A House Divided … and Reunited?

In recent weeks you’ve almost certainly heard about what many have been calling the Domino’s Debacle. If you’ve missed any of the crucial details, here’s the need to know: Domino’s launched a nationally-available gluten-free pizza crust. There was just one big problem—while the crust was made with gluten-free ingredients, Domino’s took no precautions to prevent cross-contamination. The result was that the gluten-free pizza came with an important and prominent disclaimer, including in a video with Domino’s CEO: it wasn’t safe for those with celiac disease and other sensitive forms of gluten intolerance. Which, for many, then begged the question: then who is the pizza for?

Things got even more complicated when the National Foundation for Celiac Awareness got involved. They had just launched their revised and expanded GREAT Kitchens program, with more extensive training and education modules for restaurant staff and which now included a two-tiered certification. Those restaurants that underwent training, had their ingredients verified as gluten-free, and had their cross-contamination controls approved could earn a green rating. If a restaurant did the training and ingredient verification, but couldn’t (or didn’t) address cross-contamination, they’d earn an amber rating. Domino’s earned the amber rating.

The gluten-free community, by and large, was up in arms. The NFCA had meant for the amber rating to help consumers by drawing distinctions between restaurants that did gluten-free the “right” way and those that perhaps fell short, where more caution was required if opting to dine there. Instead, it seemed to create confusion, frustration, and downright anger. Some effectively accused the NFCA of selling out, or overreaching its capacity, or otherwise failing to advocate on behalf of its core constituency: those with celiac disease.

While many were quick to note that this misstep did not diminish the previous excellent work of the NFCA, nor the excellent work it continues to do in other areas, the gluten-free community mobilized quickly and ferociously to voice their disapproval and call for change. “Ditch Amber” became their battle cry. Cynthia Kupper, executive director of the Gluten Intolerance Group, wrote a pointed open letter to NFCA executive director Alice Bast calling for the abandonment of the amber designation. The folks at 1 in 133 organized a petition that quickly amassed more than 3,000 signatures. For one week, social media and the blogging world were ablaze with commentary and the #DitchAmber hashtag.

Meanwhile, the controversy bubbled up enough that the mainstream media began covering it in stories. The major celiac research centers (Chicago, Maryland, Beth Israel, and eventually, Columbia) weighed in, as did other national and regional celiac and gluten-free organizations. (Click here for a great summary over at Gluten-Free Fun.)

And then, at the end of the last week, NFCA announced that it was suspending the amber GREAT Kitchens certification while it re-evaluated the designation. There was much rejoicing, cries of victory, and at least one instance where a blogger friend of mine was moved to write a song about the whole thing. NFCA had listened to a chorus of voices and made the only move realistically left on the chess board.

For my own part, I’ve been sitting on the sidelines … until now. Others have done a great job covering the events. I didn’t want to add a redundant voice to an already saturated landscape of blogging. I wanted to wait to see how NFCA would respond, and how things would shake out, before I weighed in. I only wanted to enter the fray if I felt I had something new, meaningful, and constructive to offer, and I hope (and believe) that I do, which is why I’m writing today.

First, a disclaimer: As many of your know, I’m one of the NFCA’s Athletes for Awareness. It’s a volunteer position, but it’s an affiliation none the less. I’m also in the midst of my 3rd Annual Gluten-Free Ultramarathon Challenge, which raises money for the NFCA, because I believe in the good work they do on behalf of the entire gluten-free community. However, I do not write this blog post on behalf of the NFCA. I write this blog post independently, without their consultation, and it expresses my personal opinions. Enough said about that.

What I do want to say more about are several points that I feel either a) haven’t been addressed thus far in the dialogue, or b) have been said too quietly or by too few people. Here we go…

GIG and NFCA

I want to believe that GIG, NFCA, and the other major advocacy groups cooperate and play nice together for the greater good of the gluten-free community. And for the most part, they do. But it’s also undeniable that to a certain extent they are also direct competitors. They compete for your donations. They compete for sponsors. And when it comes to GIG and NFCA, they also compete directly with their programs.

Both groups offer gluten-free product certifications and gluten-free restaurant certifications. For products, GIG has its highly-respected Gluten-Free Certification Organization, while NFCA has its gluten-free certification in partnership with Quality Assurance International. For restaurants, NFCA has the GREAT Kitchens program (the subject of so much scrutiny recently), while GIG has the Gluten-Free Restaurant Awareness Program. (Notably, GIG’s GFRAP also is a tiered certification program with multiple levels, and all approved restaurants get to use the same logo, regardless of level of certification.)

It’s unlikely that a product or restaurant would pursue certifications from both organizations. They’re going to choose one. And so while GIG executive director Cynthia Kupper’s open letter to the NFCA included some important and cogent points, it’s also important to keep in mind that her letter also serves as a de facto “defense” of GIG’s GFRAP.

Transparency and Disclosure

One thing we, the gluten-free community, have been asking for—especially in the context of the FDA’s forthcoming gluten-free labeling standard—is transparency and disclosure. We want companies to tell us what’s in our food, and we want them to be open and honest about their manufacturing processes, especially when a product isn’t made in a dedicated gluten-free or allergen-free facility and there’s a chance for cross-contamination. We expect the same of restaurants.

Domino’s has given us just that—it’s the openness we’ve been asking for—and now we’re taking them over the coals for it. It pains me to say it, but we should perhaps be giving Domino’s a pat on the back. Do I think they should have (and could have) done more to address cross-contamination issues and offer a pizza that more of us in the gluten-free community could enjoy? Absolutely. Do I think Domino’s offers its disclaimer partly at the counsel of its lawyers to address issues of liability? Sure.

But let’s also give a little credit where a little credit is due.

By the way, if you’re looking for some stellar of examples of pizzerias that really seem to get how to do gluten-free well, check out Naked Pizza, Pizza Bistro in NY, and Garlic Jim’s in CA, for just three examples. (But don’t get me started on Chuck E. Cheese’s frozen gluten-free pizza in a bag. There are pros and cons to that one. I’ll save that for another blog post…)

Amber Alert

Based on the loud reaction in the gluten-free blogging and social media world, it seems people were pretty united in denouncing NFCA’s amber designation. I think I’m one of the only people who didn’t consider it a total bust. In my opinion, the amber designation has the potential for real value to the gluten-free community, but it needs to be re-oriented and re-branded … not as a certification or endorsement, but as an advisory or warning.

As many of us have seen, restaurants are increasingly offering gluten-free menus. Some do so with a genuine interest in serving the needs of the gluten intolerant community, and are diligent in addressing kitchen practices and minimizing the potential for cross-contamination. But others are looking to capitalize on the fad/trend component of the gluten-free diet these days, and may be offering up a superficial gluten-free menu that lacks the kitchen controls to make ordering such food safe for celiacs and others with sensitivities to gluten.

The amber designation could be re-aligned to serve as an Amber Alert, a warning to take caution. This re-positioning achieves a double victory: 1) it educates consumers about potentially unsafe restaurants, and 2) it encourages restaurants to step up their game and earn the NFCA’s green certification, because nobody wants to be branded with an amber alert.

There are, of course, challenges to implementation such an approach, but it’s one worth considering. There’s value in telling diners where they can eat (via the green certification). There’s also potential value in warning them where they shouldn’t eat (via an amber alert designation).

Sympathy for the NFCA’s Circumstance

I must say that I feel for the NFCA and the tough situation the organization has found itself in. I was in a similar situation myself a while back.

In what feels like another life, I once upon a time worked as an ecologist—and later, as a program manager—for an environmental non-profit. We managed a number of tiered environmental certification programs (you could join the program, complete an environmental plan, or get fully certified). Certified properties could use a logo and designation in their marketing. One property type that we worked with—often surprising people—was golf courses, traditionally considered bad actors when it comes to the environment. Some joined the program and earned certification for altruistic reasons; they genuinely wanted to improve their environmental management and they did. But others merely joined the program and did a minimum of effort, arguably to benefit from the PR value. Our idea was to help improve their management practices (a noble cause for which we achieved great results). But some of our peer organizations in the environmental community cried foul, accusing us of working with the enemy. It strikes me that NFCA’s recent time in the hot seat is quite similar.

Here’s the real challenge: it was true of the work I did with the environmental group, and it’s true of the NFCA’s re-vamped GREAT Kitchens program. The certification is really addressing two different audiences … the company and the consumer. On the one hand, you want to educate the company and help to improve their practices, and you want to reward progress made. On the other hand, you want to clearly communicate with the consumer via certification logos, designations, and what it all means. It can be difficult to do both simultaneously. There’s a fine line to walk, and sometimes you have to pick an allegiance to the greater good. But is that greater good to educate the companies, or advocate on behalf of the consumer?

Moving Forward

As some astute bloggers have pointed out, somewhere in the foreseeable future, much of this discussion will become a moot point. Voluntary programs such as NFCA’s and GIG’s exist to fill a vacuum. In the absence of a gluten-free standard in the U.S., someone has to step up and help to define it, so that consumers know what they’re getting. This applies to restaurants as much as to products you buy in the supermarket.

And once the FDA’s gluten-free standard becomes official, it will apply to restaurants as well. When a restaurant makes a health claim about its food—and “gluten-free” qualifies as such a claim—that restaurant becomes beholden to the FDA standards for the claim.

This begs an obvious question: if this whole discussion will eventually become a moot point, what will happen to voluntary certification programs such as NFCA’s and GIG’s? From where I sit, one of three things will likely happen:

1. The NFCA, GIG, and others will phase out or abandon their programs, since the FDA’s gluten-free standard will cover things. I don’t believe this will happen.
2. The NFCA, GIG, and others will align their restaurant programs to match the forthcoming FDA standards, and will in essence become third-party verifiers to confirm restaurants’ compliance with the regulations. This is a possibility. (And the FDA could certainly use the assistance, since they lack the capacity to routinely monitor compliance at all restaurants offering gluten-free items on the menu.)
3. The NFCA, GIG, and others will bolster their restaurant programs to exceed basic FDA gluten-free regulations, to help restaurants go above and beyond and distinguish themselves as superior actors. I think this is the most likely scenario.

I don’t have a crystal ball to foresee what the future actually holds, but I can say this: Remember that, while our tactics and approaches may differ, at the end of the day we’re all on the same team, motivated largely by altruism and shared circumstances, values, and needs. We all live under the very big tent that is the gluten-free community. For a brief period, we were a house divided. But we’ve reunited. Let’s try to keep it that way.

–Pete