I need to develop an Allergen Control Program for a flour mill which produces primarily wheat flour. We do produce a few non-gluten origin flours but we do not claim that they are gluten free. Our labeling states "Produced on Equipment that Processes Wheat" (our current statement is a work in progress as well).
All of our grain is stored together segregated only by Conventional and Organic origin. So wheat and non-wheat/glutenous grains are stored next to each other.
When producing non-gluten flours we do a thorough cleaning of the milling system and a purge at the beginning of the product run to ensure that the system is as clear as possible of residual previous product. We do not test for residual allergens and we do not claim that our non-gluten origin products are wheat/gluten free. So in a sense we are NOT controlling allergens in our facility.
Our only "control" is through our labeling. Each wheat product we produce is labeled with 'wheat' in the product name, or if 'wheat' is not in the name a "contains wheat" statement is printed on the label. As I mentioned for non-gluten origin flours the allergen warning "Produced on Equipment that Processes Wheat" is currently being used. Our labels are generated in-house and we do have a label generating and check policy and SOP as well as verification.
I have a pretty standard Allergen Control Program template to work from, but as I have read it all I can imagine myself doing is cutting it down to a few short points since it seems to me there is NO control aside from our labeling. It makes sense to me that I will have a very short allergen program but I am a little nervous cutting out so much information without having anything to add back in. Does anyone have any suggestions or support on this matter?