How much testing is performed on certified gluten free products?

[RMJ]

It has already been discussed in these forums that the GFCO certified products use step down testing, meaning that not every lot of product is tested for gluten. In some cases, after enough passing results, products only need to be tested once each quarter! Manufacturing facilities are supposed to be audited annually.

GFCO Step down testing - see pages 22-23

What about other certifying organizations? The information I can find online for the Gluten Free Food Program, endorsed by the National Celiac Association, only says that companies must “submit one  gluten test of each product to be certified” prior to certification. Is that just one test on one lot?  What about ongoing testing after certification? How often are manufacturing facilities audited?

Gluten Free Food Program guide to finished product testing for certification

Are these certifying organizations set up primarily for the benefit of the celiac consumer, or for the marketing departments of the companies selling gluten free products?

[RMJ]

Here is information about another certifying organization, NSF.  If one scrolls to the bullets in the NSF Gluten-Free certification section, it looks like each lot is tested for gluten. Their limit is 15ppm, which is below FDA requirements but higher than some other certifying organizations.

NSF

[Scott Adams]

Great questions, and maybe another topic for an article! The GFCO has become the standard, but could probably be greatly improved, but I've not looked into the standards of other organizations like SCS Global, NCA, and NSF. 

[RMJ]

Here is some information on SCS.  It says they will prescribe a testing schedule, but doesn’t say how they determine the schedule.

SCS gluten free certification overview

This mentions auditor supervised testing:

SCS certification

[Scott Adams]

I like the idea of the company not performing the testing, which seems like a huge conflict of interest to me.

[GardeningForHealth]

At this point I would also say that any gluten laboratory testing needs to not be bound by an NDA and must be allowed to be publicly released to anyone who requests it.

[RMJ]

 

 

3 hours ago, GardeningForHealth said:

At this point I would also say that any gluten laboratory testing needs to not be bound by an NDA and must be allowed to be publicly released to anyone who requests it.

That may be too extreme, it would probably keep companies from testing! Pharmaceutical companies don’t release their CoAs to anyone who asks.

 

[RMJ]

I understand that evaluation of processes, procedures and raw materials is important.  In the pharmaceutical industry where I worked for over 40 years there is a saying that one can’t test quality into a product at the end.  However, I think any reasonable consumer would think that if a product is labeled as certified gluten free, that each lot of product would actually be tested for gluten. That’s what bothers me the most. Consumers might also expect that testing to be independent, done by the certifying body.  It would be interesting to do a poll to see what consumer’s expectations are.

[GardeningForHealth]

6 minutes ago, RMJ said:

 

 

That may be too extreme, it would probably keep companies from testing! Pharmaceutical companies don’t release their CoAs to anyone who asks.

 

I was just reading through USDA recalls today; the recalls at this link publicly call out the name of the company, what is being recalled, and why. This is the kind of transparency needed. We do not say that this USDA recall database is too extreme. Among many reasons why products may end up being recalled, undeclared wheat in the product is one reason. However, I noticed that currently, the policy of the USDA seems to be more reactive than proactive when it comes to undeclared allergens. It most cases it seems that we have to wait until people are exposed to find out about the problem.

I would rather that companies who do not test their finished products do not declare their products gluten free at all. This would eliminate gluten exposures that happen from cross-contamination, which is where the gap in regulatory enforcement seems to be right now. There may be more cross contamination going on than we realize at this point, and current FDA requirements for gluten-free labeling are very lax; no testing is required to declare the products gluten-free.

Companies could instead have a separate product line that they put a gluten-free label on, and test these products, and charge more for them--but make their gluten tests available to anyone who asks for them. It serves no one to hide gluten testing and this should not be privileged information. If companies stopped labeling "gluten-free" out of fear of being caught, then other companies would see a market opportunity and fill the void.