NZ and Australia have the safest
gluten free labeling requirements for celiacs in the world. But there is a lot
of debate worldwide, as to what is a safe level of gluten for celiacs to
consume, if any. Many countries have adopted 20 ppm as the level to adhere to
on food labels, and less than 20 ppm is the accepted standard in many
countries, including the USA, UK and Europe, for food manufacturers to adhere
to. The
International CODEX standard, also defines ‘foods containing less than 20 ppm of
gluten’ as safe and suitable for a celiac diet.
So are the strict gluten free labeling laws so necessary in
Australia and NZ? These two countries continue to implement “no gluten detected” as the
acceptable standard, Gluten is treated as an allergen under the Australia New Zealand
Food Standards Code (ANZFSC). Standard 1.2.3 of the ANZFSC states that a food
business must declare the presence of any gluten in its food product. Additionally,
where a food product’s label claims that the product is ‘gluten free’, the ANZFSC,
Standard 1.2.7 stipulates that ‘the food must not contain detectable gluten’.
Australian regulators have a
strict view on the regulation of allergens. Both the Australian Competition and
Consumer Commission (the ACCC)
and the New South Wales Food Authority (the NSWFA) have upheld an exacting interpretation of the term gluten
free and require that in foods labelled as gluten free, gluten must be completely
non-detectable. The consequence of a false claim on a gluten free label is
usually a food recall.
Now, we would all have to agree
that gluten free labeling requirements have been implemented for the protection
and safety of those with celiac disease, but are the levels adopted by NZ an
and Australia putting too big a burden on manufacturers to comply with such low
level requirements, and does this in turn affect the celiac by forcing the
price up for gluten free products which comply with the standards?
It is my view that consideration
of market factors or profits must remain secondary to the necessity to provide
safe food for the celiac. And this in turn means that the celiac has to pay
higher prices for gluten free products that are safe for them to eat. All
people who consume a gluten free diet are aware of the fact that they have to
pay more, and in my opinion good health is worth the extra price, because what
would be the cost of not eating gluten free compliant food? The cost to your health would be way too
high!
NZ and Australia currently have a
fantastic variety of readily available gluten free foods that test well below
20 ppm, so obviously providing gluten free foods at this very low level is
commercially viable. There is no reason why, especially as testing becomes more
sensitive, that the status quo in NZ and Australia cannot be maintained.
Reducing the detectable level of
gluten in foods on a global basis would be a good thing for the health of celiacs.
But not everyone agrees with reducing the level of detection for
gluten in foods.
Compliance with gluten free
standards, even at current levels, is obviously not being regulated enough in
some countries. There have been many scares lately about foods labelled gluten
free which are actually not and have caused severe reaction in celiacs who have
consumed them. If food manufacturers do not have the best interests of celiacs in
mind they will be pushed out of the market especially if lower detection levels
are implemented.
Also, many cafes and restaurants
who have a gluten free menu do not really understand what it means to be gluten
free and dining out is one of the biggest concerns that a celiac has. The fear
of being “glutened” is a real threat for those with celiac disease, and yet
very few countries regulate the level of gluten free on menus. The FDA says
that given the public health significance of gluten free labeling, restaurants
making a gluten free claim on their menus should be consistent with FDA's
definition. In the UK the law relating to gluten applies to both packaged foods
and to foods sold in catering establishments such as cafes and restaurants.
Not all experts support the view that there is
robust evidence that 20 ppm is actually a safe level for celiacs. Some argue
that less than 10 milligrams per kilogram would be safer for celiacs. The Health Hazard Assessment for GlutenExposure, recommends a level of less than 1ppm gluten in foods labelled gluten
free “In
summary, these findings indicate that a less than 1 ppm level of gluten in
foods is the level of exposure for individuals with celiac disease on a gluten
free diet that protects the most sensitive individuals with celiac disease and
thus, also protects the most number of individuals with celiac disease from
experiencing any detrimental health effects from extended to long-term exposure
to gluten”. It is interesting to note that the FDA
did not adopt these recommendations. More research needs to be conducted to look
into the safe levels for celiacs.
The Australian Food and Grocery
Council (the AFGC) is
proposing that Food Standards Australia & New Zealand (ANZFS) alter the standard of ‘gluten free’
in Australia. The AFGC wants ANZFS to allow a food to contain up to 20
milligrams of gluten per kilogram to still be called ‘gluten free’. This would
bring the Australian regulation of ‘gluten free’ claims in line with British
and European standards as well as the Codex. This move is supported by Coeliac
Australia.
One of the issues of having not
detected as the standard is the lack of definition and definitive guidelines
and it becomes a moving target. The ANZFS does not stipulate a threshold or a specific testing methodology in the gluten free standard. However, the
definition of gluten free requires that gluten be ‘not detectable’. So what
does that actually mean?
Trying to measure small amounts
of material can be tricky. When testing products, some analytical services
refer to a Limit of Detection (LOD) whereas others refer to a Limit of
Quantitation (LOQ). The LOD is the level at which something can be detected with a level of
certainty, while the LOQ is the level at which the amount of that something can be measured with a level of
certainty. Most test results refer to a value that is less than the LOD or LOQ
for the test method used, such as < 20 ppm of gluten detected. So what does
not detected mean in the NZ and Australia?
Current testing methods can measure the level of gluten in
food down to less than 3 parts per million (<3 ppm). Thus in NZ and Australia, foods advertised as being gluten
free' and displaying the Crossed Grain symbol must not contain detectable
gluten which can only be detected to <3 ppm.
As food testing technologies are
constantly evolving, the levels of detection and quantitation are becoming lower
and lower. On the one hand, this allows more certainty in measuring the
presence of smaller quantities of a substance in a food product. However, one
of the problems with testing at lower levels is the risk of cross contamination
of the test itself, for example the presence of gluten in the air of a testing
facility may be picked up as being present in the food product when in fact
that might not be the case. The lower the detection limit of a test, the lower
the certainty could be.
There are also important
commercial and legal ramifications for the food industry if gluten free claims
continue to be defined by lack of detection as in the ANZFS. It means they
would have to use the latest method and the lowest detection levels possible. New tests will be able
to detect minute traces of gluten (maybe as low as parts per billion) meaning
that foods currently defined as gluten free may disappear.
This would be
disastrous for people with celiac disease who rely on safe gluten free food as
a medical necessity, not a lifestyle choice. In fact, zero tolerance gluten rule limits
food options for people with celiac disease and will eventually become
unworkable as testing methods become extremely sensitive. A new definition of gluten free
may give celiacs in NZ and Australia a wider food choice and do away with
unnecessary food recalls.
So should the ANZFS re-define a safe and practical maximum level of
gluten? Technically speaking this would be the right thing to do. If the ANZFS were to adopt the
widely accepted worldwide trend, then ‘foods
containing less than 20 ppm of gluten’ could be labelled as gluten free. Or if
it were to keep to its current levels, then ‘foods containing less than 3 ppm of
gluten’ would be considered to be gluten free.
It is my opinion that the level of detection must be
stipulated in the gluten free standard and that NZ and Australia should be in
line with the rest of the world. But whether this means NZ and Australia
raising their levels, or the rest of the world lowering theirs is a matter for
debate. I believe the safest practical testing level should be observed, and currently
it has been proven that gluten free food can be manufactured and tested effectively
at a level of <3 ppm, so I can see no reason why this should not be adopted
as the new worldwide standard. No-one has really proven categorically what a
safe level of gluten is and research into this matter needs to continue.
No comments:
Post a Comment