Treatment Guide

Domino’s Pizza, Celiac Disease Experts and Defining What Is REALLY Gluten-Free

what is gluten free

Is Food That Contains Gluten Really Gluten-Free?

Domino’s Pizza recently announced it would offer gluten-free pizza for gluten sensitive customers. Domino’s made it clear that the pizzas used a gluten-free crust, but are manufactured using the same equipment as the other gluten-containing foods and are not safe for people with celiac disease.

Domino’s worked with the National Foundation for Celiac Awareness (NFCA) and received the NFCA’s new, and now suspended, “Amber Designation.” This designation was to tell people that although the ingredients are gluten-free, the product cannot claim that cross contamination does not occur. The “Amber Designation” differed from the NFCA’s existing “Green Designation,” which tells the customer that the product is tested to less than 10 parts per million of gluten. “Amber” was basically a caution sign.

What Did Gluten-Free Watchdog Organizations Say?

  • The Gluten Intolerance Group (GIG) and other organizations called for a recall of the NFCA’s “Amber Designation.”
  • The North American Society for the Study of Celiac Disease commented on Domino’s Pizza ‘Gluten-Free’ Crust Announcement as follows,

May 10, 2012 – The North American Society for the Study of Celiac Disease (NASSCD) takes note of the recent announcement by Domino’s Pizza to offer gluten-free crust.

A gluten-free diet is a serious medical treatment for people with gluten sensitivity or celiac disease. The only people who benefit from a gluten-free diet have these medical conditions.  As little as 10 mg of gluten in a day can trigger celiac disease activity.

It is a complete exploitation of the term “gluten-free” and a total disservice to proclaim that a product is gluten free when, in fact, it is not.  The NASSCD, along with other organizations within the celiac community, has been working with the U.S. Food & Drug Administration to put forth a “gluten-free” standard. That standard would require that, to qualify a food product as “gluten free,” the end product must contain less than 20 parts per million (ppm) of gluten.  Anything short of this standard would be false advertising.

The idea that products that do not meet this standard can be beneficial, in any way, is factually wrong.  Gluten exposure can be detrimental to people with celiac disease or gluten intolerance. Repeated exposure can lead to grave medical complications, not to mention a poor quality of life.

We strongly encourage Domino’s and other manufacturers to properly label and market gluten-free offerings, as so many responsible companies have done. There should be no need for disclaimers. A product is gluten free (less than 20 ppm), or it is not.  Marketing a product to be “sort-of” gluten free or “low” gluten is completely useless for those who require the strict diet.


Stefano Guandalini, M.D.
President, North American Society for the Study of Celiac Disease
Professor of Pediatrics Chief, Section of Gastroenterology
Founder and Medical Director, Celiac Disease Center
University of Chicago Comer Children’s Hospital

Dr. Guandalini notes that only foods which contain 20 parts per million (PPM) or less should be considered to be gluten-free. The Gluten Intolerance Group agrees. The National Foundation for Celiac Awareness uses 10 PPM as their standard and The Celiac Sprue Association – USA considers 5 PPM to be gluten-free. Other organizations around the world use these, and other, numbers.

There is no standard definition, even among the national organizations, international organizations and celiac disease experts as to what should constitute gluten-free.

Health Safety First – How Many Parts Per Million Is Safe?

According to Tricia Thompson, MS, RD, and editor of the Gluten-free Dietitian, a slice of 20 parts per million (PPM) gluten-free bread contains about .5 milligrams of gluten.

That may not sound like much, but how many milligrams of gluten would you eat in a day if every meal contained some 20 PPM gluten-free food?

Example of Meals in a Typical Day:

Breakfast. Eggs and Gluten-free Toast.

Lunch. Gluten-free Pizza.

Snacks. Gluten-free Crackers, Pretzels, Cookies.

Dinner. Salisbury Steak with Gravy and Gluten-free Pasta with Dessert.

What would the total amount of gluten equal? Five milligrams? Ten?

And how many of us only eat the recommended serving size?  I know I don’t.  I exercise regularly and definitely exceed the 2,000 calorie diet listed on nutrition labels.

If I ate a 20 PPM diet, I would be eating gluten every day.

So, what effect would 1 or 5 or 10 milligrams of gluten have on a person’s health if that person had celiac disease?

Dr. Carol Semrad, a researcher at the University of Chicago, found some people experienced villous atrophy (intestinal damage) when they consumed less than 10 milligrams of gluten per day.(1)

Gut symptoms are not a reliable indicator of intestinal damage. Malabsorption of nutrients occurs before villous atrophy is seen on biopsy and the majority of symptoms and disorders in celiac disease are caused by malabsorption. Neurological symptoms, heart disease, osteoporosis, reproductive disorders and a host of other symptoms can develop before evidence of intestinal damage, with or without gut symptoms.

Now, considering symptoms can change over time and malabsorption of nutrients occurs before villous atrophy on biopsy, how much 20 PPM “gluten-free” food will we need to consume before we become sick? That is, how sick will you need to get before you realize the “gluten-free” food is the cause? The answer – we don’t know.

Would people who are labeled “gluten sensitive” be ok with a 20 PPM diet? Again, the answer is – Who knows? Was the person misdiagnosed as gluten sensitive when they have celiac disease? Is their gluten sensitivity related to a neurological condition where they experience schizophrenic symptoms? Were they diagnosed with gluten sensitivity before it had progressed to celiac disease?

*Sidebar: Gluten Free Works defines gluten sensitivity as any adverse health reaction to gluten exposure in any body system or tissue. While “experts” debate its definition and try to ascribe certain symptoms to it, we consider gluten sensitivity an umbrella term. In effect, if you have gluten sensitivity, it means gluten causes health problems for you. Therefore, we believe gluten sensitivity covers celiac disease, non-celiac gluten sensitivity reactions, gluten intolerance, any innate harmful effects of gluten on cells and organs, and gluten allergy.*

And what about those people who experience anaphylaxis allergic reactions to gluten? A woman who follows our Gluten Free Works Twitter account mentioned this is her exact condition just yesterday. I spoke with another person who must carry an Epi Pen a short time ago. Their conditions are life-threatening. What will these people do when they see gluten-free labels, but not know whether the food contains gluten?

Defining What is Really Gluten-Free?

First, we must define Gluten-Free. Let’s look at the parts of the word.

Gluten. Storage proteins found in grains. We will focus on wheat, barley rye and oats.

Free. Not united with, attached to, combined with, or mixed with something else. (2)

We can thus define gluten-free as “not united with, attached to, combine with, or mixed with gluten.” In other words, NO GLUTEN.

Using our definition, a product that contains gluten, of any measure, is not gluten-free.

It is Gluten Free Works’ stance that if a product contains low amounts of gluten, it should be labeled “low gluten” or “<20 PPM Gluten” or some other designation that tells you the truth about the product, so you can use, or not, based on an informed position. It should not be labeled “gluten-free.”

Gluten Free Labeling According to Gluten Free Works:

  1. Gluten-Free. No gluten.
  2. Low Gluten. Less than 20 PPM gluten.
  3. Everything else.

Considering the potentially life-threatening consequences involved, applying a gluten-free label to products that actually contain gluten is a terrible idea, completely illogical, and an affront to common sense.

Please share this article with others!


Semrad C. “Is cross contamination an issue?” Speech by Carol Semrad, MD., Associate Professor, University of Chicago, given at Columbia University Topics in Gastroenterology, Nutrition, Celiac Disease and Beyond Seminar. Friday Sep 9, 2005.

Merriam-Webster Dictionary Online, Free definition 11 (1)

Author Information: John Libonati, Philadelphia, PA
Editor & Publisher, Recognizing Celiac Disease.
John can be reached by e-mail here.

About John Libonati

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Author Information: John Libonati, SW Florida Publisher, & The Gluten Free Works Treatment Guide.


  1. I think it would definitely help if there was a “low gluten” label as well as a “gluten-free” label. Because as we all know, just because something is labeled “gluten-free,” doesn’t mean it’s always gluten-free! It’s extremely frustrating that the term “gluten-free” is getting tossed around like a basketball. It needs to really be exactly that: gluten-free. Not sometimes gluten-free, not sort of gluten-free, not maybe gluten-free. It must be definite!!

  2. There is already something like that for dairy products-rice dream ice cream bars with a chocolate coating says it’s DF on the box, but there is milk in the ingredients. It’s just not right.

  3. Excellent article! Thank you.

  4. This was an eye opener. I will pass on the information to all my customers.

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