FDA Docket No. 2005N-0279

Food Allergen Labeling and Consumer Protection Act

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.

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 2nd 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.

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.

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

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