4 steps to an FDA-approved gluten-free menu

A growing number of restaurants across the nation have been offering gluten-free menus in recent years. But do they meet the first ever gluten-free definition announced by the Food and Drug Administration (FDA)? Most likely, many will not.

After six years of deliberation, the FDA announced on Aug. 5, 2013 a new regulation and uniform standard for the term “gluten-free,” which must be met by Aug. 5, 2014.

The new definition states that the gluten-free term can only be used if the food item is “inherently gluten-free and does not contain 1) a gluten-containing grain, 2) a gluten-containing grain that has not been processed to remove gluten (e.g., wheat flour), or 3) a gluten-containing grain that has been processed to remove gluten (e.g., wheat starch), if the use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food. Also, any unavoidable presence of gluten in the food must be less than 20 ppm.”

The 20-ppm benchmark is the key to this ruling, as it is the level that health researchers around the world agree is the safe amount of gluten that will not adversely affect those with celiac disease.

Currently, many restaurants state that their gluten-free menu is not for those with celiac disease but only for those with gluten sensitivity. They also sometimes state that they can’t guarantee there is no gluten present in the “gluten-free” meal. Generally, this means that the menu item is free of ingredients that contain gluten, but the restaurant is not taking the additional steps necessary to protect against cross contact with gluten.

Cross contact means that a non-gluten item comes in contact with, or touches, an item with gluten. Even a speck of gluten as small as the size of a grain of sand can travel through utensils, cookware, prep tables, frying oil, etc., and get into food, which can cause harm to someone with celiac disease. There is even some evidence that gluten can be spread airborne, especially by flour products.

After Aug. 5, 2014, the FDA states that “Any food product labeled ‘gluten-free’ that does not meet the criteria established in the final rule, including a food that contains 20 ppm or more gluten, would be deemed misbranded and would be subject to regulatory enforcement action.” Restaurants can take the following steps to help ensure that they do meet the criteria:

1. Get commitment from management

Beckee Moreland, director of gluten-free industry initiatives at the National Foundation for Celiac Awareness (NFCA), recommends that management take the GREAT Kitchens course (Gluten-free Resource Education Awareness Training).

“This way, management will understand what it takes to identify potential gluten sources, develop protocols and procedures to protect against cross contact, and train the front of house and back of house staff,” explains Moreland, who is passionate for the cause because she herself has celiac disease. “Then once management makes the commitment, the restaurant can move forward with confidence because they understand the process and the need for education and training. And restaurants that follow through with their commitment will receive the benefits of a loyal following from those with celiac disease and their family and friends, as well as the bigger market of those who are gluten sensitive but don’t have celiac disease.”

2. Analyze gluten presence

Many foods are naturally gluten-free, such as fresh unprocessed meats, poultry and fish; fruits and vegetables; nuts, beans and some whole grains and starches, such as potatoes, corn, quinoa and rice. However, gluten can be hidden in seasonings, sauces, flavorings and other ingredients, so you will need a gluten-free expert to provide a thorough analysis of every ingredient and food label, including all sub-recipes and purchased and prepared items.

“We work with a lot of restaurants, helping them identify menu choices that do not contain gluten. They are sometimes surprised when we tell them that a spice blend contributes gluten to an otherwise gluten-free choice. However, they do appreciate the education, so they can find a gluten-free spice substitute,” says Nicole Ring, RD, Healthy Dining’s Director of Nutrition. “It seems like a chicken breast with fresh vegetables and quinoa should be a gluten-free choice, but you have to be very cautious with marinades, sauces, dressings and other ingredients that may contain gluten.”

Generally, organizations that certify gluten-free products require the products to contain 10 ppm or less. That means that food products labeled and certified as gluten-free are rigorously tested in batches to meet the 10 ppm and thus are certified as “gluten-free.” So restaurants that purchase the certified gluten-free products can feel confident about using these products.

3. Train restaurant staff

The NFCA’s GREAT Kitchens program provides five multimedia interactive modules online to effectively train restaurant personnel to develop, prepare and serve gluten-free options with confidence.

The front-of-house module includes topics such as taking orders, answering questions, approaches to serving guests with gluten-free needs, communication with back-of-house staff and prevention of mistakes. The back-of-house module includes menu development, preparation, avoiding cross contact, storage, and communication with front-of-house staff. The implementation module for management includes a downloadable manual with posters, charts and other support materials. The modules also address the specific needs of a gluten-free diner and understanding whether ingredients contain gluten.

4. Monitor adherence to protocol

Once the gluten-free items are identified and analyzed, the staff is trained and the protocols are in place, it is important to regularly monitor adherence and continue training for all new staff.

When asked whether this new FDA regulation will hinder food suppliers and restaurants when it comes to offering gluten-free products, Moreland states, “It is going to help bring more gluten-free specialty products to market. Many companies have been waiting for this ruling so that they can launch new gluten-free retail products. Soon to follow will be wholesale options, such as more variety in gluten-free breads, pastas, pizza crusts, sauces, dressings and other ingredients.”