Vendors are mentioned in only two of the 80 GFCO Standard requirements, but don’t let this fool you — ingredients are a major source of risk in gluten-free production, and proper vetting and review of raw material suppliers is essential to mitigate this risk.
The GFCO Standards that directly mention vendors are:
- The Gluten Program must contain a procedure for the selection and approval of raw materials and vendors for those materials. This procedure must specify the documentation that the client will accept from each vendor, such as vendor statements, testing data, or 3rd party certification, to ensure that all raw materials meet the GFCO 10 ppm limit.
- The Plant must maintain a list or lists of approved vendors and raw materials.
It is essential that gluten-free manufacturers evaluate and approve their suppliers, and only use the suppliers they have approved for the raw materials they use in gluten free products. Manufacturers should decide on the criteria they will use to approve their suppliers, and then apply these criteria to every potential supplier. Along with the usual variables of price, material quality and reliability, vendors should also be assessed for their gluten safety. Some methods for evaluating the gluten safety of a supplier are:
- Performing on-site audits of the supplier to see their procedures and practices first-hand
- Confirmation of any 3rd party certifications held by the supplier
- A request for statements from the supplier that describe their gluten safety measures
- A request that the supplier provide gluten testing data with every lot of material
GFCO does not require that manufacturers collect vendor statements, or testing data, from all of their raw material suppliers as part of this approval process. Instead, GFCO provides manufacturers with risk factors of 1 through 4 for each raw material, with levels 3 and 4 considered to be materials with a high risk of gluten contamination or cross-contact. These risk levels assist in determining the type of vetting and/or documentation that a manufacturer should require when choosing or approving a vendor.
Risk level 1
ingredients are those that typically do not contain protein, and do not share any part of the supply chain with gluten grains. These ingredients do not need vendor statements for gluten.
Risk level 2
ingredients are those that typically do not share any part of the supply chain with gluten. While GFCO does not require regular testing for these ingredients, we do recommend that clients collect vendor statements or perform testing on the initial lots that they purchase, and do this again any time they change suppliers, or any time their supplier reports they have changed their own sourcing, to make sure their supplier has addressed any gluten risks.
Risk level 3 and 4
ingredients share parts of the supply chain with gluten grains, and/or have been the subject of gluten-related recalls. For these reasons, GFCO requires testing on each lot of these high-risk materials. Manufacturers do not need to collect vendor statements on these ingredients as long as they are doing the assigned testing, but they may want to collect them and submit them to GFCO to determine if they are suitable for reducing the risk level of the ingredient.
No matter how a supplier is chosen and approved, it is essential that the plant maintain the documentation that they’ve used to approve the supplier, keep a list of approved suppliers, and only buy their raw materials from those suppliers.
Once suppliers are chosen, it is important to review their performance on a regular basis. At least once a year, a review of any quality, timeliness or safety issues will provide information for the manufacturer to decide if they want to continue with their supplier, or look for others. Strong relationships with suppliers, built on factual performance information, are essential for the production of safe gluten-free foods.