Food Safety First Newsletter

FOOD SAFETY FIRST

October 2017

In this issue

A Message from the Vice President
Training Testing Staff
Impact of GF Labeling Reg
Proficiency Testing Sign-Up
Gluten-Free Oats in Canada
Precautionary Allergen Labels on Certified Products
Meeting Notes
Certification Updates
GFCO Contact Information

A Message From GIG’s Vice President of Food Safety

Hello Certified Companies and Affiliates!

It’s been a long time since I’ve spoken with many of you, and others are brand new to GFCO and the GIG family of programs. I want to take the opportunity of the change in season to thank you all for being a part of our certification program, our mission, and most importantly, the gluten-free community. Much like many of you, we started this program from the ground floor, pouring our hearts into everything we have built. We’ve worked countless hours to build up the reputation and grow to meet the ever-increasing market demands. GFCO started because of a consumer need to quickly and easily identify products that are safe for celiac people, including many of the children and family members of our staff. With the addition of our ISO 17065 Accreditation last year, we have made many updates to policies, procedures, training, etc. Essentially, every part of our program has been elevated to the next level. Our team is excited to share the news that this year’s recently completed audit for our ISO Accreditation yielded zero non-conformances. How amazing is that!?!

If you follow our social media, you have seen some of the incredible things that our organization has been able to do this year, including sponsorship of 29 celiac children to attend summer camp over the summer of 2017, numerous Generation GF gatherings and support meetings for kids and teens with celiac disease, groundbreaking research about gluten-free beer, the gluten-free status of spices and much, much more. Let me tell you, we are just getting started! We went from our first certified company in 2005 to now well over 2,300 certified brands, encompassing nearly 50,000 products globally. We have added some fantastic staff to our Food Safety team over the past couple of years and more will be arriving soon to keep up with our growth of business. Transparency is our goal as changes must be implemented to ensure impartiality of our certification, as well as allow for the continued scaling of the program.

This growth has allowed us the ability for some crossover between our certification programs, especially in the realm of food service. Do you have a certified product that is sold for use in food service establishments like restaurants, hospitals, or college campuses? We can provide information to ensure the safe handling of your products in these institutions, as well as instructions for obtaining GFFS certification. We offer training and even certification of restaurants under our Gluten Free Food Service Certification. These food service companies can even receive a discount on their certification for being a verified customer of a GFCO company. We are working out the details of additional partnerships and opportunities that will provide you with even more savings so look for announcements about these in the weeks and months to come.

On behalf of the entire GFCO team (and truly, our entire organization), from the bottom of my heart, THANK YOU for choosing GFCO for your gluten-free certification. Thank you for riding out the bumps of growth with us and understanding some of the challenges even nature has presented us in our Florida office recently. Thank you for your support and feedback as we have grown. Please let us know if you are interested in any of the amazing marketing opportunities or other partnering options that we have as an entire organization. We want to help ensure the growth and success of all of the companies who have believed in us too.

Channon Quinn

Vice President, Food Safety

REMINDER: Testing Submissions for the third quarter of 2017 were due on October 10th. Please make sure you have submitted your data to [email protected] .

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Training and Competency Evaluation for Testing Staff

Requirement 71 of the GFCO Certification Standard states that “ All Plants and Brand Owners performing testing in their own facility must have documentation of the training of the employees performing the tests, including annual competency testing”. This article will give you some ideas for meeting this requirement.

The first thing that requirement 71 asks for is training. Any employee who will test ingredients or finished products for gluten, or who will do swab testing, must be trained on the test method. Start by choosing a test method from the GFCO Approved Kit list (attached). If your plant is new to testing, ask the kit manufacturer if they can provide you with a video or other training materials, and keep a record of the staff who take this training. This is also a good idea if your plant has been testing for a while but does not have records that show that the staff have been trained. Once you have trained one or more of your staff members, they can provide training to new employees.

Keep records of all training. Write down the training date, the names of the staff members that were trained, and how the training was done (e.g., watched video from kit manufacturer, or demonstration from current testing staff). Your training records can also include results from any quizzes, or observation notes from the staff member giving the training.

Once your staff have training records on file, you will want them to show that they are competent at testing. One quick way to do this is to have a trained supervisor pick 2 or more food samples, some with gluten and some without. The supervisor will test the gluten content of each sample using your in-house test kit, then package these samples to conceal their identity, keeping a private record of each sample’s gluten result. The “blinded” samples are then given to the testing staff as unknowns, to be tested and recorded like all other samples. For swabbing, the supervisor can intentionally contaminate a surface with gluten-containing or gluten free materials. Competence can then be shown by comparing the test results obtained by each staff member to the known gluten content of the samples/surfaces, as well as by confirming that each staff member is recording the test results correctly.

Competency can also be assessed by splitting 2 or more samples and having one set tested by a staff member and the other set tested by an independent ISO 17025 accredited laboratory, or by assigning a staff member to participate in the plant’s proficiency testing round. In every case, the staff member’s testing results and quality of test records/reports should be evaluated. The results of all competency evaluations should be recorded, and any errors should be followed by re-training or other corrective action.

Competency evaluation should be done each year for all staff that perform gluten testing. Keep in mind that competency evaluation and proficiency testing are two separate things. Competency evaluation is designed to show that your staff are performing testing according to your internal procedures, but proficiency testing is meant to show that your testing procedures give results that are in line with all other test kit users.

Impact of Gluten-Free Labeling Regulation

The US Food and Drug Administration (FDA) final rule on gluten-free labeling went into effect in August of 2014. This August, at the three year anniversary of the ruling, the FDA posted an interview with Drs. Carol D’Lima and Alessio Fassano, talking about the impact of this regulation.

In the interview, the Drs. D’Lima and Fassano point out the great work that manufacturers have done in embracing the ruling and providing a wide range of products for gluten-free consumers. We at GFCO agree that industry has gone above and beyond in complying with gluten-free labeling rules, and especially applaud those companies that have taken the extra step to certify their products as gluten-free. This has been integral in allowing shoppers to easily find safe products, and in building trust with gluten free consumers.

The full text of the FDA interview can be found at:

https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm577489.htm

GFCO Proficiency Testing Registration Now Open

GFCO will be accepting registrations for participation in the 2017 GFCO Proficiency Testing (PT) round until October 31 2017. This gluten proficiency testing program is being offered to all companies that carry a GFCO product certification, as well as to their manufacturing plants. If your company or manufacturing facility performs in-house gluten testing, participation in this program is one way to meet GFCO Standard requirement 72. If your company or facility does not do any in-house testing, but meets all of their testing requirements through the use of outside laboratories, then this requirement is not applicable and you do not need to participate in a proficiency testing program. In this case you must be prepared to provide laboratory testing results to the GFCO auditor to show that you are exempt from the proficiency testing requirement.

To register, go to http://www.gluten.org/proficiency-registration before October 31, 2017 and complete the registration form. A separate registration form will be required for every facility that wishes to participate. The cost for participation is $100 per registration.

During the month of November, testing samples will be shipped to every company that has registered. Along with the samples, participants will receive testing instructions as well as information on submitting the test results and test kit data online. GFCO will not provide test kits for this program. Participants are expected to use the gluten test kits that they typically use for in-house testing.

Participants will have until December 31, 2017 to submit their test results and test kit information online. Every facility that submits data will receive a unique participant number. A final report will be sent to all participants during the month of January, 2018. In this report, all results will be identified only by participant number in order to maintain confidentiality. Participants will be able to review their results by their unique identification number, and with enough participation we will be able to break the results down by test method/test kit.

There is a chance that one or both of the proficiency testing samples may contain gluten, so participants must be prepared to handle the samples in a way that will not affect the gluten-free status of their facilities, equipment, raw materials or finished product, and also not adversely affect employee health.

Proficiency testing helps to demonstrate that the companies that make GFCO certified products are competent and qualified to assess ingredient and product gluten safety using in-house test methods. We are looking forward to a successful PT round!

PT Timeline:

September 1 through October 31: Register online
November 1 through November 30: PT samples sent to all registrants
December 31: Deadline for submitting PT sample results online
January 2018: Final report sent to all participants

Gluten-Free Oats in Canada

Oats are considered a gluten containing grain under Health Canada regulation. But after a thorough review of studies on the safety of oats for persons with celiac disease, Health Canada in 2015 issued a Marketing Authorization which allows specially produced or processed oats, and products containing them, to be labeled gluten-free. The specific requirements of this Marketing Authorization are:

Any oats used in gluten-free products must be specially produced/processed to be free of wheat, rye and barley
Any reference to these specially produced/processed oats must refer to them as “gluten free oats”, to show that they are different from regular oats. This means that they must be listed as “gluten free oats” in the ingredient list, and anywhere else they are mentioned on packaging.

This requirement differs from US labeling regulations, and may require companies selling certified product to use separate packaging for each country

Precautionary Allergen Labeling

In the last two issues of Food Safety First, we have taken a look at the use of precautionary allergen labeling (PAL) by companies that manufacture GFCO certified products. The use of statements such as ”may contain wheat” or “processed on shared equipment with wheat” on certified gluten-free products generates a lot of questions from gluten free consumers. To respond to these questions, GFCO has written a guidance document for consumers to help them understand what these kinds of labels mean on certified products. The following is the section of that document that helps them interpret these statements. We are sharing this with our manufacturers so that you can reference it in the event that you receive questions about PAL from gluten free consumers:

HOW TO INTERPRET VOLUNTARY ADVISORY STATEMENTS AND ALLERGEN STATEMENTS ON GFCO CERTIFIED PRODUCTS

“May Contain Wheat”: This statement may be used by companies that handle wheat in their facility, but keep it segregated from gluten-free production. Plants that produce GFCO certified products and also handle wheat take additional precautions to ensure that all ingredients and the certified finished product contain <10 ppm gluten.
“Processed on Shared Equipment with Wheat”: Some GFCO certified products are made in facilities that also manufacture products that contain wheat, but these facilities have very strict controls, cleaning protocols, and equipment and product testing requirements to ensure that gluten remains below 10 ppm in their gluten-free finished products.
“Contains Wheat”: Should only be used if wheat has been intentionally added to a product. On a GFCO-certified product this would indicate that the product contains wheat starch, wheat grass, or some other gluten-free component of wheat. If a product is GFCO certified you can feel safe in knowing that the product contains less than 10 ppm gluten, which is twice as strict as the FDA labeling requirement for gluten-free labeled products. In addition, a food whose labeling includes the term “wheat” in the ingredient list or in a separate “Contains wheat” statement as required by the Federal Food, Drug, and Cosmetic Act (the FD&C Act) and also bears the claim “gluten-free” will be deemed to be misbranded by the FDA unless its labeling also bears additional language clarifying that the wheat has been processed to allow the food to meet FDA requirements for a “gluten-free” claim.

Meeting Notes

This year, GFCO was represented at the International Celiac Disease Symposium (ICDS) in New Delhi, India, the AOAC International meeting in Atlanta, GA, and the American Association of Cereal Chemists International (AACCI) meeting in San Diego, CA. At all three meetings, GFCO presented scientific data that we are using to help make decisions about certification requirements and food safety. As this data is published, links to these studies will be made available in future issues of Food Safety First.

The following are some other highlights from these meetings:

AOAC has published Standard Method Performance Requirements for detecting wheat, rye and barley in oats
The R-BioPharm RIDAQuick Gliadin was approved as a Final Action Official Method by the AOAC Research Institute
Several new therapies for celiac disease were presented at the ICDS meeting, including transglutaminase 2 (TG2) inhibitors, short gliadin/hordein peptides intended to block HLA DQ2.5 (Nexvax), antibodies to block IL-15, and budesonide for refractory CD. All of these have shown benefits for some persons with CD, but there are none yet that are ready for widespread use. With the exception of Nexvax, which is intended to induce immunological tolerance to gliadin, the patients receiving these treatments would still need to maintain a gluten-free diet.

Certification Updates

On September 29th, GFCO completed its ISO 17065 surveillance audit with zero non-conformances. ISO 17065 is an international standard for product certification, and our adherence to this standard is verified by an independent accreditation body, A2LA . GFCO maintains this high standard for product certification because we believe it is essential for the gluten free community that we operate a true product certification scheme, as opposed to the management system certification schemes offered by other organizations. Our goal will always be to identify the safest foods for gluten free consumers.

REMINDER: Please notify your Customer Service Representative of any changes to your certification. This might include adding, removing or changing products or ingredients, adding new production lines in your plant, or moving production into or out of a facility. This last one is very important, because we schedule annual audits at each plant that we have on file for a company. We do not want to send an invoice for a plant audit and later find out that your company is no longer working there.