HACCP plan for gluten-free products

Hi!
Following because I am looking for ways to check we have removed gluten from baking trays before going on to non gluten product.
Currently there is no verification of the cleanly, they are just thoroughly washed and dried before going on to the next product.
The gluten free products are produced in their own stand mixer in their own room, so it's only the trays that are used for both products.
The HACCP plan is also set up now as one flow that includes dough products, baked products and gluten free/gluten.
Do you think I can keep it just as one flow? I think in this way, I will be able to avoid doubling up a lot when I do the risk assessments.

Zanorias said -
 

AJL I would certainly recommend you verify and document the (hopefully?) effective cleaning to remove gluten prior to gluten free production, especially if making a claim or reflective allergen labelling on the product! You can have both gluten and gluten free in the same HACCP flow as long as the processes are similar and both follow the flow. 

I notice you have a dedicated room and mixer for gluten free and if the only common equipment used for both gluten free and gluten containing is baking trays, would it not be easier to have dedicated trays too and reduce the risk of contamination through shared equipment? Perhaps it has been considered and not feasible, but in any case you should at minimum verify that "thorough" cleaning is "suitable" to remove gluten.

 

Zanorias, thank you- yes it is a potential route that we could use different trays for the gluten free. 

I am NOT saying there is no verification that our gluten free product is in fact gluten free. But confirming that the product is gluten free by worst case scenario testing of next product after the allergen is different to actual cleaning validation, which is what I was hoping to go for. 

I was hoping for something a little more productive, like a validation process where someone has sent in swabs or something along those lines? 

Maybe a procedure? :)

We do line the trays as well with paper when we are producing gluten free products, which further reduces the risk. But yes, ideally we would go over completely to dedicated trays -  $$$ ! 

Thanks for the comments about the HACCP flow- I would like to keep it as it is with just one flow. 

There is gluten which is actually the only allergen, and some products do get baked, but I guess it's always possible to reflect all these processes on the same plan - I wanted to simplify the plan by splitting the flow up, but I guess I had been thinking more because I wanted to make my product decriptions a little more simple- having 'combined' product descriptions can somtimes make it a little confusing for me - but I guess that is more due to a lack of experience than anything else.