Friday, September 30, 2011

Our Comments to FDA on Gluten-Free Labels

Following is the letter Gluten-Free Living sent to the Food and Drug Administration regarding proposed rules for gluten-free labeling.

The deadline for comments is this coming Monday.You can send your comments to the FDA here. Click on "submit a comment" and type FDA-2005-N-0404 into the search bar. On the next page that comes up,  about halfway down, click "submit a comment" next to the gluten-free labeling notation

 However, if you want to sign onto the 1in133 and American Celiac Disease Alliance letter, you only have until noon Sunday. The groups need some time to get all the signatures into a form they can then submit to the FDA.
Meanwhile, we thought you might be interested in what Gluten-Free Living had to say about some key points regarding gluten-free labeling:

As publishers of the first magazine exclusively for those who follow the gluten-free diet, Gluten-Free Living has long been a witness to the confusion gluten-free labeling causes. The lack of any definition for what is gluten free leads to many questions from our readers.

Our experience with the diet and our knowledge of the medical research related to celiac disease, leads us to support 20 parts per million as a valid standard for use of the gluten free-label. The best research to date shows that the vast majority of those who have celiac disease can safely consume products with less than 20 ppm of gluten.(1)

A standard stricter than 20 ppm of gluten has not been proven to be medically necessary for most people with celiac disease. The 20 ppm standard has been accepted internationally after a long review by the World Health Organization’s Codex Alimentarius. (2)

We are familiar with the point of view that gluten-free should mean “zero” gluten, but we know zero gluten is impossible to achieve or test for in the real world. So setting zero as a standard has little meaning.

A standard set lower than is medically necessary for the vast majority of those who have celiac disease and gluten intolerance could have the effect of decreasing the availability of gluten-free food. This would unnecessarily make it more difficult to comply with the gluten-free diet. In Australia, where the amount of allowable gluten is lowered each time tests get more stringent, this is already happening. (3)

If the standard for gluten free labeling is set at less than 20 ppm consumers can then assume that food labeled gluten free might have trace amounts of gluten (between a theoretical zero and 20 ppm). The addition of statements spelling out that minute levels of gluten might be present in gluten-free food would be redundant and add to consumer confusion without any real benefit.

The use of a two-tier system, with” gluten free” and “ low gluten” labels tied to different levels of allowed gluten, was debated and rejected when the gluten- free definition was first proposed. The idea was originally rejected because it is confusing to gluten-free consumers and that is still the case. We continue to oppose use of a low-gluten label.

The question of whether naturally gluten-free foods should be allowed to use the gluten-free label without saying all food of the same type is also gluten free is a little harder to answer.

For inherently gluten-free one-ingredient foods like milk, eggs, canned fruit and vegetables, the risk of gluten contamination is generally so slight, we can realistically assume all foods of this type would be gluten free. So a statement saying all foods of this type are gluten free would generally be accurate. It would also prevent companies from trying to falsely imply that their naturally gluten-free item has some advantage over other brands. Gluten-free consumers have complained about food makers trying to take advantage of the gluten-free fad by putting the gluten free label on all types of naturally gluten-free products.

Naturally gluten-free grains might be in a slightly different category. Grains have a higher risk of being cross-contaminated because of shared fields, transport vehicles and processing machinery. A recent small study showed that some inherently gluten-free grains were highly cross contaminated by gluten-containing grains. (4)

However, the study was based on a small number of samples and even the authors state that general conclusions about gluten-free grains cannot be drawn from it. So it is not yet clear that there is enough evidence to differentiate between naturally gluten-free grains and other inherently gluten free foods when it comes to gluten-free labeling. A larger study into cross-contamination of gluten-free grains is needed. If such a study showed wide-spread cross-contamination, the FDA should allow food makers who take steps to prevent cross-contamination to label their products gluten free without saying all other grains of the same type are also gluten free.

Overall, a medically justified gluten-free threshold that can consistently be verified through testing is what’s needed most by those who have celiac disease.

This threshold should not unnecessarily decrease the availability of gluten-free products and make it harder to comply with the gluten-free diet. We believe the 20 ppm standard satisfies these requirements and we urge the FDA to quickly approve it. Until then, those who rely on the gluten-free diet as the only way to treat celiac disease are left on their own to figure out what is safe. This is an untenable situation that has existed for far too long.

1.Catassi C, Fabiani E, Iacono G, et al. A prospective, double-blind, placebo-controlled trial to establish a safe gluten threshold for patients with celiac disease. Am J Clin Nutr 2007;85:160–6.


3. Price G, Maintiaining Our Food Choices, The Australian Coeliac, 2010, December, 31-33

4. Grace T, Lee A, Thompson T, Gluten Contamination of grains, seeds and flours in the United States, a pilot study, Journal of the American Dietetic Association 2010, June, 814 -976

Wednesday, September 28, 2011

Latest gluten-free news from Starbucks

Here is the latest from Starbucks on gluten in Light Frappuccinos:

"Starbucks has removed the gluten ingredient from its Light Frappuccino® Blended Beverages.

As you may know, in the summer of 2010 Starbucks began offering customers the opportunity to customize their favorite Frappuccino ... This new offering caused initial changes to the recipes of the Light Frappuccino beverages and resulted in a gluten-containing ingredient being used in the Light base.

Starbucks has heard feedback from many customers who are living a gluten-free lifestyle and has worked diligently to change the recipe to remove the presence of the gluten ingredient.

The Light Frappuccino beverage ingredient list will no longer state "contains gluten." However, due to other restrictions in declaring a product "gluten-free," Starbucks statement regarding all beverages must remain the same, as follows:

We do not claim that any of our beverages are gluten free because we use shared equipment and handle gluten and allergens throughout the store. Customers that have questions should ask to review the ingredient statements with their barista or can call 1-800-23-LATTE for ingredient information."

While I find Starbucks' position on gluten-free drinks baffling, I see this as good news. The Light Frappuccino was a drink that clearly containing gluten in the form of barley in the base mix and had to be avoided. Now that's not the case.

Whether you drink any beverage at Starbucks is a personal decision. Some gluten-free consumers work out arrangements with their local Starbucks baristas to lessen the exposure to cross contamination and feel safe having coffee and other drinks there.  Before Starbucks started saying that it could not claim any of its drinks were gluten free, the company advised consumers to ask that containers used to mix drinks be washed before a gluten-free order was prepared.

Amy Ratner 

How should gluten-free grains be labeled?

The Food and Drug Administration is taking a second look at naturally gluten-free grains as part of its effort to finally pass rules for gluten-free labeling.

When the FDA announced in August that it was re-opening public comment on a proposed gluten-free definition, the agency said it was reconsidering how inherently gluten-free grains should be labeled.

Under the proposal, all naturally gluten-free food can only be labeled gluten free if the label also says any other food of that type is also gluten free. For example, sorghum flour labeled gluten free has to say all other sorghum flour is gluten free.

Now the FDA is considering whether gluten-free grains should be labeled differently than other naturally gluten-free food. That’s because of the risk that grains may be cross-contaminated by wheat, barley or rye.

Cross-contamination of grains can occur in the field or through shared equipment during transport, processing or packaging. A recent small study showed that some gluten-free grains actually contained fairly high levels of cross contamination.

The FDA is considering whether grain and flour companies that take steps to prevent cross-contamination should be allowed to use the gluten-free label without implying that products made by less diligent companies are just as safe.

The bottom line is whether the gluten-free label on naturally gluten-free grains would help gluten-free consumers select products that are safer.

The labeling rule for all naturally gluten-free one-ingredient foods was proposed to prevent food companies from using the gluten-free label to give the false impression that their products are somehow better than identical products. For example, a gluten-free label on naturally gluten-free water is meaningless since all water is gluten free.

Grains are the only naturally gluten-free food the FDA has specifically said it is interested in reviewing in regards to the labeling provision. Other naturally gluten-free, one-ingredient foods like canned fruit and vegetables, milk, butter and eggs have minimal, if any, risk of being cross contaminated. But changes to overall rules for labeling of inherently gluten-free foods could be made based on public comments sent to the agency.

Most important, you only have until Monday to comment on the gluten-free definition. You can  send your  comments to the FDA here. Click on "submit a comment" and type FDA-2005-N-0404 into the search bar. On the next page that comes up, down about halfway down, click "submit a comment" next to the gluten-free labeling notation

And if you want to sign onto the letter available from 1in133, a grass roots group that formed to push for gluten-free rules, you have to do so by noon Sunday. That will give the group time  to get the information into a form that can be sent to the FDA.  The FDA estimates it will take about a year to go through all the steps before gluten-free rules are finalized.

Rules for gluten-free labeling are already long overdue. The FDA was supposed to finish them three years ago as part of the Food Allergen Labeling and Consumer Protection Act. Under the proposed rules, food labeled gluten free must contain less than 20 parts per million of gluten. This cut off would include trace amounts for gluten from cross contamination and would be verified through testing.

Amy Ratner

Tuesday, September 27, 2011

Gluten-free musings on Expo East

Expo East, which was held at the Baltimore Convention Center last weekend, is the food industry's showcase of natural products. But it could easily have been dubbed a fashion show for gluten-free items. They were everywhere you looked.

In a "New Products Showcase," where new items that have caught the eye of Expo organizers were set up, I thought I might find a few that were gluten free. It turns out so many were labeled gluten free my hand was getting tired from writing them down.

When these were whittled down to the winners, three products labeled gluten-free were still standing: Little Duck Organic's Tiny Fruits, best packaging, Brad's Raw Leafy Kale, most innovative, and Nibor Chocolate's Daily Dose, best of press. Luna Pops' Hibiscus Lemon pop, which won the best new food prize, contains only gluten-free ingredients.  It is made on the same machinery used to make flavors that contain wheat, but Dina Mills, a company representative, said the equipment is thoroughly cleaned and sanitized between flavors.

One of my personal favorites from the show - "home free" crunchy vanilla cookies came close, making it into the finalist category for best food.

On the main exhibit floor, I spent two days sampling new gluten-free items and talking with gluten-free company representatives. I ran into George and Ceil Chookasian, owners of Foods by George, who have been making gluten-free products as long as Gluten-Free Living has been publishing. We marveled at all the changes in the gluten-free market place -- so many of them positive. (Watch for my upcoming blog on what I thought were the most interesting new products at Expo East.)

But I did run into one remnant of the "old" gluten-free days when a representative of one company insisted to me that vinegar contains gluten. She said she had done her research, and she was sure that vinegar was not gluten free. When asked I for details on the research, she said when she accidentally eats something with vinegar her tongue swells and her head gets foggy for three days.

I told her that at Gluten-Free Living we respect anyone's right to make their own diet decisions based on whatever information they choose. But I do not think a company representative has a right to give incorrect information in a forum where people who represent gluten-free companies should know what they are talking about.

On vinegar the facts are simple and indisputable - the gluten peptide in vinegar is too large to carry over in the distillation process. This is true even when vinegar is made from wheat. And according to the Vinegar Institute, vinegar is usually made from naturally gluten-free apples, grapes, corn and rice. Malt vinegar, which is fermented and not distilled, is usually made from barley and is not gluten free.

 Although Gluten-Free Living did the ground-breaking work on vinegar and distillation, most reputable celiac disease support groups and medical centers now agree distilled vinegar is gluten-free.

This includes the University of Chicago Celiac Disease Center, the Celiac Center at Beth Deaconess Medical Center, the University of Maryland Center for Celiac Research, the Celiac Disease Foundation, the Gluten Intolerance Group, the National Foundation for Celiac Awareness, the Canadian Celiac Society, the American Dietetic Association, the Vinegar Institute, the Children's Digestive Health and Nutrition Center, the North American Society for Pediatric Gastroenterology, Hepatology and Nutrition.

Any research on the topic from reputable sources would quickly reveal these facts.

So while I applaud and appreciate all the new gluten-free products being made by a wide variety of companies, I do expect all of them to make sure they know what they are talking about. Knowledgeable company representatives can make good decisions about the steps they have to take to make sure their products are truly gluten free. And they know to dismiss misinformation that needlessly limits options and causes gluten-free consumers to worry about ingredients that are known to be safe.

I am glad most of those I talked to at Expo were in that category.

Amy Ratner

Thursday, September 15, 2011

Celiac Awareness

Tuesday was Celiac Awareness Day, but the good news is that “awareness” of a gluten-free diet and lifestyle has exploded with growth since I was diagnosed with celiac disease almost 15 years ago.

We asked the question on Facebook, how has increased awareness improved your gluten-free life. For me, I am so excited by the depth and breadth of products in the freezer section and on the store shelves. With two members of my household on a gluten-free diet, it is fantastic that I don’t have to order everything online anymore.

I love the fact that more and more colleges are aware of a gluten-free diet and have food to accommodate this diet in the dining hall. I think by the time my son goes off to college, it should be pretty easy for him to navigate the dining halls.

Restaurants are also more aware than ever before about dietary restrictions. I wish every restaurant indicated which items on their menus were gluten-free, but I think the restaurants that offer gluten free menus, or indicate which items are gluten-free ingredients, are awesome.

I think it makes my life so much easier that celiac disease is no longer thought of as this “rare and unfortunate” disease. These days almost everyone knows someone on a gluten-free diet! I definitely used to feel like a freak when I asked for a burger without a bun. Now, I might get asked if I have a gluten issue or if I want a lettuce wrapped burger.

Other people on our Facebook page had great posts about how awareness has improved their gluten-free life. A few people said that increased labeling and increased products made it easier for family and friends to shop for them or feed them. Others said that awareness of celiac disease got them healthy again after years of baffling symptoms or feeling unwell. Mostly, people said that increased awareness has reduced the “blank stare” effect after explaining that they can’t eat gluten.

One person pointed out that a gluten-free diet was pretty good to Novak Djokovic this year. Three grand slam wins, three different trophies to kiss and while I don’t know his reason for a gluten-free diet, he sure has brought positive attention to a gluten-free diet!

Kendall Egan

Friday, September 9, 2011

Remembering 9/11

Here in New York, we never forget 9-11. In certain spots, all we have to do is look up to see the void where the towers used to be. And that makes looking back from a 10-year vantage point all the more involving. With memory in mind, I’d like to reprise an editorial I wrote for Gluten-Free Living just after the attack. I hope it helps you look forward with hope for all our futures.

A Word from New York

As many of you know, I’m a New Yorker. I grew up in the Throgs Neck section of the Bronx where, when the weather is clear, you can see the Manhattan skyline from several vantage points.

We New Yorkers are a tough breed. Nothing deters us… or at least nothing did until September 11, 2001. It was the first time in my life that I actually banged my head on the wall.

My fear and frustration were magnified because my brother works (now worked) in a building across the street from the towers and we had no word from him… until late afternoon when he turned up with a horrific story I won’t detail here. And he is one of the lucky ones.

Which would mean I have less reason than others to be angry. I got my brother back. Thousands of people did not get their relatives back. Thousands and thousands.

But I am angry. The towers were still standing when a commentator said, “This is the end of life as we know it.” Like you, I want my life back. I want all those people back.

I want my brother to sleep in peace. I want to drive up the New Jersey turnpike, glimpse the towers over my right shoulder, and know “I’m home.” It was such a comforting feeling that I didn’t appreciate enough when I had it.

This is what we’ve all been doing over and over…talk and talk and talk, as if talking would change the reality. But I write here because there is a gluten-free lesson in this tragedy, a very simple lesson…only three words: It doesn’t matter!

It doesn’t matter that you have to live a gluten-free life. Not in the sense that life is short, but in the sense of priorities. Food is fuel. Even if you live to eat rather than eat to live, food is still fuel.

It doesn’t matter that you have to change your lifestyle. You can, much more easily than you think.
It doesn’t matter that you see danger lurking in all the food around you… hidden toxins that will do you no good. You can work your way around them…in fact, you have to!

It really doesn’t matter that others don’t understand. We need to take care of ourselves. It doesn’t matter that doctor after doctor misdiagnosed you. That’s water under the bridge. It doesn’t matter that food processors seem to have your needs at the bottom of their priority list. The ones at the top benefit everyone, celiacs included.

And, you’ll have to trust me on this, when disaster strikes, it doesn’t matter that you have to follow a gluten-free diet. Everyone suffers in a catastrophe. Everyone has to figure out unique ways to cope. You can… and you will.

It does matter that you keep on trucking. That you stare adversity in the eye, give it your best Bronx cheer, and surmount it. That you help others cope! Boy do I mean that last one. New York is surviving on our American ability to work together. There’s a real lesson here for everyone.

I am writing this a few days after the tragedy and have no idea what might happen between now and when you read this issue. I can only hope it is not worse than what has happened already.

I would not believe that such a thing could happen and that it would hurt so much. That hurt for me will be symbolized by the erasure of the towers from the New York skyline, the elimination of their promise of home and comfort. Without their presence, home will seem much, much farther away.

Ann Whelan

Thursday, September 8, 2011

The 3PM Snack Attack

What's going on all day in school that has my kids arriving home ready to chew nails they are so hungry? Does thinking and learning really drive the metabolism of the elementary and secondary school set into overdrive? Gluten-free or gluten ingesting, my kids are super hungry at 3pm.

All I know is that my kids walk in the door and right into the kitchen. Pantry doors are flung open, the refrigerator and freezer get looked over. Without careful planning, kids go right for the stuff that I probably shouldn’t be buying in the first place.

This year I am planning ahead! Trail mix, peanuts in the shell, spicy pecans and candied walnuts are all in my pantry shelves right now. There is a bit of sugar because the trail mix has chocolate and the candied walnuts are, well “candied.” However, this is a high energy, filling option that is just plain better than potato chips.

I kept this summer circular from Stop & Shop grocery stores because they had some fun “stuffed packet” recipes, there was one with a split banana with chocolate chips, peanut butter chips and mini marshmallows all wrapped in a parchment and foil packet to throw on the grill. One could probably put the packet in the oven with a banana, peanut butter and a little honey and have a gooey, warm after school snack! I could probably do a fun packet with apples, cinnamon and brown sugar too.

Bagel pizzas are a great post football or soccer practice treat. I keep gluten-free bagels in the house at all times and toppings such as marinara sauce and mozzarella cheese are easy to have on hand.

These days, there is a nice variety of gluten-free crackers so cheese and crackers or peanut butter with crackers is always available.

Pre-made guacamole and salsa are some of the best things to have in the refrigerator because that is a great serving of vegetables with some corn tortilla chips. Kids could easily make nachos for an after school fiesta.

Popcorn kernels, the good old fashioned kind that you pop with a little oil in a pan, is now a pantry staple in my household. Everyone knows how to make a really good bowl of popcorn. There are no chemicals and no microwave fires this way!

Frozen gluten-free waffles and cream cheese with jelly are delicious. We always visit a farm on the North Fork of Long Island and pick up multiple bottles of fruit syrups such as strawberry, blueberry, beach plum and raspberry for our waffles. They are really amazing.

Hummus and dips with chopped up vegetables are a great option too, they just have to be handy and prepared and right in the front of the refrigerator! Apple slices and nutella or peanut butter is a better option than cookies. I also find that if there is a container of cut up fruit salad right at eye level in the fridge, it will get devoured.

I want my kids to feel refueled for homework and sports practices, but I am subtly trying to enforce good eating by providing options. I find that all of these snacks are easily gluten free which makes it very easy to have kids converge on the kitchen as their school day ends.

Kendall Egan

Friday, September 2, 2011

Comments on Gluten-Free Labeling rules

Comments on gluten-free labeling have been trickling in to the Food and Drug Administration, with new ones being made public nearly every day.

As of this morning, the agency has posted 90 comments on the regulations  website. So far, those in favor of allowing less than 20 parts per million of gluten in gluten-free products are running evenly with those who want a stricter cut off. Not everyone who commented specifically addressed the 20 ppm standard, but of those who did, 14 say they support it. Meanwhile 13 pushed for a lower level with about half  saying gluten-free should mean zero gluten.

At this point, while the numbers are interesting, they are rather meaningless. The FDA usually takes a while to get comments posted. There is still about a month to go before the comment period closes and the FDA will not begin to pay attention to comments until then.

So far, individuals have made the most comments with 64. Businesses have sent 10 comments, as have those who identify themselves as members of  celiac support groups . There are also six comments from those who identify themselves as part of the medical community.

But the FDA has not yet posted any comments from those who used the labeling letter on the website of 1in133, the grass roots groups pushing for final approval of gluten-free labeling. There also aren't any comments from celiac disease experts or from the national celiac disease support groups.

That does not mean there is any problem. It just means they have not been posted yet.

We know these are all coming. The 1in 133 group's efforts are widely publicized and the group has been very successful in drumming up support. The National Foundation for Celiac Awareness has written to its members urging them to join the 1in133 letter writing campaign. You can sign the 1in133 letter here.

We have also seen letters from Alessio Fasano, MD, of the University of Maryland's Center for Celiac Research, and Stefano Guandalini, MD, of the Celiac Disease Center at the University of Chicago supporting 20 ppm. You can sign onto Fasano's letter here.

You can also send your own comments to the FDA here. Click on "submit a comment" and type FDA-2005-N-0404 into the search bar. On the next page that comes up, down about halfway down, click "submit a comment" next to the gluten-free labeling notation.

 I have been covering labeling for Gluten-Free Living from the beginning, when the Food Allergen Labeling and Consumer Protection Act first directed the FDA to come up with rules for what can be labeled gluten free. So I have been through FDA public comment periods a few times already.

When the FDA first asked for public input in 2005 as it was working on the proposed definition, 500 individuals, companies and organizations responded. In 2007, after the proposal was released, the FDA again sought comments. At that time you could not read them online so I went to the FDA's cramped reading room, where letters and printed emails filled four heavy binders.

The comments came from people with celiac disease, gluten-free food companies, mainstream food makers, large grocery chains, celiac disease support groups, consumer advocates and the medical community. All are likely to comment again this time around. And we all know the gluten-free community has grown wildly even since 2007. That should result in even more commentary from all sides.

The comments posted in this latest round do reveal some interesting points, including some gluten-free consumers' continued desire for zero gluten in gluten-free food.

 "I would prefer that the gluten-free label only be allowed on food and beverages that contain zero gluten," John Lewis wrote. "If it contains less than 20 ppm I would like that to be stated. Otherwise, I find the labeling misleading."

Fifteen-year-old Kenny Peyton Nathe got right to his point. "What I think you should do is pretty simple actually. If it is not 100 percent gluten free, don't put "gluten free on it."

On the other side of the debate about gluten levels, Jane Alcantara wrote, "As a person recently diagnosed with celiac, it is thrilling to think that gluten-free labeling may become a standard...I highly encourage the FDA to pass the labeling proposal."

Elizabeth Kordeck wrote that she fears too narrow of  definition of gluten-free "will turn off food producers as they will not be able to meet overly stringent guidelines." "If 20 ppm has been widely tested and accepted as a safe level...that is a huge leap forward," she told the FDA.

Some companies have also commented, with Juliette Parker of the Marvelous Food Company writing that her company already meets a 5 ppm standard with two products. She wrote that it is not a problem to make products with 5 ppm or less of gluten. A representative of Genius Bread, a British product being introduced in the US and Canada, wrote in support of the 20 ppm standard, which is recognized internationally.  

Some writers urged the FDA to require "gluten" to be labeled whenever it's in a food or medication though both of those moves are beyond the reach of this labeling regulation.

And cross-contamination from shared equipment and facilities was on the mind of others. They said it should be prohibited in the production of foods labeled gluten-free. One writer said she did not think naturally gluten-free foods like milk and eggs should "be allowed to be labeled gluten free just to capitalize on trend."

Whatever your personal opinion on the gluten-free definition, the comments are a reminder that the clock is ticking on sending yours to the FDA. The deadline is Oct. 3. It's something that's easy to put off, as we are aware at Gluten-Free Living given that we are still working on our own letter.

So get to it. We promise we will too!

Amy Ratner