The Food and Drug Administration (FDA) announced its final ruling on voluntary gluten-free labeling for packaged food products in August 2013. At its core, the ruling requires packaged food products carrying a “gluten-free” claim to contain less than 20 parts per million (ppm) of gluten, the threshold considered safe for the majority of people with celiac disease.
The announcement came as no surprise to food manufacturers, as the ruling was years in the making.
What did come as a surprise was wording in the preamble to the ruling addressing restaurateurs and foodservice operators: “with respect to restaurants, FDA guidance suggests that any use of an FDA-defined food labeling claim (e.g., “fat-free” or “cholesterol-free”) on restaurant menus should be consistent with the regulatory definitions.”
This requests that foodservice operators only make a “gluten-free” claim when they can ensure the food item contains less than 20ppm of gluten. Without testing each dish that leaves the kitchen, guaranteeing less than 20ppm of gluten is a hard promise to keep.
The FDA does not regulate the restaurant and non-commercial foodservice industries, so its suggestion that foodservice establishments comply with regulatory definitions is at this point just that, a suggestion.
“While it expects restaurants to comply, the FDA has not released guidance that would enable the foodservice sector to understand how it can reasonably ensure compliance given the setting and cost pressures that exist,” says Beckee Moreland, Director of GREAT Kitchens Program, National Foundation for Celiac Awareness. And, it may take years for local and state authorities to enact regulations.
So, what should foodservice operators do in the meantime? While operators may not have to adhere to the ruling, most agree it’s in everyone’s best interest to do so.
“It’s just the right thing to do,” says Robert Landolphi, Manager of Culinary Development, University of Connecticut. “Especially for the number of students requiring a gluten-free diet. In 2002, we had two students requiring a gluten-free diet. Today, we have over three hundred.”
In the absence of an official set of compliance guidelines, here are some best practices to keep your gluten-free customers safe and garner their trust.
Be Accurate and Transparent with Labeling
“Operators should make accurate claims and be transparent about their ingredients and kitchen practices,” says Moreland.
The University of Colorado Boulder is doing just that. Polly Pollard, UC Boulder’s Executive Chef d’Aboyeur for Housing and Dining Services, says that because their facilities are not dedicated gluten-free, the only time they label an item “gluten-free” is when it is certified as such from the manufacturer, and they serve it in its original sealed package. Rather than label something “free,” which they cannot guarantee, they rely on their menu tag program— "A9 Identified"—to help customers identify when the top eight allergens, gluten, pork and alcohol are present.
Transparency is at the heart of the Compass Group’s "Avoiding Gluten?" program. It is designed to encourage communication with and provide menu suggestions for gluten-free customers, and accompanying signage clearly explains what they can and cannot guarantee with respect to serving gluten-free.
“Our goal is to communicate how we have prepared the foods being considered, while making it clear that we cannot guarantee the foods contain less than 20ppm of gluten due to the presence of gluten from other menu items,” says Jennifer Ignacio, MS, RD, Nutrition Communications Manager, Compass Group North America.
Moreland also warns against using confusing disclaimers or terms such as “low gluten,” “gluten-friendly,” and “gluten-free ingredients,” as they do not benefit the customer.
Create Gluten-Free Recipes for All to Enjoy
Reviewing and revising your operation’s recipes to be gluten-free for all to enjoy is a win-win. And, according to Megan Coats, Registered Dietitian for Cal Poly Campus Dining, it is now easier and more affordable to do.
“As manufacturers have developed more and more gluten-free options, we have made changes to key products so that it does offer the opportunity for us to produce more menu items that satisfy a wider customer base,” says Coats. “Because of the increase in need for gluten-free products, companies have become more competitive with pricing, so we are able to offer a varied menu for our gluten-free/allergen-free station.”
Dining services at the University of Connecticut went through that exercise back in 2002. They identified 20% of their recipes were already gluten-free, and then figured out how to revise as many others as possible. They used white rice flour to thicken soups, chickpea flour and a designated fryolater to make falafel, and changed all of their stocks, dressings and breadcrumbs to be gluten-free. Just these few changes made a significant impact on reducing the amount of gluten in their facilities.
Tap Into Your Greatest Resource—Your Customers
The University of Connecticut created Gluten-Free Galleys in all of their residential dining facilities, where they stock students’ favorite gluten-free brands of breads, tortillas, cookies, and other common packaged foods.
“The students are our secret shoppers,” says Landolphi. “We meet gluten-free students at their specific dining locations and ask them for their favorite items and brands. We then stock all dining locations on campus with these items, so they have their favorites no matter where they eat.”
Invest in a Training Program
A great training program is at the heart of a foodservice operation that knows how to cater to customers with special dietary needs.
Some operations may have the personnel and resources to create an internal training program. For those that don’t, there are several reputable third-party programs that provide excellent training. The National Foundation for Celiac Awareness, Gluten Intolerance Group and The National Association of College & University Food Services (NACUFS) all provide options.
According to Coats, Cal Poly’s dining operations completed NFCA’s GREAT Kitchens training program in summer of 2013.
“The process has been an extremely positive one,” says Coats. “It has added a level of security and trust among the students, their parents and dining.”
With comprehensive training and the above protocols in place, knowing how, when and where to identify gluten-free options becomes a whole lot easier. Dennis Pierce, Director of Dining Services for the University of Connecticut, says it best.
“If a student has one bad experience, then we have to regain their trust, because they will question everything they put in their mouth moving forward.”