Going Gluten-Free: What Manufacturers Should Know

Gluten-Free Certification Program (GFCP). Administered by the Allergen Control Group and endorsed by North American Society for the Study of Celiac Disease, the GFCP employs a Hazard Analysis Critical Control Point (HACCP)-based standard that addresses incoming and process hazards, including undeclared gluten, as part of a manufacturer’s overall food safety management system, Blanton says.

The ingredients used in GFCP-certified products must contain 20 ppm or less of gluten, and the facility must have an auditable GMP/HACCP-based food safety system or equivalent in place. It must also undergo an annual audit from a GFCP-licensed auditing company or certification body.

Middleton says Eurofins Food Safety Systems chose to partner with the Allergen Control Group by using their GFCP because of its strict requirements to ensure that products are gluten-free. Another benefit is that it can be easily paired with a Global Food Safety Initiative certification audit, which is in high demand by many in the industry.

SGS Solutions: Independent Gluten-Free Certification. SGS is the only independent certification body offering manufacturers a choice of gluten-free certification schemes, Blanton says. With its global network of laboratories and specialists, it has the expertise to help manufacturers adopt effective gluten-free risk management policies.

Crossed Grain Symbol Gluten-Free Product Certification. Administered by the Association of European Coeliac Societies (AOECS), this scheme certifies that a product has 20 ppm or less of gluten. It involves a stand-alone audit against AOECS’ gluten-free standard, Blanton says. Manufacturing facilities producing AOECS-certified products must be audited, with finished products being tested annually by accredited laboratories.

Oats: A Controversial Grain

Although oats are biologically gluten-free because they aren’t a type of wheat, barley, or rye, commercial oats universally contain wheat and barley, starting with contaminated planting seed to shared processing equipment.

“Most consumers with celiac disease tolerate oats grown under a purity protocol well,” Newell says. “Attempts to clean the wheat and barley contamination using mechanical and optical processes are controversial because contamination occurs in hotspots throughout batches. One bite might be safe, the next might cause illness.”

Countries have different requirements regarding oats. In the U.S., oats fall in the category of non-gluten grains; they can be called gluten-free if they contain less than 20 ppm gluten.

Canada does not allow the use of regular oats in gluten-free products, Newell says, but GMP may bring the cross-contamination level below 20 ppm, meeting the requirements to use the label “gluten-free oats.”

The Codex Alimentarius standard states that gluten-free products must not contain oats and must not exceed 20 ppm. “The Codex definition includes oats as a source of gluten, but most countries have decided that oats that are free of contamination from wheat, rye, or barley can be considered gluten free,” Allred says.

Challenging Aspects

Understanding and complying with an organization’s standards is probably the most challenging requirement for manufacturers. “Most companies fail to completely read, analyze, and implement a standard’s requirements and how it will be perceived by the auditor when they visit their facility to conduct the audit,” Blanton says. “It is important to fully review a company’s standard operating procedures, employee practices, written policies, food safety manuals, and so forth to ensure they meet a standard’s provisions.”

Think of the standard as a guide to compliance and how you would present evidence to the auditor to ensure they see that policies and procedures meet that goal. A good example is most standards require manufacturers to have an organizational chart showing who is responsible for each phase within the organization. “The auditor is not going to be able to assess a facility’s reporting lines unless he can see a clear chart showing the areas of responsibilities and their reporting lines for each position starting at the top,” Blanton says.