Food Safety First Newsletter

Quarter 4 2020

In this issue

TTB Gluten Free Ruling
Safe Audits During Coronavirus
GFCO Standard Update
Coronavirus Update
ICT for GFCO Audits
2020 Proficiency Testing
Plant Changes
Public Product List
2020 Gluten Free Beer Conference
GFCO Contact Information

TTB Gluten-Free Ruling

On October 13, 2020, the United States Alcohol and Tobacco Tax and Trade Bureau (TTB) released ruling 2020-2, titled Gluten Content Statements in the Labeling and Advertising of Wine, Distilled Spirits, and Malt Beverages. This new ruling supersedes the previous TTB ruling, 2014-2, on gluten-free labeling.

The change in this new ruling is that “TTB is revising its policy to allow the term “gluten-free” on labels and in advertisements for distilled spirits distilled from gluten-containing grains as long as good manufacturing practices are followed that prevent the introduction of any gluten-containing material into the final product”.

The TTB determination under this ruling also states that “Any industry member making a “gluten-free” claim on a label or in an advertisement to describe a product that is comprised of a distillate distilled from gluten-containing grains and of other protein-containing ingredients should be prepared to substantiate, upon request, the absence of protein in the distillate and the absence of gluten in any added ingredients, and to verify that the producer has taken appropriate measures to ensure that the product or its ingredients is not subject to cross-contact with gluten after distillation.” GFCO has issued a guidance that discusses the use of protein testing in distilled spirits, and other documentation measures, in response to the recent FDA ruling on fermented and hydrolyzed products.

REMINDER: Testing Submissions for the third quarter of 2020 were due on October 10th. Please make sure to submit your data to [email protected]

Automated reminders will now be sent 45 days after the testing due date, to any client who has not submitted testing data or a notice that they did not produce certified products during the previous quarter. Testing and the submission of testing data are a requirement for certification, and the failure to submit testing data, or a notice that no certified products were produced, may result in the reduction, probation or withdrawal of certification.

Coronavirus Update

All GFCO certification bodies are continuing to schedule annual audits for facilities that are able to receive them. If your plant has specific requirements for visitors to help lessen the risk of coronavirus transmission, please let your certification body know.

For companies whose recertification is being affected by the inability to schedule an audit, the GFCO Scheme is willing to issue short-term certificate extensions. Please contact your certification body to ask about this option.

In very limited circumstances, GFCO is allowing remote audits of facilities. The use of remote audits is based on a detailed risk assessment, including the following requirements:

The audit must be for a renewal—no remote audits can be performed in plants that were not audited by GFCO the previous year.
The plant must be dedicated to gluten-free production, as verified on the previous audit report.
The plant must only use low-risk ingredients, per the risk assessment performed by GFCO.
The plant must be current on testing submissions, proficiency testing and packaging proof submissions.

Other criteria apply, and your certification body will reach out to you to propose a remote audit if your plant meets these criteria, and if all attempts to perform an on-site audit have been exhausted.

Safe Audits During Coronavirus

GFCO is continuing to conduct audits in facilities that are allowing visitors. Along with the usual precautions of mask wearing, distancing and hand washing, the following are some additional steps that the plant can take when hosting an auditor, to help keep everyone safe:

Prior to the auditor’s arrival, go through the GFCO Standard and collect all of the records and documents that will demonstrate that you are meeting the Standard requirements. Also gather together any other records or documents that you think the auditor may want to see. You may then provide these to the auditor in an available office or conference room to review on their own.
If your facilities allow, have a tablet or other device available to the auditor during this document review stage, linking them directly to a staff member who can answer any questions.
For electronic records, consider sharing them from another room via a tablet or other device, to reduce the amount of time that the auditor and staff members spend in the same room together.
Appoint one key contact person to accompany the auditor during the plant observation, and have any additional plant personnel participate via tablet or phone video conferencing.

Except for very limited cases, it is essential that GFCO auditors observe manufacturing locations in person, in order to ensure product safety. But the safety of our clients and their staff is essential as well, and GFCO auditors will take any reasonable precautions required by the plant in order to complete the on-site audit. The suggestions given above describe some methods to reduce the proximity and duration of exposure between the auditor and plant personnel, which can make the audit safer for everyone involved.

GFCO Standard Update

This is a reminder that all GFCO auditors will begin auditing to the 2020 version of the GFCO Standard beginning December 1, 2020. Auditors are being trained now on the updated audit checklist, so they can begin using it on that date.

The 2020 version of the GFCO Standard can be viewed and downloaded as a stand-alone document at www.gfco.org/standard-update. This site also houses a document that summarizes the changes to the Standard that were made in this 2020 revision.

The 2020 version of the Standard is also included in the current version of the GFCO Scheme Manual, which is available to view and download at www.gfco.org/certification. This copy of the Standard in the Scheme Manual includes explanations and evidence examples for each audited Standard requirement.

ICT For GFCO Audits

The coronavirus pandemic has accelerated many certifiers’ adoption of Information and Communications Technology (ICT) for auditing and other certification activities. GFCO is no exception, and we have developed policies for the use of ICT in our program. The following is a summary of those parts of the policy that may affect some of our clients:

As mentioned in our coronavirus update, ICT or “remote” auditing cannot be used as the sole observation method for new facility audits.
ICT or “remote” auditing may be used as the sole observation method for renewal/surveillance audits in cases where there is no possibility to perform an on-site audit, and where the plant meets a defined risk profile, such as the requirements under coronavirus described above. However, there can never be two consecutive fully remote audits of any facility.
Certification bodies may choose to use ICT at any time to perform a “hybrid” audit for new or surveillance audits. In a “hybrid” audit, an otherwise qualified auditor will be onsite to perform in-person observations, while the audit is directed remotely by a fully qualified GFCO auditor.
Your certification body may also use ICT to verify resolution of a non-conformance.

There are a few other situations where ICT is acceptable in the GFCO program, but the most important thing to remember is that the use of ICT must be approved by the audit site prior to its use, and the certification body must maintain records of this approval.

2020 Proficiency Testing

The deadline for signing up for this year’s proficiency testing round is November 30. You may sign up at www.gluten.org/proficiency-registration. If you register very near the deadline, please try to pay by credit card—we cannot ship samples until payment is received, and we want to leave you time to perform the testing prior to the December 31 result submission deadline.

If you miss this years PT round, don’t worry! We plan on taking sign-ups for the 2021 PT round beginning January 1st.

Plant Changes

Please remember that every certification client is contractually obligated to inform their certification body of any changes in the status of their manufacturing facility, including the addition of any new or used equipment, a change from being dedicated to gluten-free production, the addition or removal of products, or any other change that may affect their certified products.

In many cases, these changes can be reviewed at your next annual audit, but GFCO must review the changes and make that determination.

Public Product List

Thank you to all GFCO certification clients who continue to include their products on our public product list! This list is the primary way for consumers to confirm the certification status of products, and we are getting feedback already from many gluten-free consumers who are using the list when they shop.

The list is available online at https://gfco.org/product-directory/, and it currently displays more than 22,000 GFCO certified products. If you don’t see your products on the list, and would like to, please contact your certification body and let them know.

Please visit the list when you have a chance, and make sure that your products are listed in a way that makes it easy for consumer to find them. You can change the way that your products are shown on the list by updating your Product & Ingredient list with your certification body.

Come See Us! (virtually at least)

GFCO is proud to have participated in the Food Safety Summit October 19—22. Did you participate? It’s not too late to explore GFCO’s booth and others in the exhibit hall as the virtual event will remain available until April 2021. Registration to view the Exhibit Hall free then visit our booth using this link.

On September 23, 2020 gluten-free breweries from around the world connected virtually at the 2^nd Annual Gluten-free Beer Conference, hosted by Golden-based Holidaily Brewing Company. Out of over 8,000 craft breweries in the U.S., only 15 breweries are dedicated gluten-free, meaning they brew, package, and sell gluten-free beer only.

The conference began with a welcome from Holidaily Founder, Karen Hertz, who announced this year’s theme – A Commitment to Quality. “As dedicated gluten-free breweries we have unique challenges, but we also have unique responsibilities,” said Hertz. “One of those is our commitment to quality. The Gluten-free Brewers Group sets the highest standards for gluten-free beer.”

Hertz went on to remind attendees of the group’s goals: to improve customer experience, promote safe gluten-free products, and join forces in leading the gluten-free beer industry.

Attendees heard from Lauren Torres of the Brewers Association, who delivered the keynote presentation on “Defining Quality.” Julia Herz presented beer and food pairings to improve taproom experience and boost sales. Other sessions ranged from brewing, to marketing to FDA labeling.

JP Bierly, Owner of Bierly Brewing, and a member of the group’s steering committee urged attendees to join various committees within the Gluten-free Brewers Association.

“The association is a self-governed group that strives for positive change in the gluten-free beer industry,” said Bierly. “Together we make this change happen by focusing on education and advocating for safe gluten-free beer in a unified voice.”

With the momentum from the 2^nd Annual Gluten-free Beer Conference, Hertz is confident in the direction of the group and the industry. “Customer safety is absolutely the number one priority,” said Hertz. “Gluten-free breweries can now make 100% gluten-free beer that doesn’t compromise on taste. This is the standard moving forward.”

Follow along with the hashtag #getbeercurious to learn more about gluten-free beer. Breweries interested in joining the Gluten-free Brewers Association can reach out to Kaitlyn Gipple at [email protected].

Is your industry banding together in an impactful way? Send us your news for possible inclusion in a future newsletter.

MARKETING NEWS!

The GFCO rebrand efforts are off to a fantastic start. Approximately 15% of brands have changed to the new mark and consumer awareness and excitement are building. Be sure your marketing department signs up for our marketing newsletter to hear about the exciting ways your brand can participate in our efforts.