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On 27 September 1996 Ted Wolff wrote:
 
>I do not know, but for some reason i am too slow in my brain to understand
>why something that contains gluten of 20mg/kg or 40mg/kg is called free of
>gluten.  For my understanding it would be wise to call something free if it
>actually contains none of the product that it is associated with.
 
Nice idea, Ted, but I am afraid (no, I am quite sure about it!) that there
would be only a few GF food items left (perhaps not more than 10% of the GF
products currently on the market) if food law enforcement practitioners
would take zero for a limit.
 
What's the guarantee that the food you're selling is absolute glutenfree?  Do
you have certificates?  Do they state "absolute zero" ?  I have met many
producers oe rwrailers who were convinced that their food was zero gluten
while in reality it did contain hundreds of mg/kg gluten.
 
You can't be sure about gluten contamination unless you have incorporated
checks for it in your HACCP plan. And if you do so you might need to
control the input of raw materials as well as your end products even if you
only use rice, millet, buckwheat or corn. Remember that the chance of GF
cereals becoming contaminated with wheat during storage, milling and
packaging is far from theoretical. It is just not sufficient to say that
your products are "zero gluten". You have to prove it!
 
F.W. Janssen,  Zutphen  The Netherlands