Everything but the gluten-free kitchen sink: Addressing
your concerns about labeling, confusing ingredients, and
the gluten content of food
Part Two
Tricia Thompson, MS, RD
Disclosure
∗ Owner/Founder of Gluten Free Watchdog, LLC
∗ Creator www.glutenfreedietitian.com
Confusing Ingredients &
Gluten Content of Food
∗ Confusing ingredients
∗
∗
∗
∗
∗
∗
Oats
Naturally gluten-free grains
Wheat starch
Gluten-removed beer
Brewer's yeast
Yeast extract & autolyzed yeast extract
∗ Testing gluten-free foods for gluten
Oats
Oats:
FDA Gluten-Free Rule
∗ Under the FDA's gluten-free labeling rule, oats are
considered a naturally gluten-free grain and are allowed in
gluten-free foods
∗ All criteria of the rule must be met
∗ Oats included in a single ingredient food (e.g., rolled oats, oat
flour, steel-cut oats) do not need to be certified gluten-free
∗ Oats included in a multi-ingredient food (e.g., granola,
oatmeal cookies, instant flavored oatmeal) do not need to be
gluten-free or certified gluten-free
Source: FDA Gluten-Free Labeling Rule, Aug 5, 2013
Oats:
Academy of Nutrition & Dietetics
Consumer Recommendations
•
•
•
Get the okay from your dietitian or doctor BEFORE adding
oats to your diet
Eat ONLY those oats & oat products labeled gluten-free
Enjoy up to 50 grams of gluten-free dry oats each day
½ cup dry rolled oats
¼ cup dry steel cut oats
1 packet instant oatmeal
½ cup granola
•
•
•
•
•
Call dietitian or doctor if you have GI symptoms after
adding oats to your diet
•
Symptoms may be due to an increase in fiber intake
Source: Celiac Disease Toolkit, Academy of Nutrition & Dietetics, 2011
Oats: Cross-Contact
∗ If oats are a naturally gluten-free grain why should
gluten-free consumers eat only those products
containing oats that are labeled gluten-free?
∗ Regular oats are highly likely to be contaminated with
wheat and/or barley
∗ Cross-contact can occur when oats are being grown,
harvested, stored, transported, or processed
Oats: Gluten Contamination
Brand (4 lots tested in duplicate)
Mean ppm Gluten
McCann's
< 3, 12, 23, 725
Country Choice
<3, 120, 131, 210
Quaker
338, 364, 971, 1807
Source: Thompson. NEJM. 351; 19:2012-22
Oats: Purity Protocol
∗ Specially produced gluten-free oats follow a purity
protocol such as the following:
∗ Using pure seeds
∗ Growing the oats in fields that are not rotated with
gluten-containing grain
∗ Using dedicated or thoroughly cleaned equipment
∗ Processing the oats in a dedicated facility
∗ Testing the oats extensively
Oats:
Confusing Ingredient Labeling
∗ Some consumers look for the wording "gluten-free
oats" or "certified gluten-free oats" in the ingredients
list
∗ If you do not see "gluten-free" in the ingredients list
this does not necessarily mean that the oats used in
the product are "regular" oats
Oats:
Use of "Gluten-Free" in the
Ingredients List
∗ According to personal email correspondence
with the FDA, "Gluten-free is not part of the
common or usual name for an ingredient. In
addition, the term could be considered
intervening material in the ingredient
statement… Technically it may be considered a
misbranding violation…The firm has the option
to state that the oats are gluten-free elsewhere
on the label.”
Oats:
Choosing Oat Products (opinion)
∗ Choose oat products from manufacturers who
∗ Source their oats from a supplier whose growers follow a
purity protocol
∗ As a general rule, oats and oat products certified gluten-free
by a third party organization are a good choice
∗ Some manufacturers choose not to use a third party
certification but nonetheless follow a strict purity protocol or
source their oats from a supplier of certified gluten-free oats
∗ Test their product extensively
∗ Are willing to answer consumer questions
Other Naturally Gluten-Free Grains
Naturally Gluten-Free Grains:
FDA Gluten-Free Rule
∗ Under the FDA's gluten-free labeling rule, naturally
gluten-free grains, such as millet, sorghum, and teff
are allowed in foods labeled gluten-free as long as all
criteria of the rule are met
∗ Like oats, naturally gluten-free grains may be
contaminated with wheat, barley, and/or rye
Source: FDA Gluten-Free Labeling Rule, Aug
5, 2013
Naturally Gluten-Free Grains:
Academy of Nutrition & Dietetics
Consumer Recommendations
∗ Buy naturally gluten-free grains and flours that are
labeled gluten-free
∗ Buy grain-based foods that are labeled gluten-free
∗
∗
∗
∗
Rice crackers
Rice noodles
Buckwheat noodles
Corn tortillas
Source: Celiac Disease Toolkit, Academy of Nutrition &
Dietetics, 2011
Naturally Gluten-Free Grains:
Cross Contact
∗ Naturally gluten-free grains may become contaminated
with wheat, barley, or rye anywhere along the production
line from the field to the packaging plant
∗ US grain standards allow grains and beans to contain a certain
percentage of other grains or "foreign material"
∗ "Other grain" and "foreign material" are not included in the
ingredients list
∗ Even when the "other grain" is wheat, the word "wheat" does
not need to be declared in the ingredients list, Contains
statement, or an allergen advisory statement
Source: http://www.gipsa.usda.gov/fgis/standproc/usstands.html
Naturally Gluten-Free Grains:
Gluten Contamination
∗ What we tested: 22 naturally gluten-free grains not labeled
gluten-free
∗ What we found: 9 products contained measurable gluten
between 8.5 ppm and 2,295 ppm gluten
∗ Of these 9 product, 4 contained an allergen advisory
statement for wheat; 5 did not
∗ Conclusion: A certain percentage of naturally gluten-free
grains and flours are not gluten-free when purchased by
consumers
Source: Thompson, Lee, Grace. JADA. 2010:110;937-940
Naturally Gluten-Free Grains:
Choosing Products (opinion)
∗ Choose gluten-free grains and flours (and products made
from them) that are labeled gluten-free
∗ Do not assume that if a naturally gluten-free grain or flour
NOT labeled gluten-free does NOT include an allergen
advisory statement for wheat on product packaging it is
safe to eat
∗ Do NOT assume that the product with the allergen
advisory statement is contaminated with gluten and the
product without the allergen advisory statement is not
contaminated with gluten
A Word about Wheat Starch
∗ Wheat starch IS allowed in labeled gluten-free foods as
long as all criteria of the gluten-free labeling rule are met
∗ Not all wheat starch is created equal
∗ Wheat starch contains varying levels of gluten protein
depending upon processing
∗ What is sometimes referred to as "Codex wheat starch" or
"gluten-free wheat starch" is used in some gluten-free foods,
most commonly in the European Union
∗ Manufacturers who choose to use wheat starch in their
products should make sure it is of sufficient purity through
testing of both the ingredient and the final product
Gluten-Removed Beer
Gluten-Removed Beer:
TTB Interim Policy
∗ Beers made with BOTH malted barley and hops are
regulated by the Alcohol Tobacco Tax and Trade
Bureau (TTB)
∗ The TTB does not allow beer to be labeled gluten-free
∗ Beers made without either malted barley OR hops OR
both are regulated by the FDA
∗ What is commonly thought of as "gluten-free" beer is
regulated by FDA
Gluten-Removed Beer:
TTB, cont
∗ The TTB will allow beer labels to include the statement,
"Processed (or treated or crafted) to remove gluten" for
products made with wheat, barley, rye, crossbred varieties of
these grains OR any ingredients derived from these grains IF
these grains or ingredients have been processed (or treated
or crafted) to remove all or some of the gluten
∗ The product label must also include the following statement,
"Product fermented from grains containing gluten and
[processed or treated or crafted] to remove gluten. The
gluten content of this product cannot be verified, and this
product may contain gluten”
Source: TTB Ruling, February 11, 2014
Gluten-Removed Beer:
Is it "Safe?"
∗ Whether“gluten-removed”beer should be consumed
by people with gluten-related disorders remains
highly controversial
∗ It is difficult to quantify the amount of gluten in a
product, such as beer when the protein has undergone
hydrolysis (meaning it has been broken apart into
smaller fragments)
∗ A competitive ELISA is used to assess gluten content
when the protein has been hydrolyzed
Gluten-Removed Beer:
Is it Safe, cont
∗ Questions remain as to whether the competitive R5
ELISA can accurately quantify peptide fragments into
parts per million intact gluten protein
∗ Neither the FDA nor the TTB consider the competitive
R5 ELISA a validated assay for such purposes (i.e.,
quantifying gluten peptide fragments into parts per
million of intact gluten protein)
Gluten-Removed Beer:
Brewer's Clarex
∗ Barley-based “gluten-removed” beers are treated
with a prolidase enzyme such as Brewer’s Clarex
∗ This enzyme breaks apart protein at the amino acid
proline
∗ The R5 ELISA detects the 5 amino acid sequence
QQPFP where the P represents proline
∗ Brewer’s Clarex may render the R5 ELISA ineffective
at measuring gluten
Gluten-Removed Beer:
Opinion
∗ Gluten-removed beers may be safe but until there
is a test that can accurately detect and quantify the
gluten protein in these beverages it may be best
for individuals with celiac disease to err on the side
of caution
∗ For more information on gluten-removed beer please
see: http://bit.ly/GFWDglutenremovedbeer
Brewer's Yeast
Brewer's Yeast:
Definition
∗ Brewer's yeast refers to the "live yeast" used to make
beer AND the "spent yeast" which is a by-product of the
beer brewing process (i.e., what is left of the yeast once
it has been used to make beer)
∗ Brewer's yeast used in food as a flavoring agent is
typically spent yeast and as such may be contaminated
with malt
Source: Food Flavorings, 3rd edition. Aspen Publishers
Brewer's Yeast:
Academy of Nutrition and Dietetics
Consumer Recommendation
∗ The Academy of Nutrition and Dietetics currently
recommends that if brewer's yeast is listed as an
ingredient in a food NOT labeled gluten-free it should
be avoided
Source: Celiac Disease Toolkit, Academy of Nutrition &
Dietetics, 2011
Spent Brewer's Yeast:
As the Source of Yeast Extract
∗ Spent yeast also may be the source of yeast extract and
autolyzed yeast extract
• This issue first came to my attention in 2010 when testing the
product Marmite
– The primary ingredient in Marmite is yeast extract derived from
spent yeast
– Test results:
• Sandwich R5 ELISA 28 ppm, 31 ppm
• Competitive R5 ELISA 3,700 ppm gluten peptide, 3,400 ppm gluten
peptide
Source: http://www.glutenfreedietitian.com/is-marmite-glutenfree/
Spent Brewer's Yeast:
As a Source of Yeast Extract, cont
∗ You may start to come across products sold in the US
that include the following in the ingredients list:
∗ “autolyzed yeast extract (barley)”
∗ “yeast extract (barley)”
∗ Barley protein does not have to be declared under
FALCPA in the US but some manufacturers are
voluntarily declaring barley protein in the ingredients
list
∗ This is most likely a beneficial effect of Health Canada's
food allergen labeling law which requires the
declaration of all gluten sources in packaged food
products, including barley
Yeast Extract:
Opinion
∗ It is my recommendation that individuals with glutenrelated disorders avoid products NOT labeled glutenfree containing the ingredients yeast extract or
autolyzed yeast extract unless the source is confirmed
∗ We do not know at this time how often spent yeast is the
source of yeast extract
∗ In the US there is no way to know from the food label
whether the ingredient yeast extract contains barley protein
unless the manufacturer declares barley voluntarily
Testing Gluten-Free Foods for Gluten
Testing:
FDA Gluten-Free Rule
∗ FDA does NOT require manufacturers who label food
gluten-free to test for gluten contamination
∗ Foods must contain less than 20 parts per million
∗ The only way to ensure this level is met is to test
∗ FDA does NOT provide recommendations to
manufacturers regarding specific testing methods
∗ The Agency has stated that if FDA tests food as part of rule
enforcement they will use the R5 ELISA Mendez method and
the Morinaga Wheat Protein ELISA
Source: FDA Gluten-Free Labeling Rule, Aug 5, 2013
Testing:
Gluten Free Watchdog Findings
∗ Number of labeled gluten-free foods tested: 158 products
(46 certified); food purchased from retail establishments,
including grocery stores and online merchants based on
convenience (readily available in Massachusetts) or
because a food was requested to be tested through Gluten
Free Watchdog
∗ Note: This study is based on data from Gluten Free
Watchdog (www.glutenfreewatchdog.org)
Source: Thompson T, Simpson S. Eur J Clin Nutr. 2015
Feb;69(2):143-6
Testing:
Gluten Free Watchdog Findings, cont
∗ Categories of foods tested: baking ingredients,
beverages, bread products, chili, condiments,
cookies, crackers, entrees, flour, grains, gravy, hot
cereal, mixes, nuts and seeds, pasta, ready-to-eat
cereal, snack bars, snack food, soup, spices,
supplements and tortillas
Testing:
Gluten Free Watchdog Findings, cont
∗ Assay used: Ridascreen Gliadin R5 Sandwich ELISA
(R7001) with cocktail extraction solution. If the food
was suspected of containing gluten protein
fragments due to the use of certain fermented or
hydrolyzed ingredients, it also was tested using the
competitive R5 ELISA (Ridascreen Gliadin R7021) and
extracted with ethanol
Testing:
Gluten Free Watchdog Findings, cont
∗ Results: Based on the highest extraction test result, 8
samples (5.1%) of tested food, including 2 that were
certified had gluten levels greater than or equal to 20
parts per million of gluten
Summary
∗ Oats: Choose products that are labeled gluten-free and use oats
from suppliers of specially produced oats
∗ Naturally gluten-free grains: Choose products that are labeled
gluten-free
∗ Wheat starch is allowed in labeled gluten-free foods
∗ Gluten-removed beer: Avoid this product until there is an accurate
test to assess gluten content
∗ Brewer's yeast: Avoid foods containing brewer's yeast unless the
product is labeled gluten-free
∗ Yeast extract & autolyzed yeast extract: Do not eat foods
containing these ingredients unless the product is labeled glutenfree or you clarify the source of the ingredient with the
manufacturer
∗ Testing: Gluten-free foods are not required to be tested for gluten
Thank you!
Questions? Please contact me…
[email protected]