Thursday, March 25, 2010

Kinnikinnick's Position on Oats in Gluten Free Food

Update 2: on June 17, 2012, Health Canada released the final draft of regulations regarding the labelling of Gluten Free in Canada which come into effect August 4, 2012. These regulation continue the status quo on oats and they WILL NOT be allowed in products labelled gluten free. Read our response here.

Update: On May 18, 2010, Health Canada announced it was seeking input from industry and consumers on proposed revisions its gluten free labelling regulations. Health Canada The main focus of these changes are to allow products with oats to be labelled gluten free. The following post was written before this call for input was made public but our position remains the same. Allowing oats into the gluten free category is a mistake and could be confusing and potentially harmful, especially to the newly diagnosed.  We will be making a submission (essentially this blog post and the comments we have received on it) to Health Canada in the next week or so.

As is often the case, a question on Twitter this morning has prompted a post. The question was:
Do you think Kinnikinnick will ever manufacture their own oats for baking & cooking?”
The short answer is No. We won't make, use or sell oats. And that certainly could have been a “tweet” but we get asked this question a lot and it really deserves an in-depth explanation.
In order to explain our position, it’s probably worth a look at the history of oats, gluten and Celiac Disease.
Let’s get right to the basics. What exactly is gluten? The seeds of most flowering plants especially grains have evolved to store proteins which provide nourishment during germination. This protein is often called gluten, an unfortunately generic term which in itself causes confusion. The reason for the confusion is that rice and corn contain proteins which are often referred to as rice gluten or corn gluten. These “glutens” are not a concern for people with Celiac as they do not contain the harmful proteins that cause the immune response which is the root of Celiac Disease.
So which “Glutens” are the ones people with Celiac need to avoid? For most of the last 50+ years , the grains to avoid have been recognized as Wheat, Barley, Rye And Oats. (WBRO) These grains contain the proteins Gliadin, Horedein, Secalin and Avenin respectively and these are the proteins that we really should refer to when we use the word “gluten” in relation to Celiac. However, starting in 1995, some research began to show that some Celiacs we able to tolerate pure, uncontaminated oats. These tests were repeated with varying results over the next 10 years. By around 2005, the consensus began to say that consumption of oats is probably safe for most Celiacs, if intake is limited to around 50-70 g of pure uncontaminated oats, based on 5 year long clinical study. [*]
Being a family of Celiacs running a company who has been making Gluten Free foods for almost 20 years, we have some issues, both philosophical and practical, with that premise.
Let’s look at the philosophical issues first.
It’s probably safe for most Celiacs. The problem is that it is certainly not safe for all.
“Oats are not recommended within a year of diagnosis because of the [risk of avenin]-sensitive enteropathy” [*]
"There are case reports of individuals with celiac disease relapsing from the consumption of pure uncontaminated oats." [*]
“The patients drafted for this [2004] study were those who had symptoms of celiac disease when on an 'pure-oat' challenge…This study found that 4 patients had symptoms after oat ingestion, 3 had … avenin-sensitive enteropathy(ASE). All three patients [had the] DQ2.5/DQ2 [gene]. While [this] represents only 25% of celiac patients, it accounts for all of the ASE celiacs”
"Some coeliacs respond adversely to oats. Estimates range from 0.5 to 20% of the GSE population. With coeliac disease non-compliance to achieve normal intestinal morphology is a risk factor for refractory disease and cancer." [*]
It’s probably safe for most Celiacs based on a 5 year study.
For us, a 5 year study just isn’t long enough when we’ve seen so many other things (especially chemicals & pharmaceuticals) show problems on a much longer time line (10-20+ years). Perhaps more concerning is that "the studies looking at safety of oats in celiac disease have involved a small number of subjects". [*] Let’s talk in 2025 when we've had 20+ years and thousands of people studied. We’ll see then if there are no issues like increased rates of cancer and other Celiac related diseases.
It’s probably safe for most Celiacs if intake is limited to around 50-70 g
So you have your 1/2 – 3/4 cup oatmeal every morning. Is that enough to get you going, perhaps you need a bit more. Oh, and those oatmeal cookies are awesome so a couple at lunch or coffee are great. Maybe some haggis for dinner? (well, it's possible) Oops, you’re now up to twice the recommended amount. What does that mean, long term? I don’t think we really know, especially if you are getting trace amounts of other gluten proteins from cross contamination.
It’s probably safe for most Celiacs if the oats are pure and uncontaminated.
A [2008] study made by a team of doctors in Spain used [four different state of the art testing] techniques to evaluate 134 varieties of “pure,” “uncontaminated” oats from Europe, the United States, and Canada.
Results showed that just 25 of the samples were actually pure, and contained no detectable levels of contamination. The other 109 samples [of “pure” oats] all showed wheat, barley and/or rye contamination. The results also showed that contamination levels vary among oats from the same source." [*]

Now to the practical reasons.
Supply of pure, uncontaminated oats.
As noted above, finding truly pure oats on a consistent basis is no small problem. Let’s assume that suppliers of pure oats have a 100% success rate and we could use them. There is still a limited, but admittedly growing supply of "pure" oats. These oats are grown by a relatively small number of farmers, often in the same area. Any problems with the crop year could cause disruptions in supply due to this small supply base. These oats are also a premium ingredient (ie: expensive) due to the labour intensive steps taken to ensure that cross contamination doesn't occur.
Oats aren't appropriate for every Celiac.
Also as noted above, there is some portion of the Celiac population, perhaps as much as 20%, who can't tolerate oats. The research also shows that no one should have oats until their gut has completely healed (ie: at least a year after diagnosis and being completely GF). Adding oats and the resulting oat cross contamination would prevent these people from using a product. What is more concerning is the fact that these people might eat an oat containing product, get sick and not realize why. How can you tell a customer that oat containing products are OK for most Celiacs, but not them? In keeping with our Mission Statement of providing our customer with "a risk free source of food products", we’re just not going to “go there”
Limiting Oat consumption to 50-70 g per day
How do we, as a manufacturer, manage that problem? We make our products as tasty as we possibly can. Do we add a disclaimer to our packages "We know these are tasty, but please don't eat more than 3 of these a day because you might get sick, if not immediately, then perhaps over the long term, if you do"? I don't think so.
A little matter of the Law
Lastly but definitely not least-ly, there is the little problem of the law. Currently in Canada, it is illegal to use oats in a product that is labelled gluten free. Under Section 9.9.4 Gluten-Free Foods [B.24.018, B.24.019] of the Food Labelling & Advertising Act [*]
"A food is not permitted to be labelled, packaged, sold or advertised in a manner likely to create an impression that it is "gluten-free" unless it does not contain wheat, including spelt and kamut, or oats, barley, rye, triticale or any part thereof."
That’s pretty much the show stopper right there. Even if we had no misgivings about using oats and we had solved all the practical issues, we couldn’t do it the way the law is currently written. Given the speed of governments on issues like this, we can probably look forward to a change in, oh, 2025. Which might be a good thing. We might finally know by then whether oats are safe.
It’s important to note that these are concerns based on our reading of the literature and many will say that they are unfounded and that’s fine. Am I saying oats aren't safe for Celiacs? No. I'm saying that I'm not convinced there is enough long term evidence to say one way or the other. We aren’t going to make any kind of change regarding oats until these questions of long term safety are answered to our satisfaction. Oh, and the law changes.
As I always say, don't believe me. I'm just a guy posting on a blog. Do your own research! Probably the definitive resource for starting your investigation is this page at
Note: I've cited Wikipedia here several times and it's not always the best source of accurate information but in this case the pages cited are properly annotated with various papers and studies.
Let's hear what everyone thinks in the comments. I'm sure it will be interesting.

Tuesday, March 2, 2010

Kinnikinnick Now In Publix

We've just had it confirmed that 6-7 Kinnikinnick products have been "planogrammed" in 325 Publix stores in Florida and Georgia. What does it mean to be "planogrammed"? When a chain launches a new line of products, it will often create a planogram which is basically just a diagram of the stores shelves and how products will look & fit on the shelves. For the store this helps it maintain a consistent look. For the general consumer, this means that the dish soap is in the same place in the same way on the store shelves no matter what store you visit.

For the Kinnikinnick consumer what this means is something even more exciting. It means that each of these 325 stores has a map that says "put these 6-7 Kinnikinnick products on -that- shelf." Finding shelf space is the most difficult thing facing a manufacturer so being planogrammed is a -big deal-.

The general break down of the stores is as follows:

Orlando/Tampa area - 121 stores
Miami area - 44 stores
Jacksonville area - 84 stores
Atlanta area - 76 stores

We don't have exact locations or what 6-7 products are plannogrammed yet but I'll update this and our store finder when we get more information.

But wait, it gets even better.

All Publix stores have access to 17 of our products and can get them in if you ask for them. I'll post a list of the 17 shortly. Many Publix stores including some of the 325 stores in the planogram program are already carrying quite a few of these products.

As always, if you don't see Kinnikinnick in your local Publix store, or any store for that matter, ask the store manager. We've even created an introduction to Kinnikinnick letter you can take to them found here

Stay tuned for more exciting announcements coming soon.