Remember, it is your responsibility to make sure the gluten-free foods that you prepare or eat are in fact gluten-free. Neither I, my staff nor anyone associated with this document are liable for any adverse reaction or negative consequence that may be experienced by you or others for food which you or they eat or prepare based upon information contained in this document.
Anytime that anything in this document refers to “food” or the ingestion thereof, it includes everything that is consumed by eating or drinking.
The FDA, Grains With Gluten And Cross-Contamination
Before I get into details, I need to get some generalities out of the way. First, I want to talk about the FDA and what they do and don’t do. Then, I’d like to chat about cross-contamination as well as non-obvious direct contamination issues.
The FDA and Wheat
It is important that you understand what is considered “wheat” by the FDA. If you would like to look at what information the FDA gives in their guidance for compliance with the labeling law click this link: “FDA Labeling Law Compliance Guide.”
Here’s an excerpt from that link:
“The term ‘wheat’ in Section 201(qq) means any species of the genus Triticum.” That would include common wheat, durum wheat, club wheat, spelt, semolina, Einkorn, emmer, dicoccon, kamut, and triticale.
The FDA and Barley and Rye
Barley and Rye are not considered major allergens by the FDA, so they may not be listed at all if they’re present in small amounts (“trace” ingredients). The guidelines about wheat that I linked above state about Barley and Rye that
“…It depends on whether the trace ingredient is present in a significant amount and has a function in the finished food. If a substance is an incidental additive and has no function or technical effect in the finished product, then it need not be declared on the label. An incidental additive is usually present because it is an ingredient of another ingredient.”
Gluten can also “hide” on a label when it is part of a “spice” or “natural flavor” or “artificial flavor.”
“These may be declared in ingredient lists by using either specific common or usual names or by using the declarations “spices,” “flavor” or “natural flavor,” or “artificial flavor.”
One of the major problems that you will run into as a gluten-sensitive individual or as someone who must help feed gluten-sensitive individuals is a thing called cross-contamination…
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