Thanks you. IS there any specific requirements for Gluten free
You sell product into the UK if I remember correctly?
It may depend to an extent on the expectations of your customers - typically our clients supplying the retailers and large brands ask for considerably more detail than a standard allergen questionnaire, and also use the answers as part of a risk assessment process to then determine whether sites need a physical audit of their gluten controls (even for sites that have been "approved" as suppliers in the normal sense, are BRC/IFS/FSSC22000 certified etc) . I'm not saying that it's truly necessary, but the UK market has one or two over-the-top idea and it can unfortunately be necessary to jump through the hoops to be able to do business here...
Confidentiality requirements preclude me sharing specific documents here, but common questions I see are:
- Is any material containing gluten used on the same line as the product(s) supplied? If so, what form does it take, and how is it controlled?
- Is any material containing gluten used in the same factory, but not on the same line? If so, what form does it take, and how is it controlled?
- Is any material containing gluten stored in the facility, even if it is not used? If so, how is it stored and controlled?
- Are all staff trained in allergen control systems and allergen awareness?
- How is the cleaning process validated and how frequently is this done? (They also usually request evidence of the validation, and want to know the accreditation status of any laboratories used for testing, whether the analysis is within the scope of accreditation etc)
- How is the cleaning process verified and how frequently is this done? (again evidence is usually requested as for validation)
- What storage and segregation controls are used in the facility?
- Is production scheduling used as a control to prevent cross contamination? If so, are the staff responsible for scheduling production trained in the allergen control requirements?
- Are any of the raw materials used in the product sourced from suppliers that also handle gluten? If so, are the suppliers' controls verified during supplier approval, how is this done, and how frequently is it reviewed?
- What finished product testing is conducted to validated and verify the gluten-free status of the ingredients(s) supplied?
- Can you confirm that all products supplied will contain less than 20ppm gluten and are suitable for a gluten-free claim in accordance with regulation (EU) 828/2014?
- Are you able to provide a certificate of analysis for each batch showing the gluten content? If so, is the analysis from an accredited laboratory? If not, please confirm how the method has been validated.
I'm sure there are more questions but those are the main ones I recall off the top of my head. Again I'm not saying that you have to take this approach, but providing it as a guide as to what others are doing in the market here...
