GF Lex – Drawing Lines Part I: Cross-Contact from Farm to Facility

As individuals with celiac disease, we must make decisions on a daily basis as to what we consider safe to consume. These choices are deeply personal, based upon our own positive and negative experiences. The levels of trust we are willing to put into other people, other kitchens, and other products vary widely between us.

When it comes to drawing lines we refuse to cross, each individual with celiac disease is faced with his or her own consequential decisions.

Setting the entire adventure of dining away from home aside, the products we choose to allow into our own kitchens are frequently laden with more potential risks than we may have even acknowledged. Growing accustomed to label-reading is not simply a task with which the newly-diagnosed struggle. It is an evolving skill that requires time and experience to master, and constant study to practice. Once we become acquainted with the common hidden sources of gluten, and familiar with the inconsistent aliases of potential gluten-containing ingredients, we are still left with difficult questions of safety regarding prepackaged foods.

On my gluten-free journey, one of the hardest lines for me to draw was in respect to “precautionary” or “advisory” labeling on boxed and bagged foods. You are likely familiar with these phrases, from the arresting “processed on equipment also used to process wheat,” to the unsettling “processed in a facility that also processes wheat,” to the at times downright puzzling “no gluten ingredients.” What are these phrases really saying? Scientifically, what do they imply? Legally, what are they required to designate? And most importantly, in reference to you, and to your own, personal health…

What do they mean?

0116 - Facility processing wheat

In this three-part cereal–

I mean, “serial,”

I’ll explore the roots of these phrases, and touch on the intricate complexities surrounding them. In so doing, I’ve unearthed the topic of cross-contact, the term currently being used to refer to the longstanding issue of cross-contamination of gluten-free products with gluten-containing material. These articles will be looking into cross-contact from three angles: from the farm to the manufacturing facility, from the facility to the store shelf, and from the FDA’s current ruling about it all. In delving into the murky world of contamination, manufacturing, and government regulation, I have discovered information of which I was unaware, threats I did not know existed, and a hydra of questions I never imagined I would have to ask in attempting to answer the universal food quandary of celiac disease:

Is it safe?


0116 - Bob's GF Oats

Cross-contact is a deeply complex issue. There are so many opportunities for a product to become contaminated and unsafe for consumption that it behooves one to examine the issue from the ground up. Literally.

Gluten-free grains are the foods in a celiac patient’s diet that are the most frequently at risk for cross-contact, and are also the staples most often substituted when transitioning to a gluten-free lifestyle. The journey of that bag of oats, or cornmeal, or sorghum flour from the farm to the bag in your pantry, however, is a long one. The path from that bag of flour to that boxed entrée in your freezer, that loaf of bread on your counter, or that package of wafers in your pantry is even longer. Each trek a product takes is a complicated one from its very origins, fraught with pitfalls, perils, and plentiful potential problems.

Whoa, excuse me. Brain fog…

Let’s leave the letter “p” out of this for now, and continue to the farm, shall we?

In 2005, a helpful presentation by the North American Miller’s Association illuminated several important details about the grain-farming process, and is worth examining. This organization, which at the time milled 96% of the nation’s wheat, corn, and oats and processed 160 million pounds of grain each day, supplies makers of packaged foods, bakers, and retailers across the country. This is where the vast majority of our grain comes from, in the United States.

From the outset of the farming process on a traditional farm, there is seldom a dedicated space for gluten-free grains. Farmers need to rotate their crops to continue to optimally utilize their land, and with grains, this often includes a rotation of wheat, barley, rye, and oats… on the same land. Pieces of the gluten-containing crop can therefore be tilled into the soil, or be scattered on the ground near the gluten-free crop. Even if grown separately, the different crops are commonly grown near one another, and can be shed into one another’s space in that way. This means that even as your oats are still growing, they may be growing in, on, or next to something that is, unfortunately, harmful to you.

Valuable farm machinery is maintained and cleaned to keep it in good repair, but the same harvesting, transport, and storage equipment is routinely used for all crops. That means that while being cut down in the field, while riding in a truck bed to a storage facility, and while biding its time in a silo, your grains are probably hobnobbing with unsavory characters already.

Additionally, grain elevators and silos are not often scrubbed out between storages. This is in part due to the impracticality of scrubbing down these massive structures while farmers and farm workers labor to harvest their crops at their timely peak. It is also due to dust being a very real health issue for farm workers, and agitating it (as would be done in cleaning) is not only advised against, but at times regulated against, for the safety of those involved. Therefore, although farmers are doing the best they can, their grains may be contaminated with gluten dust, debris, and, well, other grains.

At the same time, farmers are held to rigorous standards by their certifying government agencies, standards that must be met before grain can be marketed. There are specifications for the production of each grain, but the ones with which we would be particularly concerned include oats and corn. Oats are allowed a 0.5-1% “cereal grain admix,” with 2-3% allowed dependent on their grade. One can only imagine what has been accidentally kicked into that cereal admix (but my imagination certainly conjures up plenty of barley, wheat, and rye grains. And maybe some tiny, fun-shaped marshmallows. What can I say, my imagination is pretty defective…). Even our golden child, corn, is allowed to be composed of 2-4% “broken corn and ‘foreign material,’” dependent upon grade.

These are, from many perspectives, stringent standards. As a celiac patient imagining grains of barley and wheat being processed along with your oats and corn, however, you may already be asking yourself difficult questions while attempting not to give yourself an ulcer. Such regulations were clearly not designed with us in mind, and unfortunately, do not seem to have been revisited with such a consideration, either.

After grains are harvested and stored, and prior to milling them, an additional step is often taken in an attempt to produce a purer product: they are “cleaned.” The process of “cleaning” grains is also a controversial one (and one which recently brought General Mills into question recently; but more on that, later). What the term means, essentially, is that individual grains are separated from most of their vegetable waste, and are then sorted out by length, width, and density. This is sometimes accomplished by passing them through filters, sometimes by optical sorting based on color, size, and shape, and sometimes with “proprietary methods.” As you can imagine, separating grains of differing sizes and shapes would be simpler and more thorough than separating grains that possess similar physical properties. A grain of corn and a grain of wheat may be easy to discern from one another, for example. But a grain of wheat and an oat? As wheat, barley, rye, and oat grains are essentially exactly the same size, and of similar shapes and colors, you can see how this easily becomes complicated.

Regardless of the outcome of the “cleaning” process, grains used in flours move on to the mill afterward. Mills are regularly inspected, and good practices indicate they should regularly be cleaned, and free of dust. The type of cleaning done in a mill is typically “dry,” however, utilizing vacuuming and wiping out, which may leave grain residue and debris behind. Again, this is usually for safety reasons (involving dust being incredibly unhealthy for workers). There are procedures in place for changing grains in a mill, but these do not routinely involve testing for the presence of other grains.

When testing is initiated in facilities or mills, it is incredibly difficult, if not impossible, to obtain what could be referred to as a “representative sample” of the entire process. As has been seen in nearly every test for gluten contamination in milled products, from bagged finished product all the way back to initial grain sampling, sample composition and percentage of gluten found varies widely from sample to sample. Often, this variance is so wide that to imply the safety of even one particular product seems impossible. Testing every bag of a product, instead, is also infeasible. At many institutions, even testing every batch of product is impractical, due to the sheer volume being processed and produced.

In addition, “cereal admix,” the contaminating grains in various grain products, has never been tested on an industry-wide basis in either oats or corn. Standards, therefore, are often enacted at the discretion of individual mills. The use of flours from various mills in a single packaged product, therefore, could lead to such variable test samples as to make them unusable in a comparison study.

0116 - Retro Rolled Oats Ramekin

Oats are the primary culprit for contamination risk, and there may be no better topical example of this than that of “Gluten-Free” Cheerios, released last year. You may recall that 1.8 million boxes were recalled as contaminated, after potentially harming millions of celiac patients, because wheat flour was used on the production line in which oat flour was intended. Under scrutiny before this dangerous mishap, however, was General Mills’ proprietary sorting process used to “clean” its oats. This process, which apparently took four years to develop, was shared with the FDA and Health Canada, but was repeatedly not divulged to the public, even after numerous requests to verify the safety of the product for individuals with celiac disease. Cheerios were to be tested for gluten contamination at three levels, one of them being the grain level after the sorting process (the others at the flour level, and then the finished product). This repeated testing is not often performed by other manufacturers, and seemed a trustworthy precaution… and yet we see what has happened, anyway.

Gluten Dude, a celiac disease advocate, attended a summit with General Mills to discuss the manufacture of Gluten-Free Cheerios last year. From this, he learned about the routine contamination of oats at the grain level. A chilling illustration of this was the image in this blog post, which seared itself into my mind, as I had never truly understood how “cross-contacted” oats could be. The image shows a container of the 15,000 pieces of oats in an average batch of cereal, and then, off to the side, the average “cross-contact” with wheat and barley. There are 100 pieces each of these grains. Yes, whole pieces of wheat and barley, just rolling around in the oats. A lot of them. To achieve the legal threshold of less than 20 ppm of gluten (more on this in future articles), it is said that 199 of these pieces needed to be removed. Thank goodness for that. But that means 1) those “oats” were pretty darned unsafe to begin with, and 2) somewhere in the technically legal, technically “clean” oats (and then in your MOUTH) a piece of wheat or barley is still knocking around… and we are just supposed to be ok with this.

These facts and statistics are disarming, at the very least. I will mention, however, that there is a distinct difference between dedicated gluten-free oats (grain grown start-to-finish gluten free) and oats that are grown as “regular” oats, and then “cleaned” at the “back end” of production, before milling, such as the oats used in Cheerios, and the oats grown on most commercial farms. These “regular” oats are the oats we have been discussing thus far.

Dedicated gluten-free oats, alternatively (and thankfully; profoundly, grovelingly thankfully), do exist, and are grown as what is considered a specialty crop. These oats are sown in specifically-designated fields, on specialized farms. To produce dedicated gluten-free oats, several companies (for instance, Cream Hill Estates, Avena Foods, and Gluten-Free Harvest) have enacted their own discriminating methods to ensure that their crop is gluten-free, from beginning to end. These practices include using pure seed uncontaminated by vegetable matter, growing the oats in fields in which wheat, barley, and rye had not been grown for at least 3 years, and using specific, cleaned machinery for seeding, harvesting, transport, and storage. These oats are also processed in facilities designated as gluten-free, and they are tested for contamination before and after processing, as well as at the farm. Sometimes these oats are also certified gluten-free by a third party, and all must hold up to both FDA and Health Canada regulations.

I was stunned at (and again, incredibly grateful for) the lengths to which these companies and others go in ensuring that the gluten-free oats we purchase are actually gluten-free, and completely understand the perplexing differences in price, now. I would gladly pay just a little more to be able to enjoy my oatmeal cookies with a little-less nerve-wracking, undue anxiety over cross-contact, and a little more vegan chocolate chips.

And maybe a shot of rum. To calm the nerves.

But what about more refined products? After your grains leave the mill as flours, flours that may be baked into that bag of GF pretzels, kneaded into that frozen GF pizza crust, or vacuum-sealed into that package of GF muffins, what happens to them? And what goes on in the facilities sending batches of gluten-free pasta noodles, herb crackers, and shortbread cookies down their production lines?

I will further explore this in the next article in this series. For now, I will simply continue to contemplate whether I, personally, should bother attempting to consume gluten-free grains at all (as much as I truly love my gluten-free oats– or, more precisely, the cookies I make with them). The more we educate ourselves about where our food comes from and how it is produced, however, the better informed we are to make the difficult decisions affecting our lives and our health. These decisions belong to each individual uniquely, and no answer will be the “right” one for every person with celiac disease.

Take time to think about what you decide to consume. Take time to consider the companies and individuals you choose to trust with your food and to pay for their diligence and hard work. And most importantly, take the time to understand what you are putting into your body, the risks involved in how it is made, and potential rewards of nourishing and healing yourself through your dietary choices. Utilizing all the resources available, think about what is right, for you.

Ultimately, we each have to decide what is safe.


Works referenced, and further reading:

“The Cheerios Recall (aka… The Gluten-Free Sh*t Storm),” on GlutenDude’s website, October 2015.

“Feasibility of Milling Gluten-Free Flours,” by Jane DeMarchi, North American Miller’s Association, August 2005.

“General Mills ‘Gluten-Free’ Cheerios: Comment from Gluten Free Watchdog,” by Tricia Thompson, on the Gluten Free Watchdog website, March 2015.

“Gluten-Free Cheerios? Here’s the Deal,” on GlutenDude’s website, March 2015.

“Gluten-Free Cheerios: Take Two,” by Tricia Thompson, on the Gluten Free Watchdog website, August 2015.

“Oats and the Pitfalls of Gluten-Free Labeling,” by Tamara Duker Freuman, on US News & World Report’s Health website, October 2015.

“Our Story on Gluten Free,” on the Bob’s Red Mill website, 2016.

All photos copyright Alexis, aka GF Lex, 2016

3 thoughts on “GF Lex – Drawing Lines Part I: Cross-Contact from Farm to Facility”

  1. Another excellent article, Alexis! Like Diane, looking forward to part 2. Knowing that there is only soft (at best) regulation over our food supply is most unsettling. Also, I agree that it ends up being a personal decision about what is safe- but it shouldn’t have to be personal. In an ideal world, we would have a safe food supply with objective controls and measures. Thank you for shedding more light on General Mills, for linking to the enlightening & entertaining Gluten Dude, and for citing the always informative work of Tricia Thompson. Thank you, once again, for this exceptional piece! 🙂

  2. Taking readers through the real-world practicalities and realities of growing, harvesting, storage, transport and manufacturing of grains has opened my eyes. As someone who eats oatmeal every single day, I’d only recently learned that my gf oatmeal brand was machine sorted. The graphic photo of the amount of gluten grain contamination in one box of oat cereal really hit home for me as well. I’ve slowly moved away from most processed gf food because of the arsenic in rice issue, but even more so since the Cheerios debacle. Thank you.

  3. Wow. Thanks for your comprehensive review. I look forward to reading the next installment and can see more clearly now that more processed food is more at risk for cross contact with each additional step in its manufacture. All the more reason to stick with whole foods (purchased anywhere – not just Whole Foods).

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