Everyone,

Although the Survey was due by March 15th, you can still give your
comments for another month. So it's not to late. Suzanne

--- In Los_Angeles_Celiac@yahoogroups.com, "Mary Courtney" <mary@...>
wrote:
>
> 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
>
>
>
>
> [Non-text portions of this message have been removed]
>