Treatment Guid

Hurry! Today is the Deadline to Tell the FDA What YOU Want Gluten-Free to Mean

Cleo Libonati Gluten Free Works

October 3 is the last chance to have a say on what “GLUTEN-FREE” should mean on food packaging labels.

Don’t miss this opportunity to be heard!

Here is the link to send in your comments on the proposed rule submit comments to the FDA.


Here are the 3 simple steps to get started:

  1. Under “submit a comment” button, check the “open for comment/submission” option,
  2. Enter docket number FDA-2005-N-0404 in the “keyword” space, then
  3. Select “Search.” This takes you to a new page for your comment.


On the Comment Page, do these 4 steps:


  • Press the “agency” button, select FDA
  • Under “document type,” check “proposed rule”
  • Scroll down to view the gluten-free docket
  • Select “make a comment”  this takes you to the easy comment page…you have 20 minutes to fill in the info.


Comment period closes at 11:59 pm EST.  Do it now!   For concise info straight from the FDA, go to their press release.


Our Stance:


1.  Gluten Free Works takes the position that “gluten-free” should mean zero (no) gluten. Therefore, the lowest level possible to test should be the standard. Australia uses 3 parts per million.


Fundamentally, celiac disease, before causing any other adverse effect, causes malabsorption.  This means before inflammatory damage to the small intestines develops, with or without gut symptoms, gluten can be causing nutritional deficiencies that can be debilitating and life threatening.


2.  No oats. Oats contain the gluten protein called avenin which has a toxic sequence proved to cause villous atrophy (intestinal damage) in susceptible persons. Research has demonstrated that some stains of oats cause a lesser reaction than other forms of gluten, but some strains can cause the same degree of inflammatory response as wheat. Until we can be certain who reacts and which strains cause a reaction, it is prudent not to include oats in the gluten-free diet.


We know this by research results and from our personal experience and from many letters to us from people who cannot tolerate oats. While you may think you can tolerate oats because you have no digestive symptoms, only nutritional blood testing can verify that, in fact, you do or do not have malabsorption causing nutrient deficiencies.


Author Information: Cleo Libonati, RN, BSN
Cleo Libonati is a Co-Founder of Gluten Free Works, Inc.
She is the author of Recognizing Celiac Disease.
She can be reached by E-mail.


    About Cleo Libonati, RN, BSN

    Cleo Libonati, RN, BSN is CEO and co-Founder of Gluten Free Works, Inc. and She is the author and publisher of the highly recommended celiac disease reference guide, Recognizing Celiac Disease.

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