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Does Canada really call for zero ppm in GF products?

H.

-----Original Message-----

From: Joe Herman <jhinsf@...>

< >

Cc: < > < >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please point out research which discusses a commercially available gluten test which tests to the level of zero ppm?

I have never seen this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, "Lillyth Denaghy Keogh-Quillan" <lillythdenaghykeoghcomcast (DOT) net> wrote:

See, everyone says there is no way to make

it zero ppm. I think that is TOTAL BS. That is Canada’s standard, and they are

really great place to live with celiac.

So whenever people say it can’t be done –

it IS done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section

that I thought GF should only be ZERO ppm.

From: [mailto: ] On Behalf Of Darcy

Sent: Thursday, April 15, 2010

10:10 AM

Subject: RE: [ ] FDA

Research Study (really just a survey)

I agree with both of you – I chose “Gluten-Free†but what

I want that to mean is that it does not contain gluten (below a certain very

low level such as 20 ppm – they will never say absolutely none) and is also

made in a safe manner. There is a comment section at the end where this

can be written in.

Unfortunately the survey doesn’t offer that level of distinction

at all (what the words actually mean) and doesn’t address cross-contamination

from manufacturing practices very well.

I do agree that it’s great to see them doing this survey!

Thanks,

From:

[mailto: ]

On Behalf Of Harper

Sent: Thursday, April 15, 2010

9:08 AM

Subject: Re: [ ] FDA

Research Study (really just a survey)

I believe that Gluten-Free is the more

restrictive, all-inclusive statement.

H.

when asked which of the following labels would lead me to buy the

product, I checked the "made in a gluten free facility" over "no

gluten ingredients" and "gluten free,"

-----Original Message-----

From: TrVerb@...

Sent: Thu, Apr 15, 2010 8:48 am

Subject: Re: [ ] FDA Research Study (really just a survey)

I think you must have only thought you checked the "I follow

a gluten free diet" box, because that's what I did and I did the whole

survey - they are obviously only interested in people who are either following

it for themselves or preparing food for someone who is. I am guessing you

checked the "I don't follow a gf diet" by mistake.

I am surprised by the negative response to this survey. I am

thrilled that they are asking me these questions, which are clearly designed to

ascertain what kind of labeling laws they need to consider - we are being given

the opportunity to encourage the government to make it a law that labels need

to be as specific as possible (when asked which of the following labels would

lead me to buy the product, I checked the "made in a gluten free

facility" over "no gluten ingredients" and "gluten

free," which I would hope would encourage whoever reads this survey to

understand the issue goes beyond the actual ingredients to where the product is

processed). It sounds to me like some of us are offended that they are

asking "how much do we really understand about celiac" and how smart

or stupid or educated we are. But they do need to know how much more education

they need to provide. Look, I have friends who have diagnosed celiac who are

convinced spelt is fine and "a little" wheat now and then is fine,

too, and who don't ever think about cross contamination issues. I don't want

those people driving the discussion and influencing the law! So PLEASE,

everybody do this survey and take the opportunity at the end to stress that we

need to know about EVERY gluten ingredient, not just wheat, and EVERY cross

contamination issue...

Tristan

-----Original Message-----

From: <kristin_boston >

Sent: Thu, Apr 15, 2010 8:38 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Pam,

What a strange "survey"! I answered the first few

questions, until the diagnosis question and the "do you follow a

gluten-free diet" question. As soon as I checked the box that said

that I followed a gluten-free diet, it told me I did not qualify for the

survey! What kind of survey about gluten labeling disqualifies people who

are on a gluten free diet? The Celiac Disease Foundation is

supporting this?

Best,

From: Pam Newbury <pknewburyearthlink (DOT) net>

Sent: Wed, April 14, 2010 11:57:18

PM

Subject: [ ] FDA

Research Study (really just a survey)

Below is the information from the FDA and the link to the survey

(this is a reposting from my previous post today). My understanding is

that their survey is what they refer to as a “research studyâ€. If you

click on the link below it will take you to the survey.

Participation just means completing the survey. Pam

<image001.jpg>

Celiac Disease

Foundation is assisting the FDA in seeking Participants for a Research

Study on Gluten-Free Claims on Food Labels and is requesting your

assistance.

The U.S. Food and Drug Administration (FDA) is seeking adults diagnosed

with celiac disease or gluten-intolerance or caregivers to such

individuals to participate in a research study on their grocery shopping

habits. Participants will be asked to take an Internet survey, which will

take approximately 10 minutes to complete.

The survey is available at www.synovate. net/forgluten

Please contact Kosa at kkosa@... or

1-800-334-8571, extension 23901, if you have any questions about the

study. To request a paper copy of the survey, please call 1-877-4GLUTN1.

From: [mailto:celiacbayar eagroups (DOT) com] On Behalf Of Ahroon Yoch

Sent: Wednesday, April 14, 2010

4:36 PM

@ groups.

com

Subject: Re: [ ] FDA

Research Study

How can we get to be a part of the study?

Sent from my iPhone

On Apr 14, 2010, at 3:15 PM, "Pam Newbury" <pknewbury@earthlink .net> wrote:

They want to know what consumers think about different ways of

labeling foods gluten-free. I think they want to know what is confusing

and what people will trust when it comes to how the gluten-free claim is

presented on a label. I don’t like how they went about it, but I’m trying

to be glad they are at least asking us what we think. I wrote a lot in

the comments section at the end….

Pam

_

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Guest guest

no, Canada calls for 20 ppm and Europe sets the standard at 200 ppm. http://www.celiac.com/categories/Gluten%252dFree/

-----Original Message-----

From: Harper <flatcat9@...>

Sent: Fri, Apr 16, 2010 9:12 am

Subject: Re: [ ] Zero ppm?

Does Canada really call for zero ppm in GF products?

H.

-----Original Message-----

From: Joe Herman <jhinsfgmail>

< >

Cc: < > < >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please point out research which discusses a commercially available gluten test which tests to the level of zero ppm?

I have never seen this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, "Lillyth Denaghy Keogh-Quillan" <lillythdenaghykeoghcomcast (DOT) net> wrote:

See, everyone says there is no way to make

it zero ppm. I think that is TOTAL BS. That is Canada’s standard, and they are

really great place to live with celiac.

So whenever people say it can’t be done –

it IS done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section

that I thought GF should only be ZERO ppm.

From: [mailto: ] On Behalf Of Darcy

Sent: Thursday, April 15, 2010

10:10 AM

Subject: RE: [ ] FDA

Research Study (really just a survey)

I agree with both of you – I chose “Gluten-Free†but what

I want that to mean is that it does not contain gluten (below a certain very

low level such as 20 ppm – they will never say absolutely none) and is also

made in a safe manner. There is a comment section at the end where this

can be written in.

Unfortunately the survey doesn’t offer that level of distinction

at all (what the words actually mean) and doesn’t address cross-contamination

from manufacturing practices very well.

I do agree that it’s great to see them doing this survey!

Thanks,

From:

[mailto: ]

On Behalf Of Harper

Sent: Thursday, April 15, 2010

9:08 AM

Subject: Re: [ ] FDA

Research Study (really just a survey)

I believe that Gluten-Free is the more

restrictive, all-inclusive statement.

H.

when asked which of the following labels would lead me to buy the

product, I checked the "made in a gluten free facility" over "no

gluten ingredients" and "gluten free,"

-----Original Message-----

From: TrVerb@...

Sent: Thu, Apr 15, 2010 8:48 am

Subject: Re: [ ] FDA Research Study (really just a survey)

I think you must have only thought you checked the "I follow

a gluten free diet" box, because that's what I did and I did the whole

survey - they are obviously only interested in people who are either following

it for themselves or preparing food for someone who is. I am guessing you

checked the "I don't follow a gf diet" by mistake.

I am surprised by the negative response to this survey. I am

thrilled that they are asking me these questions, which are clearly designed to

ascertain what kind of labeling laws they need to consider - we are being given

the opportunity to encourage the government to make it a law that labels need

to be as specific as possible (when asked which of the following labels would

lead me to buy the product, I checked the "made in a gluten free

facility" over "no gluten ingredients" and "gluten

free," which I would hope would encourage whoever reads this survey to

understand the issue goes beyond the actual ingredients to where the product is

processed). It sounds to me like some of us are offended that they are

asking "how much do we really understand about celiac" and how smart

or stupid or educated we are. But they do need to know how much more education

they need to provide. Look, I have friends who have diagnosed celiac who are

convinced spelt is fine and "a little" wheat now and then is fine,

too, and who don't ever think about cross contamination issues. I don't want

those people driving the discussion and influencing the law! So PLEASE,

everybody do this survey and take the opportunity at the end to stress that we

need to know about EVERY gluten ingredient, not just wheat, and EVERY cross

contamination issue...

Tristan

-----Original Message-----

From: <kristin_boston >

Sent: Thu, Apr 15, 2010 8:38 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Pam,

What a strange "survey"! I answered the first few

questions, until the diagnosis question and the "do you follow a

gluten-free diet" question. As soon as I checked the box that said

that I followed a gluten-free diet, it told me I did not qualify for the

survey! What kind of survey about gluten labeling disqualifies people who

are on a gluten free diet? The Celiac Disease Foundation is

supporting this?

Best,

From: Pam Newbury <pknewburyearthlink (DOT) net>

Sent: Wed, April 14, 2010 11:57:18

PM

Subject: [ ] FDA

Research Study (really just a survey)

Below is the information from the FDA and the link to the survey

(this is a reposting from my previous post today). My understanding is

that their survey is what they refer to as a “research studyâ€. If you

click on the link below it will take you to the survey.

Participation just means completing the survey. Pam

<image001.jpg>

Celiac Disease

Foundation is assisting the FDA in seeking Participants for a Research

Study on Gluten-Free Claims on Food Labels and is requesting your

assistance.

The U.S. Food and Drug Administration (FDA) is seeking adults diagnosed

with celiac disease or gluten-intolerance or caregivers to such

individuals to participate in a research study on their grocery shopping

habits. Participants will be asked to take an Internet survey, which will

take approximately 10 minutes to complete.

The survey is available at www.synovate. net/forgluten

Please contact Kosa at kkosa@... or

1-800-334-8571, extension 23901, if you have any questions about the

study. To request a paper copy of the survey, please call 1-877-4GLUTN1.

From: [mailto:celiacbayar eagroups (DOT) com] On Behalf Of Ahroon Yoch

Sent: Wednesday, April 14, 2010

4:36 PM

@ groups.

com

Subject: Re: [ ] FDA

Research Study

How can we get to be a part of the study?

Sent from my iPhone

On Apr 14, 2010, at 3:15 PM, "Pam Newbury" <pknewbury@earthlink .net> wrote:

They want to know what consumers think about different ways of

labeling foods gluten-free. I think they want to know what is confusing

and what people will trust when it comes to how the gluten-free claim is

presented on a label. I don’t like how they went about it, but I’m trying

to be glad they are at least asking us what we think. I wrote a lot in

the comments section at the end….

Pam

_

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Share on other sites

Guest guest

My guess is that the survey seeks to determine what we believe the terms mean, and whether we have any knowledge of cross-contamination. The questions may not be intended to give the information they seem to ask for. I can't remember the content well enough to give examples. Again, this is just my reading of it, a guess on my part.

H.

" . . . the survey doesn’t offer that level of distinction

at all (what the words actually mean) and doesn’t address cross-contamination

from manufacturing practices very well. . . . "

-----Original Message-----

From: TrVerb@...

Sent: Fri, Apr 16, 2010 9:15 am

Subject: Re: [ ] Zero ppm?

no, Canada calls for 20 ppm and Europe sets the standard at 200 ppm. http://www.celiac.com/categories/Gluten%252dFree/

-----Original Message-----

From: Harper <flatcat9aol>

Sent: Fri, Apr 16, 2010 9:12 am

Subject: Re: [ ] Zero ppm?

Does Canada really call for zero ppm in GF products?

H.

-----Original Message-----

From: Joe Herman <jhinsfgmail>

< >

Cc: < > < >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please point out research which discusses a commercially available gluten test which tests to the level of zero ppm?

I have never seen this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, "Lillyth Denaghy Keogh-Quillan" <lillythdenaghykeoghcomcast (DOT) net> wrote:

See, everyone says there is no way to make

it zero ppm. I think that is TOTAL BS. That is Canada’s standard, and they are

really great place to live with celiac.

So whenever people say it can’t be done –

it IS done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section

that I thought GF should only be ZERO ppm.

What a strange "survey"! I answered the first few

questions, until the diagnosis question and the "do you follow a

gluten-free diet" question. As soon as I checked the box that said

that I followed a gluten-free diet, it told me I did not qualify for the

survey! What kind of survey about gluten labeling disqualifies people who

are on a gluten free diet? The Celiac Disease Foundation is

supporting this?

Best,

___

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Guest guest

Yes. They do. I have spoken to manufacturers

who have told me they test their products to Canadian standards, which are zero

ppm. Canada

will not let your product into the country with a GF label on it unless it

tests at zero ppm.

At least, this was the case a few years

aog.

From: [mailto: ] On Behalf Of Harper

Sent: Friday, April 16, 2010 9:12

AM

Subject: Re: [ ] Zero

ppm?

Does Canada really call for zero ppm in

GF products?

H.

-----Original

Message-----

From: Joe Herman <jhinsfgmail>

< >

Cc: < >

< >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please

point out research which discusses a commercially available gluten test which

tests to the level of zero ppm?

I have never seen

this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, " Lillyth Denaghy Keogh-Quillan " <lillythdenaghykeoghcomcast (DOT) net>

wrote:

See, everyone says there is no way to make

it zero ppm. I think that is TOTAL BS. That is Canada’s

standard, and they are really great place to live with celiac.

So whenever people say it can’t be done –

it IS done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section

that I thought GF should only be ZERO ppm.

Link to comment
Share on other sites

Guest guest

I was told by a manufacturer that it was zero

ppm. He said that they tested to zero ppm. So, even if it isn’t Canadian

standard, there MUST be a test for it if this guy was dong it…

From: [mailto: ] On Behalf Of TrVerb@...

Sent: Friday, April 16, 2010 9:16

AM

Subject: Re: [ ] Zero

ppm?

no, Canada calls for 20 ppm and Europe

sets the standard at 200 ppm. http://www.celiac.com/categories/Gluten%252dFree/

-----Original

Message-----

From: Harper <flatcat9aol>

Sent: Fri, Apr 16, 2010 9:12 am

Subject: Re: [ ] Zero ppm?

Does Canada really call for zero ppm in

GF products?

H.

-----Original

Message-----

From: Joe Herman <jhinsfgmail>

< >

Cc: < >

< >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please

point out research which discusses a commercially available gluten test which

tests to the level of zero ppm?

I have never seen

this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, " Lillyth Denaghy Keogh-Quillan " <lillythdenaghykeoghcomcast (DOT) net>

wrote:

See, everyone says there is no way to make

it zero ppm. I think that is TOTAL BS. That is Canada’s

standard, and they are really great place to live with celiac.

So whenever people say it can’t be done –

it IS done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section

that I thought GF should only be ZERO ppm.

From:

[mailto: ]

On Behalf Of Darcy

Sent: Thursday, April 15, 2010 10:10

AM

Subject: RE: [ ] FDA

Research Study (really just a survey)

I agree with both of you – I chose

“Gluten-Free” but what I want that to mean is that it does not contain

gluten (below a certain very low level such as 20 ppm – they will never say

absolutely none) and is also made in a safe manner. There is a comment

section at the end where this can be written in.

Unfortunately the survey doesn’t offer

that level of distinction at all (what the words actually mean) and doesn’t

address cross-contamination from manufacturing practices very well.

I do agree that it’s great to see them

doing this survey!

Thanks,

From:

[mailto: ]

On Behalf Of Harper

Sent: Thursday, April 15, 2010

9:08 AM

Subject: Re: [ ] FDA

Research Study (really just a survey)

I believe

that Gluten-Free is the more restrictive, all-inclusive statement.

H.

when asked which of the following labels

would lead me to buy the product, I checked the " made in a gluten free

facility " over " no gluten ingredients " and " gluten

free, "

-----Original Message-----

From: TrVerb@...

Sent: Thu, Apr 15, 2010 8:48 am

Subject: Re: [ ] FDA Research Study (really just a survey)

I think you must have only thought you

checked the " I follow a gluten free diet " box, because that's what I

did and I did the whole survey - they are obviously only interested in people

who are either following it for themselves or preparing food for someone who

is. I am guessing you checked the " I don't follow a gf diet " by

mistake.

I am surprised by the negative response to

this survey. I am thrilled that they are asking me these questions, which are

clearly designed to ascertain what kind of labeling laws they need to consider

- we are being given the opportunity to encourage the government to make it a

law that labels need to be as specific as possible (when asked which of the

following labels would lead me to buy the product, I checked the " made in

a gluten free facility " over " no gluten ingredients " and

" gluten free, " which I would hope would encourage whoever reads this

survey to understand the issue goes beyond the actual ingredients to where the

product is processed). It sounds to me like some of us are offended that

they are asking " how much do we really understand about celiac " and

how smart or stupid or educated we are. But they do need to know how much more

education they need to provide. Look, I have friends who have diagnosed celiac

who are convinced spelt is fine and " a little " wheat now and then is

fine, too, and who don't ever think about cross contamination issues. I don't

want those people driving the discussion and influencing the law! So PLEASE,

everybody do this survey and take the opportunity at the end to stress that we

need to know about EVERY gluten ingredient, not just wheat, and EVERY cross

contamination issue...

Tristan

-----Original Message-----

From: <kristin_boston >

Sent: Thu, Apr 15, 2010 8:38 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Pam,

What a strange " survey " ! I

answered the first few questions, until the diagnosis question and the " do

you follow a gluten-free diet " question. As soon as I checked the

box that said that I followed a gluten-free diet, it told me I did not qualify

for the survey! What kind of survey about gluten labeling disqualifies

people who are on a gluten free diet? The Celiac Disease Foundation

is supporting this?

Best,

From: Pam Newbury <pknewburyearthlink (DOT) net>

Sent: Wed, April 14, 2010 11:57:18

PM

Subject: [ ] FDA

Research Study (really just a survey)

Below is the information from the FDA

and the link to the survey (this is a reposting from my previous post today).

My understanding is that their survey is what they refer to as a

“research study”. If you click on the link below it will take you to the survey.

Participation just means completing the survey. Pam

<image001.jpg>

Celiac Disease

Foundation is assisting the FDA in seeking Participants for a Research

Study on Gluten-Free Claims on Food Labels and is requesting your

assistance.

The U.S. Food and Drug Administration (FDA) is seeking adults diagnosed

with celiac disease or gluten-intolerance or caregivers to such

individuals to participate in a research study on their grocery shopping

habits. Participants will be asked to take an Internet survey, which will

take approximately 10 minutes to complete.

The survey is available at www.synovate. net/forgluten

Please contact Kosa at kkosa@... or 1-800-334-8571, extension

23901, if you have any questions about the study. To request a paper copy

of the survey, please call 1-877-4GLUTN1.

From: [mailto:celiacbayar eagroups (DOT) com] On Behalf Of Ahroon Yoch

Sent: Wednesday, April 14, 2010

4:36 PM

@ groups.

com

Subject: Re: [ ] FDA

Research Study

How can we get to be a part of the study?

Sent from my iPhone

On Apr 14, 2010, at 3:15 PM, " Pam Newbury " <pknewbury@earthlink .net> wrote:

They want to know what consumers think

about different ways of labeling foods gluten-free. I think they want to

know what is confusing and what people will trust when it comes to how the

gluten-free claim is presented on a label. I don’t like how they went

about it, but I’m trying to be glad they are at least asking us what we

think. I wrote a lot in the comments section at the end….

Pam

_

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Share on other sites

Guest guest

Perhaps the manufacturer was misinformed

about Canada’s

regulations, but he was *very*

clear on his testing having been done at ZERO ppm, rather than 20. Who

knows, perhaps he was misinformed all around, or using some other way of

testing. I don’t know. But when I spoke with him, he kept

saying “zero parts per million”…

From: [mailto: ] On Behalf Of Pam Newbury

Sent: Friday, April 16, 2010 6:03

PM

Subject: [ ] Zero ppm?

Lillyth,

I can only assume your manufacturer was using a bit of hyperbole or

didn’t consider the difference between zero and 20 ppm significant.

When I hear conflicting opinions I always try to find a primary source.

Here is the information closest to a primary source that I could find on this

subject.

Here is the actual

regulation from the Canadian Food Inspection Agency. You will note it

makes no actual mention of “parts per million.”

9.9.4 Gluten-Free Foods [b.24.018, B.24.019]

A food is not permitted to be labelled, packaged, sold or

advertised in a manner likely to create an impression that it is

" gluten-free " unless it does

not contain wheat, including

spelt and kamut, or oats, barley, rye, triticale or any part thereof.

For information detailing how they actually test foods labeled

gluten-free, I found this on the Health

Canada web site:

Tolerance to gluten varies among individuals with CD and there

are limited clinical scientific data on a threshold for the amount of gluten

required to initiate or maintain an immunological reaction in CD patients.

Therefore, there is no clear consensus on a safe gluten threshold level.

Currently, as per section B.24.018 of the Food and Drug Regulations (Government

of Canada 2009), a food cannot be labelled as " gluten-free " if it

contains wheat, including spelt and kamut, or oats, barley, rye or triticale or

any part thereof. For compliance purposes, for food products labelled as

" gluten-free " , Health Canada

uses a maximum limit of 20 ppm. Based on current scientific evidence, this generally

represents a maximum level which can be used to interpret Section B.24.018 of

the Food and Drug Regulations where

a food is prepared under good manufacturing conditions aimed at achieving the

lowest possible levels of gluten resulting from cross-contamination. This

action level is consistent with the Standard for Foods for Special Dietary Use

for Persons Intolerant to Gluten (CODEX STAN 118 - 1979) established by Codex

Alimentarius (Codex 2008) and is subject to periodic review as new data become

available regarding emerging analytical techniques and a possible gluten

threshold. This maximum limit will be applied to " gluten-free "

natural health products which may contain gluten as a contaminant.

(Health Canada is a federal agency in Canada charged

with keeping Canadians healthy.)

I believe

I’ve posted this link before, but since it gives a good presentation of

the differing opinions on the meaning of “Gluten-Free” so I’m

posting the link again.

http://www.celiactoday.com/Community/Opinions_Differ_as_US_FDA_Prepares_To_Define_What_‘GlutenFree’_Means

The lowest

test I have heard of detects gluten at 3 ppm. I don’t

know why they don’t use this test routinely or why the FDA doesn’t

use 3ppm as a standard instead of 20. Maybe it is expensive or hard to

administer. Or maybe most manufacturers would just be very unlikely to be

able to meet this standard. At this point, I am not aware of

any test that will detect anything less than 3 ppm gluten.

Pam

From:

[mailto: ]

On Behalf Of Lillyth Denaghy

Keogh-Quillan

Sent: Friday, April 16, 2010 2:23

PM

Subject: RE: [ ] Zero

ppm?

Yes. They

do. I have spoken to manufacturers who have told me they test their

products to Canadian standards, which are zero ppm. Canada will not

let your product into the country with a GF label on it unless it tests at zero

ppm.

At least, this was the case a few years aog.

From:

[mailto: ]

On Behalf Of Harper

Sent: Friday, April 16, 2010 9:12

AM

Subject: Re: [ ] Zero

ppm?

Does Canada

really call for zero ppm in GF products?

H.

-----Original Message-----

From: Joe Herman <jhinsfgmail>

< >

Cc: < >

< >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please point out research which discusses a

commercially available gluten test which tests to the level of zero ppm?

I have never seen this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, " Lillyth Denaghy Keogh-Quillan " <lillythdenaghykeoghcomcast (DOT) net>

wrote:

See, everyone says there is no way to make it zero ppm. I

think that is TOTAL BS. That is Canada’s standard, and they

are really great place to live with celiac.

So whenever people say it can’t be done – it IS

done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section that I thought GF should

only be ZERO ppm.

_,___

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Below is a link to a well-researched and informative

discussion on testing for gluten. It is dated June 2009. Note that

it states that testing to Zero ppm is not possible to achieve (and apparently

the Canadian Gov. would like to have that standard if it was practical).

I think I would have heard if there were a new test out that could

test for zero ppm (or even anything less than 3) because it would be big news

in the celiac world; none of my searching on the web came up with any such

test.

http://www.theceliacscene.com/pdf/PPM.pdf

Pam

From:

[mailto: ] On Behalf Of Lillyth Denaghy

Keogh-Quillan

Sent: Saturday, April 17, 2010 3:11 PM

Subject: RE: [ ] Zero ppm? -

No, I’m not disputing that. I just wonder if this

particular manufacturer had some different means of testing that *can*

test to zero ppm. Again, he could have been very misinformed about the

test, but I was wondering if he had some new way of testing, is all…

And even if he doesn’t, I think that at some point it

certainly *could* happen.

From:

[mailto: ] On Behalf Of TrVerb@...

Sent: Saturday, April 17, 2010 9:12 AM

Subject: Re: [ ] Zero ppm? -

It's time to put this thread to rest. It's been established that

the Canada standard is 20 ppm. Whatever one manufacture claims is irrelevant.

-----Original Message-----

From: Lillyth Denaghy Keogh-Quillan <lillythdenaghykeogh@...>

Sent: Fri, Apr 16, 2010 8:13 pm

Subject: RE: [ ] Zero ppm?

Perhaps the manufacturer was misinformed about Canada’s

regulations, but he was *very* clear on his testing having been done at

ZERO ppm, rather than 20. Who knows, perhaps he was misinformed all

around, or using some other way of testing. I don’t know. But

when I spoke with him, he kept saying “zero parts per million”…

From: [mailto: ]

On Behalf Of Pam Newbury

Sent: Friday, April 16, 2010 6:03 PM

Subject: [ ] Zero ppm?

Lillyth, I can

only assume your manufacturer was using a bit of hyperbole or didn’t

consider the difference between zero and 20 ppm significant. When I hear

conflicting opinions I always try to find a primary source. Here is the

information closest to a primary source that I could find on this subject.

Here is the actual regulation from

the Canadian Food Inspection Agency. You will note it makes no actual mention

of “parts per million.”

9.9.4 Gluten-Free Foods [b.24.018, B.24.019]

A food is not permitted to be

labelled, packaged, sold or advertised in a manner likely to create an

impression that it is " gluten-free " unless it does not

contain wheat, including spelt and kamut, or oats, barley, rye,

triticale or any part thereof.

For information detailing how they actually

test foods labeled gluten-free, I found this on the Health Canada web site:

Tolerance to gluten varies among

individuals with CD and there are limited clinical scientific data on a

threshold for the amount of gluten required to initiate or maintain an

immunological reaction in CD patients. Therefore, there is no clear consensus

on a safe gluten threshold level.

Currently, as per section

B.24.018 of the Food and Drug Regulations (Government of

Canada 2009), a food cannot be labelled as " gluten-free " if it

contains wheat, including spelt and kamut, or oats, barley, rye or triticale or

any part thereof. For compliance purposes, for food products labelled as " gluten-free " ,

Health Canada uses a maximum limit of 20 ppm.

Based on current scientific evidence, this generally represents a maximum level

which can be used to interpret Section B.24.018 of the Food and Drug

Regulations where a food is prepared under good manufacturing conditions

aimed at achieving the lowest possible levels of gluten resulting from

cross-contamination. This action level is consistent with the Standard for

Foods for Special Dietary Use for Persons Intolerant to Gluten (CODEX STAN 118

- 1979) established by Codex Alimentarius (Codex 2008) and is subject to

periodic review as new data become available regarding emerging analytical

techniques and a possible gluten threshold. This maximum limit will be applied

to " gluten-free " natural health products which may contain gluten as

a contaminant.

(Health Canada is a federal agency

in Canada charged with keeping Canadians healthy.)

I believe I’ve posted this

link before, but since it gives a good presentation of the differing opinions

on the meaning of “Gluten-Free” so I’m posting the link

again.

http://www.celiactoday.com/Community/Opinions_Differ_as_US_FDA_Prepares_To_Define_What_‘GlutenFree’_Means

The lowest

test I have heard of detects gluten at 3 ppm. I don’t

know why they don’t use this test routinely or why the FDA doesn’t

use 3ppm as a standard instead of 20. Maybe it is expensive or hard to

administer. Or maybe most manufacturers would just be very unlikely to be

able to meet this standard. At this point, I am not aware of

any test that will detect anything less than 3 ppm gluten.

Pam

From:

[mailto: ] On Behalf Of Lillyth Denaghy

Keogh-Quillan

Sent: Friday, April 16, 2010 2:23 PM

Subject: RE: [ ] Zero ppm?

Yes.

They do. I have spoken to manufacturers who have told me they test their

products to Canadian standards, which are zero ppm. Canada will not let

your product into the country with a GF label on it unless it tests at zero ppm.

At least,

this was the case a few years aog.

From:

[mailto: ] On Behalf Of Harper

Sent: Friday, April 16, 2010 9:12 AM

Subject: Re: [ ] Zero ppm?

Does Canada really

call for zero ppm in GF products?

H.

-----Original

Message-----

From: Joe Herman <jhinsf@...>

< >

Cc: < > < >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please

point out research which discusses a commercially available gluten test which

tests to the level of zero ppm?

I have never seen

this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, " Lillyth Denaghy Keogh-Quillan " <lillythdenaghykeogh@...>

wrote:

See, everyone says

there is no way to make it zero ppm. I think that is TOTAL BS. That

is Canada’s standard, and they are really great place to live with celiac.

So whenever people

say it can’t be done – it IS done. It is sheer laziness on

the part of manufacturers…

Oh, and I added in

the comments section that I thought GF should only be ZERO ppm.

_,___

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Share on other sites

Guest guest

I bet that’s what they dude I talked

to was referring to then.

This also begs the question, if testing to

5 ppm is possible, why isn’t everyone doing that? My guess is the

food lobby…

From: [mailto: ] On Behalf Of Pam Newbury

Sent: Saturday, April 17, 2010

8:35 PM

Subject: [ ] Zero ppm?

Below is a link to a well-researched and informative

discussion on testing for gluten. It is dated June 2009. Note that

it states that testing to Zero ppm is not possible to achieve (and apparently

the Canadian Gov. would like to have that standard if it was practical).

I think I would have heard if there were a new test out that could

test for zero ppm (or even anything less than 3) because it would be big news

in the celiac world; none of my searching on the web came up with any such

test.

http://www.theceliacscene.com/pdf/PPM.pdf

Pam

From:

[mailto: ]

On Behalf Of Lillyth Denaghy

Keogh-Quillan

Sent: Saturday, April 17, 2010

3:11 PM

Subject: RE: [ ] Zero

ppm? -

No, I’m not disputing that. I just wonder if this

particular manufacturer had some different means of testing that *can* test to zero ppm. Again, he

could have been very misinformed about the test, but I was wondering if he had

some new way of testing, is all…

And even if he doesn’t, I think that at some point it

certainly *could* happen.

From:

[mailto: ]

On Behalf Of TrVerb@...

Sent: Saturday, April 17, 2010

9:12 AM

Subject: Re: [ ] Zero

ppm? -

It's time to put this thread to rest. It's been established that

the Canada

standard is 20 ppm. Whatever one manufacture claims is irrelevant.

-----Original Message-----

From: Lillyth Denaghy Keogh-Quillan <lillythdenaghykeoghcomcast (DOT) net>

Sent: Fri, Apr 16, 2010 8:13 pm

Subject: RE: [ ] Zero ppm?

Perhaps the manufacturer was misinformed about Canada’s

regulations, but he was *very*

clear on his testing having been done at ZERO ppm, rather than 20. Who

knows, perhaps he was misinformed all around, or using some other way of

testing. I don’t know. But when I spoke with him, he kept

saying “zero parts per million”…

From:

[mailto: ]

On Behalf Of Pam Newbury

Sent: Friday, April 16, 2010 6:03

PM

Subject: [ ] Zero ppm?

Lillyth, I can only assume your

manufacturer was using a bit of hyperbole or didn’t consider the

difference between zero and 20 ppm significant. When I hear conflicting

opinions I always try to find a primary source. Here is the information

closest to a primary source that I could find on this subject.

Here is the actual regulation from the Canadian Food Inspection

Agency. You will note it makes no actual mention of “parts per

million.”

9.9.4 Gluten-Free

Foods [b.24.018, B.24.019]

A food is not permitted to be labelled, packaged, sold or

advertised in a manner likely to create an impression that it is

" gluten-free " unless it does

not contain wheat, including

spelt and kamut, or oats, barley, rye, triticale or any part thereof.

For information detailing how they actually test foods labeled

gluten-free, I found this on the Health Canada web site:

Tolerance to gluten varies among individuals with CD and there

are limited clinical scientific data on a threshold for the amount of gluten

required to initiate or maintain an immunological reaction in CD patients.

Therefore, there is no clear consensus on a safe gluten threshold level.

Currently, as per section B.24.018 of the Food and Drug Regulations (Government

of Canada 2009), a food cannot be labelled as " gluten-free " if it

contains wheat, including spelt and kamut, or oats, barley, rye or triticale or

any part thereof. For compliance purposes, for food products labelled as

" gluten-free " , Health Canada uses a maximum limit of 20

ppm. Based on current scientific evidence, this generally represents

a maximum level which can be used to interpret Section B.24.018 of the Food and Drug Regulations where a food is

prepared under good manufacturing conditions aimed at achieving the lowest

possible levels of gluten resulting from cross-contamination. This action

level is consistent with the Standard for Foods for Special Dietary Use for

Persons Intolerant to Gluten (CODEX STAN 118 - 1979) established by Codex

Alimentarius (Codex 2008) and is subject to periodic review as new data become

available regarding emerging analytical techniques and a possible gluten

threshold. This maximum limit will be applied to " gluten-free "

natural health products which may contain gluten as a contaminant.

(Health Canada

is a federal agency in Canada

charged with keeping Canadians healthy.)

I believe I’ve posted this link before, but since it gives a

good presentation of the differing opinions on the meaning of

“Gluten-Free” so I’m posting the link again.

http://www.celiactoday.com/Community/Opinions_Differ_as_US_FDA_Prepares_To_Define_What_‘GlutenFree’_Means

The lowest test I have heard of detects gluten at 3 ppm. I

don’t know why they don’t use this test routinely or why the FDA

doesn’t use 3ppm as a standard instead of 20. Maybe it is expensive

or hard to administer. Or maybe most manufacturers would just be very

unlikely to be able to meet this standard. At this point, I

am not aware of any test that will detect anything less than 3 ppm

gluten.

Pam

From:

[mailto: ]

On Behalf Of Lillyth Denaghy

Keogh-Quillan

Sent: Friday, April 16, 2010 2:23

PM

Subject: RE: [ ] Zero

ppm?

Yes. They do. I have spoken to

manufacturers who have told me they test their products to Canadian standards,

which are zero ppm. Canada

will not let your product into the country with a GF label on it unless it

tests at zero ppm.

At least, this was the case a few years aog.

From:

[mailto: ]

On Behalf Of Harper

Sent: Friday, April 16, 2010 9:12

AM

Subject: Re: [ ] Zero

ppm?

Does Canada

really call for zero ppm in GF products?

H.

-----Original Message-----

From: Joe Herman <jhinsfgmail>

< >

Cc: < >

< >

Sent: Fri, Apr 16, 2010 8:41 am

Subject: Re: [ ] FDA Research Study (really just a survey)

Can someone please point out research which discusses a

commercially available gluten test which tests to the level of zero ppm?

I have never seen this.

Sent from my iPhone

On Apr 16, 2010, at 8:00 AM, " Lillyth Denaghy Keogh-Quillan " <lillythdenaghykeoghcomcast (DOT) net>

wrote:

See, everyone says there is no way to make it zero ppm. I

think that is TOTAL BS. That is Canada’s standard, and they

are really great place to live with celiac.

So whenever people say it can’t be done – it IS

done. It is sheer laziness on the part of manufacturers…

Oh, and I added in the comments section that I thought GF should

only be ZERO ppm.

_,___

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