Below is a (long) example of comments to the FDA on their proposal regarding
gluten-free labeling. I haven't pasted them into the FDA site yet, so feel free
to use this forum to comment on them and/or try out your own.

I hope you'll be inspired to participate in labeling that will be especially
helpful to the newly diagnosed. To make your comments, paste this into your
browser:
http://www.accessdata.fda.gov/scripts/oc/dockets/comments/COMMENTSMain.CFM?EC_DO\
CUMENT_ID=1398&SUBTYP=CONTINUE&CID=&AGENCY=FDA



"As a celiac following a strict gluten-free diet for over twenty years, I find
it necessary to my health (and ability to make a living) to know if even "gluten
free" processed foods are processed or packaged in a gluten-free facility or at
least on a gluten-free manufacturing line.



As an educator for new celiacs, I find the proposal has taken into consideration
how confusing gluten-free shopping can be, especially for the newly diagnosed
celiac and their family members.



To make scanning a label easier, I propose that only the term "gluten free" be
used without there being allowed synonyms. A universally used seal would be even
better. A single food label can contain a variety of type sizes and font styles.
Yesterday, two of us couldn't find "gluten-free" on a "busy" tub of margarine
made from rice, even though (as we saw at home) it was running across the top
with a yellow background.



Yes, please DO PROHIBIT most oat manufacturers from saying that oats are
naturally gluten free. If I ever chose to eat oats, I would want them labeled so
that I could tell the difference between oats that were grown, processed and
packaged for celiacs and those that were not. "Safe" oats are currently too
expensive, so I hope that the legislation will encourage more development and
competition.



The rest of the proposal concerning naturally gluten-free foods is NOT
completely satisfactory. After run-ins with flavored water, flavored rice cakes
and popcorn, coated produce, and contaminated corn tortillas, a celiac can have
trouble believing that anything sold in the aisles of a supermarket is
"naturally" gluten-free. However, since many people do not know where their food
comes from and what can happen to it between harvest and market, a little
education on the label about what is "naturally gluten free" is a good idea if
done properly. The word "plain" should be inserted in the "all X is gluten-free"
or "X, a gluten-free food" statements, because there are so many flavored
products of all kinds, e.g, flavored rice cakes, popcorn, water.



In other words, since all packaged juice is not gluten-free, it is proper that a
"100% juice" bottle or an ordinary carton of "plain milk" be able to state that
type of product is naturally gluten-free. But the language must be more
specific, e.g., "All 100% juice is gluten free" and "All plain milk is
gluten-free." I'd hate to see a carton of chocolate milk that says, "Milk, a
gluten-free food" or "All milk is gluten-free" because the consumer might
generalize and assume that a milk beverage flavored with malt (made from barley)
is covered by that educational statement.



It is possible that the 20 ppm threshold will cause gluten-contaminated products
to be labeled in a way that means I cannot trust the "gluten free" labeling on
new products for my own strict adherence. So that the majority of celiacs have
an easier time adhering to the diet, I'm willing to research products until
better testing is available.



If someone needs examples of foods that seem gluten-free, but which can make
some celiacs noticeably sick, there are manufacturers that label their products
as having "no gluten ingredients" and have started revealing that they are "made
in a facility that processes wheat." I could have told you that they were
contaminated with gluten five years ago when the same products (then marketed to
celiacs) consistently made me ill. I wish I knew, for example, how many parts
per million of gluten that Diamond Crackers contain, so I could better comment
on the 20 ppm threshold of gluten mentioned in the proposal.



I have stayed well during the past year using naturally gluten-free foods and
products now labeled "gluten-free." While I used (and trusted) most of them
before the 2006 labeling began, I find myself looking around more for a wider
variety of processed foods than I used to because of the improved labeling. I
don't know how many parts per million of gluten my favorite gluten-free products
may average, but I believe from my "gut" experience that none of the major
manufacturers of gluten-free products have betrayed their celiac customers."



Mary Courtney




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