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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 millionâ€â€¦

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.â€

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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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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