2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC949
Submitter : Miss. Alyson Fitzsimmons Date & Time: 09/14/2005 06:09:33
Organization : Federal Drug Administration
Category : Federal Government
Issue Areas/Comments
Please find my comments below for the FDA questions as to how to DEFINE GLUTEN-FREE food labels, FDA Docket #2005N-0279. The numbers of each comment correspond to the questions.
1.) Gluten- Free (GF)should be listed on a food label when all ingredients listed contain no gluten or any additives contain no hidden gluten. I am not knowledgeable as to how many parts per million molecules of gluten is acceptable by the medical community to determine the food safe, but it should be stated if there is minimal gluten so the consumer can determine if it is safe. If the item is GF but manufactured in a facility where gluten is present, that should also be stated.
2.) I identify GF foods by extensively reading labels and analyzing each ingredient, its potential source of production and any potential additives that may have been added (ex: nuts in an ingredient -- where they dusted with flour?)I spend at least 1/2 - 1 hour more grocery shopping reading for gluten sources. Six months ago, when my daughter was first diagnosed as a Celiac, it took a 3 hours per week to do grocery shopping. Now that I'm more knowlegeable about products, I don't have to read each item in every label, but I still skim the known items to make sure a new ingredient hasn't been added (which happens more often than I would like).
3.) It appears to me that only 5% of the foods I purchase are labeled Gluten-Free. If I shop at a health food store, maybe 10-15% at best. The types of food that state GF would be cereal, crackers, flours, cake mixes and occassionally the unique item (from a conscientious manufacturer) like rootbeer. The items that you don't expect to be labeled (i.e. root beer) makes it much easier to be completely reassured before purchasing that one less product in your cart was questionable.
4.) Yes. If "GF" is stated on a label, I am much more likely to buy that product over another product or even buy it because it states that it is free of gluten. The rootbeer is a perfect example, I could easily have purchased another brand or type of soda. In reference to the tomato sauce example in the question, again the wording of "GF" would definitely entice, if not convince me to purchase the GF labeled item before the other. The only reason I wouldn't purchase the GF item over the other item would be if the other non-labeled item was an old favorite and that I had prior knowledge that it was gluten-free( either by checking with the company or reading from a celiac support group that it was deemed GF).
5.) I would definitely consider a two or more level of GF labeling helpful. Not only does it help me determine whether to make the purchase at that moment, it is a source of information for me to consider and determine at a later date whether I think, after reviewing medical information, whether the parts per million of a potential gluten containing item is safe enough to eat. I also find it very helpful to read GF and other labeling (i.e., lactose free, nut free, wheat free etc.) simplified in a check-mark system on the front of the label. We only have to worry about gluten in our family, but it still helps to decide for us, and others we mayh prepare meals for, to see the simple labeling. As an example Heinz, UK labels their ketchup and Salad Creams, available in the USA, with this system;Heinz USA does not label their products with a check mark system and one must read the general ingredients section on the back of the container. Europe is far ahead of the USA in its labeling, I am puzzled as to why we cannot also label our items in a way that protects and helps all citizens. Gluten is extremely damaging to a person who suffers with Celiac Sprue, it can cause irreperable damage and even life-threatening illnesses. I hope that the FDA will consider better labeling for the 1 out of every 133 americans that suffers with Celiac Sprue.
Thank you.