Our company has gone back and forth whether or not to list out "gluten from barley" in the allergen portion for our specifications. We recently (over the past 7 months) have researched and determined that the FDA does not require it to be labeled as an allergen. Reading through the SQF Edition 8 , it does state " the allergen managemnt program shall include the identification, management, and labelling of products containging gluten, where applicable".
Does this mean we need to treat it as an allergen and list in the allergen portion for labels, production scheduling, cleaning, etc?
I have always been under the impression it was more of a sensitizing agent, than an allergen.
any comment, link, or direction would be helpful on this! We want to make sure we aren't missing a big allergen management step!