2005N-0279 Food Labeling; Gluten-Free Labeling of Foods; Public Meeting
FDA Comment Number : EC994
Submitter : Mrs. Paula Montagna, MS, RD Date & Time: 09/14/2005 06:09:57
Organization : Nutrition and Lifestyle Counseling
Category : Health Professional
Issue Areas/Comments
I am a Redgistered Dietitian in Private Practice. I consult with Physicians of Internal Medicine and Gastroenterology. I work with patients to understand the gluten free diet and decipher food labels. I also make food lists for patients of acceptable food items. Patients fall into three categories. Those that are in fear of eating the wrong foods and severely limit their intake, thus become sickly and lose weight. Those who do their best to understand the foods allowable but are frustrated and limit themselves due to lack of choices. and those who limit their food items and fill up on all the wrong items to compensate for hunger or not knowing what to eat. Thank you for this opportunity to submit my thoughts, expereinces and opinions. Paula Montagna, MS, RD Nutrition aand Lifestyle Counseling, Long Island, NY

1) What should ?gluten-free? mean on a food label? Why?
Label Gluten free to identify those foods that do not contain gluten/ gliadin, or its dervivatives, and those containing wheat, rye and barley.

2) How do you identify foods that do not contain gluten? Time spent identifying foods? I research food items by reading labels, looking on the internet. This takes a considerable amount of time to stand in the store reading the labels with a list of dervivatives in my other hand to check for key words. The derivatives are often difficult to understand what they actually are and difficult to understand how much of an item it contains. I am concerned with missing an item that may actually be a derviative as these items often have long unusal names that are difficult to understand.
I am also concerened with causing un due harm and often proceed on the side of caution.
3) What percentage of foods and which types purchased are marked ?gluten-free??
Minimal items that I am aware of, other than items that are made by the maker to be gluten free. There are some makers that do a good job labeling their items but they are maker that are conscious that their product is gluten free.There is also a big concern that an item may in fact contain gluten in some form whereas one may never suspect it, as it is not realy consistent wtih that item.

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. Yes, I recommend to my patients and choose for my family items that are in the natural state, ie. not containing unnecessary additives/ fillers.


5) Would you consider a two or more level definition of gluten-free helpful?
Yes, this would be helpful for patients with varying sensitivites to have a 2 level defiinition. Gluten free and trace amounts. The more information that can be provided the better as this is often a difficult task to undertake.