NASSCD Summary Statement on OatsTricia Thompson
The North American Society for the Study of Celiac Disease recently released a summary statement on oats. In the interest of full disclosure, I am a member of NASSCD. While I provided comments via a dietitian colleague on various drafts of this statement, I am not a member of the executive council and was not directly involved in the writing of this statement. The statement can be accessed HERE. Please share your thoughts.
Gluten Free Watchdog Position Statement on Oats:
- Gluten Free Watchdog supports the use of gluten-free oats by the celiac disease community that are produced under a robust gluten-free purity protocol.
- At this time we do not in general support the use of regular commodity oats that are cleaned at the “end” of production via mechanical and/or optical sorting.
- We are not necessarily opposed to the use of such oats in the future if their gluten-free status can be definitively demonstrated via a rigorous testing protocol.
For more information on oats, please click HERE.
Hi Trish –
Beth forwarded your GFW to me a few minutes ago.
Below is a response that I sent to the NASSCD, and, as we have discussed, you also may want to consider emphasizing the importance of sampling and testing as two separate components of the same exercise.
I have read your Summary Statement on Oats.
Thank you for having studied this issue and for providing an informative and tolerant position.
If there is an opportunity for clarification and/or amendment, I would like to suggest that you add four (4) words to the Summary:
In paragraph 5, second-to-last line, insert “sampling and” after the word “reliable”.
In the final summary, second-to-last line, insert “sampling and” after the word “reliable”.
This is because sampling and testing are two very different procedures, and manufacturers need to be told so. If a sample is not representative of the whole lot, testing may produce erroneous results. “Sampling” should not be lumped with “testing” even though it may appear to be obvious that the biochemical component of the exercise cannot be completed without a sample. How the sample is obtained is crucial.
Thank you, Tracy (Cream Hill Estates Ltd, Montreal)
Hi Tracy, Thanks so much for sharing your comments. Testing and sampling is discussed numerous places on Gluten Free Watchdog, including in the posts about General Mills and Quaker as well as https://www.glutenfreewatchdog.org/news/standards-for-testing-food-for-gluten-issues-that-need-addressing/
Sampling and testing is one of the reasons I am not on board with the use of Grain Millers’ oats by gluten-free manufacturers. It is very difficult if not impossible to ensure that a single 0.25 gram sample of oats is representative of the level of gluten contamination in 2,000 pounds of oats. It is hoped that Grain Millers is at least testing in duplicate based on recommendations from GFWD.
I find the statement from NASSCD very concerning. The health of the gluten-free community has been put at risk by oats labeled gluten-free that are not grown and processed under purity protocol. The issue is ever-growing with reports of illness related to these oats increasing by the day. For an organization that is dedicated to our community to take this position is reprehensible. My concerns below:
“Recently, companies have developed new processes to render regular,
commodity oats to be gluten-free. Oats used in labeled gluten-free foods may
now include mechanically/optically-sorted oats, a process which separates oats
from wheat, barley and rye by color, size and shape. These methods are used to
produce “clean” gluten-free oats.”
To use the word “clean” in reference to mechanically and optically sorted oats is very misleading. “Clean” oats are those grown under purity protocol. Commodity oats, “dirty” oats, will never be as safe for our community as those grown and processed under purity protocol. Why is it worth risking the health of the entire gluten-free community to endorse sorted oats?
” Manufacturers may use different testing methods to assess the gluten-free status
of raw ingredients, milled flour, and finished product. This information is not
This was a missed opportunity by NASSCD to set forth a clear protocol for sampling and testing of all oats labeled gluten-free, whether purity protocol or sorted commodity oats. Not to single out NASSCD, I would welcome any of the advocacy organizations in our community doing this. Mean testing is inadequate. Pulling one sample from 10,000 bushels of oats is inadequate. We need a firm protocol for sampling and testing. With so many reports of illness related to sorted oats, it is unconscionable that any organization dedicated to the gluten-free community would be so subdued in their “encouragement” to develop testing and sampling protocol.
“Patients eating oats from any source may complain of symptoms. This could be
due to one or more of several factors, including intolerance to the increase in
fiber, food intolerances (e.g., Fermentable Oligo-saccharides Di-saccharides
Mono-saccharides and Polyols (FODMAPs), or fructose), contamination with
gluten, or, rarely, the development of an immune response to oat protein, similar
to that occurring due to gluten.”
NASSCD could have addressed the thousands of illness reports related to sorted oats, many from those who have previously tolerated purity protocol gluten-free oats with no issue. An ongoing challenge is attributing the illness and reaction after consuming sorted oats on an increase in fiber intake, ancillary food intolerances, avenin intolerance. When will someone representing our community step up and acknowledge that there is a problem with sorted oats? Blaming those who have been sickened by sorted oats on a number of other possibilities not only dismisses those who have become ill, it fails to address the root of the problem.
There is a very simple answer to all of this; NASSCD sadly missed it in their statement. Further encouragement of those who grow, produce and sell purity protocol oats would benefit those who must avoid gluten by medical necessity. Farmers are willing to grow safe crops for those of us who must be gluten-free, companies are willing to sell a safe product. Instead we are focused on an attempt to remove gluten from a cheap, contaminated commodity crop instead of focusing on a product that is safe for all.
Thank you for commenting, Johnna. Testing protocols are desperately needed and not just for oats. However, NASSCD is not the group to do this. This group is composed primarily of physicians who do not have expertise in testing. That said, they could have reached out to those who do have expertise in testing to help them understand the different testing protocols followed by different manufacturers. Some of these protocols are available on GFWD. Pasted below is a post I wrote a few years ago entitled, “Standards for testing food for gluten: Issues that need addressing.” For anyone wondering, none of these issues have been resolved.
We all know that food labeled gluten-free should be tested for gluten. Some of us are familiar with the tests that should be used to assess gluten content. But most of us don’t know how tricky it actually is to test for gluten. This blog is meant to start a conversation by pointing out the lack of standards when it comes to gluten assessment.
There are a lot of “shoulds” when it comes to testing food for gluten. Unfortunately just because something “should” be done does not mean that it will be done. A few of the “shoulds” are discussed below.
Food that is labeled gluten-free should be routinely tested at a third party laboratory well-versed in assessing food for gluten. The labs I have utilized are the Food Allergy Research and Resource Program (FARRP) and Bia Diagnostics (the lab used by Gluten Free Watchdog, LLC). Products should be tested using an ELISA that has been formally validated in a multi-lab performance evaluation at levels used for regulatory purposes. My pick is the R5 ELISA (Ridascreen Gliadin R7001 by R-biopharm) with cocktail extraction (Art. No. R7006, official R5-Mendez method). In addition, samples should be tested in duplicate—two extractions.
Beyond these three choices—lab, assay/extraction, and number of extractions—what happens to samples when they arrive at a lab is largely determined by the protocols established by the specific facility. Unfortunately, these protocols are not standardized between labs.
Note to manufacturers: It is your responsibility to specify to the lab the ELISA and extraction method you want used to test your samples. If you want your samples tested in duplicate you must request this as well.
At the lab
A product may arrive at a lab in several forms, including in retail packaging as sold to the consumer or as part of a retained sample from the manufacturer (not packaged for retail). Protocols for testing samples once they arrive at the lab are among the issues that need addressing.
All commercially available lab tests come with instructions from the manufacturer. The instructions for the R7001 assay from R-biopharm illustrate how much room there is for interpretation by individual labs. The instructions state to:
“Homogenize well a sufficient amount (at least 5 g or 5 ml) of sample (grind it thoroughly to powder and mix well or mix well the solution respectively).”
From the homogenized sample, 0.25 grams are added to the cocktail solution for testing.
Note: To homogenize a sample means to evenly distribute everything in that sample, including any gluten.
The instructions from R-biopharm for the R5 ELISA raise a lot of questions which need addressing as soon as possible:
Note: This is not an R-biopharm problem per se; these instructions are used merely to make a point.
Selecting the 5 gram sample
How does the lab make sure that the 5 gram sample selected for testing is representative of the entire sample sent to the lab?
Is the entire sample mixed before the 5 gram sample is taken?
Is the 5 gram sample taken from only one part of the entire sample?
Or are different aliquots (smaller samples) taken from the bottom, top, and middle of the package?
Once the 5 gram sample is selected, how does the lab go about homogenizing the sample?
Is it ground for a set period of time?
Is it ground to a certain particle size if it is a relatively dry sample?
What about samples that are moist or have a high fat content. How are they dealt with?
Reproducibility of results
How does the lab make sure the 0.25 gram sample actually tested is representative of the 5 gram sample?
Is the 5 gram sample tested in duplicate—are two 0.25 gram extractions tested?
These are just a few of the many issues related to gluten testing that must be addressed. The Food and Drug Administration is not going to dictate to manufacturers how to go about ensuring their product is gluten-free or tell laboratories handling food samples how to go about testing product. These issues are left to the manufacturers and laboratories to determine. But due diligence is required from both laboratories and manufacturers to ensure that food labeled gluten-free is indeed gluten-free. Unfortunately, what constitutes “due diligence” has yet to be defined.