Thank you for your comment!
My assessment is based on allergen / micro/ chemical/ physical / legality/ quality etc factors but including raw material characteristics as well as risk during production/processes through to final product and intended use of finished product.
As our gluten free product is intended to be consumed by coeliac – the risk of getting gluten in the flour (manufacturer handles and process gluten as well) is relatively low to medium but consequences of it are pretty high – coeliac suffer allergy reactions and of course instant recall if gluten found. So I could not operate without certificate of analysis for each batch received/or testing each batch at intake. This makes the raw material high risk to me.
Maybe it is a wrong approach for risk assessment of raw materials but it works for me…for now of course :)
Thks yr reply.
One thing for sure is that BRC certainly dodged a few bullets by avoiding any Glossary definitions/Interpretations of "Raw Material Risk Status".
It may depend on yr location but I deduce that if similar to the UK, the situation you describe is highly "subjective" from a "risk status" POV, eg as per the extract below -
Caterers can only use the phrase ‘gluten-free’ if they can demonstrate that, when tested, their product is 20 parts or less of gluten per million. They will also be required to demonstrate that any products claiming to be 'very low gluten' also comply to the legislation.
Caterers producing foods with no deliberate gluten containing ingredients, but due to the high risk of gluten cross-contamination, will be unable to label foods as ‘gluten-free’ or ‘very low gluten’. Instead, if steps have been taken to control gluten cross-contamination, caterers will be able to indicate which foods do not contain gluten containing ingredients. This allows people with coeliac disease to make choices about the food they eat based on their individual levels of sensitivity
I agree that a conservative viewpoint of the above could take a "high risk" option although as i understand the above extract would also specifically exclude product labelling statements such as "gluten-free". The above extract seems to me a rather Russian Roulette scenario for people suffering from coeliac disease, ie Thanks but No Thanks.
I can certainly understand yr requirement of COAs in this situation. I presume this facilitates the use of a PRP at the raw material reception stage.
However, unless the OP is also faced with a situation of above complexity, I anticipate they will need a labelling CCP with a "contains gluten" statement and a Risk status of Low. Unless further local legalities dictate of course.