<<Disclaimer: Verify this information before applying it to your situation.>>

With 27 years of reading labels since my diagnosis, I feel that a discrepancy 
in the FDA regulations is to blame for this problem.   

The Food Allergen Labeling Law requires that the Top 8 Allergens are listed 
on ingredient labels.  Milk, eggs, soy and peanut are individual foods.  Tree 
nuts, fish and shellfish are groups of related foods.  Unfortunately, wheat is 
just "wheat" in the Allergen Labeling Law.  Without a more specific 
definition, the term could be either a group of foods or the common name for a single 
grain.  While the allergy and celiac communities consider it to be a group of 
foods, some manufactures obviously view it differently.  

While a case can be made that it is a family of foods, the definition for 
"wheat" provided by the FDA  in the Proposed Voluntary Gluten-Free Labeling IS 
very specific.  Please refer to  http://www.cfsan.fda.gov/~dms/glutqa.html#q7  
In Question 7, "Wheat, meaning any species belonging to the genus Triticum." 
leaves no doubt that it is a group of grains.  There is no debate that spelt and 
kamut that aren't wheat under the "triticum" family definition.  

Lacking the "Triticum" definition, however, it does seem reasonable to 
interpret the nonspecific "wheat" in the  Allergen Labeling Law as a single food, 
especially since the Allergen Law predates the proposal for voluntary GF 
labeling. The mandatory labeling for peanuts AND soy would even seem to support the 
single food view of 'wheat." While both are members of "Fabacae" family, they 
are the only 2 members of the large legumes family to get allergen status.

The FDA could quickly resolve the problem once and for all by providing an 
amended definition for "wheat" in the Allergen Labeling Law to make it 
consistent with the more scientific definition in proposed voluntary gluten free 
labeling.  Until that happens, unscrupulous manufacturers will continue to challenge 
the single vs. group interpretation and put health of vulnerable individuals 
at risk.  

It's too bad there weren't more "scientists" at the table when the Food 
Allergen Labeling Law was written. I makes me wonder if cheese from goat or sheep 
milk requires an allergy flag or does 'milk' come only from cows?  I think I'll 
read a few labels the next time I'm at the store!

Bev Lieven
Milwaukee, WI 


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