Monday, August 8, 2011

Gluten-free Labeling: Register your comment with the FDA

I have posted this because it is important. Please read.

Gluten-free Labeling: Register your comment with the FDA: "
Last week, The Food and Drug Administration re-opened comments on its proposed gluten-free labeling rules. We have 60 days in which to submit comments to these proposed regulations. The comment period ends October 2, 2011.

Whenever a government agency prepares a set of guidelines, they open them up to the public to comment. It’s important to have a significant volume of comments to help shape guidelines and policies, but those comments must also be of decent quality. Every comment is read, logged, and recorded. This is an important (and often-overlooked) tool the public can use to help influence public policy.

Nancy at Gluten Freeville wrote a post which outlines the substantive points of the FDA’s proposed guidlines. You can read that here.

To submit your comments on the FDA’s proposed guidelines on gluten-free labeling, go to and:

1. Choose “Submit a Comment” from the task bar.

2. Enter the docket number FDA-2005-N-0404-0135 in the “Keyword” space (you don’t need to worry about the “Document Type” drop-down menu).

3. Select “Search.”

4. Scroll down to the results window and click on the “Submit a Comment” blue text to register your comment. Keep your comments professional and smart; they won’t be taken seriously if they’re overly emotional, ranting, derogatory, or filled with wild accusations, typos, and general cray-cray wackadoo-ness (which I know you won’t do, but I needed to put it out there).

Sample text you can cut and paste, then customize to your liking:

I have celiac disease/gluten intolerance, and I am requesting that the FDA institute clear, stringent guidelines on the labeling of gluten-free products. I know there is a recommendation of a level of <20 parts per million being gluten-free, but that is not gluten-free. People with celiac and gluten intolerance can get very, very sick from gluten-free foods that are produced on the same lines as regular food. If a food product carries the label “gluten-free,” but also has a disclaimer that it was processed in the same facility that also processes wheat or other gluten ingredients, then IT IS NOT GLUTEN-FREE, even if it did test at <20 ppm. If I consume that product, here is what will happen to me over the next 3-5 days:

1) I will suffer uncontrollable explosive diarrhea; 2) I will experience numbness and tingling in my extremities; 3) I will experience excruciating joint pain; 4) I will not be able to work or care for myself or my family; 5) I will suffer from migraine headaches; 6) I will experience a serotonin fluctuation that results in severe depression; and 7) the risk of my developing lymphoma increases five-fold.

Please establish gluten-free labeling rules that are clear, straightforward, and truthful about what the product actually is and how it is manufactured/processed. Again, cross-contamination is an enormous risk, and food that is produced in facilities that are not dedicated gluten-free facilities are not gluten-free foods. If a gluten-free food is processed on the same lines as wheat or other gluten-containing ingredients, companies should be required to disclose that on their packaging.

Lastly, please add gluten to the top allergens list.

Thank you for your consideration.

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After you’ve registered your comment with the FDA, it would be great if you could take a minute to email a short thank-you to Senators Patrick Leahy (D-VT) and Ron Wyden (D-OR) for urging the FDA to re-open the comments on these regulations and actually set some rules around gluten-free labeling, as they were instructed to do by Congress way back in 2007. Doesn’t matter if you’re not from Vermont or Oregon — Senators Leahy and Wyden deserve our thanks for pushing the FDA to establish guidelines. Here’s some text you can cut and paste into a thank-you email, and customize to your specific needs:

Dear Senator Leahy/Wyden:

Thank you for urging the FDA to establish rules around gluten-free labeling. I have celiac disease/gluten intolerance, and this is a very important issue for me and my family. Too often, those of us who can’t eat gluten get very, very sick because of the lack of labeling laws that allow trace amounts of gluten into the foods we eat. So, thank you for making the FDA do the work they have promised to do for years.


Your Name Here

Senator Leahy’s email contact form is here:

Senator Wyden’s email contact form is here:

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Lastly, please Digg and StumbleUpon this post, forward it to your friends and family, “Like” it on Facebook, Tweet the link — do whatever you can to encourage your friends, family, colleagues, and others to help support strong labeling practices. There are handy little buttons at the bottom of this (and every post, actually) to help spread the word.

This is one where we need all hands on deck. Thanks for taking a few minutes to tell the FDA how you feel. It’s really important, and I hope you will encourage others to register their comments, as well.

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A little background reading on the issue:

The Washington Post: FDA says “gluten-free” is not for fad dieters

ABC News: “Gluten-free” — FDA may be closer to definition (except, ugh, they call it “Celiac’s disease” in the intro)

Boston Globe: When foods labeled “gluten-free” aren’t


1 comment:

Marlys said...

Thanks for this very important message!