Gluten Free Measuring
Good Day!
We are an SQF certified site making regular and gluten free products. We have Gluten Free Certification with BRGCS. We have always had a dedicated room for this but now we are moving to non-dedicated. We measure our ingredients the day before production, so I'm having trouble figuring out how to measure gluten free ingredients without any cross contamination. We don't have a separate room to do this. We have warehouse space to keep all the ingredients separate, but it is not suitable as per SQF standards for food production (floors and walls not to SQF code). I'm not sure how to go about measuring. We've tried cleaning, testing for gluten in the pm after production (negative result), testing again in the am at the start of production (negative result) and 2 hours after production starts (positive result), so this can't be done in the regular measuring space even though it is a ways away from production. Is my only option to stop production 2 days earlier to measure? Thanks for any other ideas.
Hy there hope you doing well,,
the far i can see is you have problem with your positive result on GF testing right after 2 hour production? what kind of measuring that you done? like method or somethings, or you use external Laboratory or in house testing?
but i can see you have problem with cross contamination, have you ever do the root cause analysis? and what kind of cleaning that you have done?
hope its can help you,
thanks and regards
Jens
As mentioned in previous comment, have you done a risk analysis to see where the potential cross-contamination is coming from? Have you considered other factors such as contamination coming from employees or the equipment?
Treat them as you would allergens. Obviously you could have gluten free ingredients in with the gluten as there would be no issue, it is the other way around that is the issue. Thus treat the gluten ingredients as allergens. So figure out a way you can utilize this to your advantage for measuring. Are you down on the weekends? If so, maybe try doing a rigorous cleaning Friday, do your gluten test after cleaning, test again Monday morning and then maybe try to set your schedule that on Mondays and Tuesdays you do all your measuring in the room for Gluten free ingredients. Pull those out then Tuesday and place back into storage. Then the rest of the week it is Gluten ingredient measuring only. Just an idea...
Require employees to use different scoops for regular and gluten-free ingredients. If there is any chance of dust or cross-contamination, your best bet is to measure them in separate places as well.
Force the company to go back to dedicated
As i'm sure you're aware-the consequences for someone with celiac disease from exposure are just as damning as someone with a peanut allergy
Ethically, if you're testing positive after 2 hours--non-dedicated is just a pipe dream as you can no longer call your products gluten free
If the label of a prepackaged product declares that due to the risk of cross-contamination, the product may contain a food allergen or gluten, the cross contamination statement:
- must be declared immediately after the "food allergen source, gluten source and added sulphites" statement or, if there is none, the list of ingredients, and must appear within the same background colour and/or within the same solid borders as the statement or list of ingredients [B.01.010.4(1)(a)(i)-(ii), FDR]
- must appear without any intervening written, printed or graphic material between it and the "food allergen source, gluten source and added sulphites" statement or, if there is none, the list of ingredients [B.01.010.4(1)(b), FDR]
- must appear in bold, if the cross contamination statement is not introduced by a title and if the cross contamination statement begins on the same line immediately after the list of ingredients or the food allergen source statement that precedes it [B.01.010.4(1)©, FDR], and
- if the cross contamination statement is introduced by a title, that title must appear in bold if the statement begins on the same line immediately after the list of ingredients or the food allergen source statement that precedes it [B.01.010.4(1)(d), FDR].
BTW SQF cannot pull your license to operate, that's CFIA. When they come to inspect (and they will if they haven't already) be fully prepared to back up your gluten free claims with good data
Force the company to go back to dedicated
As i'm sure you're aware-the consequences for someone with celiac disease from exposure are just as damning as someone with a peanut allergy
Ethically, if you're testing positive after 2 hours--non-dedicated is just a pipe dream as you can no longer call your products gluten free
If the label of a prepackaged product declares that due to the risk of cross-contamination, the product may contain a food allergen or gluten, the cross contamination statement:
- must be declared immediately after the "food allergen source, gluten source and added sulphites" statement or, if there is none, the list of ingredients, and must appear within the same background colour and/or within the same solid borders as the statement or list of ingredients [B.01.010.4(1)(a)(i)-(ii), FDR]
- must appear without any intervening written, printed or graphic material between it and the "food allergen source, gluten source and added sulphites" statement or, if there is none, the list of ingredients [B.01.010.4(1)(b), FDR]
- must appear in bold, if the cross contamination statement is not introduced by a title and if the cross contamination statement begins on the same line immediately after the list of ingredients or the food allergen source statement that precedes it [B.01.010.4(1)©, FDR], and
- if the cross contamination statement is introduced by a title, that title must appear in bold if the statement begins on the same line immediately after the list of ingredients or the food allergen source statement that precedes it [B.01.010.4(1)(d), FDR].
BTW SQF cannot pull your license to operate, that's CFIA. When they come to inspect (and they will if they haven't already) be fully prepared to back up your gluten free claims with good data
Further to above
B.24.018 It is prohibited to label, package, sell or advertise a food in a manner likely to create an impression that it is a gluten-free food if the food contains any gluten protein or modified gluten protein, including any gluten protein fraction, referred to in the definition gluten in subsection B.01.010.1(1).