Gluten-Free Labeling (Updated): Aug 2011 G-Free Newsletter

I’m starting to feel like the proposed gluten-free labeling laws are like blind dating.  She/he’s perfect, they tell you!  And then you meet and spend some time together and start to realize it’s all not quite as marvelous as you first thought.

The teleconference on August 2nd was great!  We heard that the comment period was re-opened and we might even have a law by 2012.  Several prominent researchers, including Dr. Alesso Fasano and Dr.Stefano Guandalini, spoke in favor of the new proposed legislation with a 20 ppm standard. “This is a standard that has been in use in Europe for almost two decades, & the science supports the U.S. adopting it as well,” commented Dr. Fasano.  I posted some of the highlights of the teleconference, but upon reading the 90+ page safety assessment, there are a lot more questions that come up.

The safety assessment suggests that for the most sensitive Celiac, ONE ppm would be the safest standard, as opposed to the proposed 20 ppm.

“The tolerable daily intake level for gluten in individual s with CD was determined in a safety assessment to be .4 mg gluten day for adverse morphological effects and .015 mg gluten a day for adverse clinical effects. The LOC (Level of concern) of gluten in food that corresponds with these TDI (total daily intake) values at the 90th percentile are less than 1 ppm for both morphological and clinical effects. In sum, these findings indicate that less than 1 ppm level of gluten in foods is the level of exposure for individuals with CD on a GFD that protects the most sensitive individuals with CD and thus protects the greatest number of individuals with CD from experiencing detrimental health effects from long term exposure.”

Or, in plain English, to protect all Celiacs, we’d be looking at 1 ppm or less.  This is a big difference than 20 ppm!

I think instinctively we all want the standard to be at zero, but first, we can’t get below what machines can detect (general consensus is around 3ppm).  It seems like the most important job of the FDA is to explain the gap between the proposed 20 ppm and the safety report’s recommendation of 1 ppm.  According to the Federal Register: “Currently, analytical methods that can reliably and consistently detect gluten at levels lower than 20 ppm do not appear to be available. In addition, it may be difficult or infeasible for food manufacturers to meet a lower gluten threshold level or that meeting a lower level could increase their food product costs. As a result, fewer and/or more expensive GF-labeled foods would be available to individuals with CD, placing them at higher risk of developing serious health complications from CD and other related diseases.

Huh? There are still other programs out there which will certify foods at 5 and 10 ppm, such as CSA, GIG and NFCA, so it appears we have the technology.  Also, by all accounts the GF marketplace is booming.  Tricia Thompson, trailblazing RD of Gluten Free Watchdog states:

“Based on testing done by Gluten Free Watchdog (, the majority of food is testing below 5 ppm gluten* and most of the products testing this low do not carry any specialty certification.”

In other words, we’ve got the technology and the gluten-free market can handle it.

I hope FDA provides a clearer answer AND expresses how they determined 20ppm was safe level for almost all Celiacs, ideally yesterday!  People need this info to comment intelligently on the proposed ruling.  I’m a dietitian, but not trained in reading studies on levels of concern and how that translates into real life, and neither is the general public.  I hope they choose to make their decision-making transparent, AND I hope they lower the level.  If we can do it, I personally believe we should.

However, I also think the danger of not having a law is greater than the danger of the 20ppm, and at the point, best case scenario, we’ll have a law in effect in 2013.  I do want them to get on with it! We need something uniform, standard and most of all, enforceable.

The rest  of my wish list includes:

  • Incorporate newer research, such as the studies that came out on gluten free grains and flours and cross contamination.
  • Take this opportunity to define the “made in a factory” statements.
  • Look closely at the issue of considering oats gluten-free, since there is still a good deal of controversy on the issue.
  • I truly hope they do NOT go down the path of “low gluten”, which seems excessively confusing to people.
  • I would love it if they would label gluten in medications, even though they were pretty clear it’s not on the table at this point

Resources around the web:

1 in 133 has a new FAQ section

Tricia Thompson, MS, RD has a fabulous article here

Gluten Free Living

Michael Taylor of the FDA also just posted on the proposed gluten-free regulations.

How does this change your view of the proposed gluten-free labeling laws?  The FDA says they want to hear from us. Let’s grant their wish.

The comment period starts Aug 3rd around noon, and you can submit your comment here: and entering Docket No. FDA-2005-N-0404

For more information and a statement from the FDA, please see:

Agree?  Disagree? What’s on your wish list?  Whatever your view, I hope everyone who has a vested interest in this legislation takes the time to write into the FDA.

A very big thank you to the FDA for hosting this discussion and taking this next step, and to 1 in 133, American Celiac Disease Alliance, University of Maryland Center for Celiac Research and many, many others for getting this legislation moving again.

News, Events & Resources:

DC Celiacs

Next Meeting Date: Saturday, September 10, 2011, 2:00–4:00 pm
Speaker: TBD
Location: Rockville Library

CSA Chapter 100 is hosting a conference with one my favorite authors, Melinda Dennis. Please RSVP for meeting with number of guests attending by emailing or call 571-289-5675 with any questions.

Gluten Free Travel Site is one of my favorite on-the-go resources, and they’ve launched a monthly gluten-free newsletter.  This month, they feature a great resource list, and of course, many dining reviews, too.

Tis the season for fresh yummy fruit!  See what I had to say about Farmer’s Markets for Channel WUSA9

Harris Whole Health offers individual sessions, family sessions and group classes to help people eat healthier and feel better! Whether you are dealing with Celiac Disease, food allergies, picky eaters, children on the Autistic spectrum, chronic illness, or if you just want to feel and look better, Cheryl can help you achieve your goals. For an appointment with Cheryl Harris, Registered Dietitian and Nutritionist, please click here or call 571-271-8742.