Food Safety First Newsletter

January 2019

In this issue

2019 Buyer’s Guide - Action Needed
Production Batch Records
Expo West Opportunity
Certification Updates
GFCO Contact Information

2019 Buyer’s Guide - Action Needed

GFCO is putting together the first edition of the 2019 Buyer’s Guide, which lists all GFCO manufacturers and their certified Products.

GFCO clients have the ability to opt out of having their Company or Products included in the Buyer’s Guide.

Please contact Paul Vachris at [email protected] by January 31, 2019 if you would like to ask that your Company or Products NOT be included in this year’s Buyer Guide. If you would like your Company and Products to be included in the Buyer’s Guide, there is nothing you need to do.

REMINDER: Testing Submissions for the fourth quarter

of 2018 were due on January 10th . Please make sure

you have submitted your data to [email protected] .

Production Batch Records

The GFCO Certification Standard has four requirements that deal directly with production batch records:

40. The Gluten Program must include a requirement that each product be prepared from a detailed recipe/batch sheet/order, including a specific product number or unique name for each ingredient/raw material/formulation/process.

43. The Gluten Program must include a procedure for ensuring that the correct recipe/formulation is used for each product lot, including documentation that the recipe/formulation was verified.

44. The Gluten Program must include a requirement that records be kept for each lot of product; these records shall include the product lot number, date of production, size of production lot, identity of all equipment, machinery and packaging used in production as well as the product identification, volume and lot number of each raw material used. This batch record must be signed or verified by the employee preparing the lot, or by the production supervisor if multiple employees are involved in recipe preparation. These batch records must be maintained and available for a suitable period as determined by the client, but at least as long as the product might be used by the public.

45. The Gluten Program must include a procedure for ensuring that the correct raw ingredients and packaging were used in the preparation of each lot, and that a review of this information is documented prior to release of the lot.

Production batch records are an indispensable part of any product safety program, including gluten-free manufacturing. While they can feel like one more record-keeping task, well-kept batch records are invaluable in the event of a contamination incident, and can offer insight on the performance of your facilities and staff.

The first place where people think of reviewing their batch records is in the event of a recall, pullback or other production problem. Detailed batch records can help to limit the extent of a recall or pull-back, provide important clues in the investigation of the event, and provide peace-of-mind that the scope of a recall or pullback is adequate. These important functions are best completed when the manufacturer uses a consistent definition of a lot or batch, and when the lot or batch is as discrete as possible. While it isn’t possible in every type of production, lots that have a defined beginning and end, which use only one lot of each ingredient, and are made from one pull or staging of those ingredients, are best for limiting the scope of a recall or pullback. Manufacturers can vary from these optimal conditions, but must understand that it can lead to a wider scope in the event of a recall or pullback. For instance, if there is a contamination incident that is traced back to a specific ingredient, but that ingredient lot changed part-way through production, there is a chance that you will be recalling the entire batch even if only one lot of the ingredient was contaminated. The same thing could happen if the wrong ingredient is pulled mid-way through production and added into the batch, rather than staging all of the ingredients for production before it begins. In some types of production a batch cannot have this kind of strict definition, but the manufacturer should understand the risks involved in defining their batches this way, and take whatever steps they can to minimize this risk.

Detailed batch records can also provide valuable information that can be used to improve your manufacturing operations. By reviewing them regularly, you can see trends that may offer insight into possible areas of economization or consolidation of activities. For instance, since your batch records are recording the equipment/production lines used for each batch, a review may show that you have reached a production level where you could move all of your gluten-free products onto one line, saving the costs of changeover testing. Or you may see that one shift is making more errors in pulling ingredients than others, pointing out an opportunity for targeted training.

Batch records are an important, centralized storehouse of information about your operations, which is why they are the focus of multiple GFCO Standard requirements. Make sure your plants are keeping detailed and accurate batch records, and take advantage of all of the information they have to offer.

GFCO Offering Your Company the Opportunity to be at Expo West!

The Natural Products Association's Expo West, the largest show for our industry, is coming to Anaheim from March 6th to March 9th, 2019, and once again this year, GFCO is giving your company the opportunity to display your certified products as part of our booth in the main exhibit hall. Your participation will allow you to interact personally with more than 85,000 industry attendees, including buyers, distributors, industry reporters, and social media bloggers and influencers. Our booth provides a great opportunity for certified companies that would otherwise not be able to showcase their products at an event like Expo West and gain this important exposure at a fraction of traditional event costs.

Expo West is the perfect way to expand and gain recognition for your business. The cost to participate and be part of the GFCO booth is $2500 and includes the following:

Display space at GIG's Natural Products Expo West booth in 2019. Display space is 36" wide and 12" deep. You may display product packaging, specials, company info or finished goods, or any combination of the aforementioned items (no sampling).
Company / Brand Logo on the back display wall of our 40' x 10' booth on the main floor at Expo West.
Highlighting your company on our social media platforms on Facebook, Twitter, Instagram, and the GIG web site (www.gluten.org), during Expo week.
One (1) exhibitor badge to the Expo West show and exhibit floor.
The ability to network and promote your product to 85,000+ industry attendees.

To register your company to join us in the sunshine at Expo West, go to the following link: https://www.gluten.org/product/exhibit-product-gfco-expo-west-2019/ and click on the protected: Expo West 2019 Booth Space. From there:

Enter passcode "0474" to begin registration.
Complete the registration information form at the bottom of the product description and click to submit.
Purchase your shared booth space with GIG by adding your item to the cart and completing your transaction using a credit card (note, there will be a credit card processing fee).

Deadline for inclusion of your logo on our booth space is February 1st .

With any questions or difficulties completing the transaction, please contact either Channon Quinn, at [email protected] or 253-218-2956, or Chris Rich at [email protected] or 253-545-1826. We look forward to seeing you in Anaheim!

Certification Updates

On December 21st, GFCO sent an email to all GFCO clients notifying them of a change in the GFCO audit fees. All audits performed by the GFCO certification body on or after January 21st, 2019 will be charged at a flat rate of $700 USD, whether done within the U.S. or internationally. This is a small increase over the previous audit costs for some clients, and a small decrease for some others, and was necessary to standardize our systems, implement improvements, and maintain a high-quality auditing staff.

The GFCO grain count requirement, with a threshold of 0.25 gluten-containing-grains per kg of whole, intact grain products sold bearing the GFCO log, went into effect on January 1, 2019. This requirement only applies to finished products, not to a plant’s ingredients. Contact [email protected] if you have questions about this requirement and how it may apply to your operations.