Manufacturer Use of Regular Oats in Gluten-Free Foods: Statement from Gluten Free Watchdog

Ten years ago individuals with celiac disease were advised against eating oats. This was not because oats inherently contain gluten but because oats available commercially were highly likely to be contaminated with wheat or barley. Ten years ago we did not have oats that were specially produced and processed to be gluten-free. Today, thanks to the pioneering efforts of Cream Hill Estates, Avena Foods, Great Northern Growers/Montana Gluten-Free, and Gluten-Free Harvest specially produced and processed gluten-free oats and oat ingredients (e.g., rolled oats, steel cut oats, oat flakes, oat flour, oat bran, and oat groats) are available to gluten-free manufacturers and consumers.

Production and Processing

It is important to remember that there are two major activities required to bring gluten-free oats from field to table. The first is production, which takes place at the farm and involves seed sourcing and planting, growing, harvesting, transport and storage. The second is processing, which takes place at the mill and involves cleaning, mechanical sorting, dehulling, stabilizing against rancidity, and transforming into flakes, flour, steel-cut, whole groats, and bran for human consumption. Contamination can occur anywhere along this route. Here, for simplicity, Gluten Free Watchdog will use the term “produce” to refer to both production and processing.

Purity protocol for gluten-free oats

Cream Hill Estates was one of the first (along with Avena Foods, Great Northern Growers/Montana Gluten-Free, and Gluten-Free Harvest) to set tough standards for oats specially produced to be gluten-free. The specific purity protocol developed by Cream Hill Estates included the following:

• Using pure seed
• Growing the oats on fields that had not grown wheat, rye or barley in the crop rotation for at least 3 years
• Using dedicated and/or thoroughly cleaned equipment for seeding, harvesting, transport, and storage
• Processing the oats in a dedicated gluten-free facility
• Extensive testing of oats for gluten contamination both at the farm and the processor before and after processing

This protocol was developed out of necessity. These steps were needed to ensure a truly gluten-free oat supply for individuals with celiac disease.

Oats today

Presently, not all gluten-free manufacturers are sourcing their oats from suppliers of specially produced gluten-free oats who use ALL aspects of a purity protocol similar to the one above. Some manufacturers and suppliers may be sourcing “regular” oats from farms that have wheat or barley contamination in their fields or equipment. At least one manufacturer is using a proprietary mechanical process to remove wheat and barley from regular oats*. In addition, some suppliers MAY be using optical sorters in addition to conventional cleaning equipment to remove wheat and barley. However, it is not clear how well these sorting processes work on “regular” oats from the standpoint of ensuring a consistently reliable source of gluten-free oats. For oat producers and processors that adhere to an established purity protocol, optical sorting (and other proprietary sorting processes) could be another important step in ensuring a “safe” source of oats for the celiac disease community.

*General Mills is using a proprietary mechanical process that they claim removes wheat and barley from regular oats. These oats will be used in the gluten-free varieties of Cheerios which will be available nationally by the fall of 2015. A separate post on Cheerios is forthcoming. Update (2/12/15): This comment has been posted. Please click HERE

What is “optical sorting?”

The most sophisticated optical sorters allow grains to be sorted (and rejected) on the basis of color, size, and shape. According to a brochure on Sortex optical sorters from Buhler, “For all different varieties of oats, whether rolled, hulled, kilned, malted or flaked, the precision sorting of the SORTEX range produces safe, clean products whilst maximising yields. The SORTEX range can remove cross-contamination, foreign materials, discolouration and subtle spot defects.”

Gluten contamination in regular oats

We know from a study published in 2004 that “regular” oats available in the US market cannot be considered gluten-free. Based on testing four different lots of three brands of oats, it is clear that oat contamination varies tremendously between brands and between lots of the same brand. There also may be a great deal of variation within the same lot, especially if the lots are large. This is why testing (and a lot of testing of representative samples) is necessary.

Source: Tricia Thompson. Gluten Contamination of Commercial Oat Products in the United States. New England Journal of Medicine. 2004;351:2021-2022

Testing of gluten-free or certified gluten-free oats and oat-containing products through Gluten Free Watchdog

Gluten Free Watchdog has tested a number of gluten-free and certified gluten-free oats and oat-containing foods. To date three products containing oats have tested at or above 20 parts per million of gluten. After two of these manufacturers changed oat suppliers the products tested below 20 parts per million of gluten at the time of retesting. The third product has not yet been retested.

Note: It is the policy of Gluten Free Watchdog to retest products testing at or above 20 parts per million of gluten approximately one year after the original test date.

A tale of two countries and gluten-free oats

Gluten-free claims on oats in the US

In the United States, oats and oat-based ingredients (e.g., oat flour, etc) used in labeled gluten-free foods do NOT have to be specially produced “gluten-free oats.” In addition, the FDA has stated that the term “gluten-free” may be considered intervening material in an ingredients list because it is not part of the common or usual name for any ingredient (and therefore may be subject to misbranding regulations). As a consequence it is very difficult for consumers in the US to know whether an oat ingredient is specially produced to be gluten-free.

Gluten-free claims on oats in Canada

Health Canada released a Notice of Intent to issue a Marketing Authorization (MA) to allow gluten-free claims for specially produced oats that do NOT contain more than 20 parts per million of gluten from wheat, rye, barley, or their hybridized strains, and for foods containing these “gluten-free oats” as ingredients when sold in Canada.

Specially produced oats are defined by Health Canada as, “Oats that are grown, transported, stored, prepared and/or processed in a manner that avoids cross-contamination by wheat, barley, rye, or their hybridized strains, or oats that are processed in a way that effectively removes cross-contamination by wheat, barley, rye, or their hybridized strains.”

For a food containing oats to be labeled gluten-free in Canada:

1. The food contains no oats other than specially produced “gluten-free oats.”

2. The “gluten-free oats” are clearly identified as such in all cases where ‘oats’ are referenced, including in the list of ingredients.

The consultation period for this Marketing Authorization for labeling “gluten-free oats” in Canada recently ended. Gluten Free Watchdog will let you know when a decision has been made.

Gluten-Free Watchdog’s plea to manufacturers

We ask manufacturers to please use only specially produced gluten-free oats (as defined by Health Canada) in their labeled gluten-free products. It is the opinion of Gluten Free Watchdog that a truly gluten-free source of oats begins with the use of pure seed and follows an established purity protocol. At Gluten Free Watchdog we understand that there is promising technology with optical sorters and other proprietary mechanical sorting processes that allow oats to be processed to remove barley and wheat grain. More information is needed before we can assess whether these sorters will allow “regular” oats to be processed enough to effectively and consistently remove wheat and barley. As always, Gluten Free Watchdog will continue to monitor the issues concerning the use and labeling of gluten-free oats.

Recommendations for consumers

As a general rule, oats and oat products that are certified gluten-free by a third party certification organization are a good choice for consumers. There are some manufacturers who choose not to certify their products through a third party organization but nonetheless follow a strict purity protocol or source their oats from a supplier of certified gluten-free oats.

At Gluten Free Watchdog we understand that this information may be confusing to consumers. It is hoped that the recommendations below will help you choose your oat products wisely.

It is the recommendation of Gluten Free Watchdog that individuals with celiac disease and other gluten-related disorders choose oat products from manufacturers:

·      Who source their oats from a supplier whose growers follow a purity protocol

·      Test their product extensively

o   Oat ingredients (e.g., rolled oats, oat flour) should be tested by the supplier and the manufacturer

§  When it comes to oats there is no such thing as too much testing

§  Suppliers may provide certificates of analysis for oats testing less than 5 ppm gluten, less then 10 ppm gluten, and less than 20 ppm gluten

·      It is the opinion of Gluten Free Watchdog that the lowest level of gluten contamination should always be requested by manufacturers

·      Ask manufacturers to what level their oats are tested and choose your products accordingly based on your own comfort level

·      Are willing to answer consumer questions

o   Manufacturers who are proud of the steps they take to ensure a consistently gluten-free product will be forthcoming with information

§  At Gluten Free Watchdog we are not proponents of manufacturers withholding information from consumers because it is “proprietary”

§  Consumers with celiac disease—a serious autoimmune disease—should be provided with the information they need to make educated decisions

§  If you have any difficulties with a manufacturer please contact Gluten Free Watchdog

A huge THANK YOU to Amy Jones, MS, RD for her critical review of this article including multiple “read throughs” to help tweak the wording!!

Another huge THANK YOU to those in the oat processing industry who were consulted for input. This article could not have been written without their help.

© Copyright February 2015 by Tricia Thompson, MS, RD for Gluten Free Watchdog. All Rights Reserved.