Allergen Control Program for a Wheat Flour Mill

Hello All,

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?

Thank you,

KWP

I think you will be fine. If you labelled Gluten Free, you'd actually have to swab to ensure that you've removed any residue. 

If you archive you're current version, if you do have to go back, it's an easy switch

Which flours are you milling that are gluten "reduced"?

Hi Scampi,

Thank you for your input and help with this and my Supplier (Farm) Questionnaire. One question- I am correct in the notion that I simply reduce the Allergen Program to focus on our labeling? And not worry about storage, cleaning, handling, etc? I suppose I should be thankful for an easy out.....it just seems I am leaving so much out. But I guess it doesn't apply?

We mill Barley, Teff, and Buckwheat Flour.

Thanks again!!

You do still need to include segregation of allergens (easier for you to segregate your non) in storage and ensure employees are trained for handling.  Labeling cannot be used to replace good GMPs, however, because you're label is clear and you are NOT offering a "wheat free" product or claiming as such, I would keep it to a minimum.

I have a friend who's a celiac and only buys non wheat flour from locations that do not process wheat at all.....her threshold for a reaction is so minute and I don't know how any mill could actually remove the protein from wheat completly. 

https://www.verywell...n-gluten-562844   (barley is not gluten free according to this)  But gluten is not an allergen of course

Dear KWP,

Despite your current goal isn't to use the claim "Free from wheat/gluten", it's OK have all the GMP measures in place.

It would be interesting anyhow, to take some samples of your product, after your system is purged. That gives you a much better vision of the situation, based on which you can advise your direction on what steps to take in the next years. 

Allergen management is a hot topic in the quality landscape. It has been integrated in the food legislation over the last years. It will not surprise me, that the requirements will be stricter in the future. It's better to be prepared.

For about your policy. You have what you have in place, I think that your description gives a very clear vision of the situation. As mentioned (however not knowing the context), maybe with a few "small" steps, you can take some important steps in you allergen approach.

Kind regards,

Gerard Heerkens