FDA Docket No. 2005N-0279

Food Allergen Labeling and Consumer Protection Act

1.  What should 'gluten free' mean on a food label? Why?

> Gluten free should mean this food is safe for people who are gluten
> intolerant. That should include everyone from diagnosed celiac to
> gluten intolerance that may be self-diagnosed. Today there are a
> predicted 1:133 people with celiac disease, whether diagnosed or not.
> If a product is labeled GF it should not contain gluten ingredients
> nor any cross-contamination from the production facility.

2.  How do you identify foods that do not contain gluten? Time spent
    identifying?

> I read labels on all processed foods, including meat packages. The
> only items I don't read labels on are fresh produce or 100% pure
> products (raw rice, beans). Most processed foods whether packaged,
> canned or frozen contain a thickener or starch.
>
> It's not just the time -- it is the sense of disappointment and
> deprivation that goes with reading a label and then having to put the
> item back on the shelf because it's not safe. Initially reading labels
> require quite a bit of time. At first a normal 30-60 minute shopping
> trip became a 90 minute trip. But as I became more familiar with what
> to avoid and gave up other foods, I became more efficient. One has to
> become familiar with all the additives and 'hidden' names of gluten.
> Now it is 2^nd^ nature. I would estimate this adds about 10% time to
> shopping, depending on type of food you buy, how knowledgeable you
> are, how fast you can read and how good your eyesight is for small
> print on labels.

3.  What % of foods and which types purchased are marked 'gluten free'?

> Less than 5% of foods are actually marked GF. Which types? Typically,
> the foods that are marked are those that are starchy or wheat based,
> such as bread, pasta, cereals, crackers.

4.  Does 'gluten free' on the label influence your buying decision? To
    what extent?

> Yes -- Absolutely! 100% of the time. It's not as if we typically have
> a choice of numerous GF products to choose from. If we find a product
> with a GF label, it's always a thrill. I buy these products 1) because
> I trust they are safe from obvious or hidden sources of gluten,
> including cross-contamination; and 2) to vote with my pocketbook, as a
> consumer. By buying products from a company that demonstrates
> familiarity with gluten intolerance, I support them and want to help
> them remain in business.
>
> Note: The single most important improvement to label foods containing
> sources of gluten would be to require that all 'starch' be identified
> by type. I specifically DO buy foods that define starch as rice,
> potato, corn or tapioca. But if 'starch' is all that is on the label I
> put it back. Better to be Safe than sorry. It is too time consuming to
> track every product, every brand to know if the starch is safe or not.
> This one change would insure fewer mistakes by those less
> knowledgeable and expand the number of foods available to those with
> celiac disease or gluten intolerance.
>
> If there is anything I can do to help improve gluten free labeling
> please let me know!
>
> Sincerely,
>
> Karen J. Keating
>
> 7511 E. Pima St
>
> Tucson, AZ 85715
>
> <Kkeating1111@hotmail.com>