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(part 2 of 2, continued from part 1)(maybe length wasn't the problem)

B) Advisory labelling:

        I agree with the statement "FDA believes advisory labeling should
not be the norm, and manufacturers should strive to eliminate the presence
of allergenic materials that are not intentionally added to a specific food
product."

        I worry that the wording "May contain traces of ...." could be used
by manufacturers to protect themselves, and might eliminate potential food
products that might in actuality be safe.

        I would prefer to see labelling as follows:

                wheat in all its forms clearly labelled in the ingredients
list.  Otherwise:
                "wheat free; made in a wheat-free environment"
                "wheat free; made on shared equipment or non-dedicated
lines"
                "wheat free; manufactured in a facility that processes other
wheat containing products."

        Symbols could be devised as a shorthand for this terminology.

        I'd like to look for the labeling statements next to or below the
ingredients list.

C) Labeling of Ingredients Exempted from Declaration
1) Common or Usual Names of Flavorings, Spices and Colors Natural
Flavors - Our concern is mainly with the following in the FDA defined
list of     natural flavors (*see below): "protein hydroylsate,
distillate, or any product of

        roasting, heating or enzymolysis that contains the flavoring
constituents derived from a     spice, fruit or fruit juice, vegetable or
vegetable juice."  The problem is the ambiguous         "vegetable" origin
of these flavors.  We would like this to be disclosed, in the ingredient
list, with a generally applicable policy, not on a voluntary basis.  Another
concern is      herbs and spices, also categorized as "natural flavors"
("herb, bark, bud, root, leaf, or       similar plant material"), which
might have flour added as anticaking agent (see incidental      additives
below).  Just listing "natural flavors" doesn't tell us what is included.

2) Labeling of incidental additives

        1) What minor ingredients would manufacturers be unlikely to
recognize as containing food allergens?

        a)Incidental wheat from cultural practices: growing crops on the
same fields where wheat         was once grown, using the same trucks and
manufacturing facilities.  Oatmeal in this      country is      considered
to be contaminated with wheat from these sources and should be  so labelled.
If      there's a wheat free source of oatmeal, we would like to know about
it.     This may be the case for other grains, such as millet, quinoa, and
others.

        b) Flour used for anticaking or sticking might be derived from
wheat.  As noted above,         this can be true of many herbs and spices
and mixes, where one might not expect wheat     flour to be present.  Or
flour may be used on a conveyer belt or other equipment. Or simply
processed in the same room, and therefore in the air.  If so, it is a
contaminant in the      final product and should be labelled as such.

        c) Enzymes of microbial origin may have been grown on wheat
containing substrates.

        d) One method of creating caramel color is to extract it from
fermented grain by-products.

        e) Emulsifiers (mono and di-saccharides) might have wheat origin
        f) Vegetable broth might have wheat origin or thickening

        2) When products that contain food allergens are further processed,
is food allergen labelling sufficent?

        Emphatic "NO."  This is a big problem.

        The inclusion of wheat in the intermediate products should be
clearly labelled.

        A couple of examples: Labels for tomato paste may or not show the
inclusion of wheat flour.       If tomato paste is an ingredient in another
product, one doesn't know if it has wheat flour         added or not unless
the ingredients of the tomato paste are included in parentheses (this   is
sometimes done).  The same is true for soy sauce and soy sauce as an
ingredient.

        3) Should the agency codify its policy that incidental additves are
not exempt from         labeling and must be declared in the ingredient
statement?  YES, please codify the labeling     to include all the minor and
intermediate ingredients.

        Not on the agenda is the issue of testing for gluten in foods, but
if there's time I'd like to speak to this issue.

Thanks for your input-

Mary Thorpe

*"At the present time, the terms "natural flavor(s)" and "natural
flavoring(s)" may include: "essential oil, oleoresin, essence of
extractive, protein hydroylsate, distillate, or any product of roasting,
heating or enzymolysis that contains the flavoring constituents derived
from a spice, fruit or fruit juice, vegetable or vegetable juice, edible
yeast, herb, bark, bud, root, leaf, or similar plant material, meat,
seafood, poultry, eggs, dairy products, or fermentation products
thereof, whose significant  function in food is flavoring rather than
nutritional"; WITHOUT DISCLOSURE OF ANY OF THOSE INGREDIENTS."