From The Gig Thread

[Scott Adams]

Well, this additional info could be quite confusing to most people, and could cause unnecessary alarm in some as well.

Again, these numbers can fluctuate from batch to batch, so I don't see how they could be printed on labels with confidence. What if they print labels with <10ppm because 20 of their last batches tested below this, then they get a batch with 12 or 15ppm? Do they throw the batch away? Print new labels? Just sell it anyway with the <10ppm on the label?

Again, these are companies that are already claiming <20ppm by using the term "gluten-free" on their labels, and in general they have gone to great expense and are taking a legal risk to do this, so why should they have to open themselves up to even more liability by having to be even more specific?

Anyway, I'm not saying that your idea isn't attractive or would not be helpful to many people, I just think that requiring it would place an unnecessary burden on most companies who might otherwise take the necessary steps to use "gluten-free" on their labels, but would not do it if there were even more risks involved.

On a strictly voluntary basis, however, some companies might get more of the "hard core" customers if they did this extra step.

Take care,

Scott

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.

[Jestgar]

On a strictly voluntary basis, however, some companies might get more of the "hard core" customers if they did this extra step.

yes, never said 'have to'. Just as some companies preface every single ingredient with the word 'organic' to sell more product, a company that intentionally keeps their products gluten free, and knows that they are gluten-free, could promote themselves by adding the <5ppm to their boxes.

It would work on me.

[Judyin Philly]

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.

Jess I get what your saying and i agree with you.

Judy

[Darn210]

Well, this additional info could be quite confusing to most people, and could cause unnecessary alarm in some as well.

Again, these numbers can fluctuate from batch to batch, so I don't see how they could be printed on labels with confidence. What if they print labels with <10ppm because 20 of their last batches tested below this, then they get a batch with 12 or 15ppm? Do they throw the batch away? Print new labels? Just sell it anyway with the <10ppm on the label?

Again, these are companies that are already claiming <20ppm by using the term "gluten-free" on their labels, and in general they have gone to great expense and are taking a legal risk to do this, so why should they have to open themselves up to even more liability by having to be even more specific?

Anyway, I'm not saying that your idea isn't attractive or would not be helpful to many people, I just think that requiring it would place an unnecessary burden on most companies who might otherwise take the necessary steps to use "gluten-free" on their labels, but would not do it if there were even more risks involved.

On a strictly voluntary basis, however, some companies might get more of the "hard core" customers if they did this extra step.

Take care,

Scott

Having worked in the auto industry on a fairly highly automated production line, I know they have printer/labelers that can easily be changed (say at the beginning of a batch run). The main packaging would remain the same and then a small sticker/label is applied with the extra info, or depending on the item, just stamped or printed directly on the item. I don't see packaging or cost of packaging as the issue. I see a company's willingness to disclose the information (liability) as the issue. But if a company has a product that is consistently less than 5ppm or 10ppm, why not get some credit for it. It would give them some pull with the more sensitive Celiacs that have to assume gluten free means 19.99ppm.

[home-based-mom]

I am nowhere near as sensitive as some people and I will buy products that are produced in a shared facility - at least until I get burned by that product. I have learned the hard way not to buy products produced on shared equipment no matter what they claim.

I tend to agree with Jess. Just let us know what we are buying so we can make an informed decision.

I am appalled at companies that put products in the market place and claim they have no idea what is in them because they claim there are too many suppliers to keep track. They aren't even trying to CYA on that one!

With laws the way some of you want them to be everything will wind up like Rice Dream which claims to be gluten free but isn't. You can't possibly want a grocery store full of products like that!

[Ridgewalker]

Having worked in the auto industry on a fairly highly automated production line, I know they have printer/labelers that can easily be changed (say at the beginning of a batch run). The main packaging would remain the same and then a small sticker/label is applied with the extra info, or depending on the item, just stamped or printed directly on the item. I don't see packaging or cost of packaging as the issue. I see a company's willingness to disclose the information (liability) as the issue. But if a company has a product that is consistently less than 5ppm or 10ppm, why not get some credit for it. It would give them some pull with the more sensitive Celiacs that have to assume gluten free means 19.99ppm.

I just read this thread for the first time, and I had the same thought as Janet.

Example-- prepackaged foods are always stamped with some sort of expiration date for that batch. I don't see how adding another stamp to specify ppm would add a huge amount to the consumer's price (strictly as a cost/labeling issue.)

[Scott Adams]

Riceguy the "gluten-free" claim on the label would mean less than 20ppm, so why would a company need to add further information per batch...of course that would add more expense to the food, and quite frankly, not many companies would want to do this, and yes, it would increase their liability. Again, the current labeling laws address these concerns rather well.

But again, this extra information would just be confusing to the average consumer, which is why not a single support organization proposed doing this--99.9% of the population likely has not idea what ppm even means...

Take care,

Scott

[RiceGuy]

Again, these numbers can fluctuate from batch to batch, so I don't see how they could be printed on labels with confidence. What if they print labels with <10ppm because 20 of their last batches tested below this, then they get a batch with 12 or 15ppm? Do they throw the batch away? Print new labels? Just sell it anyway with the <10ppm on the label?

Like I said, it can be done in the same manner as the expiration date stamp. No extra cost. Each batch has to be tested to maintain compliance, so the actual measured PPM for the batch can be stamped.

Riceguy the "gluten-free" claim on the label would mean less than 20ppm, so why would a company need to add further information per batch...of course that would add more expense to the food, and quite frankly, not many companies would want to do this, and yes, it would increase their liability. Again, the current labeling laws address these concerns rather well.

But again, this extra information would just be confusing to the average consumer, which is why not a single support organization proposed doing this--99.9% of the population likely has not idea what ppm even means...

The concern is that 20ppm isn't good enough for everyone. Furthermore, if a product is produced in a dedicated facility, it may test much lower. Again, there'd be no additional cost. Liability wouldn't be an issue either, if they actually do the compliance testing. After all, if they claim gluten-free, and it means <20ppm, then for that particular product, it's the same liability as specifying <20ppm. More than that and they're breaking the law with their gluten-free claim, just as it would be for exceeding 20ppm. The law essentially defines these two as equivalent. But that's part of the problem - and measured amount isn't gluten-free, no matter what percentage of the population can eat it without harm.

The same people who don't know what the PPM stuff is all about, are not the people who are concerned enough to look for it in the first place. People who don't read labels won't know it's there, and/or won't care.

As I see it, this could go the same way as the GMO debate. Companies label stuff non-GMO, to get more sales. Nothing is stopping companies from labeling the actual measured PPM. If I produced a product which routinely tested below 10ppm, I'd want the consumer to know it's half of what the law requires for the gluten-free claim. And again, we're looking for these statements. We're not the average consumer. We want to know what's in "natural flavors". We want to know if a product is made in a dedicated facility. We want to know, and the products in question are supposed to address OUR concerns. It is how these companies stay in business in the first place. It is also how mainstream manufacturers can tap the gluten-free market.

[neesee]

I hate to be the bearer of bad news, but you are all just going to have to accept the fact that perfection does not exist. At least not in this life.

I do quite well with the gluten-free standards that we have in place right now. I do have celiac in the classic form. So I am as sensitive as anyone else here. I just had a negative celiac panel run.

neesee

[Scott Adams]

There isn't always a date stamp on all foods, and even if there is the placement of that stamp is not in a place that the FDA would allow food manufacturers to convey allergen information. Further, most of the stamp machinery has a very limited field length that would likely not accommodate such information (I proposed that a European company whose foods I sell change their date format from the European on DD/MM/YYYY to instead say 14-Sept-2008 or something similar and they could not do this without buying new machinery).

We can fantasize all day about what we'd like to see happen, but this doesn't mean that companies will buy into such things and go to the trouble, expense and risks associated with our dreams. These types of schemes were never proposed to the food industry for good reason--they would not have accepted them--even specialty gluten-free food manufacturer would likely never voluntarily do this.

I have an idea, why not try to get one "gluten-conscious" company to do this voluntarily if it is so simple and won't cost them anything?

Take care,

Scott