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

In retrospect, it is clear that the name of
the 'organization' shopping changes to the labeling bill
should have been identified.  The organization is the
National Food Processors Association (NFPA).  In
the interest of space, it was not feasible to list the name
of every member of the group.  Large associations establish
policy position, which are endorsed by their membership. We
are not aware, nor has any Congressional staff working on the
bill indicated, that specific food manufacturers have openly
supported HR 3684.

According to the NFPA website, they are "the voice of the
$500 billion food processing industry on scientific and
public policy issues involving food safety, nutrition,
technical and regulatory matters and consumer affairs.
NFPA's members process and package fruits, vegetables, meat,
fish, and specialty food and beverage products using a
variety of technologies including canning, freezing,
refrigeration, dehydration, and aseptic manufacturing."

For those who may be interested, the link below provides a
list of NFPA members with websites -- clearly, not all
members are reflected in this list.
www.nfpa-food.org/memberlinks.htm

As for NFPA's specific objections, there were several,
primarly related to specific allergens -- soy lecithin, fish
gelatin, and the effective date.  The sooner changes can go
into effect the better. This is what we have heard
repeatedly, and the position which the ACTF has supported.

With regard to section 6 of HR 3684 -- voluntary labeling
for GF foods, this language was included in the labeling bill
in 2002.  This language precedes the creation of the American
Celiac Task Force.  Clearly, if there were objections, those
celiac organizations working on the bill at that time would
have expressed them to the Committee staff.  To our
knowledge, no celiac organization has expressed concerns, or
asked that it be removed.

There are positives related to this section. The FDA will
be required to develop, for the first time, a definition
for the term 'gluten-free.'  A 'proposed regulation' with a
defintion of 'gluten-free' will be developed, and the public
will have the opportunity to provide comments, views, and
concerns about that 'proposed' regulation (sometimes called
rules).  The FDA will review the public comments, before
finalizing the regulation.  Very often, the comments provide
information which leads the FDA to modify what was originally
proposed.  Becauses this provision has the greatest impact on
the celiac community, THIS IS the best opportunity to express
our views on something that is critically important to all
celiacs.

Through this process the FDA will clearly be looking at ALL
the offending grains, not just wheat.  They will also be
forced to arrive at a definition after reviewing 'other'
standards such as the Codex, or the UK standard.  Something
that has never been done before.  Once a definition is
reached, the celiac community is in a far better position, to
request further improvements to the food labeling laws.

When the ACTF began working with Congress in March 2003, key
decisions regarding what allergens would be included had
already been made. Rather than starting at ground zero,
Congressional staff started where they had left off in 2002.
In doing so, the Senate was able to pass the bill
unanimously. Because of the Senate action, it has helped pave
the way for quicker action in the House.

We have stated all along, and everyone agrees, the bill is
not perfect. It will, however, give celiacs information they
desperately need and deserve. With rare exception, the
celiac community is in agreement on this point. It is
evidenced in the thousands of letters sent to Congress in
support of both S. 741 and HR 3684, and in the information
presented on dozens of support group websites, and in their
newsletters.

Andrea Levario and Allison Herwitt
Co-Chairs, American Celiac Task Force
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* Visit the Celiac Web Page at www.enabling.org/ia/celiac/index.html *