A
gluten-free diet is one that that does not contain the protein gluten. Gluten
is found in grains such as wheat, barley and rye (sometimes in
oats).Gluten causes inflammation in the small intestines of people with celiac
disease. A gluten-free diet is required by patients with celiac disease (1%
population) as it helps to control signs and symptoms and prevent
complications.
Earlier
in 2016, the FSSAI had notified the Food Safety and Standards (Food
Products Standards and Food Additives) Second Amendment Regulations,
2016 relating to standards for gluten food and low gluten food.
Correspondingly it made changes in Food Safety and Standards (Packaging and
Labelling) Regulations, 2011 in packaging labels for gluten free and low
gluten foods (rice, millets, ragi, oats, rye, barley, maize, wheat,
pulses and legumes) specially processed to reduce gluten content to a
level 20-100mg/kg.
Under
these new regulations, FSSAI defined gluten-free food as food that consists of
or is made of one or more ingredients containing rice, millets, ragi, pulses or
legumes. A “gluten-free food” is one in which gluten levels are below 20 mg/kg.
It also said that
“A
food which, by its nature, is suitable for use as part of a gluten free diet
shall not be named as ‘special dietary’, “special dietetic” or any other
equivalent term, however, such food may bear a statement on the label that
‘this food is by its nature gluten-free’.”
The
Gluten-Free Food Labeling Final Rule issued by the US FDA in 2015 has defined
"gluten-free" as meaning that the food either is inherently gluten
free; or does not contain an ingredient that is:
· a gluten-containing
grain (e.g., spelt wheat);
· derived from a
gluten-containing grain that has not been processed to remove gluten (e.g.,
wheat flour); or
· derived from 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 ppm or
more gluten in the food. Also, any unavoidable presence of gluten in the food
must be less than 20 ppm. That is the lowest level that can be consistently
detected in foods using valid scientific analytical tools. Also, most people
with celiac disease can tolerate foods with trace amounts of gluten without
causing adverse health effects.
Why
didn’t FDA adopt zero ppm gluten rather than less than 20 ppm gluten as one of
the criteria for a food labeled gluten-free?
FDA
used an analytical methods-based approach to define the term gluten-free and
adopted < 20 ppm gluten as one of the criteria for a food labeled
gluten-free because the agency relies upon scientifically validated methods for
enforcing its regulations. Analytical methods that are scientifically validated
to reliably detect gluten at a level lower than 20 ppm are not currently
available. In addition, some celiac disease researchers and some
epidemiological evidence suggest that most individuals with celiac disease can
tolerate variable trace amounts and concentrations of gluten in foods
(including levels that are less than 20 ppm gluten) without causing adverse
health effects. (https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm362880.htm)
As
per the FSSAI draft Food Safety and Standards (Labelling and Display)
Regulations, 2018: The term “Gluten Free” shall be printed in the
immediate proximity of the name of the product in the case of products
described in regulation 2.14 of the Food Safety and Standards (Food Products
Standards and Food Additives) Regulations, 2011, namely ‘Gluten Free’.
The
term “Low Gluten” shall be printed in the immediate proximity of the name of
the product in the case of products described in regulation 2.15 of the Food
Safety and Standards (Food Products Standards and Food Additives) Regulations,
2011, namely: “Low Gluten”. The label shall carry a ‘warning’ that ‘the
food labeled as Low Gluten may pose a risk for those with celiac disease.
But
now the FSSAI has decided to take “Low gluten” label out of the regulation as
in celiac disease no amount of gluten is safe.
HCFI
Recommendations
· The term “Low gluten
foods” to be taken out of the label.
· Gluten free should
instead be labeled as zero gluten (since the public perception is that
gluten-free means some amount of gluten is allowed).
· Awareness should be
created that ‘beer’ contains gluten and is harmful to gluten sensitive
population. The harm reduction alternative is honey water wine, which has <
3% alcohol.
· There should be
options for gluten-free foods in airlines and trains.
· In all parties,
marriages and restaurants, there should be a provision for gluten free foods.
Medical associations should pass a resolution to this effect on priority.
· Non-celiac wheat
sensitive persons (up to 10% of the population) should be offered wheat-free
food options.
· Wheat available in
the market should also be labeled as high gluten wheat and low gluten wheat
(both are harmful to celiac disease but low gluten wheat may have some solution
for non-celiac wheat sensitive persons).
Dr KK Aggarwal
Padma Shri Awardee
President Elect Confederation of Medical
Associations in Asia and Oceania
(CMAAO)
Group Editor-in-Chief IJCP Publications
President Heart Care Foundation of India
Past National President IMA
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