From The Gig Thread

[gfp]

GFP you're trying to turn this thread into a labeling debate, which it isn't. You are also ignoring the fact that you attacked someone in this thread whose sole aim is to help celiacs like you--and you basically accused them of lying and taking money to promote McDonald's.

Both of these really do seem to me to be proper topics for debate at the GIG.

As I said, I worded things badly but there is a very fundamental question. Do GIG get paid for the work they do from the food industry.

This is really fundamental. It's not illegal and indeed this is EXACTLY the situation in the UK with CUK.

In order for CUK to pass a company the company have to pay CUK.... in order for them to use the gluten-free logo they have to pay etc.

There is nothing illegal about this, they do work..they get paid. It does however throw into question their bias.

It also really makes life hard for the small gluten-free manufacturers who actually CARE. They cannot afford the CUK fees, the same goes for private resto's vs chains.

I fully realise SOMEONE has to pay for analysis. However the question for the GIG should be how/who.

I don't think CUK set out to become what it has become, it transformed because things changed around them.

GIG can actually address this now. There are several ways of doing it including setting up a blind fund the food industry can contribute to but does not get to influence how the money is spent.

You conveniently ignore scientific data, and you fail to understand that while setting a personal goal of zero tolerance is perfectly fine and both Cynthia and I recommend this, it may not work for labeling regulations. You also keep using 200ppm, but the actual amount to call something gluten-free is now 20 ppm in Europe and Canada, and will likely be the same in the USA. This just came out today:

Aliment Pharmacol Ther. 2008;27(11):1044-1052.

Systematic review of studies published between 1966 and May 2007: Tolerable Amount of Gluten for People With Coeliac Disease

Conclusions: The amount of tolerable gluten varies among people with coeliac disease. Although there is no evidence to suggest a single definitive threshold, a daily gluten intake of <10 mg is unlikely to cause significant histological abnormalities.

As I understand it is TWO limits.

20ppm is for NATURALLY gluten-free and 200ppm for food processed to be gluten-free.

I understand from psawyer (and I have no reason to doubt him) that the most illogical part of the codex (basically the tolerance can be raised to 200ppm by including wheat starch) will not be adopted in the US.

This certainly shows that OUR voices collectively do matter.

I really do think this is a VERY suitable topic for the GIG.....

However:

The paper you quote is as I bolded, a review of previous studies. (I am still trying to get my hands on a full copy not just abstract)

As for scientific data: The paper is not DATA, it is opinion. (perhaps considered opinion but opinion). The same as the Fasano paper, I am not really interested in opinion or conclusions but data. Conclusions, precis' etc. are there to substantiate what the researchers set off to prove. This is often not the same thing. Much as Fasano has done a lot of good stuff he is working with in his won words a billion dollar a year industry in zonulin inhibitors. To his credit the paper does show the results but the conclusion really doesn't fit the results. I don't know the exact relationship between Alba and Fasano, I do know he is a spokesman for them and that they received a $135M cash investment and they are working on a product that will allow us to eat small amounts of gluten.

I think it far more likely that the paper is to back-up Alba's work than simply to baseline a safe gluten level.

Don't get me wrong ... this is his job, he is being paid to do what he is doing. It's not illegal or evil etc. he is a guy being paid to do a job. As a scientist who has written biased scientific papers I would be a complete hypocrite to criticize him. I wrote the papers to prove what my company wanted to prove.

Back in the 90's I presented a research paper at a oil industry conference. The paper itself was IMHO quite groundbreaking but the strange thing was I got pulled up for ignoring a commonly held 'law'. (not that it matters but Wylie, M.R.J., 1963 The Fundamentals of Well Log Interpretation, 3rd Ed, 2nd ed 1957 p72, Academic Press, NYC). This paper had been abused for 20+ years ... and when I said it was useless in the context people who had been using it in that context objected.

I didn't have a big insight ... there was no secret, I just READ the actual paper and the original paper itself said it was only applicable in a certain restricted case)

The reason it caused so much upset was simply because these people had not read the original paper, they had read summary papers that used the formula and referenced it, then other papers saw the reference and included it without ever reading the original paper.

The people who were the most upset were the 'experts' in this field.

Thus when I read any scientific paper I look for inconsistencies between data/results and conclusions. I have since used the same formula to prove there is no oil where there is, because it would be inconvenient for the company to have found a small amount. This is the way that industry paid for scientific research works. I can keep the data and just apply analyses I know are inappropriate for that situation. Its done everyday by millions of research scientists.

I can only draw parallels with the tobacco industry. We spent 50 years of conflicting studies over if it caused cancer or not.

The well funded tobacco industry ones said "no conclusive evidence", we later found out that was because they destroyed it.

Again I go back to the recent Fasano study... One person had clinical relapse on 10mg/d.

Is that not enough all by itself to say for many people 10mg/d is too much?

However the part I can't get over is that in the 10mg/d study group the 'average' villi growth was negative over 90 days.

It is not a huge amount and better than the 50mg/d group but still its negative.

We have to look at this in context... what is negative villi growth?

Scientific fact, the villi are constantly being repaired, just like the rest of our body so negative after 90 days means that they were being destroyed but repaired partly. Even zero growth would mean damage to the villi was occurring if the individual had damaged villi to start with.

So the question is ... what would be the result after 180 days or 360 ? What are the long term effects of "a little damage each day"

This is not answered and this is my concern. We don't know the long term effects but the paper clearly shows damage after 90 days.

Don't get me wrong, its totally possible that it might turn out to be no worse, my opinion though is that until we actually know we should aim for the safe option.

It's only my opinion but I think if this was something we understood the mechanisms of better it would not be considered acceptable. The grey areas surrounding celiac disease give considerable leeway. After all we can't actually decide exactly what we call celiac disease and what we call gluten-intolerance.

Even here you have celiac.com, gluten-freemall and glutenfreeforum, GIG stands for Gluten Intolerance Group.

These are NOT criticisms, times have moved on but again IMHO we cannot start to limit on the best defined group (biopsy proven celiacs) and say the others (neuro/thyroid) are not our problem.

I'm not suggesting the GIG change its name to "The Biopsy Proven Celiac Group", but I think that the forthcoming GIG meeting/conference NEEDS to address where it stands. I'm not blaming GIG ... but IMHO you can't go on and call yourself GIG and only cater for the GI effects of gluten. I really don't think this is the aim of either this site, the GIG or Cynthia Kupper but the times have changed and the outside world has changed so the aims need to be carefully addressed and brought up to speed.

Again, it won't do anyone any good if you make zero tolerance laws because you can't test that low, and any lawyer worth their salt would never recommend that ANY company put a "gluten-free" label on a package if the threshold is zero--don't forget, these companies get ingredients from many sources that are out of their control.

1-2 ppm is easily possible, just expensive. But you actually sum it up perfectly.

these companies get ingredients from many sources that are out of their control

They don't actually have to..... this is just the way it is because of the way the laws are (I don't mean the laws force them they just don't firce them to do otherwise).

The bulk food product suppliers are not accountable, they have no law requiring them to state if the bulk product is gluten-free or not so the gluten-free manufacturer has to rely on them.

(This severely penalizes the small gluten-free manufacturers who buy small and can't afford their own analysis.)

This is what I talk about for the QC/QA chain.... give the gluten-free manufacturers SAFE products to start from.

A large degree of contamination takes place AFTER the crops are harvested because of the way they are stored and transported.

This can change, I don't know how bulk transport works exactly in the US but I do here in the UK.

Food can only be transported in bulk containers used exclusively for food products. You can't transport sand or wallpaper paste in a container then use the same container for food.

It makes sense but really how harmful is sand (after all we just grew the carrots in sand and some of it still clings to them) but that is how the food transport laws are. Wallpaper paste ( I found out the other day ) is basically modified starch.... of course the anti-fungicides etc. are hardly food but you start off with the same starch... some of is it designated food and some of it is designated wallpaper paste (and I guess lots of other thing)s.

The DIFFERENCE is simply what happens after in the QC/QA processes. From this point on the food designated starch is transported in food transports, stored in food containers etc.

It is just a process. I'm sure the manufacturers would prefer not to follow it but its a legal requirement so they do.

There is no reason the law could not state any of the 10 top allergens must be transported in dedicated containers. (Fish and shellfish already are just because of convenience so it leaves 8) or at least the inverse.

If a company want to transport corn they know is gluten-free who do they call? So far as I know (and I would be surprised if its different) the haulage companies do not offer the option of 'food containers not used for wheat'. Why?

There is no market because the raw products are not certified anyway and noone is required to.

Create the requirement and the market will follow.

I can call any number of hauliers to transport inflammable fluids, toxic industrial waste, contaminated hospital waste .....

These markets exist due to legislation, no more or less.

99% of contaminated hospital waste is pretty harmless. Presuming you don't eat it or get it in your blood its reasonably SAFE.

However legislation exists for the 1% that is not.

All I am proposing is gluten-free means gluten-free as well as can be tested. <20ppm would mean <20ppm.

Who can bring this about? Groups like GIG, boards like this one.

Please quit hijacking this thread and start a new one on the topic of labeling laws--this thread is about topics for the upcoming GIG conference.

Well OK, I'll stop labeling at that but it is still IMHO a suitable topic for the upcoming GIG.

[RiceGuy]

I agree with what you're saying.

Recently, I heard that some baseball games were prohibiting peanuts, just to help those whom are allergic to peanuts to go enjoy the games. I'm sure I don't have to detail what my first thought was, but obviously, they wouldn't have done that if they didn't think there was a market for it. Awareness within a given industry can create change, but typically only when there's money to be made, or a law demands it.

With that story of the waitress receiving a $1000 tip for helping a customer get a gluten-free meal, you can bet she and many other waitresses and waiters subsequently have an increased awareness. Restaurants (at least the one involved in that story) would be wise to be more accommodating. However, they buy things in bulk, reuse containers and utensils, etc. So they can only do so much on their own, though they could help put pressure on the suppliers.

Lately, I've had bags of veggies with bits of other veggies thrown in. I suppose the packager is using shared lines or something. There are no gluten or allergy statements on the bags. Bits of carrots in a bag of peas may be safe as long as that's all it is, but then there's the occasional corn kernel. Not only is corn a top allergen, but being a grain, it might get contaminated with wheat even before the packager gets it.

There are innumerable products with tamper-proof seals, but it seems to me there is a greater problem - contamination.The industry goes into spasms over E. coli, recalling products and such, and investigators go bananas tracking down the source. That's all well and good, but when it comes to gluten, we're essentially left looking out for ourselves, and without the ability to test for CC. About all we can do is ask manufacturers/suppliers, and try to decide how much to trust them. If laws force them to be careful, it would help, but it could be harmful to small companies with small profits margins. Seems to me, for a product which is produced in a dedicated facility, there's more chance of gluten contamination from wherever they get their ingredients. And that would typically be a larger company, who can more easily do the testing.

[lovegrov]

"I worded things badly..."

Understatement of the century.

richard

[gfp]

Seems to me, for a product which is produced in a dedicated facility, there's more chance of gluten contamination from wherever they get their ingredients. And that would typically be a larger company, who can more easily do the testing.

Rice guy, exactly the reason the legislation has to be brought in at the correct place and level of the supply chain.

The problem is the food industry is run by the giants. They have the money and power to lobby but they are the last people who should be influencing any standards.

I appreciate that with the best will in the world accidents can and do happen. A small resto or gluten-free manufacturer cannot exhaustively test which is why they should have the ability to buy guaranteed gluten-free products.

Presently the problem is a pass the buck problem.... the gluten-free bakery can blame the supplier, the supplier the wholesaler of bulk and them the farmers.

My bet is most corn farmers are able to guarantee their corn is free from gluten. Certainly most carrot, potato and tomato growers are and there are plenty of places in the far east where wheat isn't grown within 100 miles of the paddy fields.

Yes birds carry seeds, hence the whole GM debate... but somehow the manufacturers say GM free.... their lawyers are not saying "what if the birds and bees do their thing"... because at the end of the day if it happens they will say, well the birds and bees did their thing.

So the next problem is transport and storage. Indeed this is the biggest area where legislation needs to be made.

If a farmer has a gluten-free crop and a supplier needs it they have no way of transporting it as gluten-free. Make a category of gluten-free food transport and this problem is solved. The haulier is responsible for providing transport which is and always has been gluten-free and certifying the crop at either end.

How does this work in practice?

Well, if the haulier is 100% certain the grain transport truck has only ever been used to transport gluten-free things they can take the guarantee of the farmer at one end and guarantee it at the other. The grain transport log will show each job and what was carried from and to...

This isn't going to cost millions ... it just needs that when new food transport is commissioned it is given an allergen log.

[Scott Adams]

GFP you have no idea about the real expense of such measures and what it would mean to the cost of the foods--very few people would be able to afford the real cost associated with taking out another 10 or 20 ppm of gluten. Anyone can sit around and create dozens of different scenarios that would keep more gluten out of the food supply, but you must understand that each has a cost associated with it, and when you add these real costs back onto the price of the foods it would make them unaffordable for most people (which is the case already with the price of many gluten-free foods--even without such measures). I believe you live in France where there may be government subsidies for such ideas, but that isn't the case in most countries--the customer bears such costs in the USA.

If a farmer has a gluten-free crop and a supplier needs it they have no way of transporting it as gluten-free. Make a category of gluten-free food transport and this problem is solved. The haulier is responsible for providing transport which is and always has been gluten-free and certifying the crop at either end.

Take care,

Scott

[Jestgar]

GFP you have no idea about the real expense of such measures and what it would mean to the cost of the foods--very few people would be able to afford the real cost associated with taking out another 10 or 20 ppm of gluten.

Then don't label foods "gluten-free", label them <10 ppm or <20 ppm or <200 ppm. Provide the actual information, not just the legal interpretation of the information.

And really, until people start making a fuss, nothing will ever change.

[lovegrov]

Then don't label foods "gluten-free", label them <10 ppm or <20 ppm or <200 ppm. Provide the actual information, not just the legal interpretation of the information.

And really, until people start making a fuss, nothing will ever change.

That will also cost a TON of money. Food prices will go up for everybody, not just for people with celiac.

richard

[Jestgar]

(I am still trying to get my hands on a full copy not just abstract)

I can send you this file.

[Fiddle-Faddle]

That will also cost a TON of money. Food prices will go up for everybody, not just for people with celiac.

richard

Funny--when I first looked into gluten-free ten years ago, and tried the truly awful gluten-free items available then, I asked why it wasn't possible to make something that tasted better, and was told that it would cost a TON of money.

[RiceGuy]

Then don't label foods "gluten-free", label them <10 ppm or <20 ppm or <200 ppm. Provide the actual information, not just the legal interpretation of the information.

And really, until people start making a fuss, nothing will ever change.

That's a good idea IMO, and I don't see it costing any extra at all. Why? Because if the company is in compliance with the law (or even whatever their own labels currently state), then they are testing, and can simply replace the gluten-free statement with the actual PPM which they must already know.

It would also create better competition in the gluten-free marketplace. That is, competition to provide a better, safer product, rather than one which can only satisfy some inadequate one-fits-all rule. People will then go for the lower PPM, and either the other companies improve their quality standards, or they go under.

And yes, we do need to make some noise. Public outcry creates change. I think there's a saying that goes; "The squeaky wheel gets the grease".

[ravenwoodglass]

That's a good idea IMO, and I don't see it costing any extra at all. Why? Because if the company is in compliance with the law (or even whatever their own labels currently state), then they are testing, and can simply replace the gluten-free statement with the actual PPM which they must already know.

It would also create better competition in the gluten-free marketplace. That is, competition to provide a better, safer product, rather than one which can only satisfy some inadequate one-fits-all rule. People will then go for the lower PPM, and either the other companies improve their quality standards, or they go under.

And yes, we do need to make some noise. Public outcry creates change. I think there's a saying that goes; "The squeaky wheel gets the grease".

I so agree.

[psawyer]

Folks, let's all take a deep breath, and then count to ten.

Then, let's see if we can get back to the topic at hand, which is about labeling things "gluten free."

Several posts here have crossed the line set by board rule #1.

[Scott Adams]

I think you might be missing the point here: If you make the threshold zero no companies will put "Gluten-Free" on their label do to liability concerns...would that be a victory for us?

Take care,

Scott

Then don't label foods "gluten-free", label them <10 ppm or <20 ppm or <200 ppm. Provide the actual information, not just the legal interpretation of the information.

And really, until people start making a fuss, nothing will ever change.

[Scott Adams]

PS - Everyone please re-read the board's rules--remember this isn't a place to quarrel...

Thank you!

Scott

[Jestgar]

I think you might be missing the point here: If you make the threshold zero no companies will put "Gluten-Free" on their label do to liability concerns...would that be a victory for us?

Take care,

Scott

I'm not saying 'zero', I'm saying label it what it is, even if it's "made from naturally gluten free materials in a shared facility". I just want to know what I'm buying.

[Scott Adams]

Labeling it "what it is" often changes with every batch--especially when foods are co-packaged on lines that also make foods that contain wheat. Labels are very expensive. To do what you propose would mean printing dozens of versions of labels for each food...maybe even hundreds of versions...this expense would be passed on to the consumer and in the end it would likely just make things more complicated.

Also, making our labeling laws for gluten lower than those of Canada and the EU would make it illegal for those foods to be sold here, thus a huge number of outstanding products would no longer be available, unless the manufacturers of those foods wanted to do new labels for just their American exports that did not have "gluten-free" on them, again, more expense.

Take care,

Scott

I'm not saying 'zero', I'm saying label it what it is, even if it's "made from naturally gluten free materials in a shared facility". I just want to know what I'm buying.

[lovegrov]

Funny--when I first looked into gluten-free ten years ago, and tried the truly awful gluten-free items available then, I asked why it wasn't possible to make something that tasted better, and was told that it would cost a TON of money.

I'm truly curious as to what this has to do with the discussion about expensive labeling for "regular" food. Requiring various different labels for different products would indeed raise the cost for everybody, particularly since the only way to properly apply those labels would be to test every batch of product. And I'm not sure it would even do us much good.

richard

[Scott Adams]

In reply to Jestgar's post...I may be misunderstanding what you mean. The new labeling laws in the USA, if adopted as drafted, would require food companies to guarantee that if they use the claim "gluten-free" on their labels it would mean that the product would contain less than 20ppm when tested. So essentially your <20ppm would be satisfied...items with this claim would mean <20ppm. Items without the "gluten-free" claim could fall into any range, they could be more or less than that, but those products are not making any claim about the gluten content of their products.

Just to help me understand your proposal, do you mean to say that companies who want to test their products and label them "gluten-free" if they fall below 20ppm should not be able to do so if they find 4ppm gluten in them? Also, do you mean that all food companies, even if they don't make any claim about gluten content, should have to put such gluten quantities on their products?

If your answer to the 4ppm scenario is no, companies should not be able to use "gluten-free" on such products, what level of testing would allow such use of "gluten-free" on a label? If all companies have to put their gluten content on all of their products, how do they do this as it fluctuates slightly with each batch?

My concern here is that your proposal, if I understand it correctly, may really just undo years of hard work that has gotten tougher labeling laws in place that really will greatly help a gluten-free consumer. Again, it is very easy for companies to simply throw their hands up in the air and simply remove such claims from their packages, and when this starts to happen I don't think it helps a gluten-free consumer.

Take care,

Scott

[Jestgar]

In reply to Jestgar's post...I may be misunderstanding what you mean.

I think so.

If a company routinely checks it's product, and it is routinely less than, say 10 ppm, they should be able to state <10 ppm on their packaging.

If the product is made using naturally gluten-free foods, they should be allowed to put that on the label if they choose -with or without testing.

Shared facilities should be stated (as they are).

They gray areas come in from companies that don't know the sources of their materials. There is no reason why they shouldn't. A company that, for example, buys malt from different sources could either:

a ) make no gluten claims whatsoever

b ) routinely test their product to determine the gluten content and label the packaging (as <100 ppm if it routinely falls within that range.

c ) ask the suppliers to provide gluten content information.

Even grayer areas come from things like oats and wheat starch. Those may require more specific labeling (oats grown in dedicated fields and routinely test at <10 ppm, for example).

Things aren't labeled as 'peanut free', they simply state whether or not the product may have come in contact with peanuts. Why not the same for gluten?

[Scott Adams]

Jestgar, I am still not sure that you answered those 2 questions. So can a company use "Gluten-Free" on the packaging if they have 4ppm? Is your answer yes, but they have to put additional info as well? Does a company that isn't making the "Gluten-Free" claim also need to do this? Sorry but it still isn't clear from your answer. There are already labeling laws in place that account for wheat as an allergen, so companies already must list this on the ingredient label.

Also, naturally gluten-free ingredients, like rice flour, can be cross-contaminated at the mill, during transport, or at a retail store, for example, if scoopers are used in cases where customers buy raw ingredients--so what difference should it make whether the ingredients are naturally gluten-free or not?

Take care,

Scott

[Jestgar]

With regard to your first point. My box of Blue Diamond Almond nut thins already does what I think other companies should do. "gluten-free"is legally defined as <20 ppm. OK. My Nut-thins say "Wheat and gluten-free" on the front.

Under the ingredients it says "Produced in a facility that also makes products containing wheat, soy, pecans and hazlenuts.

Each production run is sampled and tested to confirm gluten levels do not exceed 20 ppm."

This is all the information I need to be able to make a choice as a consumer. I know the ingredients are (should be) gluten-free. I know the facility may or may not be gluten-free. I know that the company tests its product and tels me that if there is gluten, it's at a very low level (below the legal definition).

If I'm very sensitive, I don't buy it. If I'm not very sensitive, I may choose to eat them now and again.

With regard to the second point;

If there's virtually no chance that the product came in contact with gluten frozen blueberries, for example, put no gluten claims.

If you can't guarantee anything (don't know source of materials and don't want to test) put "Ingredients may have been processed in a facility that processes wheat.."

I don't expect companies to rearrange everything to accommodate me, I just want to know what is, or might be, in their food. And I realize you can't control everything, things should be kept within reason. If, for example, rice is never transported or processed in anything that comes near any other grain, it can reasonably be assumed to be gluten free. Oats, on the other hand, are guilty until proven innocent.

[jerseyangel]

Jess--

I understand what you're saying and I agree with you. As a person who happens to be extremely sensitive, I would appreciate it if manufacturers would simply state the facts--whatever they are-- and then let me decide if I want to buy or not.

It's simply a matter of full disclosure. Your "Blue Diamond" example is exactly what I would like to see on everything--it would make life so much easier.

Why would that make a product more expensive

[Scott Adams]

Hello Jestgar,

Thank you for this. It looks like we agree on most of this stuff, like:

• Companies can use "Gluten-Free" on a label if they guarantee that something contains <20ppm--I agree.
  
• The Allergen Protection Act already requires companies to list any of of the top 8 allergens present, so labels that say "Produced in a facility that also makes products containing wheat, soy, pecans and hazelnut" are already required--and this is true for foods that don't claim to be gluten-free on their labels. I also think this is a good idea I see this more and more now.
  

I view these as areas where we differ:

• Requiring companies to put "Each production run is sampled and tested to confirm gluten levels do not exceed 20 ppm" on the label. The reason I differ with you on this is that any company that puts "gluten-free" on their labels knows that they are required to guarantee this already--they could be sued if they do this improperly--and it is my experience that companies that use "gluten-free" on their labels are already doing regular batch testing per production run (even though the new regulations are not yet in effect). Of course it's fine with me if they want to add such additional information to their labels, but requiring them to do so is really just repetitive--they would simply be restating the "gluten-free" claim on the label, wouldn't they?
  
• You said: "If you can't guarantee anything (don't know source of materials and don't want to test) put 'Ingredients may have been processed in a facility that processes wheat..' " The problem with just adding this claim to any foods where there may be cross-contamination is that it is really a CYA approach that doesn't always convey real information about the product. Many companies do this now with peanuts, even if peanuts are not used in their facilities. So it can be misinformation designed by attorneys to avoid any liability, and essentially to by-pass real compliance with the Allergen Protection Act. There should be some basis in fact before applying such claims to packaging, otherwise tons of products might go needlessly off limits to people with allergies, just because some large food manufacture decides that they want to just put "Ingredients may have been processed in a facility that processes X, Y and Z" on the label to cover their butts.
  

Last, I noticed that you didn't cover your proposed use of the specific ppm of gluten in product labels, and who would be required to do that, and how it would work.

Take care,

Scott

With regard to your first point. My box of Blue Diamond Almond nut thins already does what I think other companies should do. "gluten-free"is legally defined as <20 ppm. OK. My Nut-thins say "Wheat and gluten-free" on the front.

Under the ingredients it says "Produced in a facility that also makes products containing wheat, soy, pecans and hazlenuts.

Each production run is sampled and tested to confirm gluten levels do not exceed 20 ppm."

This is all the information I need to be able to make a choice as a consumer. I know the ingredients are (should be) gluten-free. I know the facility may or may not be gluten-free. I know that the company tests its product and tels me that if there is gluten, it's at a very low level (below the legal definition).

If I'm very sensitive, I don't buy it. If I'm not very sensitive, I may choose to eat them now and again.

With regard to the second point;

If there's virtually no chance that the product came in contact with gluten frozen blueberries, for example, put no gluten claims.

If you can't guarantee anything (don't know source of materials and don't want to test) put "Ingredients may have been processed in a facility that processes wheat.."

I don't expect companies to rearrange everything to accommodate me, I just want to know what is, or might be, in their food. And I realize you can't control everything, things should be kept within reason. If, for example, rice is never transported or processed in anything that comes near any other grain, it can reasonably be assumed to be gluten free. Oats, on the other hand, are guilty until proven innocent.

[Jestgar]

I view these as areas where we differ:

• Requiring companies to put "Each production run is sampled and tested to confirm gluten levels do not exceed 20 ppm" on the label. The reason I differ with you on this is that any company that puts "gluten-free" on their labels knows that they are required to guarantee this already--they could be sued if they do this improperly--and it is my experience that companies that use "gluten-free" on their labels are already doing regular batch testing per production run (even though the new regulations are not yet in effect). Of course it's fine with me if they want to add such additional information to their labels, but requiring them to do so is really just repetitive--they would simply be restating the "gluten-free" claim on the label, wouldn't they?

Yes, but it's repetitive because we know what it means. Someone new to the gluten game might see 'gluten-free', and assume that the 'made in...' statement is meaningless because it says gluten-free on the box. If it also states <20 ppm, even the most uninitiated would have to wonder if that meant there might be some gluten in it, especially if they were having issues after eating that product.

You said: "If you can't guarantee anything (don't know source of materials and don't want to test) put 'Ingredients may have been processed in a facility that processes wheat..' " The problem with just adding this claim to any foods where there may be cross-contamination is that it is really a CYA approach that doesn't always convey real information about the product. Many companies do this now with peanuts, even if peanuts are not used in their facilities. So it can be misinformation designed by attorneys to avoid any liability, and essentially to by-pass real compliance with the Allergen Protection Act. There should be some basis in fact before applying such claims to packaging, otherwise tons of products might go needlessly off limits to people with allergies, just because some large food manufacture decides that they want to just put "Ingredients may have been processed in a facility that processes X, Y and Z" on the label to cover their butts.

Yes, your point here is valid. My point is larger than this. We should know where our food comes from, and I have an example. A few years ago in Washington State, a cow was found to have Mad cow disease. Because there were no laws requiring breeders to keep track of where their cows came from, hundreds of cows were destroyed in the hopes of including those that had been the source of the disease. If breeders had simply been required to include dam info on every calf's tag, the parent herd of the sick cow could have been quickly identified, isolated and tested or destroyed.

Somebody already knows if my quinoa is processed in a wheat mill. Just put that info on the label.

Last, I noticed that you didn't cover your proposed use of the specific ppm of gluten in product labels, and who would be required to do that, and how it would work.

I never meant per each batch. I meant as a labeling concept. If, for example, my almond thins box said <5 ppm, I'd eat a whole lot more. It could be used to a company's advantage, to sell more product.

[RiceGuy]

If all companies have to put their gluten content on all of their products, how do they do this as it fluctuates slightly with each batch?

I cannot speak for anyone else, but what I'd like to see is a PPM value which represents the largest amount, with a safety factor, of the gluten content which can reasonably be expected. In other words, just like a manufacturer might make claims of "guaranteed 98% pure", why can't we have "guaranteed XX PPM or lower"? I wouldn't expect each and every package to be individually tested. However, just as every package gets a freshness date, the tested PPM for that batch could easily be included in the info currently being stamped on the packages. In whatever frequency they test, they can label.

Furthermore, if a product is produced on dedicated lines, or in a dedicated facility, that adds weight to any claims, and a value of XX PPM would mean more for gluten-free facilities and equipment than for shared IMO. After all, the value is less likely to fluctuate wildly, like it could in a shared facility, where a single mistake could at any time introduce gluten contamination. When I buy nuts, the package states that they're processed in a facility which processes peanuts and/or other nuts. I want the same sort of thing concerning gluten. Companies don't even have to test that.

And I agree that a company should know the status of all source ingredients. This is (or should be) standard practice already. Since it happens at all levels of production, that info should be (and likely is) already passed down the chain, so the manufacturer of the consumer product has all the data they need.

Not long ago, I asked a company about the GMO status of one of their products. It took awhile to get through to the rep what I wanted to know (they just didn't seem to understand the specific nature of the question), but they eventually sent me a PDF file which they got from the company who made the ingredient in question. So they had the info, but simply neglected to pass along to the consumer what they already knew.

I get the impression that companies simply don't want to bother, and/or they feel the consumer doesn't care. In the past, I'm sure people didn't even think to ask much, especially since processed foods are a relatively new thing. That is, it wasn't long ago that most of the adults grew up on whole ingredients, with most if not everything made from scratch. So I'd guess as processed and pre-packaged foods filtered in, the consumer wasn't thinking about chemicals and stuff. And I'd also guess that many foods were being made from ingredients much closer to what we'd use in our own homes. It was taken for granted. For instance, bread dough had to be allowed to rise a lot longer than it does now. They didn't have the quickly multiplying yeast used in high volume production today.