I have been waiting for the proverbial dust to settle a bit regarding the whole National Foundation for Celiac Awareness (NFCA)/Domino’s debacle hit the social media space last week.  I was off and on jury duty so was only able to follow the events briefly before heading out in the morning and then once I got home in the evening.  Unplugging for a bit actually gave me a bit of time to think about the situation and, in particular, the NFCA’s GREAT Kitchens designation.

First off, let us not forget the championing that the NFCA has done and continues to do on behalf of Celiacs to help raise awareness.  That goes without question and I think that Alice Bast and her staff have done a tremendous job.  I do however take issue with the GREAT Kitchens program credentialing system at both the Amber and Green designation-levels.  I think that the NFCA is well outside of its depth in trying to take on such a large initiative without really being able to effectively monitor or regulate the restaurants participating in their program.

I was actually invited to a virtual press conference the NFCA had to explain the new GREAT designations a couple of weeks ago.  I have to say I did find the system a bit confusing – in particular the Amber designation that seemed to not really stand for anything other than, in the words of the NFCA, a restaurant using gluten-free ingredients and has completed staff training to understand the health needs of those with gluten-related disorders. However, these restaurants cannot guarantee an environment free of cross-contamination.  This seemed to raise flags and confusion among those on the call only to be magnified when Domino’s and it’s gluten-free crust were announced to be carrying the Amber designation hit the airwaves.

I had trouble wrapping my head around the whole credentialing concept the NFCA has undertaken and tried to get a better understanding of exactly the type of commitment and training was required by those agreeing to take part.  To my surprise, and NFCA please correct me if I am wrong, to earn the highest-level of Green, participating restaurants need only have their staff take part in 90 minutes of online training modules.  Now this seemed a bit strange to me because there didn’t really seem to be any hard follow-ups or checks that would ensure that restaurants actually not only understood but were following the guidelines consistently.  I also question whether, given the complex nature of Celiac disease and the restrictions Celiac diners face, if online learning is the most effective method to use.  I mean I can watch 90 minutes of brain surgery but that doesn’t make me a surgeon.  Okay, perhaps a bit of a strong example but I don’t expect a restaurant employee to understand the intricacies of Celiac disease after 90 minutes – and quite frankly they have my health in their hands.  I was diagnosed more than ten years ago and I am still learning – and that’s with 90,000+ hours of learning.

Add the Amber designation into the mix and well, it really starts to become murky and dilute the seriousness that should be taken when it comes to restaurants understanding the needs and intricacies of safely serving Celiac guests.  So this brings us back to the Domino’s gluten-free pizza being not suitable for Celiacs. I did a double-take when I saw that but was thankful that at least they, per the NFCA product messaging, called out that it was definitely not recommended for Celiacs.  I would think that for a restaurant to earn even the Amber designation that all franchise employees would be required to take the training module.  I just find it hard to fathom that every U.S. Domino’s franchised employee took the Amber certification module (in whatever form it was given) as called out in their credentialing criteria.

In my opinion (and clearly I am not alone) the Amber designation does little to help ensure that an establishment is even remotely safe for Celiac diners.  All it does is potentially lull Celiac diners into a false sense of confused security.  It still requires us to remain diligent and ask the right questions wherever we dine – gluten-free, gluten-friendly, or otherwise.

The NFCA continues to do great work to help raise awareness for Celiac disease but has perhaps overstepped it’s capabilities in trying to act as an accrediting agency without the infrastructure needed to support and continually maintain that participating restaurants  are in fact adhering to the guidelines.  The NFCA called this out on the conference call stating they were relying on diners to report back on their experiences at credentialed restaurants as they just didn’t have the capacity to take this on themselves.

My friends over at 1 in 133 have started a petition to Ditch Amber and I encourage all Celiacs to make their voices heard by signing the petition to help the NFCA realize the error of its ways.  Cynthia Kupper, Executive Director of the Gluten Intolerant Group (GIG) wrote a tremendous open letter to Alice Bast, Executive Director at NFCA which is definitely worth reading and makes some really excellent points.  We, as a community, need to come together on this one because there is already far too much confusion out there when it comes to Celiac disease as the general public is constantly bombarded with the gluten-free FAD vs. the gluten-free reality that is our lives.

Update: May 16, 2012

I received an e-mail from the NFCA yesterday evening that provided additional detail on their GREAT Kitchens credentialing program and to be completely transparent and allow for both sides of the issue to be heard I am sharing it with my readers.

From Jennifer North, Vice President, NFCA:

We are in the process of rolling out our expanded GREAT Kitchens training program, which will be replacing the 90-minute GREAT Kitchens program that we currently have on celiaclearning.com.

We also provide on-site training and consulting (that integrates gluten-free training into a restaurant’s existing training program).

The new training will have five topical modules, PDF checklists and manual and a variety of other tools. We’ve launched our Ingredients module and the remaining modules will be released in a beta version, one by one, over the next 4-6 weeks.

In order to be eligible for the designations, restaurants completing the online training must also complete the appropriate checklists, sign an Agreement of Gluten-Free Intent (which is different language for each designation), submit a sample menu, have a Complaint Policy in place and get a passing score on the corresponding test. The modules are:

• Ingredients
• Front of House
• Back of House
• Gluten-Free Guests
• Special Diets Overview

Restaurants engaging in training outside of the online program must also complete these processes, or the equivalent.

I thank the NFCA for providing additional details regarding the program.  I also had a few additional questions regarding the additional detail they provided that I have e-mailed to the NFCA and will post the answers as soon as I receive them.  Stay tuned.  Here’s what I asked:

1. Could you please explain the method of administration and time commitment for restaurants for both the Amber and Green designations?
2. Are the on-site training and consulting services you referenced add-ons and not a required part of the formal credentialing process?
3. How is the credentialing of franchises handled? Must each employee at each location take part in the formal training process and subsequent testing and how is this tracked and certified? If not, how is this handled?
4. Unless a restaurant utilizes your in-house consulting option there is no on-site visit made to any of the restaurants applying for credentialing?
5. I know that the NFCA mentioned that it is relying on consumers to help monitor participating restaurants via several mediums. After credentialing has been awarded, is there no formal check by the NFCA to ensure that restaurants are complying? How often must a credentialed restaurant re-certify to maintain their designation?