I found a link to a proposal open for comments having to do with labeling gluten free foods.
The link is:
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm265838.htm
My comment went as follows:
I would strongly recommend that two labels be created, Gluten-Free, and Gluten-Safe.
This would accommodate safety and allow manufacturers to correctly label food and create a situation where manufacturers would be encouraged to be honest.
Tolerances are only estimates of what is ok for celiacs as a group. 20PPM could possibly be ok for some people and possibly not. The danger is that any number other than absolute 0 is a sliding number and will likely be subject to change by doctors and or even lobbyists. I expect this to happen. This would not be a good thing unless the rules are written so the PPM could only be changed to a smaller number and never a larger number.
For example let’s put it another way. Let’s assume gluten is salmonella. How much is it ok to consume? Are you going to go with a few drops are ok or are you going with none at all?
The only number that works for everybody is 0 PPM gluten.
Gluten-Free is a logical term and should mean only one thing. 0% gluten sourced from ingredients that contain 0% gluten. We should not make it any more difficult on the consumer and service chain than it needs to be to keep the population of allergy sufferers safe.
Gluten-Safe is logically a term for what has been determined safe by doctors and lobbyists. Quite likely, after the initial change and standard grumbling about the change, marketing will love this term.
There is no reason to not have these two terms, as defined above, when comparing to other countries definitions of Gluten-Free. Any error made by the foreigner will be even safer. As a US citizen I expect my terms to be different slightly from foreign terms. As a general rule everybody expects this. So multiple country definitions of these terms should not be a factor.
Lastly, do not omit food colors or any ingredients from these rules. I don’t care about my food being the right shade. I only care about its safety.
Use the instructions provided at the link above and put your two cents in.