The Gluten Algorithm

by | Aug 14, 2019

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How many times have you looked at a particular item of food you were about to eat, and thought to yourself “Is it truly gluten-free?” If you suffer from celiac disease, or gluten sensitivity, you’ve probably asked yourself this question countless times?  So how do you address that question?  Well, typically, you use what I call “The Gluten Algorithm”.  All celiacs and gluten-sensitives know the algorithm, or some variation of it.  Although it’s probable that very few have ever called it an “algorithm”.  The term “Algorithm”, for those who don’t know, is described by Wikipedia like this:

In mathematics and computer science, an algorithm is an unambiguous specification of how to solve a class of problems.

In a nutshell, an algorithm is simply a set of instructions for solving a problem.

A problem…

All too often, that’s precisely what celiacs and gluten-sensitives find themselves faced with.  When they go grocery shopping, eat out, or get together with friends and family, they face the problem of trying to figure out what they can or cannot eat.  So, in order to work out this problem, they resort to The Gluten Algorithm.  You’ll probably find it looks familiar:

Step 1: Check for the words “Gluten Free” or a gluten-free certification

If the item does not have a “Gluten-Free” pronouncement on the label, skip this step and move on to step 2.  If it does, you’re good to eat it right?

Hmmm… well, it’s complicated…

NEWS FLASH: Some gluten-free-labeled foods are not 100% gluten-free

It’s true.  The FDA says that if a product is labeled gluten-free, it has to adhere to the “20 ppm rule”.  This rule states that a food that is labeled gluten-free cannot have more than 20 parts gluten per every million parts of other stuff.  Realistically, 20 ppm is a tiny amount of gluten.  But it goes without saying that 20 ppm, is actually not 100% gluten-free.  Nonetheless, celiac disease research has shown that 20 ppm is probably the right threshold.  Studies have shown that the majority of celiacs seem to be able to tolerate this level without adverse effects.

The Balancing Act

“But, but, but… wait!”  You say?  Why do we need to allow any gluten?  Can’t “gluten-free” just mean “gluten-free?”

When it comes to eliminating gluten from manufactured foods, there is somewhat of a delicate balance to maintain. On the one hand, gluten is very pervasive in our food supply chain. In some circumstances, it’s nearly impossible to eliminate it entirely.  On the other hand, manufacturers need to keep gluten out so people don’t get sick. So, where is the balance?

If you set the allowable gluten threshold too low, many manufacturers will find it impossible to comply.  Those manufacturers who do make the effort to comply will likely have to raise prices to cover the additional costs involved in ensuring that less gluten gets into their products.  When it comes right down to it, the result would be fewer gluten-free food choices and higher prices.  So, in the end, the balance appears to be 20 ppm. It’s low enough that the majority of gluten-sensitive people shouldn’t be harmed (based on scientific research). Yet it’s high enough that many manufacturers can reasonably meet the requirement.

So, if 20 ppm is the best option all around, does that mean it works for everyone?  Of course not.  One-size-fits-all solutions almost never work for everybody.  Although research indicates that most people are okay with 20 ppm, it’s virtually certain that some are not.  If you routinely react to foods that are labeled gluten-free, you may be one of them.  In such a case it’s probably advisable to stick to a diet of naturally gluten-free food, and very few (if any) processed foods.

Gluten-free labeling is voluntary

Also, it’s important to keep in mind that gluten-free product labeling is voluntary.  In other words, it’s up to the manufacturer to decide whether to label a product gluten-free or not.  If a product is labeled gluten-free, the FDA does not require any tests to verify that it meets the 20 ppm rule.  By law, the manufacturer has to comply with the rule, but it’s entirely possible that a company could label a product gluten-free when it has more than 20 ppm.

Now that’s not to say that the law has no teeth.  The FDA can, and does, impose consequences on companies that aren’t in compliance.  But it’s not like the FDA is out in the field with gluten test kits in hand, performing random inspections at manufacturing facilities.  If evidence of a potential violation comes to their attention, they will step in and investigate, but otherwise, they more or less leave it up to the industry to police itself.  I’m sure that most companies would take care to be in compliance with the 20 ppm rule before they slap a gluten-free label on a product.  But there have been cases documented where some products have been out of compliance.

Gluten-Free Certification

In an effort to provide better assurance that food manufacturers have done their due diligence, there are various certifying organizations that can certify a product gluten-free to various levels.  You have likely seen the certification logos (shown below) on some gluten-free food products.  All of these organizations set gluten-free standards to which manufacturers must adhere in order for their products to carry the logo.  Of the four standard gluten-free certifying organizations in the United States, two of them (Beyond Celiac GFCP and NSF) stick with the 20 ppm rule.  One (Gluten Intolerance Group GFCO) lowers the threshold to 10 ppm.  And the fourth (NCA) lowers it to 5 ppm.  Most of these organizations require periodic re-testing of products and/or facilities in order to keep the certification.  Generally speaking, these certifications are a step beyond what the FDA requires.  As such, they probably represent your best chance of getting a product that lives up to its billing as gluten-free.

It’s important to take care, however, when looking for certifications.  Some manufacturers put gluten-free logos on their products that could easily be mistaken for certifications.  Some of them even look somewhat similar to valid certification logos.  However, in reality, they usually don’t represent any certifying organization, or any level of compliance, aside from the FDA’s 20 ppm rule.  In these cases, there is no third party backing up their claim, although the logo may make it appear that way.  The following logos are the generally accepted certifying organizations in the United States as of this writing.

Gluten-Free Certifying Orgainizations


Gluten Free Certification Organization Logo
Gluten Free Certification Program Logo
NSF Gluten Free Certification Logo
National Celiac Association Gluten-Free Recognition Seal


You should investigate any other logo, including those claiming to be from another certifying organization, prior to accepting that the product has been certified gluten-free.

So, back to the algorithm.  If a product has a gluten-free certification, that’s probably about the best assurance you’ll get that it won’t make you sick.  If there’s no certification, but it’s labeled gluten-free, that’s probably your next best bet.  So in these two cases, are you safe to go ahead and eat it?

Well… in a perfect world, I would say yes.  Unfortunately, there have been instances where manufacturers have messed up.  Sometimes, it’s pretty egregious.  There have even been documented cases, where a product is labeled gluten-free, yet it lists wheat or malt as an ingredient!  I think that in most of these situations, these are oversights on the part of the manufacturer, and not done intentionally.  But it goes without saying that you shouldn’t implicitly trust a product that has the gluten-free label.  So, the safe bet would be to proceed to step 2 of the algorithm.

Step 2: Check the Food Allergen Labeling

The next step is to check the Food Allergen Labeling.  Food Allergen Labeling was part of the US Consumer Protection Act of 2004, which took effect in 2006.  This law requires food manufacturers to label their products accordingly if they contain any of eight designated food allergens. Supposedly these eight allergens account for 90% of all food allergies.

Unfortunately, food allergen labeling is only moderately helpful to those requiring gluten-free food.  Why?  Because gluten is not one of those eight food allergens. Instead, wheat is the item that made the list. While wheat is generally the most common source of gluten, it’s not the only source. Gluten is also present in rye and barley, not to mention a handful of other grains and wheat derivatives.  So, in a nutshell, if the Food Allergen Labeling lists wheat, stop right now and stay away from that product.  Otherwise, you’re not done yet—proceed to step 3.

Step 3: Check the ingredient list for anything that contains gluten

Some gluten-containing ingredients are obvious.  For example, if the ingredient label lists wheat, barley, or rye, the product is obviously not gluten-free.  Some other gluten-laden ingredients are obvious if you’ve educated yourself a bit with regard to gluten sources on ingredient labels.  For example, if it lists malt, well, that’s made from Barley, so that’s out.

Some ingredients may be inconclusive, such as “modified food starch”.  That stuff can be made from wheat, but it’s also often made from corn.  And some ingredients, at first glance, may seem likely to contain gluten, but they really don’t.  I’m talking about things like “maltodextrin” or “monosodium glutamate”.  Maltodextrin does not contain malt, nor does monosodium glutamate contain gluten.

In the end, if you find a gluten-containing item in the ingredient list, then obviously, you take a pass on that product.  If you don’t find any obvious gluten sources, you may still find yourself unsure about some non-obvious ingredients.  This is especially common with those ingredients that require a degree in chemistry to even pronounce (Butylated Hydroxyanisole, anyone?) So if you’re still unsure after reading the ingredient label then continue with step 4.  Otherwise, if you’re fairly confident that the product is gluten-free, proceed to step 5.

Step 4: Visit the manufacturer’s website and/or ask Google

Okay, so you’ve made it to step 4 of the algorithm.  You’ve likely decided that the food is possibly/probably/maybe gluten-free.  But you’re just not 100% certain.  So now what?  Well, at this point, you resort to Google, because we all know that Google knows everything and is never wrong…  right????  So, you google for something like “brand X frozen pepperoni pizza gluten-free”.  Google will probably point you to Brand X’s website.  And perhaps after digging around for a bit, you’ll find a definitive “yes” or “no” on the product’s gluten-free status. Alternatively, if you can find Brand X’s customer service phone number or e-mail address, you might be able to get some answers that way.

If you got an answer using one of these methods, and you’re satisfied with it, you can proceed to step 6.  If you got an answer, but you’re still unsure, proceed now to step 5.  But what if the manufacturer wasn’t any help?  In that case, you’ll probably wind up wading through Google’s search results for a while, trying to find an answer that 1) seems definitive and reliable, and 2) was written sometime in recent history.  It’s common to find online forum posts that address the food in question.  But frequently those posts are from years prior.  Having a recent answer is important since manufacturers can change ingredients occasionally.  In short, maybe a product that used to be gluten-free isn’t anymore.

So if you’ve found that definitive answer and you’re happy with it, proceed to step 6.  Otherwise, continue with step 5.

Step 5: Test the food yourself (if you can)

Now this is a cool, relatively new development!  With the advent of a device called the Nima Sensor, you can now test your food for the presence of gluten.  Back when my wife was first diagnosed with celiac disease, I think I’d have given my right arm for one of these!  So, if you happen to have a Nima Sensor, it’s a great addition to your personal gluten algorithm.  However, it’s not without its shortcomings.

Limitation #1: Cost

First of all, you may find that the Nima is a bit on the spendy side.  The sensor itself costs $289 for a starter kit.  Once you have the sensor, each test you do requires a capsule (The $289 starter kit mentioned previously includes 12 capsules).  The capsule is basically just a small bottle that slides into the Nima Sensor.  You open the bottle cap, drop a pea-size quantity of food into it, screw the lid on, and pop it in the Nima Sensor.  After a few minutes, the Sensor gives you an indication whether the food sample was gluten-free or not.

The capsules are single-use, and cost $59 for a 12-pack (just under $5 each).  Long story short, the cost of the capsules can add up pretty quickly if you do a lot of tests.  So, depending on your personal economic situation, it may or may not be something you can easily incorporate into your own gluten algorithm on a regular basis.

Limitation #2: Accuracy (maybe)

Aside from cost, another potential limitation with the Nima Sensor is due to the fact that it only tests a tiny bit of food.  Nima calls it a “pea-sized” portion.  If the food you’re testing contains a small amount of gluten, it’s possible that the sample you put into the capsule might not contain any.  In this case, the Nima Sensor will say the sample is gluten-free.  But in reality there might be gluten elsewhere in part of the food you didn’t test.

In addition to the issue of test sample size, the Nima’s accuracy has been called into question by some.  In short, the Nima Sensor is not 100% accurate.  Nima states that the device is accurate to above 96.9% for foods with gluten content of 20 ppm or above, according to a peer-reviewed study that they published.

The long and the short of it is that the Nima Sensor can give both false positive (saying there’s gluten in a sample that’s actually gluten-free) and false negative results (saying a sample is gluten-free when it really isn’t).  Nima readily admits to this, and says that the false readings are rare, and sometimes may be due to factors external to the device.  They are also forthright in saying that you shouldn’t consider the Nima as a definitive testing tool.  Rather, it’s intended to be another tool in the toolbox.  Or as I would say, it’s another step in the algorithm.  The point is that you use it, along with other tools, to help inform your decisions.  You don’t use it exclusively to make your decisions.  And to be fair, no gluten test is 100% accurate.

The Nima Sensor is a wonderful tool, and it can provide added peace-of-mind.  In most cases, I have found that it generally works as advertised.  So, while it has received a bad rap from a few corners of the gluten-free community, my feeling is this is largely undeserved.  There are many Nima users out there who have found great value in this device.  Some of them describe it in life-changing terms.

So, coming back to the algorithm, if you have a Nima Sensor, you need to decide if the benefits of testing the food outweigh the cost involved.  Either way, proceed now to step 6.

Step 6: Go ahead… if you’re sure…

If you made it this far, and you’ve decided that the product is gluten-free, and you’re absolutely certain that you’ve covered all your bases, then congratulations!  You’re ready to go.  However, if by this point you’re still uncertain as to the gluten-free status of the product, you have a decision to make.  Do you simply throw caution to the wind and eat it anyway, believing that you did your due diligence and what you don’t know won’t hurt you?  If you’re gluten-free by choice—or in other words, if you don’t suffer from celiac disease, and you’re not gluten-sensitive—then maybe that’s a viable option.  Otherwise, taking a pass on that food product is really the only assuredly safe choice you have.

Obviously, The Gluten Algorithm leaves a lot to be desired.  It is incapable, in many cases, of yielding either reliable or accurate results.  Of course, this is not due to the fault of the algorithm itself.  Rather, the information provided on food labels and/or other sources is often not complete enough to provide accurate results.  Nonetheless, it’s really the only practical option available in many cases.  Having a Nima Sensor, as mentioned in step 5, can be helpful to provide some added peace of mind.  But it’s not a panacea, and many people simply aren’t in a position where they can realistically test everything they’re about to eat.

The case for the naturally gluten-free diet

Now, I know that the purists out there are going to object, saying that there is another option.  Yes, there is.  And in many ways, it’s honestly probably the best (healthiest) option in general: Eating a diet of naturally gluten-free, fresh food, free of any sort of processing, hopefully 100% organic, and non-GMO.  If it’s an animal-based product, make sure it was grass-fed, free-range, humanely raised, not treated with hormones or antibiotics, etc. etc. etc. If you can make that solution work for you, more power to you!  Like I said, I do believe it’s probably the healthiest option for everyone; not just gluten-sensitives.

The problem with this solution, however, is that it’s difficult for many people.  Some people just don’t have the time or energy required to make every meal of every day entirely from scratch.  Some people have difficulty with the costs involved.  No ifs, ands, or buts about it, all-natural, organic food is extraordinarily expensive.  This is particularly true for those on a tight budget or those with a lot of mouths to feed. Some people have trouble with the availability of such food options in their area.  In my family’s case, living in a very rural area, we find this to be particularly challenging.

Traveling also presents challenges if you don’t have easy access to facilities for food preparation.

In short, for many people, the exclusively all-natural food option simply isn’t an option.

Back to the problem

So, people find themselves resorting back to asking the algorithm its opinion on their food choices.  Over… and over… and over… they ask the algorithm if they can eat this or that. Sometimes the algorithm replies “yes.”  Sometimes it replies “no.”,  but in many instances, it just results in a definite “maybe.”  If you’ve used the algorithm before, you can probably relate when I say it’s sometimes no better than asking a magic 8-ball.

Another opinion

At “Is It Truly Gluten Free?”, my goal is to independently test foods that are labeled gluten-free, as well as foods whose gluten status is inconclusive.  These tests are performed in a controlled environment where I take steps to avoid erroneous results. I do everything I reasonably can to eliminate cross-contamination during the testing process.  I also try to ensure that test samples are properly homogenized (mixed well) so that any gluten is well-distributed throughout the sample.  This helps to increase the odds that if there is gluten in the food, it will make it into the test sample.

Now obviously, I can’t say with absolute certainty that my tests are 100% accurate either.  For this reason I believe that the key to any testing strategy is repeated testing.  Even the very reliable (and expensive) ELISA testing is less than helpful if you only perform the test once.  One or two years down the road, the gluten content of any product may change.  If that happens, that one-time test is no longer accurate.   I believe that, as more tests are conducted, the confidence level in the combined results over time rises.  Therefore, I intend to perform multiple tests, over time, on each product.  My hope is that repeated testing might allow us to catch products that are inconsistent in their gluten content.

The principle is this: that just because one bag of potato chips tests gluten-free, that does not necessarily mean the next one will.  Hopefully, over time, and with multiple tests per product, we will get a better idea of just how consistently gluten-free each product is.  By so doing, I hope I can provide you with a relatively reliable second opinion.

Despite best efforts and intentions, there are no guarantees

It should be noted, however, that the gluten-free diet is, to an extent, prone to error, due to the pervasiveness of gluten in our environment.  Even if we test ten bags of chips, and find them all to be gluten-free, it doesn’t mean that the eleventh won’t have some gluten.  By the same token, it’s possible that all ten bags of chips may have had some gluten. That gluten simply may not have wound up in our test sample.

As such, I am providing all of these test results with the simple caveat that your mileage may vary.  I cannot guarantee that the gluten-free status of the products I buy and test will be the same as those that you buy.  The results of these gluten tests are being provided to you solely for informational purposes.  I strongly recommend that you not base your dietary choices exclusively on the results of these tests.  Rather, I encourage you to make your diet and lifestyle decisions in accordance with your individual needs, circumstances, and research; and always in consultation with your doctor.


I suppose that this site, its accompanying YouTube Channel, and its other social media presences really amount to simply one more step in the Gluten Algorithm.  But my hope is to make it a step that helps you to arrive at better conclusions.  Conclusions that are hopefully more accurate; conclusions that hopefully provide you with a greater sense of peace about your food choices.  Let’s face it; it’s a big enough challenge just to be gluten-free.  Adding inaccurate information to that challenge, along with food labeling that sometimes hinders, rather than helps, only piles on the anxiety.  Nobody needs that.  At “Is It Truly Gluten Free?”, I hope to be able to provide you with information that will help you to achieve, and maintain, a better quality of life.


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