Following the January 2013 webinar "It's Not Just Food Anymore: An Update on Gluten-Free Alcoholic Beverage Labeling," NFCA invited listeners to submit their questions about labeling regulations. The questions and answers from webinar panelist Tricia Thompson, MS, RD of Gluten-Free Watchdog, are included here.
Q: When are manufacturers going to start labeling hard liquor with new gluten-free labels?
A: Gluten-free labeling of alcoholic beverages regulated by the TTB is voluntary. It is not clear at this time whether manufacturers will choose to label qualifying beverages gluten-free.
Q: Are there gluten free beers that are 100% gluten free because they don't have barley malt in them?
A: Beers made using a substitute for malted barley are regulated by the FDA and may be labeled gluten-free if they meet the criteria proposed by the FDA. Varieties include Bard’s Tale and Redbridge (made by Anheuer-Busch).
Q: What about drink mixes? Do they follow FDA labeling laws?
A: Drink mixes, such as bloody Mary mix are under the jurisdiction of the FDA. If a product is labeled gluten-free it should abide by the criteria included in the FDA’s proposed gluten-free labeling rule.
Q: What about gluten-free beer made in non-gluten-free facilities? Can we trust test results of non-barley based beer that were tested pre-fermentation? Do you have a suggestion for the best way for non-barley based beer producers to test their products?
A: Under the FDA’s proposed gluten-free labeling law, products under their jurisdiction (e.g., beer made using a substitute for malted barley) must contain less than 20 parts per million of gluten regardless of whether gluten is in the product due to an ingredient or cross contamination. Manufacturers of these types of beer should test their raw ingredients for gluten contamination using the formally validated sandwich R5 ELISA Mendez method (Ridascreen gliadin R7001). The final product should be tested using both the sandwich and competitive R5 ELISAs. The competitive R5 ELISA, while not formally validated is the best available test we currently have for assessing fermented and hydrolyzed products for gluten.
Q: What is the difference between the sandwich R5 ELISA and competitive R5 ELISA?
A: Please see the blog entry Gluten Testing: Hydrolyzed Gluten on GlutenFreeDietitian.com and the National Foundation for Celiac Awareness' (NFCA) webinar archive for the slides and recording of “Setting the Record Straight: Dispelling Gluten-Free Manufacturing and Production Myths.”
Q: How would cross-contamination be detected in gluten-free beverages manufactured in facilities also producing gluten-containing products?
A: First, manufacturers must make sure that their raw ingredients (starting materials) are not cross-contaminated with gluten. Just because naturally gluten-free grains are used does not mean they are not contaminated with gluten. This testing can be done using the sandwich R5 ELISA. In their interim rule the TTB states that manufacturers labeling products gluten-free must ensure that the raw materials, ingredients, production facilities, storage materials and finished products are not cross contaminated with gluten. The final product should be tested using both the sandwich and competitive R5 ELISAs. The competitive R5 ELISA, while not formally validated is the best available test we currently have for assessing fermented and hydrolyzed products for gluten.
Q: Why is it that individuals with celiac disease in other countries, such as Canada, can enjoy gluten-free beers with barley and processed to remove gluten?
A: Different countries have different gluten-free labeling rules. Individuals in the US with celiac disease are free to make the personal choice to drink a beverage labeled “Processed to remove gluten.” In the U.S., however, barley-based beers cannot be labeled gluten-free at this time.
Q: When you tested wine for gluten you used both sandwich and competitive R5 ELISAs. Why would we use the test for wine and trust it but not for malt beverages?
A: It isn’t that we trust the assay for wine but not for malt beverages. Whenever I have a fermented/hydrolyzed product tested that potentially contains gluten protein, I used both the sandwich and competitive R5 ELISAs. It is simply my standard operating procedure. Wine was therefore tested using both the ELISAs, but there is an important difference between wine and malt beverages. Wine is fermented from grapes. In other words, the starting material for wine is gluten-free. The concern with wine is wheat flour paste used to seal oak barrels in which wine is aged. Any wheat in the wine would be detected using the sandwich R5 ELISA because the wheat gluten would not be hydrolyzed.
Q: Can you provide more information on the new UPEX extraction solution?
A: UPEX stands for Universal Prolamin and Glutelin Extractant Solution. It was recently evaluated in the scientific literature. Reportedly this solution is able to extract protein from hydrolyzed and heated foods and beverages. For more information, please see the National Institute of Health website.
Q: I am confused by the significance of hydrolyzed protein and its impact on the testing for gluten using today's available tests. Can you please elaborate?
A: For an explanation of why hydrolyzed gluten is difficult to test using the sandwich R5 ELISA please see the blog entry on GlutenFreeDietitian.com: Gluten Testing: Hydrolyzed Gluten.
Q: Why is it important for the competitive R5 ELISA to be formally validated?
A: A formally validated method is defined by the FDA as one that underwent a multi-laboratory performance trial. For example, the sandwich R5 ELISA with cocktail extraction underwent such an evaluation. This evaluation was coordinated by the Prolamin Working Group of the Codex Alimentarius Commission and involved 20 different labs worldwide. The conclusion based on the findings was that the method “is well suited to determine gluten content in the range (20 ppm) which is currently being discussed by the Codex Alimentarius.” It was further stated that, “a sandwich-type assay like this is not very suitable to measure peptide which lack repetitive epitopes, in this case, a competitive assay format would be better. The scope of the method should thus be limited to gluten-free food contaminated by intact gluten protein.”
While we now have a competitive R5 ELISA it has not been formally validated. There have been issues surrounding extraction solutions capable of measuring both prolamins and glutelins as well as peptides in foods/beverages that are both hydrolyzed and heat-treated. This may have been resolved with the UPEX extraction solution mentioned above. However, this solution is not yet available commercially to my knowledge. There also have been issues relating peptide fragments to toxicity of intact gluten protein although new standards are now being used.
When it comes to allowing foods and beverages containing fermented gluten protein (i.e., protein that may be found in barley-based beers and soy sauce containing hydrolyzed wheat protein) to be labeled gluten-free, we need to make sure the assay is accurately measuring potentially toxic protein fragments. Formal validation of the competitive ELISA is the next step now that there appears to be a universal extraction solution and standards that allow for the quantification of gluten peptides.
Q: Is your sponsor, Bard's Beer, manufactured in a totally gluten-free facility using sorghum instead of wheat and barley?
A: After the webinar, NFCA contacted Bard’s Beer and received the following response:
Bard’s Beer, the original sorghum malt beer, is not produced in a dedicated gluten-free facility. Procedures are in place to thoroughly clean the equipment and we test for gluten at multiple points during each batch. Bard’s uses the Ridascreen Gliadin Competitive Assay to ensure that all of our finished products comply with the minimum standard of less than 10 ppm gluten.