Many food industry players want a piece of the $10.5 billion pie that is the gluten-free food sector. Claiming a slice means eliminating gluten from products in compliance with the Food and Drug Administration’s standards, but do the risks and costs of doing so outweigh the benefits for restaurants?
Gluten is a starchy protein found in grains that triggers an immune response and causes intestinal inflammation for those with celiac disease, but as gluten-free foods have become more mainstream, they’ve grown in popularity among Americans as a “healthier” food alternative.
The U.S. gluten-free retail market is being driven in part by books such as “Grain Brain” and “Wheat Belly,” which promote the idea that humans haven’t adapted to process gluten and should avoid it. In fact, 23 percent of Americans claim they are avoiding gluten due to non-celiac gluten concerns, according to The NPD Group. In addition, U.S. retail sales of gluten-free products surged 47 percent in 2013.
Naturally, gluten-free interest at restaurants is growing as well. NPD indicated it accounts for over 200 million restaurant visits in the past year.
“The number of U.S. adults who say they are cutting down on or avoiding gluten is too large for restaurant operators to ignore,” said NPD restaurant industry analyst Bonnie Riggs.
The FDA’s 2013 regulatory definition of the terms “gluten-free,” “no gluten,” “free of gluten,” or “without gluten” for sellers’ voluntary use in labeling sets the same gluten threshold for everyone in the industry.
Such labeled foods must “not contain an ingredient that is a gluten-containing grain; an ingredient that is derived from a gluten-containing grain and that has not been processed to remove gluten (e.g., wheat flour); or an ingredient that is derived from a gluten-containing grain and that has been processed to remove gluten (e.g., wheat starch), if the use of that ingredient results in the presence of 20 parts per million (ppm) or more gluten in the food (i.e., 20 milligrams or more gluten per kilogram of food); or inherently does not contain gluten; and that any unavoidable presence of gluten in the food is below 20 ppm gluten).”
As of August 2014, FDA-regulated foods and beverages labeled “gluten-free” must comply with this standard.
How do you accommodate customers seeking gluten-free options at your restaurant? Join the conversation in the comments below.
There are several legal, marketing and revenue concerns if a restaurant voluntarily elects to use the “gluten-free” label on menu items, such as:
• Time involved in sourcing verifiably gluten-free ingredients
• Capital investment in additional kitchen equipment to avoid gluten cross-contamination during cooking
• Development of recipe variations for menu items to substitute non-gluten ingredients
• Standardizing gluten-avoidance cooking procedures across multiple restaurant locations
• Creating, implementing and monitoring consistent adherence to back- and front-of-house employee training programs for gluten-free food handling protocols
• Sourcing ingredients from suppliers that are reliably gluten-free
• Education of restaurant staff and purchasing departments about the presence of gluten in foods that do not necessarily say “gluten” (e.g., malt, malt vinegar, barley, rye)
• Risk of FDA enforcement action if a labeled menu item transgresses the limit
• Damage to business reputation from loss of consumer goodwill if labeled menu items contain offending levels of gluten from such items’ own cooking process or from kitchen cross-contamination with regular menu items
• Adverse publicity and possible regulatory investigation if a customer reports adverse health effects to the Center for Food Safety and Applied Nutrition’s Adverse Event Reporting System
• Negative press and possible regulatory action if a patron submits a complaint to an FDA complaint coordinator
• Personal injury and/or consumer fraud claims by celiac sufferers who partake of definition-noncompliant menu items in reliance on their designation as “gluten-free”
• Enforcement action by local health departments
With these risks, if restaurants are going to use gluten-free labeling on their menus, they must commit to the standards for doing so, and consider carefully whether the additional costs, time and labor to offer gluten-free items justify the investment.
If a restaurant decides that the benefits of gluten-free labeling outweigh the costs, there is a menu of options to help them achieve FDA-compliant use of the voluntary “gluten-free” label, including in-house gluten educational training and third-party independent “gluten-free” certification. That menu also includes a guide the FDA issued in June for small food businesses to help them comply.
Groups offering gluten-free certification
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A non-profit group, the National Foundation for Celiac Awareness, offers GREAT Kitchens (Gluten-free Resource Education and Awareness Training), an online, self-managed and bilingual 90-minute multimedia course for chefs, foodservice managers and restaurant staff to teach gluten-free food preparation and handling.
After committing to gluten-free labeling, a restaurant could use GREAT modules to train and monitor employees in gluten mindfulness (e.g., taking orders, food storage, avoidance of cross-contamination).
A number of organizations, some of which are detailed below, also offer certification programs that enable customers to trust menu items labeled “gluten-free,” with each certification body having its own gluten level standards and certification costs:
The Gluten-Free Certification Program certifies foods that test to gluten levels at 10 ppm or less, which is more stringent than the FDA’s “gluten-free” definition. GFCP’s certification not only does end-product testing; it also examines a facility’s entire production process, including ingredient sourcing, employee training, cleaning practices, cross-contamination controls, operational management and an effective end-to-end testing plan. It requires an application fee, annual licensing fees, auditing fees and optional co-op marketing fees.
Non-profit The Gluten Intolerance Group’s certification program is a yearly process (based on ingredient review, on-site inspection and ongoing on-site product testing) that uses quality assessment and control measures throughout food production. Their certification standard is the same as GFCP’s: 10ppm or less. Product certification is valid for one year and renews annually. Costs include auditing fees for each site; inspector travel expenses; and a flat-rate licensing/certification fee based on risk, number of sites, and private labels.
MenuTrinfo and sister company Kitchens With Confidence offer gluten-free menu item certification and gluten-free online and in-person training, as well as facilities audits and a recommendations program. The menu certification program analyzes menus; sources ingredients and speaks with manufacturers about possible cross-contamination; checks for hidden sources of gluten; and creates a Certified Gluten-Free Menu with MenuTrinfo’s seal of confidence.
Celiac Support Association offers gluten-free certification through its CSA Recognition Seal and requires that foods yield less than 5 ppm gluten. CSA says its Recognition Seal represents a critical review of the company’s manufacturing practices and procedures to reduce risk for celiac and gluten sensitive customers. Like other similar organizations mentioned, its standards far exceed the FDA’s. CSA’s Recognition Seal program requirements include: ingredient review and sourcing; facility review; and product testing through the University of Nebraska Food Allergy Research and Resource Program.
The CSA Recognition Seal has a start-up fee, cost per item for testing; and annual fees to retain the seal in subsequent years, with fee amounts based on a percentage of sales of the food item bearing the seal.
NSF International offers a gluten-free certification program that uses “sensitive testing procedures, a stringent auditing process, on-site annual inspections and testing, and an independent application review process to validate the accuracy of gluten-free labels,” according to its website. NSF certification involves product and current procedures review; onsite inspection; random on-site food sample testing to 10 ppm or less gluten (including final products and raw ingredients); certification; and ongoing compliance via annual inspections.
Ultimately, whether the buy-in to gluten-free menu labeling is worth the cost to a particular restaurant or chain will depend on circumstances unique to each company, such as its business model, plans for existing and future menu offerings, revenue and food types on the menu.
To have their gluten-free cake and eat it too when it comes to capitalizing on the use of “gluten-free” menu labels, restaurants should consider all of the details that are necessary to ensure that every facet of their operations — from sourcing, to food handling, to cooking, to front-of-house staff answering diners’ questions — are providing foods compliant with the FDA’s definition of “gluten-free.”
Gluten is a small speck of grain that travels easily. Restaurants now must decide whether the profits to come from menu labels that tout entrees free of gluten outweigh the costs of controlling those specks within the limits of the FDA’s definition.
