The gluten-free oats situation & why it is such a sticky wicket
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 purity protocols followed by Avena Foods, GF Harvest, and Montana Gluten-Free see https://www.glutenfreewatchdog.org/news/oats-produced-under-a-gluten-free-purity-protocol-listing-of-suppliers-and-manufacturers/
- In the gluten-free community we know that General Mills and Quaker are mechanically and optically sorting commodity oats to be “gluten-free.”
- These oats are NOT produced following a gluten-free purity protocol.
- We know that Gluten-free Cheerios and Gluten-free Quaker Oatmeal contain sorted oats.
- Despite what we may think about General Mills and Quaker using sorted oats, both manufacturers have been transparent with the gluten-free consumer about the use of such oats in gluten-free products.
- What is not generally known is that Grain Millers has been mechanically sorting oats since 2012 and selling these oats to gluten-free manufacturers.
- La Crosse Milling is also mechanically sorting oats and selling these oats to gluten-free manufacturers.
- Oats not grown under a gluten-free purity protocol are in our gluten-free food supply and have been for many years.
- The labeling claims “gluten-free oats” or “certified gluten-free oats” or a certification symbol* on product packaging do not necessarily mean the oats are produced under a purity protocol.
- It is very difficult–if not impossible–for a consumer to know whether the oats used in a product are grown under a gluten-free purity protocol or mechanically sorted.
*See the statements below from GFCO and GFCP.
Manufacturers and Suppliers using mechanically or optically sorted oats:
- General Mills, Quaker Oats, Grain Millers, and La Crosse Milling are all using some form of mechanical and/or optical sorting to “clean” commodity oats to be “gluten-free.”
- General Mills is currently using sorted gluten-free oats in gluten-free Cheerios.
- Quaker is currently using sorted gluten-free oats in gluten-free oatmeal.
- Grain Millers and La Crosse Milling are currently selling to a variety of gluten-free manufacturers.
- Neither General Mills nor Quaker currently certifies their gluten-free oats via third party certification.
- Grain Millers certifies gluten-free oats through an entity called NSF International (GFWD is not familiar with this certification program).
- La Crosse Milling was asked about third party certification via email but has not yet responded to our query.
- Update: On November 2, 2015 Nature’s Path wrote the following to me in an email, “This is to confirm that Natures Path Foods has purchased the Country Choice brand name from Grain Millers. Grain Millers continue to be the supplier of our gluten free oats.”
- Update: On November 12, 2015 Bob’s Red Mill wrote the following to me in an email (see comment section for complete statement): “Our suppliers are innovative in controlling the presence of gluten by either avoiding crop rotation with gluten containing grains or using optical sorting technology to remove grain containing gluten.”
Certification of oats NOT grown under a gluten-free purity protocol
- The Gluten Free Certification Organization was contacted via email and asked the following two questions:
- “Will GFCO knowingly certify a manufacturer of single ingredient oat products if they are sourcing oats from a supplier who does not follow a gluten-free purity protocol (starting with pure gluten-free seed)?”
- “Will GFCO knowingly certify a manufacturer of multi-ingredient products containing oats if they are sourcing oats from a supplier who does not follow a gluten-free purity protocol?”
- We were referred to a Q&A on GFCO’s website* which states the following: (https://www.gluten.org/three-things-about-gfco/):
- Question: What is GFCO’s position on certifying products that use oats?
- Answer: We consider all oats not endorsed by GFCO as a high risk ingredient and that, when non- GFCO certified oats are used by a manufacturer, these products must meet built-in additional requirements for certification.”
- *Gluten Free Watchdog is aware of a manufacturer and wholesale supplier of single ingredient oat products (e.g., rolled oats and oat flour) with GFCO certification sourcing oats from Grain Millers. These single ingredient oat products are certified by GFCO.
- The Gluten Free Certification Program (endorsed by the National Foundation for Celiac Awareness in the US and the Canadian Celiac Association in Canada) was contacted and asked the following question:
- “Does GFCP have a position on the certification of single and multi-ingredient oat products containing oats that have not been produced under a gluten-free purity protocol?”
- GFCP provided an extensive response* that is included in its entirety at the end of this post.
- Excerpt: “The GFCP requires that all incoming ingredients be verifiably gluten-free as they enter any gluten-free management system which includes oats. This means that any incoming oats need to be verifiable to be “gluten-free oats” and considered as a high risk for gluten contamination. Facilities should clearly set their supplier specifications such the “gluten-free oats” have been grown, transported, stored, prepared and/or managed in a manner that avoids cross-contamination by wheat, barley, rye, or their hybridized strains to consistently achieve the food safety outcome of <20 ppm for gluten. The supplier should have written, standard operating procedures (SOP’s) in place which can be assessed and/or measured by the facility management or their agent to verify that the supplier conforms to those specifications. Those SOP’s would include but not be limited to seed purity, field management, cleaning harvesting equipment, storage management and transportation or the equivalent. This is not intended to be an onerous task but does require evidence of due diligence to achieve <20 ppm.”
- *Gluten Free Watchdog is aware of only one manufacturer in Canada producing oat-based products certified by GFCP. This manufacturer was contacted via phone and email and asked about the source of the oats used in their gluten-free products. The manufacturer has yet to respond to our query.
- UPDATE December 4, 2015: Holy Crap Oats has not responded to our query regarding the source of their oats. GFWD also reached out to their certifying body (GFCP). GFCP did not provide a direct answer to our question about the source of oats used by Holy Crap. They stated the following in email correspondence, “… We strongly support that on-farm intervention as we described be instituted as an efficient way to ensure success of achieving <20 ppm or gluten-free status for oats. Doing this, allows the source to seamlessly plug into the gluten-free management system at the manufacturing level which is then verified and validated as efficacious. However, without this, the manufacturer needs to fill the information and confidence gap using the appropriate testing methods at a frequency which reflects the risk prior to accepting the gluten-free oats into their production stream…” Until notified otherwise by either Holy Crap or GFCP, GFWD is making the assumption that the oats used in Holy Crap oat cereals are NOT purity protocol oats.
- Mechanical sorting of commodity oats to be gluten-free is likely here to stay.
- Ideally the safety and gluten content of mechanically sorted oats will be determined via independent peer-reviewed scientific studies.
- Commodity oats are highly likely to be contaminated with wheat and barley.
- Regular oats from two manufacturers currently using mechanical sorting to clean oats–Quaker and Grain Millers*–were tested in 2004. Click on table for results.
*The house brand of Grain Millers was Country Choice. Country Choice was recently acquired by Nature’s Path. There is a gluten-free variety of Country Choice Oats. These oats are mechanically sorted to be gluten-free.
UPDATE: On November 2, 2015 Nature’s Path wrote the following to me in an email, “This is to confirm that Natures Path Foods has purchased the Country Choice brand name from Grain Millers. Grain Millers continue to be the supplier of our gluten free oats.”
- If you want to know the source of oats in your gluten-free products, contact the manufacturer and ask.
- Do not assume that oat products bearing a certification seal from GFCO, GFCP, or NSF are purity protocol oats. None of these certifying bodies prohibits the use of mechanically/optically sorted oats.
- Manufacturers may be sourcing oats from two different suppliers; one may supply purity protocol oats and the other may supply sorted oats.
- If purity protocol oats are important to you, ask whether ALL oats are sourced from a supplier of purity protocol oats.
- Please be transparent about the source (purity protocol or mechanically sorted) of your oats.
- If you are purchasing oats from Grain Millers or La Crosse Milling, these oats are commodity oats that have been mechanically/optically sorted.
- Do not tell consumers that the source of your oats is proprietary information.
- Do not assume that gluten-free oats from your supplier are purity protocol oats.
- Ask your supplier if their oats are purity protocol oats or mechanically sorted oats.
Consumers and Manufacturers: At Gluten Free Watchdog we have dealt with manufacturers using regular oats* in their gluten-free products. If you are newly diagnosed with a gluten-related disorder please be advised that oats are highly likely to be contaminated with wheat and barley and you should NOT eat regular oats. If you are a manufacturer new to producing gluten-free foods, do NOT use regular oats in your products.
*Regular oats are defined here as those oats that are neither mechanically sorted nor purity protocol gluten-free oats.
For more information about General Mills mechanically sorted oats see http://www.blog.generalmills.com/2015/07/how-did-we-make-cheerios-gluten-free/
For more information about Quaker mechanically sorted oats see https://www.glutenfreewatchdog.org/news/wp-content/uploads/2015/10/PDF-GF-Fact-Sheet.pdf
For more information about La Crosse Milling (Diamond Brand) mechanically sorted oats see http://lacrossemilling.com/wp-content/uploads/2015/06/SPC-QSP-OATS-PG2-140.pdf
Currently, Grain Millers does not have any information available online about gluten-free oats.
Complete statement from the Gluten Free Certification Program (endorsed by the National Foundation for Celiac Awareness in the US and the Canadian Celiac Association in Canada)
In response to your query on the GFCP position with respect to acceptability of “cleaned oats” not subjected to verifiable, preventative protocols on-farm.
The GFCP has the obligation and the right as a private, voluntary standard to balance the regulatory requirements as a foundation and considers approaches which are most appropriate to protect consumers from inadvertent contamination from gluten. The GFCP regularly consults with experts whether industry or government including those in the Canadian Celiac Association and the National Foundation for Celiac Awareness which endorse the GFCP.
Considering the above, the GFCP requires that all incoming ingredients be verifiably gluten-free as they enter any gluten-free management system which includes oats. This means that any incoming oats need to be verifiable to be “gluten-free oats” and considered as a high risk for gluten contamination. Facilities should clearly set their supplier specifications such the “gluten-free oats” have been grown, transported, stored, prepared and/or managed in a manner that avoids cross-contamination by wheat, barley, rye, or their hybridized strains to consistently achieve the food safety outcome of <20 ppm for gluten. The supplier should have written, standard operating procedures (SOP’s) in place which can be assessed and/or measured by the facility management or their agent to verify that the supplier conforms to those specifications. Those SOP’s would include but not be limited to seed purity, field management, cleaning harvesting equipment, storage management and transportation or the equivalent. This is not intended to be an onerous task but does require evidence of due diligence to achieve <20 ppm.
The GFCP recognizes that these requirements are more restrictive than what the USFDA and Canadian regulations require. However, it feels that it is the “safe haven” approach defers to proven methods of management which prevent gluten contamination and ensures that there is sufficient level of protection to consumers as well as participating facilities and brands managers. In this way, the facility can have one management system which meets both Canadian and US regulations and the GFCP as well.
Notwithstanding the above, as more science and proven technologies become available, the management of the GFCP will continue to consult with experts such as industry and those within the CCA and NFCA based and reassess as needed. This will be done to ensure the appropriate level of protection to persons with celiac disease and gluten sensitivity is in place and that they can be confident that products carrying the GFCP trademarks will consistently deliver it.