2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC944
Submitter : Mrs. Denise Healy Date & Time: 09/14/2005 05:09:14
Organization : Mother
Category : Food Industry
Issue Areas/Comments
Dear FDA:

As the mother of a daughter, now 27, with Celiac disease, I encourage you to adopt a regulation on the use of 'gluten-free' on product labels that is in line with that which has been used in Europe and other countries (including the USA via the Codex Alimentarius) for many years--20 PPM for products that contain naturally gluten-free ingredients, and 200 PPM for products that have been rendered gluten-free such as those that may contain Codex Alimentarius quality wheat starch. The formal adoption of these existing regulations will allow for the continued importation of excellent, safe European products that are labeled 'gluten-free.'

It is very important that you do not adopt a 'zero tolerance' regulation in this matter because doing so will cause many gluten-free food companies to discontinue their use of the term 'gluten-free' on their labels out of fear of litigation--which is counterproductive for all people with this disease (most, if not all, gluten-free food companies do not grow, transport or mill the gluten-free grains that they use as ingredients--a fact that will make them vulnerable to litigation if a zero tolerance level is adopted). Last, the inclusion of trace levels of gluten in the diets of those with celiac disease have been shown to be safe in many scientific studies, for more details please see:


My daughter was diagnosed at age 3...24 years ago. I remember what it was like to write to manufacturers for labels. I was deligent about keeping her gluten-free. Help all celiacs and their families. Make it easier for us and adopt a regulation on the use of 'gluten-free' on product labels that is in line with that which has been used in Europe and other countries.

If you ever...ever want a spokesperson to talk with you about raising a celiac child into an adult, I would be happy to discuss how much easier it is today than it was for her and our family over the last two decades.

We can't go back...help us go forward.

Thank you,
Denise M. Healy
(Mother of Jennifer Ann Dodd, Celiac adult)
112 E. Madison Avenue
Collingswood, NJ 08108