GF Lex – Drawing Lines Part II: Cross-Contact from Manufacturing Facility to Store

Welcome back! When I last left you, we were discussing drawing lines, making those vital, personal decisions regarding what prepackaged foods we would and would not consider safe to consume.

Did you bring your bowl and spoon? How about your running shoes, a little more of that rum, and a GF antacid tablet? It’s time to follow our grains on a nail-gnawing trip to the manufacturing plant, while keeping a sharp eye out for sources of cross-contact. Here, we may either be having breakfast, or making a fast break from prepackaged foods altogether (that’s where the running shoes and the antacid tablet come in).

The rum? That’s just for you, my friend. Because I believe in you.

And because you may need it. Trust me on this one.

When your grains, certified gluten-free or questionably otherwise, are transported from their farms and mills of origin, they begin their long trek from the big-name company’s manufacturing facility to that neat sleeve of shortbread cookies or that colorful box of rosemary crackers in your pantry.

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There are basically two types of facilities in which your food could potentially be processed: a dedicated gluten-free facility, or a shared one (the far more common of the two). Both have standards in place and guidelines to follow in order to either be certified or to ensure the quality of their products on their own. Between the rules established and the ones observed, however, there is a lot of gray area. It is within that gray that we as consumers with celiac disease must draw our own lines.

A “shared facility” is exactly what it sounds like: a place of manufacturing that produces both gluten-containing and gluten-free products. It is primarily from the shared facility that so many potential issues of cross-contact arise. Some facilities manufacture their gluten-free products in different areas of the facility than their gluten-containing ones. Some use the same areas, but have cleaning procedures in place for decontaminating their processing equipment between production runs. We hope that these procedures are enforced, that they are thorough, and that the product emerging from the far end of the line is safe for a celiac patient to consume… but most of the time, I personally would not be staking my health on an alleged gluten-free toaster pastry.

No matter how many sumptuous, enticing sprinkles it may have on it, calling out to me like glittering, sugary sirens to a starving gluten-free sailor…

NO! FRESH PRODUCE. LEAFY GREENS.

Focus, Lex. Focus. Eyes on the prize. Good health is hard to come by these days.

Processed foods are tempting, especially ones triggering nostalgic responses, ones that you did not get to “say goodbye” to, so to speak. But even with these (farewell, sweet toaster pastry…), we must each be especially wary of precautionary labeling. I speak from experience when I say that there is nothing worse than indulging in something you have sorely missed only to (literally) sorely suffer for weeks afterward because the product was cross-contaminated; to set yourself back because of a moment of temptation. No matter what the cash-hungry major corporations claim about the safety of the goodie they are counting on your wayward heart to purchase, that treat is not worth your health.

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Back in the shared manufacturing facility, the major risks your food is going to encounter include the use of shared equipment (everything from the smallest spatula, to baking trays, to the belt on the entire production line itself), the procedures used to clean this equipment, the complications surrounding the scheduling of “runs” of gluten-free products around gluten-containing ones, and the insidious horror of airborne gluten.

Airborne gluten? What is this frightening, outbreak-style threat you speak of, you may be asking yourself. I am picturing a huge red biohazard symbol and a deafening siren blaring, you may be saying. I see red flashing lights. And maybe a few escaped, frenzied, infectious monkeys…

Whoa, calm down, I would tell you, raising my hands before me. And then I would move in very close to you, my gaze darting back and forth, muttering conspiratorially under my breath, “Don’t calm down. Your reaction is actually quite appropriate…”

I think we are good on the monkeys, though. That’s not really a thing, in this case.

All joking aside, airborne gluten is a legitimate concern in shared manufacturing facilities. Think of what a mess one can make when baking at home. When measuring, mixing, and even dusting a bench to roll out some dough, inevitably there is somehow flour everywhere. When cooking with flour, this light, easily agitated ingredient gets on everything. It also gets up your nose. Not because you put it there (…one hopes). Because it is easily made airborne.

Gluten settling out of the air after a massive manufacturing procedure is going to get everywhere, too. And on everything. Most times, we are hoping and praying our gluten-free products have been sealed up tight before this can happen, or that the lines used for their production have been cleaned thoroughly after this dust has been given time to settle out of the air again. This can take a while, however. And many busy manufacturers, unfortunately, do not have that long to wait.

Just one recent example of the failure of the shared facility occurred last year, with Cheerios. In the incident preceding the notorious recall of 1.8 million boxes of cereal, wheat flour was introduced into the line in which oat flour was intended, at one production facility. Testing on the finished product was not done for 13 days after the incident, and so a tremendous amount of boxes and potential batches were produced with the contaminated flour before the error was even realized.

When Cheerios were tested by Gluten Free Watchdog, an independent testing service operated by advocate and healthcare professional Tricia Thompson, MS, RD, the samples did come back as containing less than 20 ppm gluten. It was argued, however, that testing in batches, instead of testing individual boxes, could have skewed these testing results. This is how General Mills tests their product, however; a method that would not be representative of mishaps on the enormous scale at which General Mills operates. When these results were first obtained, Tricia Thompson advised consumers to avoid Cheerios… And this advice proved to be solid and timely.

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The Gluten Intolerance Group (GIG), whose certifications of both restaurants and products help to ensure the safety of patrons and consumers who cannot consume gluten, has released some helpful guidelines to aid facilities attempting to manufacture both gluten-containing and gluten-free foods in the same areas.

GIG’s suggestions include having separate storage areas and separate prep areas for gluten-free and gluten-containing ingredients. They also advise separate, clearly-marked equipment for processing gluten-containing and gluten-free food products, including measuring devices, bowls, pans, and other kitchen equipment. Gluten-free ingredients should be stored in clearly-labeled, well-sealed containers. It is advised that policies be enforced requiring clean hands and clothing when preparing gluten-free foods, and not allowing outside food in the facility (yes, a worker with lunchtime-burrito hands can easily make your dream croissant into a nightmare!). As far as equipment is concerned, best practices would indicate that separate equipment and production areas be used for gluten-containing and gluten-free products, with controlled air flow between the two. When this is not possible, a “wet” cleaning system (wiping, washing and hosing down, as opposed to the “dry” dusting and vacuuming cleaning system used in many mills) is advised, and cleaning should be done while breaking the equipment down as far as possible, to access as many hard-to-reach spaces as can be cleaned.

Regarding production, GIG recommends scheduling gluten-free runs at least 24 hours after any other baking has occurred, to allow flour dust time to settle out of the air (…sirens. Biohazard symbol.), so that it can be wiped away.

These are all great suggestions. And I really do hope that they are routinely followed. On our trip through that shared facility, however, I have to confess: I drank that rum. And I pitched my cereal bowl way back near the beginning of the production line.

I think it may have accidentally hit that employee carrying the outside, gluten-containing burrito in the head.

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Dedicated gluten-free facilities, as opposed to shared ones, instill a great deal more confidence in consumers with celiac disease. These facilities are utilized solely to manufacture gluten-free products. They must be certified by outside agencies. And generally, this means frequent testing of their ingredients, equipment, and products to ensure their safety.

The amount of work (and funding) that goes into maintaining a dedicated gluten-free facility, however, can be tremendous. Aside from the costs of gluten-free ingredients, the testing, certifications, and man-hours involved in assuring our safety really add up. When you are standing in a grocery-store aisle contemplating why a loaf of gluten-free bread (even the not-great varieties. Yes, you know which ones I’m talking about.) costs about four times as much as a gluten-containing one, think about how much work goes into your safely being able to consume that bread. That loaf that has been thoroughly prepared, tested, and certified, just for you.

And think of the following video, one which really opened my eyes, personally. Kinnikinnick is a dedicated gluten-free manufacturer based in Canada; if you have been gluten-free for any length of time, you have likely tried some of their products, or if not, have at least seen their yellow sunburst logo around your grocer’s shelves or freezers. Kinnikinnick documented the preparation of one of its facilities to become certified gluten-free, and the process was arresting, to say the least. The company purchased a 120,000-square-foot building in 2005 from a large, wheat-based cookie company in Canada. This building was American Institute of Baking certified, and had consistently high audit scores. It was considered very clean, by many standards.

The folks at Kinnikinnick, however, found cross-contamination everywhere. They spent over six months cleaning it, pressure washing everything (from walls to ceilings to ductwork) twice, and breaking down all equipment to its nuts and bolts. They even scrubbed out the light fixtures. They excavated caked-on wheat flour from places that would have been very difficult for the previous operators to clean, but from places that would have come into contact with literally everything produced on the equipment. Kinnikinnick took the time to bring the facility and equipment up to the rigorous Canadian standards of certification. We can only hope that other manufacturers are willing to put forth an effort as exacting as theirs.

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In the long run, one cannot expect every person with celiac disease to eschew manufactured foods altogether. Sometimes we must rely on them to feed our families, or to feed ourselves. Some of us lack the time or resources to be consistently cooking on our own, if we are even privileged enough to be able to do so in a gluten-free kitchen. Avoiding all processed foods can also become further socially isolating to patients with celiac disease, a population already marginalized by dietary restrictions. In the worst of cases, avoidance of certain foods can induce paranoia, and can even develop into eating disorders.

There are positive, reasonable steps one can take to protect one’s health, however; there are simple ways to begin the process of deciding what is and what is not acceptable to you to consume. If there is a product you would like to try, but you are uncertain of its safety because of its labeling, do not hesitate to call the manufacturer. Most packaged foods have a hotline number directly on their boxes or bags explicitly for this purpose, and all should have contact information on their associated websites, if you feel more comfortable contacting a representative via email.

When you contact a manufacturer, ask the questions that are important to you. Is the facility dedicated gluten-free? If not, how often are the lines cleaned between runs? How is this done? What is done to separate the gluten-containing ingredients from the gluten-free ones? Is the facility or the finished product tested for gluten contamination? If so, how often is this done, how, and by whom?

Perhaps the question most relevant to shared facility manufacturers and the health of a celiac disease patient would be this one: What precautions are taken to assure that this product is gluten-free not just for someone making a dietary choice, but safe for someone with celiac disease, who cannot tolerate any gluten at all?

If the manufacturer or representative is not able to satisfactorily answer your questions, the food may not be worth the risk to your personal health. It is ok to walk away in these instances, to say “no” to a product, to trust your instincts. These are the sorts of weighty choices we are burdened with as individuals with celiac disease, and if we do not take them seriously, we must bear in mind that the consequences to us may not only be unpleasant or painful, they could result in permanent damage to our bodies.

Potential exposure to trace amounts of gluten in prepackaged foods is yet another reason to regularly visit your doctor. It is a good idea to have your antibodies checked routinely to see if you may be being detrimentally affected by cross-contact, and if you need to make adjustments to your diet. Small amounts of gluten can have the same effect as large amounts: your tissues may become damaged and inflamed, you may be unable to absorb vitamins and nutrients from the rest of your food, and you may be increasing your risk of lymphoma and cancers. Your doctor and your dietician can be your best allies in situations like these, and if you find yourself awash in questions of food safety and unsure what to eat, these professionals should be the ones that you turn to, first.

At a very basic level, there will be a risk of cross-contamination in almost all prepackaged foods. We each have to decide what is worth the risk for ourselves, and must assume the grave task of drawing our own lines regarding food safety and our health, utilizing the resources available to us. Occasionally, and unfortunately, a risk will have been taken in vain. If you do decide to try a product, and suffer a reaction from it, please share this information with the gluten-free community. Sometimes, big manufacturers do not have our best interests in mind. As fellow celiac patients, however, we can draw an additional line of decency: we can at least be looking out for each other’s.

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As we continue to advocate for one another, does the government intend to do this as well? In the final installment in this series, I will be exploring the FDA rulings on the subject of precautionary labeling and gluten. All I can say is: load up that flask, and bring your reading glasses. It’s going to be a long night.

Works referenced, and further reading:

“Avoiding Gluten Cross-Contamination,” by Sharon Denny, MS, RDN, on Eat Right, by the Academy of Nutrition and Dietetics, April 2014.

“Bob’s Way – Gluten Free,” on the Bob’s Red Mill website, 2016.

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

“Contamination of Naturally Gluten-Free Grains,” by Tricia Thompson, in the Living Gluten-Free Blog on diet.com, June 2010.

“Contamination of Naturally Gluten-Free Grains: 2,” by Tricia Thomspon, MS, RD, in the Living Gluten-Free Blog on diet.com, June 2010.

“The Importance of a Dedicated Gluten Free Facility,” on The Gluten Free Insider blog, by Kinnikinnick Foods, July 1, 2009.

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

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

“Producing Gluten-Free Products in a Non-Dedicated Kitchen,” on the Gluten Intolerance Group’s website, June 2015.

“Should You Eat Foods Made in a Shared Facility or on Shared Equipment?” by Jane Anderson, on About Health, July 17, 2015.

“Three Common Ways Gluten Cross-Contamination Occurs in Manufacturing,” by Gluten Free Gigi, on the Gluten Free Gigi: Smart Nutrition Backed by Science blog, June 2013.

All photos copyright Alexis, aka GF Lex, 2016

One thought on “GF Lex – Drawing Lines Part II: Cross-Contact from Manufacturing Facility to Store”

  1. That video is sobering and a reminder of how easily gluten free products can be contaminated even by well-meaning people. Thanks for researching this important issue.

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