Is Your Facility Gluten Free Audit Ready?

Jessica Burke, Manager, Compliance & Technical Services, Allergen Control Group Inc.

So you have decided to go down the road of certifying your facility in the Gluten-Free Certification Program (GFCP). The road to GFCP certification involves several steps. While you may have done your due diligence in learning about the requirements of the program, signing your agreement and booking your audit, you can never be too prepared. Too ensure you are audit ready our technical team has prepared a summary of the top GFCP audit non-conformances so you can ensure you cover these requirements.

We often see non-conformities (NC’s) around GFCP employee training and education. The most common non-conformance in this area is failure to provide evidence of temporary and/or full time employee training around gluten control.

We recognize that employee Training is a big challenge in many facilities, especially where temporary employees are utilized and turn-over is high. However, it is important to remember employees are your greatest resource. Knowledgeable employees are more likely to follow GMPs, and will make educated decisions, reducing the company’s overall risk.

Corrective actions to NC’s around GFCP employee training may include the development of an information sheet that must be reviewed and signed by temporary employees prior to their first day of work. The record might be e-mailed to the facility by the Temporary Employment Agency, or the employee could bring the hard copy with them on their first day. A training matrix is a very useful tool for tracking employees, training modules that have been covered, and training dates. This allows employees that are absent during training sessions to be easily tracked and training scheduled upon their return.

Non-conformities around gluten containing ingredient storage are also prevalent. Common examples include the absence of gluten or allergen labels on gluten containing ingredients, and the storage of gluten containing ingredients with non-gluten containing ingredients.

The best way to ensure appropriate ingredient storage is to make it as easy as possible for employees to identify gluten and non-gluten containing products.

Corrective actions might include labelling designated shelves with stickers which indicate the allergens that are permitted to be there. Colour coded allergen stickers can be very useful as they provide a visual tool for employees to quickly assess the appropriate storage location for ingredients. Labelling ingredients immediately upon receipt will aide in the identification of gluten and non-gluten containing ingredients from arrival right through to point of use.

Regardless of the non-conformity, well thought out and thorough corrective actions are the key to preventing reoccurrence and reducing risk.