Allergen management regarding gluten
Hello,
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!
Thanks,
For the purposes of addressing allergen cross-contact I would consider gluten containing foods to be allergen foods under SQF, especially if you have other products with a "gluten-free" claim.
AFAIK, on the FDA side "gluten" is still not enforced as an allergen, and people wishing to avoid gluten in general would need to look at your ingredient statement and see that it contained barley or barley gluten and therefore was not for them. There are a lot of real celiacs out there, enough to where I would potentially treat all gluten containing foods as an allergen, and it looks like SQF agrees.
Nice thing is though, FDA has an actual exposure limit for gluten. So if you can prove that any carryover from your previous product following a simplified or dry cleaning process would result in gluten below 20ppm then the following product would meet the definition for "gluten free" so I would consider that process sufficient.
Appreciate the feedback.
I guess my biggest question is that if we are supposed to treat it as an allergen here in the facility, it would fall under our allergen management program. This would in turn require us to have it labeled as such. This would then result our finished product needing to have the allergen label of gluten per our policy.
Update the policy to indicate that gluten shall be treated as an allergen except as labeled on the final packaging?
Hi,
it depends on the area of distribution which determines the labelling on pack.
In the EU (and other areas in the world) there is no doubt that barley has to be labelled as allergen.
There are always some differences: Whereas oat is in the EU an allergen (with special exceptional regulations) it is not in the US. Compare the list of tree nuts you will see huge differences between US/EU,
Rgds
moskito
Hi antond,
I agree with moskito. It matters on where you are selling your product. The sqf code states "the allergen management program shall include the identification, management, and labeling of products containing gluten, where applicable". My company sells to both Canada and the U.S. Canada considers gluten an allergen so because of that, we segregate gluten and treat it as an allergen (along with mustard and sesame seed). However we only specifically label gluten in the ingredient statement (e.g. "contains gluten") when the product is going to Canada. If the product has barley and it's only going to the U.S., we interpret the code to mean that per U.S. regulations, it's not applicable to label the gluten in the barley*
I hope that makes sense!
*Sigh, if it were easy to backtrack and label all of our gluten-containing products (that are only going to the U.S.), we would... but we just have so many!!!