten added.' Some products which label 'no gluten added,' may already have gluten in ingredients used to manufacture the product. Therefore, the product can not be considered gluten-free even though no gluten was added as a separate ingredient.
B. Many research groups and support groups support absolutely no part of wheat, rye, barley or oats can be included in a product or any of its ingredients. On the other hand, some contend that ingredients such as barley from which the center of the bran is not used, are gluten-free. This needs to be clarified and included in the FDA policy.
2. I spend hours reading labels, which is not always successful in identifying safe products. I research safe lists at various web sites, some of which charge for information. I am educated and proficient on the computer, but many are not. The specialty stores are very expensive and too cost prohibitive for much of the gluten-intolerant population. Many are ill from long-term exposure to gluten. Yet, nursing homes, assisted living facilities, etc., often do not provide gluten-free choices. Hospitals are beginning to provide choices. In order for products to be safe for those under care of a facility, it is especially important that the criteria for labeling 'gluten-free' should not allow any ingredient with even a possibility of a trace of gluten. This would require the policy to include the possibility of cross-contamination of any product made at the same facility as gluten- containing products. In addition to foods, many toiletries, cosmetics, and even glue (such as is used on enveolpe flaps which are often licked by unsuspecting gluten-intolerant individuals) contain gluten. Prescription meds and over-the-counter meds often contain gluten in their inactive ingredients. I hope that this labeling can be required in such products other than foods.
4. Yes, 'Gluten-free' on a product label influences my decision to purchase products having the same ingredients.
5. I would not consider level-labeling because any amount of gluten may trigger a negative response, and the research considers gluten damage to be cumulative.

I am a member of Celiac Sprue Association / USA, Inc., and its chapter #5 in Oklahoma City (www.okceliac.com). I am a very active member, yet it is still sometimes difficult to identify safe foods and other products.