She isn’t just some figurehead for an organization. Cynthia actually personally performs audits of companies both big and small who are striving to make gluten-free products! Here’s what the NGFBF had to say about her:
Cynthia Kupper, Executive Director of the Gluten Intolerance Group of North America as our guest speaker on Tuesday. Cynthia is a dietitian and expert in gluten-reactive disorders and the gluten-free diet. She has been invited to numerous health professional and food industry meetings including the FDA, NIH and FARRP. She led the American Dietetic Association’s Evidence Analysis Team on Celiac Disease for 5 years in developing Management guidelines for dietitians treating persons with celiac disease and the team creating tool kits for dietitians. Her publications include numerous peer-reviewed journal articles, a continuing education manual for dietitians and many patient education materials.
As Executive Director of GIG, Cynthia has successfully launched three food industry-related programs: the Gluten-Free Restaurant Awareness Program, the Gluten-Free Certification Organization, and the Gluten-Free Food Service Accreditation. For 18 years, she has worked with large corporate restaurant chains and individual eateries to provide gluten-free menu and training options. The Gluten-Free Certification, launched in 2004, has become the industry standard for GF certification and is the largest program in the Americas. GFCO provides a high quality, third party program for gluten-free certification. The success of these programs allows consumers to have a higher level of trust and confidence in dining out and shopping for gluten-free products. The Gluten-Free Food Service Accreditation program helps all type of food services to establish Best Practices for gluten-free food production, through policies, procedures, training and monitoring.
So as you can imagine, with my interest in (and skepticism about) gluten-free foods, I was thrilled to have the opportunity to meet her and hear what she had to say. Cynthia’s talk was short but packed with information. She briefly covered market trends, how the Global Food Safety Initiative relates to the production of gluten-free foods, the critical contamination points to look for in manufacturing GF foods, food service accreditation, and the process of getting your gluten-free products certified. Here were some of the key points I took away from her talk:
Gluten Free Regulation
As I hope you already know – in the United States, there isn’t any! The FDA put out a proposal a couple years back, reopened comments on it last year, and now says it may have something out by the end of this year. At that point, manufacturers would have 18-24 months to comply with the standards. Here is the top feedback that the FDA got on its proposed regulation, which Cynthia highlighted:
- Foods that are naturally gluten free, such as an apple, potato, or bottle of water, should not be allowed to carry a gluten-free label. The reasoning is that by allowing these products to label themselves as gluten-free, they cast doubt in the consumer’s mind about the gluten-free status of their competitors’ naturally gluten-free products. (My personal take is there should always be doubt in the consumer’s mind.)
- Products shouldn’t be labeled gluten-free unless they are actually proven to be gluten-free.
- The two approved testing options in the FDA’s proposal rely on specific testing rather than a testing methodology. One is from Japan and not widely available in the USA. The other is proprietary, essentially granting that company a monopoly. A testing methodology should be laid out, rather than specific testing companies.
One major aspect of the FDA proposed regulation, if put into effect, will define gluten-free as an end product containing less than 20 parts per million of gluten. There are people out there who react at lower levels of contamination than that. So even if the regulation is put into effect, remember that “gluten-free” does not mean “absolutely no gluten.” In fact, no one knows how to test perfectly for no gluten at this point, though tests below 5 parts per million are widely available. There is also a newer nitrogen test which can confirm that there is no protein at all in a product, but of course many foods you would want to eat should have proteins other than gluten in them.
Each Gluten-Free Certification is Different
There are currently four major certification programs in the USA, and they each operate independently and with their own standards. Cynthia didn’t mention them all by name, but I’ll do it! You can read more details of each type of certification from the links, I’ve just pulled out a couple of the basics.
- Celiac Sprue Association Seal of Recognition (CSA) – Products are certified gluten-free at the < 5 ppm level. They can not contain oats. This is important to note, since some people are cross-reactive to even certified gluten-free oats. This certification also does not allow any ingredients derived from gluten-containing products, even if the end product would meet the final specification. Regular 3rd party testing is required, and audits are performed.
- Gluten Free Certification Organization (GFCO) – This is GIG’s certification program, and it has been in effect for 8 years. Products are certified gluten-free at the < 10 ppm level. Audits and 3rd party testing is performed.
- National Foundation for Celiac Awareness’ Gluten Free Certification Program (NFCA) – Products are certified gluten-free at the < 10 ppm level. Raw ingredients must be tested at below < 20 ppm to be used. Regular 3rd party testing is required.
- Canadian Celiac Association’s Gluten Free Certification Program (CCA/GFCP) – Complies with Health Canada’s regulations for gluten-free products. I believe the level they currently certified gluten-free is < 20 ppm.
I also found another certification, the Gluten Free Standards Organization (GFSA), which requires < 3ppm for full certification, performs audits and testing, and also has a special logo for products that test at higher levels that are below 20 ppm. In Australia and New Zealand there is a Crossed Grain Logo which requires < 3 ppm of gluten. The European required standard is set at < 20 ppm. What about "Naturally Gluten-Free?" In the USA this doesn't mean anything other than the ingredients don't originally contain gluten! Products that say “Naturally Gluten-Free” but do not carry one of these organizations’ logos have not been certified and may contain gluten.
I have not included the logos due to the fact that these are copyrighted images which have their use tightly controlled. Please visit each site to see the logos!
What Is Certified
I’m not sure how it works for the other certification companies, but when GFCO certifies, they do it on a production facility and product basis. The initial application and audit cover the facility and gluten-free product line it produces. The products are specifically listed. If a new product is added, it needs to get certified as well. The certification is renewed annually, and requires an actual auditing of the facility and its processes as well as independent 3rd party testing.
Sometimes even with the best intentions and processes in place, a product makes it to the consumer with too much gluten in it. The GFCO is currently investigating its first potential recall in 8 years.
Your Own Testing
There are a few resources for people who are trying to make sure their food is gluten-free, independently of certification.
- Gluten Free Watchdog – Tricia sends popular gluten-free products to the lab for the highest quality testing, and publishes a monthly report for subscribers. When products test above 20 ppm, she makes free public services announcements on facebook and on the website.
- We Are Gluten-Free – Andrew performs tests twice a week and sends the results out along with a video of the test.
- Gluten Zap Forum – Many of the people who participate in this forum consider themselves “super-sensitive.” They perform their own tests using at-home test kits and share the results on the forum.
- Test Kits – The EZ Gluten test kits work for levels down to 10 parts per million. GlutenTox kits are another option, which you can adjust to test from the 5 ppm to the 20 ppm level.
Critical Contamination Points
At every stage of bringing a product to market, there are risks for gluten cross contamination. In order to make sure a product is gluten free, there must be plans and procedures to address these risks. There must also be a good paper trail, so that suppliers and customers can be notified quickly in the case of a problem.
When products are getting certified, the auditors pay close attention to these CCPs, and Cynthia talked a bit about them. I think it is important for us as consumers to be aware of these CCPs as well. It gives us a point of reference we can use when calling manufacturers about the safety of products that are naturally gluten free!
- Vetting – Any responsible manufacturer should test the incoming raw materials for contamination. Many items that are “naturally” gluten-free can be cross-contaminated. The most recent product issue involved the corn used for it. Pallets were tested, but some of the bags within the pallets were contaminated. Unfortunately this was not caught until it was too late!
- Specs – The suppliers need to be given specific instructions on exactly what product is to be received.
- Allergen Statements – Every company involved in producing food should have clear allergen statements, and those allergen statements need to stay with the product as it goes through each part of the manufacturing process, all the way to the consumer. If an ingredient for the final product was processed in a facility with wheat, for instance, that needs to be made clear, and the end product should reflect that information.
- HACCP, 3rd Party Audits – Suppliers should have Hazard Analysis & Critical Control Points sheets which outline what the risks associated with the products they supply are and how they are addressed. From time to time they should be audited and tested.
- Segregation – Items containing allergens need to be stored separately from each other, and labeled clearly.
- Container Reuse – Containers that have come into contact with an allergen should not be used with ingredients for products that do not contain those allergens.
- When getting the products to where they need to be it’s important to make sure that they don’t come into contact with other allergens, pass under lines where other allergens are being transported, or sit in an area where they could become contaminated.
- Scheduling – If producing a gluten-free product in the same kitchen as products containing gluten, the gluten-free products need to be made after all flour has had a chance to settle (ideally at least 48 hours) and everything has been thoroughly cleaned. Then the gluten-free product needs to be made first, before gluten-containing products.
- Rework, Reuse – If an ingredient is to be used in both a gluten-free and gluten containing product, the extras from the process of making the gluten containing product may not be reused or reworked into the gluten-free product, even if that ingredient itself is naturally gluten-free.
- Labeling – All cutting boards, measuring cups, mixing equipment, etc need to be clearly labeled if they are used with an allergen. Even employees who are working with allergens should be labeled and stick to the contaminated part of the facility when working with allergens. For instance, employees may wear color coded hair nets and gloves.
Air Flow, Cleaning, Sanitation
- Where does air come from and go? – Gluten can be carried on the air, especially if flours are used in any of the products being made in the facility. The air intake needs to be clean, and if air is recirculated in the facility, it needs to be adequately filtered or not recirculated into parts of the facility where gluten-free foods are produced.
- What type of cleaning is used? – Some companies produce gluten-free products on the same lines and gluten containing products. There are different ways of cleaning equipment. The best kind of cleaning is wet cleaning. But some equipment is cleaned by pushing salt or sugar through the system or blowing it out. In these cases there is a larger chance of gluten being left behind. Also be aware that sanitized equipment may be sterile without being gluten-free. Sanitizing kills germs. It does not denature gluten.
- Scheduling in shared facilities – If a product is being made in an “incubator” kitchen, which is shared by many businesses, it’s very important for the gluten-free producer to find out what other products are being made in the kitchen. Not only does the kitchen need to be thoroughly clean, but the scheduling considerations from “Production” apply.
- Testing – Equipment needs to be tested for gluten contamination before gluten-free food is produced on it.
- Safe once packaged – Once a gluten-free product is in the packaging, it should be safe.
- Punctures – Punctures of packaging could result in cross contamination. Avoid purchasing products whose outer packaging is damaged.
- Movement on lines – When the food is traveling through the facility at various stages of production it may pass through areas where flour is in the air or something could fall from a line which is above it. Lines for gluten-free foods should not cross lines that pose risks of cross-contamination.
- Random testing – Producers should randomly test their own product to make sure that it falls below the specified level of gluten contamination.
- Proper procedures – Procedures for keeping the product safe need to be clearly outlined, detailed, and followed.
- Even one employee must be trained – Even if a company has only two members, a training program needs to be developed and in place.
- Processes written down – All processes need to be written down and followed.
- Know what they’ve been told and what they retained – The managers need to know what the employees have been trained to do, what they are actually doing, and periodically check to make sure they have retained the information.
Who Do You Trust?
- Do you buy certified gluten-free products?
- Do you trust products that haven’t been certified but don’t contain gluten ingredients?
- Have any of these CCPs given you ideas about how to stay safe when preparing foods in your own home?