Comment from Schmidt Anne

I stand with Beyond Celiac and the gluten-free community in opposition to the FDA’s draft guidance FDA-2021-N-0553-0005. I have a young child with Celiac Disease. Unfortunately, the only existing treatment is a strict, lifelong gluten-free diet. Gluten is found in wheat—which is a top 9 allergen and therefore reliably labeled on products— but also in barley and rye. Unlike other conditions where there are some options to manage inadvertent exposure, people with celiac disease rely solely on accurate food labeling to maintain good health. The FDA’s current labeling laws and guidance do not fully protect consumers, because the gluten-free labeling provision is voluntary. Existing labeling laws also go against recommendations from the FAO/WHO Expert Committee regarding Risk assessment of Food Allergens for Codex, which “determined that only foods or ingredients that cause immune- mediated hypersensitivities such as IgE-mediated food allergies and coeliac disease should be included on the list of foods and ingredients...” That would include calling out barley and rye. Consumers should be able to raise valid concerns about government policies and petition for worthwhile changes that would improve the safety of their food. Right now, the celiac disease community, as well as the food sensitive community at large, needs more protection. If this guidance is approved, it would prevent many Americans, like myself for my child, from continuing to fight for safe food. Please do not pass this draft guidance.