FreeFrom-ers need to remain vigilant

Once upon a time ‘freefrom’ food was made by people with a dietary problem for people with a dietary problem – coeliacs, people with a dairy, nut or egg allergy, lactose intolerants. But times have changed. These days, much free from food is made by companies who have little or no personal experience of living with a food sensitivity for people who do not have a food sensitivity but believe that they would feel better and be healthier if they did not eat gluten or dairy products.

In many ways, this is excellent. The growing market is attracting larger players with deeper pockets, better distribution and able to apply economies of scale to their manufacture. This means that both the range and availability of freefrom food is growing by the week, and the cost is coming down. All good news for those on restricted diets. However, this silver lining does have a cloud.

One relatively small section of this cloud is likely to disadvantage those with the less common allergies – egg, nut, soya etc. The ‘voluntary food restricters’, those who believe that they would be healthier excluding certain foods but who do not have an allergy or serious intolerance to them, are really only interested in gluten and, to a lesser extent, dairy. Because it is they who are fueling the growth in the market rather than the true allergics or intolerants, the huge growth in the range of foods on offer is large restricted to gluten and dairy-free foods.

A rather larger section of cloud has hoved into view with the sudden rash of pizza operations offering gluten-free pizza and with the impending implementation of allergen labeling regulations covering ‘food sold loose’ and through catering/restaurant outlets.

The presumption made by an allergic or coeliac shopper buying a food in a sealed retail pack which claims to be gluten free, or dairy free or nut free, is that it will be. No one really knows how small an amount of an allergen will affect a seriously allergic person, nor is it possible to tests foods below a certain level for the presence of an allergen. However, for practical purposes most allergic or coeliac shoppers will assume that a food which claims not to include gluten, nuts or dairy, and to have been made in a factory which does not use gluten, nuts or dairy, will not include them. So that as long as their own home is free of that allergen, and that they eat the food in their own home, they are pretty sure to be safe.

However, once the food ceases to be sold in a sealed pack, the game changes. No matter how diligent the caterer, pizza maker or chef, no matter how well trained the staff, once the food exists in an environment where those allergens are also present, even if it is separated from them, the risk of contamination increases exponentially. And although the Pizza Huts and Domino’s of this world are making all the right noises about separation and contamination control and are, no doubt, very genuinely intending to follow all of the guidelines, it will be extremely difficult for them to ensure, in all of their outlets ‘going forward’, that a high enough level of care and control is maintained to exclude the possibility of confusion or contamination. Moreover, their gluten-free pizzas are also going to be served in their restaurants where there will still be lots of other gluten-containing food on offer. So even if the pizzas leave the kitchen uncontaminated, danger will still lurk in the restaurant.

Similarly, the new regulations covering food sold loose and through food service require every outlet to provide allergen information about the food that they serve  – but, they are only required to provide it orally i.e. – you have to ask the staff about any allergens in the food and they have to tell you. But, given the non-existent level of understanding of allergy amongst 99% of those serving in food service outlets, the chances of you ever getting the correct information are extremely slim. (For a good deal more on this see either my earlier blog or our article on FoodsMatter.)

So while it is great, and we are all delighted, that the Pizza Huts of this world see enough potential in the gluten-free market to offer a gluten free pizza, and that the regulators are finally, sort of, biting the bullet of allergen labeling in food service, we would absolutely not advise anyone with a serious food sensitivity, be they allergic, intolerant or coeliac, to relax their vigilance. Hopefully, they will be able to eat pizzas and dine out in safety, but to do so, they need ask as many questions and make as many checks as they always have.  At least there may now be a better chance that those they ask may have some inkling of what they are talking about – although I would not even rely on that.  When waiters in up-market restaurants that pride themselves on offering gluten-free alternatives can still offer a coeliac a ‘safe’ dish because it has no butter in it, we still have a long way to go…

Footnote:
We have become peculiarly aware of this problem ourselves with the entry of Pizza Hut, among others, to the FreeFrom Food Awards. Up till now all but one of the categories in the awards have only been open to foods sold in retail packs only so our entry requirements and the information that we require have been extremely detailed and stringent.

The one exception was our ‘food service’ category – but that was originally conceived as a category for foods manufactured to be sold into food service, not for foods to be sold direct to the customer via a delivery service, so the same labeling and manufacturing criteria could be applied as were applied to ‘normal’ retail packs.

However, since one of the main purposes of the awards is to encourage more manufacturers to make ‘freefrom’ food, thus increasing the offering for freefom customers, we did not want to turn away entrants who were doing just that – ie the pizza delivery companies. But we have had to accept that it is simply not possible to apply exactly same criteria as we would to a retail entry. We are still working on it – watch this space…

 

Weird allergies

Working my way through John Scott’s weekly round-up of research (see our research forums for the full nine yards – and to subscribe to a particular thread of research if it especially interests you) I was just amazed, last week, by the weirdness of some of the allergies that he had logged…. For example:

• A woman is mysteriously growing fingernails from hair follicles – it is believed to be an allergic reaction to a large dose of steroids given to combat an asthma attack…? Read more on Technobob.com.

• A woman lost 98% of her skin and almost died when her body burst into blisters and burns – an allergic reaction to the drug, Quinoric, prescribed to treat her lupus. Reported in the MailOnline (so it must be true…)

• Twenty-five-year-old, otherwise healthy woman had a full anaphylactic reaction in the shower after she touched an inflamed area of her  leg with Chloramine-T, a chlorine derivative that is widely used as a disinfectant.  Report here.

And somewhat less weird but no less unattractive….

• React to chickens? It may not be the meat that is the problem but what the bird has been “plumped” up with: brine (salt water), chicken stock, flavour and texture-enhancing chemicals, and even the waste byproducts of other animals that can constitute as much as 30 percent of the meat’s total weight. Courtesy of Natural News

• Red wine give you a headache? (Well, non organic red wine certainly does – I can vouch for that!) Many people blame the sulphites (for sulphite free wines see here...) but others blame the tannins, found in the skins, stems and seeds of grapes. But tannins are also found in the oak of the barrels in which wine is aged so finding a wine which is not aged in oak, or in tannin free oak, is quite a problem. However, the Washington Examiner has been on the serach and among others they have found a ’2011 Cigar Box Reserve Malbec ($12) from Mendoza, Argentina, carefully fermented in temperature-controlled stainless steel tanks. The interesting thing about this wine is the vanilla highlights on the nose, which are typically associated with oak aging. The big mouthfeel features flavors of blackberry jam, dark plum and hints of pepper. The finish is rich and intense with penetrating notes of dark chocolate.’ How can you wait?…..

• Or, again from the Daily Mail: Girl left ‘looking like a monster’ after a severe allergic reaction to a home hair dye kit. Lauren Thomas, 16, said her head inflated like a football and her scalp started oozing pus just hours after using a home hair dying kit…… Read more here…

• And finally…. Not exactly an allergic reaction – but a really frustrating tale of gluten contamination  – of a duvet!! Read this post on the TrulyGlutenFree site!

Anyone got any more to offer?……

 

New codex standard for gluten-free food – and the dreaded ‘may contain’…

On January 1st the new regulations governing the use of the term ‘gluten-free’ came into force. As of Jan.1, to be able to call itself ‘gluten-free’ a food must contain less than 20 parts per million (ppm) of gluten, to call itself  ’very low gluten’  it must contain less than 100 ppm of gluten. It has taken years of negotiation, heated discussion and compromise to get these regulations established and although many people are still unhappy with them, they have been welcomed with open arms by manufacturers of gluten-free food and by many coeliacs. So, a bit more detail…

The Food Standards Agency  has written a detailed article for our CoeliacsMatter site explaining the background to the  regulations and what they will mean for both manufacturers and those on gluten free diets – and is a good place to start if you just want to understand the situation as it now is.

However, although these levels of ‘acceptable’ contamination have now been formalised by the regulators, this does not mean that either all medical experts or concerned coeliacs actually agree with them…  See the report on CoeliacsMatter of a symposium held in Oslo last year where two of the leading coeliac experts, Professors Carlo Catassi and Paul Ciclitira, went head to head on this issue. And for a very detailed exploration of the issue, including impassioned, and very interesting, comments from coeliacs who are both for and against the 20ppm level, see Alex Gazzola’s  blog on the 4th January.  For what it is worth, my own view of the situation, which also appears on Alex’s blog, is as follows:

1. There really is no gold-standard expert guidance in this area. There are a number of medical/coeliac experts who quote various trials to support their particular view of what is a safe level of gluten (zero, 20ppm, 100ppm etc) but as anyone who has worked in the medical field knows, the trial that provides the definitive answer this week, may well prove to be fatally flawed by a new trial next week. So while we can and should listen to what they say and be guided by those who seem most reliable – or sensible – we should not take any of their suggestions gospel.

2. Every coeliac, like every allergic and indeed every person suffering from any condition, is an individual and although their symptoms may fall within a general disease pattern, no one person will ever be identical with any other person. So while 20ppm of gluten may fine for coeliac A, it may cause problems for coeliac B – just as one peanut allergic person may react to inhaled peanut dust while another may only react to ingested peanut.

3. We have to be practical. If gluten free food is to be manufactured for those on gluten free diets, manufacturers must have some level to which to work. Manufacturing to zero gluten is not practically possible, so some level has to be set to give manufacturers guidance. If it is not, they will not make the food.
(I know of several manufacturers who will not sell their products as dairy free, although they actually are. Because there is no level set for dairy contamination and they do not want to risk being outside the law, they are not prepared to label the food as dairy free, thus depriving those on dairy-free diets of a good product.)

Given the current state of knowledge and the huge variability in the sensitivity of coeliacs, 20ppm seems to me to be a reasonable compromise, especially since guaranteeing that they will always meet the 20ppm level means that most foods contain significantly less gluten than that.

As for those who are ultra allergic, ultra sensitive coeliacs may not be able to tolerate this but, sadly, I do not really see that there is any other viable option.

However, it does not end there. The law of unintended consequences operates just as effectively in the food world as it does when you start invading other countries…

Just before Christmas a colleague sent me a copy of an alert put out by by an importer of lentils as follows:

We bring to our Lentil customers’ attention a change in EU regulations about labeling of allergens coming into effect in Jan 2012 where the definition of ‘gluten free’ changes from the current maximum of 200 ppm (parts per million) to a new maximum level of 20 ppm, only 1/10th of the previous tolerance.


Lentils are grown in rotation with wheat and other cereals, and grain sizes are also similar, so despite thorough cleaning over most modern plants, it is only possible to supply lentils with an allowed tolerance for cereal grains which may translate to a gluten content on the borderline of the new 20ppm limit, so there will be a risk whether lentils would be compliant with the changed ‘gluten free’ definition.


For example our specification for Dark Speckled Lentils allows a tolerance of 3 cereal grains per kilo.

Our standard specification for Red Split Lentils allows a tolerance of 0.04% cereals but through work with suppliers we can negotiate new tolerances of 1 cereal grain per kilo (which may translate to about 6ppm but this estimate will be influenced by the cereal variety, grain size and variable gluten content).

As it will be expensive and time-consuming to test each batch, we suggest it will be safer to adopt ‘May contain gluten’ labeling for all lentils.



What, effectively, this means is that yet another excellent and nutritious gluten-free staple food item will become unavailable to anyone on a gluten-free diet who will fear that they may be ‘gluten-ed’ when in fact, the chances of them being so are almost vanishingly small.

You cannot blame the lentil importer. They are quite right that it would be unrealistically expensive and time consuming to test every batch of lentils to guarantee that they were under the 20ppm limit – especially when the vast majority of their produce will be consumed by customers who are totally uninterested in whether or not their lentils are contaminated with wheat. But for those on a gluten free diet, for whom lentils had provided an excellent alternative source of nutritious food, it is hugely frustrating and upsetting.

This does not mean that the 20ppm rule is wrong (for all the reasons explored above) –  it just illustrates yet again how desperately we need  some common sense to be applied to  ’may contain’ labeling. A regulation which forbade the use of ‘may contain’ unless it were put in context (‘made in a factory in which peanuts/gluten is used’, ‘made in a dedicated nut/gluten free factory but cannot guarantee the ingredients are totally nut/gluten free’, ‘grown in rotation with wheat so possibility of contamination’ etc) would be a massive help as it would give those who wanted to avoid that ingredient enough information to make their own informed decision according to their own degree of sensitivity.

Obviously, there are practical problems – not the least being that manufacturers do not wish to have to print (or consumers to read) and essay on what food is safe for whom, but there must be a way to improve the current total lack of specificity. My own preference (as I am sure I have said before…) is for a traffic light system: red for containing nuts/gluten etc, orange for not containing any nuts/gluten etc but made in a factory/grown in a field etc where nuts/gluten are also present; green for totally free.

At least that would avoid nonsenses such as ‘may contain gluten’ labels on lentils or the even more ridiculous situation I highlighted last year with Green and Blacks who declare milk as an ingredient (which it is not)  in their dark, milk-free chocolate just in case it should be contaminated…..