Gluten, as defined by BRCGS, is a protein fraction (e.g., gliadins or glutenins) from wheat, rye, barley, unverifiable oats or their crossbred varieties and derivatives thereof, to which some persons are intolerant. Therefore, a product that will be certified Gluten-Free under the BRCGS Gluten-Free Certification Program (GFCP) global standard must not contain gluten and the site must have controls in place to successfully develop, implement and verify compliance.
A site must meet its regulatory obligations and develop a Gluten-Free Management System (GFMS) which will include a HACCP plan and supporting Pre-Requisite programs to become certified. This approach mirrors that of a site’s existing Food Safety System, if it is already certified to the BRCGS Food Safety standard or other GFSI benchmarked schemes.
The following are some of the key requirements within the standard:
- Senior leadership commitment is a vital component by providing the necessary resources to ensure gluten-free products are produced.
- Leadership must communicate to personnel their responsibilities and importance of the site’s GFMS programs.
- A written policy and procedures for implementing and maintaining an effective GFMS.
- An appointed GFMS Team Leader who has the responsibility and authority to oversee the development, implementation, review, and maintenance of the GFMS.
- Fully implemented and operational program (e.g. Pre-Requisites).
- Conduct a Hazard Analysis based on CODEX HACCP principles.
- A robust Gluten-awareness training program including gluten-handling procedures and Team Leader must have in-depth knowledge and show competency of GFMS principles.
- Supplier approvals that show proper identification and control of gluten.
- Sampling and testing plan that is based on risk of all inputs, process, work-in-process, and finished product.
- Records that demonstrate the effective application of control measures and overall compliance.
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To further guide you along the journey to becoming BRCGS Gluten-Free certified, here are some helpful tips:
1. Select and Train the GFMS Lead
Deciding who in your organization would be the best fit to champion this program may seem like an easy choice as you already have a food safety lead but it does not have to be the same person. Take the opportunity to discuss within the senior leadership team if there should be a different person to develop, implement and maintain the program, such as your head of R&D or an individual that is working alongside the food safety lead. Once selected ensure they are have taken and passed the GFCP industry training course, or equivalent course that is acceptable to BRCGS.
2. Combined Approach
When developing the Gluten-Free Policy or the other supportive programs, there may be an opportunity to build on existing framework instead of creating it new. BRCGS has stated that the policy may be combined with an equivalent policy as part of another food safety management system. Additionally, the HACCP plan remains the same 7 principles but with the incorporation of gluten has a hazard including re-assessment of the GFMS as part of the overall process.
3. Verify and Validate
Control measures must be validated and recorded. A risk based analysis will determine the appropriate sampling and testing to detect gluten presence on environmental surfaces (e.g. equipment), raw materials, and finished product. Selection of appropriate methodology for inspection including testing will ensure not only the initial validation but the continual verification of the site’s GFMS program effectiveness.
4. Be Audit Ready
Having an internal audit program with GFMS and the GFCP Global Standard elements is a requirement to ensure the activities to implement the system are in place and working as intended. This proactive approach will ensure issues are identified before the audit, corrective actions taken and for the site to drive continuous improvement.
5. A Helpful Guide
Don’t forget to review the Appendices in the standard which provides a more comprehensive understanding of certain complex topics such as sampling and testing in Appendix 5. This risk management guidance section offers an overview of best practices to evaluate the risk of contamination, define sampling parameters, testing methodology, interpret results and validation programs.
Overall the BRCGS approach adds an advanced level of requirements compared to other Gluten-Free certifications. It requires developing specific programs, challenging the current internal systems and ensuring management commitment with the focus of potential gluten presence. This creates a stronger foundation and confidence in a site’s programs and upholding consumer confidence and trust that your products are verified gluten-free.