100 SUBWAYS in Oregon offer GF sandwich bread as of Monday July 11th

Interesting news about SUBWAY! I went last night to the Subway on SW Bond in the South Waterfront to to try out their new GF sandwich offerings. I understood it to be test market event, looks like it's so much more. (See Big News below.)

I spoke to Katherine Orr, Director of Operations and Michelle, the DA (District Agent) in charge of Western Oregon, inc. Bend and SW Washington. Michelle also happens to own that Subway restaurant on SW Bond. The bread that they used was by Rich Products out of NY. Looks like they were a conventional bakery and then acquired a GF bakery. They look to be like a big food-service company offering GF items out of Buffalo.

The bread was more of a hamburger bun, smaller than the typical Subway roll. They washed their hands before every GF order, and put on new gloves. They open a bag that contains an individual GF bun, place it on a piece of paper, and sliced the roll/bun and toasted/warmed it. Then the toppings were added. Any meat is gluten-free except the teriyaki, meatball and seafood which contain gluten. They also offered samples of GF brownies. Some employees couldn't say if the brownies were also dairy free (they are) and were confused by that question.

I haven't eaten in a fast food restaurant in years, and before I was gluten free I rarely ate in one anyway, so I don't have much to compare it to. I think I ate one Subway sandwich ever in my life in the early 1990's. The GF bun was soft and not chewy or fragile/crumbly. My kids (19, 21) were happy with their meal. My daughter is also GF so she was happy. My husband ordered a sandwich which required double-toasting and felt that his bread fell apart a bit. One of my friends thought the bun was bland. Two non-GF folks like the sandwich and didn't have a problem with it at all.

Subway said that they test marketed this GF sandwich process in Texas for 1.5 years (since January 2010) with 300 restaurants offering GF sandwiches. They claim that they had zero complaints of contamination or sickness in the 1.5 years. Oregon is the second location to go GF for Subway. Though a quick internet search shows some have been in place in Texas since earlier this year only.

There were some attendees last night who were worried about crumbs of GF bread cross-contaminating w/ the meats and veggies. Valid point. Subway's response: we just dig deeper into the meats to get a piece without crumbs. What(???!!) As if crumbs can't fall deeper into the pan? Definitely a potential problem. And touching the handle of the oven, I could see some issues, too. So some cross-contamination issues are possible. Turns out the employee who made most of the GF sandwiches is a higher-up in the company. She was very efficient and was correcting some of the other employees on hand washing, etc.

A great turnout last night. When I left they thought they had passed out 120 sandwiches and were willing to continue throughout the night until the store closed at 11pm, or their inventory of 180 buns was gone. It was bustling when I got there.

Big News:

Next Monday, July 11th 100 Subway restaurants, (97 in the Portland Metro area and 13 in the Bend/Redmond area) will offer the GF bread for sandwiches. Each Subway restaurant is individually owned and operated, so I'm not sure which ones will offer GF. Last week there was a massive training of personnel on cross-contamination issues, and they used Texas' manual and procedures to get the same results. The sandwiches will be sold at $1 extra. Rich's GF brownies will be $2.

Portland Corporate Subway was told that they were the next test market two weeks ago, and I found out a day after that. They don't even have a website up, and advertising is scrambling.

I called the Irvington Subway store (NE 13th & Broadway) nearest my house and asked if they were going GF and they said, "I doubt it. I haven't heard anything about it." I then called the Park Ave Subway (near my office downtown) and they very excitedly and knowledgeably told me that all 6 downtown Subway stores "from Alder, down" have the goal of offering GF sandwiches on Monday 7/11 if their inventory arrives on time. I understand that that Subway inside PSU and the 24-hour one outside PSU will offer them also. (very smart to capture the university crowd).

Well, that's what I have to report. Pretty interesting, huh? A fast-food type restaurant offering a real GF option! Who'd a thunk it? And not just GF McDonald's french fries, but a meal (well, a fast-food meal). Feel free to share the info.
- Lisa, GIG of Portland branch manager

McDonald's French Fries

Since it's come up again recently, here is where the gluten free community stands on McDonald's french fries:

The Celiac Sprue Association (CSA) has examined the commercial manufacturing process of the natural flavoring with wheat as a starting ingredient which is used in connection with the McDonald’s Corporation French fries and hash browns. CSA provides the following statement after knowledgeable, careful evaluation and review of the process and pertinent test results.

French fries and hash browns prepared in oils with this flavoring might be considered, commercially, to “contain no gluten.”

Third party analysis of the wheat ingredient of the natural flavoring revealed detectable levels of gluten*. Factors affecting the possibility of there being any residual gluten in the final French fries or hash browns include:

• The quantity of wheat ingredient used in the manufacturing of the natural flavor represents only a small amount of the overall natural flavoring formulation.

• The manufacturing of the natural flavor involves processes that significantly reduce or possibly eliminate the levels of gluten that existed in the original wheat ingredient. These steps are completed before the flavor is added to the frying oil.

• The quantity of natural flavoring added to the frying oil represents only a small amount of the total frying oil.

• The oil frying process increases the final potato product weight by a small quantity.

All these factors serve to greatly reduce the initial level of gluten from the original wheat ingredient. The calculated level of any residual gluten in the final French fries and hash browns is below the limits of detection (BLD) of the most sensitive commercial gluten test.

For those with celiac disease, the only risk free choice is products with NO WBRO, that is, no Wheat, Barley, Rye, Oats and any derivatives or crosses in Product, Processing and Packaging.

The knowledge base, manufacturing processes and detection capabilities are always evolving and subject to re-evaluation and/or revision. This information is intended for people with celiac disease to use in making personal diet choices.

More detail about the test results on the presence of gluten in the french fries:

As it relates to the hydrolyzed milk, initial testing was conducted on the French fries and hash browns using a Neogen Veratox test at a 2.5 parts per million level of sensitivity. The Neogen Veratox test found no detectable intact milk proteins. As it relates to the hydrolyzed wheat, initial testing was conducted on the French fries and hash browns using a RIDASCREEN Gliadin ELISA test at a 3 parts per million level of sensitivity. The RIDASCREEN Gliadin ELISA test found no detectable intact gluten proteins. Because partially broken down milk or wheat proteins may be present, and they also may be clinically significant for an individual with a milk or wheat allergy, these tests are not definitive.

Consequently, we decided that additional allergen testing be done on these ingredients using the Radioallergosorbent Inhibition Test (RAST). The RAST test found virtually no wheat-allergic residues in the hydrolyzed wheat ingredient. The RAST test found some milk-allergic residues in the hydrolyzed milk ingredient. It should also be noted that the hydrolyzed milk and hydrolyzed wheat ingredients are only a portion of the natural flavoring and that the natural flavoring itself represents a small amount of the frying oil.

Official position of the Gluten Intolerance Group:

STATEMENT ON MCDONALDS FOR GIG BRANCH LEADERS
McDonald's and the Celiac Community

The Gluten Intolerance Group of NA, members of the American Celiac Disease Alliance, and others have worked at length with McDonald's, the FDA, research and industry leaders to help provide an answer to the outcry by the celiac and allergy communities to McDonald's recent announcement of wheat and dairy being in the fries.

A position statement from GIG, CDF and others in the ACDA:
The science and processing of refined oils does not allow residual proteins to be left in the oils at any level significant level to be detected or cause an allergic reaction. The flavoring agent added to the oil during par-frying is possibly suspect, however until information is provided on testing of the flavoring agent we cannot say if it is a problem or not. The flavoring company has stated to McDonald's that the flavoring has no allergenic proteins and since McDonald's policy is that the fryers used fry the French fries are dedicated and only used for potatoes, this would mean the fries are gluten-free. McDonald's is expected to make an updated statement about this situation in the very near future. We anticipate that it may include information about recent testing.

Choosing to eat any food is always the individual consumer's choice. If you feel uncomfortable with this information, it is ultimately your choice to eat the fries or not.

GIG and other leaders in the celiac community have taken a proactive position on advocating for safe food for persons with celiac disease and appropriate labeling. At the same time, it is important to recognize the need for education about how the law may initially cause confusion about ingredients that are truly safe and should not be required to be labeled, according to this law.

As we try to educate consumers, it is important that the community approach their questions and concerns in a calm, logical manner. This is not always easy to do when the health of a child or yourself is at potential risk.Ultimately, it will have positive impact on the food industry and their desire to work with us for our benefit.

Background:
The FALCPA law does not apply to McDonald's or other restaurants. It applies to packaged foods. The allergen information will appear on the packaging of foods purchased by consumers and those purchased by food businesses, such as restaurants, hospitals and schools. However, the law does not require such businesses to post this information.

McDonald's is a company that wants to be transparent and supportive of health initiatives within the fast food industry and the allergic community. In wanting to be transparent, they chose to disclose information about their fries, based on the package labeling information on the foods they purchase.

FALCPA is an excellent law, and will resolve the majority of labeling issues for persons with celiac disease, gluten intolerances and allergies. It requires that plain language be used on packaging to identify the top 8 allergens – wheat, soy, eggs, dairy, fish, shellfish, tree nuts and peanuts.

The law exempts from labeling these allergens in the event that the allergens are removed and the allergenic protein does not exist in the ingredient. An example of such an exemption is refined oil. The law allows companies to file exemptions for ingredients, if they can prove no allergen exists in the ingredient.

At this time, the FDA has not filed formal rulings on the exemptions filed.

The issue at hand:
McDonald's, wanting to be transparent and community-minded, disclosed the information on packaging of their fries, indicating that the FLAVORING Agent added to the par-fry oil included a wheat and dairy source, which the par-fry company states does not contain proteins (therefore cannot be allergenic).

People in the allergy and celiac communities feel betrayed and outraged with McDonald's for being untruthful in the past. They are angry and afraid.

Oil Processing
Refined oils are processed by cold, or heat and pressure extraction. Cold extraction oils, such as olive and peanut oils, are generally more expensive and less shelf-stable. They also retain their natural flavors, aroma, and nutritional values. Heat and pressure extraction allow oils to be more stable. Heat extraction includes oils that are extracted from the fruits and seeds under high pressure (up to 15 tons), known as expeller processing or a solvent
extraction process. Solvents are used to extract the oils from the seeds and then it is boiled to remove the solvents. These oils are often further refined using bleaching, deodorizing and high temperatures. Oils highly refined in this manner have very little of the original flavor, aroma, and nutrients of the original seeds or fruit. These oils have high smoke points and long shelf lives, making them ideal for frying. Scientists have stated that the bleaching process or high atmospheric pressure is enough to destroy the proteins.

Any flavorings are added after the deodorizing process to highly refined oils, otherwise the process would render the flavoring neutral.

The Flavorings
We do not know a lot about the flavoring used at this time, except what was reported in the press and by McDonald's.

Word reached Canada about the McDonald's information. Health Canada is launched even stricter regulations than they currently have in place for allergens. Health Canada is like the FDA in the US. This representative felt that even with their strict regulations, that these ingredients would be excluded from having to be declared on labels based on their lack of protein content. It is important to note that McDonald's products may be formulated differently in other countries; however, as the celiac community often looks to Canada for its strict gluten regulations, it is helpful to know how one person in Health Canada views this situation.

We are trying to encourage that an exemption be filed with the FDA by the oil and/or flavoring company.

Why the Confusion:
The confusion comes in that very few ingredients, that do not have allergic proteins in them have not filed for or been approved by the FDA as exempt from the law. Until they are exempt, the law requires that the label bear the starting ingredients if they are a top 8 allergen. This confuses and frightens consumers, who are depending
on this law to provide a measure of assurance to safety. We knew this would happen in the beginning and hope that the reaction of consumers to the McDonald's incident will cause the FDA to fast-pace the exemption process and stop the confusion. Remember that proteins cause allergic reactions. Companies must show no allergenic proteins are in the ingredient to be exempt from the law.

What Can We Do
First, do not panic. It is important we approach any labeling issues with a sense of fully understanding the process and issue. If the celiac community chooses react and lash out at companies, without having all the facts and full understanding, they risk isolation of those companies and others. The food industry is on the same learning curve about the law as consumers. They are watching how consumers react to labeling changes. History shows us that when we are supportive of the companies in the changes they make, they support us. When we attack, they and others will choose not to support the consumer community. Do we want companies to purposefully add wheat to their products so they do not have to deal with us? That is already happening. Wouldn't you rather pat them on the back and watch them do more to support our needs? That has happened, but could very quickly stop.

We ask that as leaders in the celiac community, that you help us to support the community needs by providing sound information and a calming effect. Help us to help consumers understand and act in a productive rather than destructive manner towards the changes. Help us to educate others about food processing and the allergen labeling law's benefits.

For more information about this information contact: Cynthia Kupper,
RD, Executive Director, GIG 206-246-6652

Cynthia Kupper, RD, CD
Executive Directo, Gluten Intolerance Group of NA
15110 10 Ave SW, Ste A
Seattle WA 98166-1820
206-246-6652; F: 206-246-6531