Published on February 6th 2024, with audits commencing on 1st August 2024, Issue 4 of the BRCGS Global Standard Gluten-Free has already had a significant impact on the food production industry – a key topic of conversation and the motivating factor behind affected sites displaying a renewed interest in audit compliance.

With this in mind, we have created a comprehensive guide to the key changes and additions to this publication – helping you to understand the important distinctions between Issues 3 and 4.

In the following article, we have also identified five ways that you can increase the likelihood of your site meeting the latest requirements. Drawing on some of the key clauses, we have highlighted five areas where you can drive standards, safeguard the future of your operation, and prepare your site for an upcoming inspection.

1. Management

Clause 1.1.2 [EXTRACT ONLY] “The site’s senior management team shall demonstrate a commitment to the gluten-free management system.” Examples of this behaviour include:

  • Communicating to employees the importance of meeting requirements
  • Providing sufficient time for gluten-free management system team meetings
  • Designating personnel with defined responsibilities
  • Providing the necessary resources, time, and financial resources
  • Fostering the continuous improvement of the gluten-free management system

The culture of a site starts from the top down, with operatives at a more junior level looking to the Management Team for direction. This dynamic is reflected in Clause 1.1.2 of the standard, with team leaders expected to prioritise gluten-free controls – channelling resources, time, and finances towards this area of the operation. It’s important to keep a record of any attempt to do this, ready to share this evidence with your auditor. Visual Management is another route to explore, as Training and Visual Standards Boards will help to reinforce key messages – impressing your auditors and engaging your operatives.

It is also essential that you establish allergen management as an integral part of your site’s culture. This can be achieved through your on-site training and by selecting ‘champions’ within each department to drive standards and motivate the wider team.

Finally, the Senior Leadership Team at your site needs to adopt an effective approach to risk assessment and root cause analysis. The best way to achieve this is to invite representatives from each department to important meetings. Involving the Hygiene Team, for instance, will prove invaluable when determining the correct approach to allergen segregation. Equally, a site’s Production Team, will be able to share valuable insights in regards to utensils and storage solutions.

2. Training

Clause 7.4.1 “Records of all relevant gluten-free training shall be available. Where relevant gluten-free training is undertaken by agencies on behalf of the company, records of the training shall be available.”

Clause 7.4.1 stipulates that records will also need to be kept of the training carried out at your site. This training should be focused on allergen management, and more specifically the management of gluten-free ingredients and products. It should also be ongoing and reflective of the latest standards. To ensure this is the case, you should explore the range of courses provided by BRCGS and its approved training partners. Another idea is to reach out to your equipment provider, as they could have helpful resources to share, whether that’s videos, articles, whitepapers, or even an in-house expert that you can speak with.

3. Equipment

Clause 4.4.1 [EXTRACT ONLY] “Procedures shall be developed and implemented to control substitutions and cross-contaminations from sources of gluten in the products. Such procedures shall include as appropriate:

  • Dedicated utensils, equipment, and areas used to handle gluten sources
  • The use of equipment, tools, and utensils with sound sanitary design
  • The cleaning of equipment/product contact surfaces/areas during operations if dedicated lines/equipment/areas for gluten are not available”

Clause 4.4.1 of the BRCGS Global Standard Gluten-Free, Issue Four highlights the importance of hygienically designed equipment. To meet this requirement, the utensils at your site must be fit for purpose, quick and easy to dismantle, suited to regular cleaning, and free from trap points and harbourages. If this isn’t the case, there will be a greater risk of cross-contamination, especially if your site doesn’t have designated equipment for gluten and gluten-free applications.

Although Clause 4.4.1 accounts for this possibility, you will likely find it easier to secure audit compliance if you can demonstrate a clear division between the ‘lines/equipment/areas’ coming into contact with gluten and gluten-free products and ingredients. Colour-coded equipment could help you to achieve this, with a specific colour assigned to allergen and non-allergen applications.

IndeliMarking is another process to explore, as it allows you to add allergen control, area segregation, and serial numbers to your equipment, without compromising on any hygiene or food safety requirements.

You will then need to think carefully about how your equipment is stored and maintained. Ideally, it will be kept away from the utensils that have been exposed to allergens and will undergo a cleaning process that accurately reflects the level of risk associated with a gluten-free production line. This process will need to be listed on your site’s Cleaning Instruction Cards. It will also need to be validated using an advanced Hygiene Monitoring System and the relevant allergen tests.

4. Storage

Clause 4.4.1 [EXTRACT ONLY] “Procedures shall be developed and implemented to control substitutions and cross-contaminations from sources of gluten in the products. Such procedures shall include as appropriate:

  • The traffic flow and handling during the receiving, storage, processing, and packaging of ingredients containing gluten sources
  • Dedicated or segregated storage of ingredients containing gluten sources
  • The identification and sanitation of bulk containers housing a gluten source or ingredients containing gluten sources”

The next area of interest is the storage of your ingredients. To secure audit compliance, you need to ensure your gluten and gluten-free ingredients are stored separately and are easy to identify. Otherwise, there is a high risk of cross-contamination. This is another opportunity for you to make use of Colour-Coding and IndeliMarking, assigning different colours to allergens and non-allergens, and IndeliMarking the lids of your containers. You should also consider the layout of your factory. Ideally, your gluten-free ingredients will be restricted to a designated area, but you will still need to limit traffic flow through this zone.

5. Documentation

Clause 2.1.1 “The site shall have a fully implemented and effective food safety plan based on Codex Alimentarius HACCP principles which specifically considers gluten as a hazard.”

As with any aspect of audit compliance, it is essential that your documentation is detailed, up-to-date, and easily accessible. If your site is still relying on paper checklists, you should explore the option of a paperless approach. A cloud-based quality management system will allow you to increase visibility, improve sustainability, automatically record your data, and save your operatives a significant amount of time and hassle. Making use of digital checklists will also help you to ensure your HACCP checks are fully traceable and that your operatives understand the importance of keeping a detailed record of any activity.

That brings us to the end of our guide to securing audit compliance against Issue 4 of the BRCGS Global Standard Gluten-Free. Of course, you will still need to work through the Standard in full, paying particular attention to Section 8 if you intend to use the AOECS crossed grain symbol. However, we hope this article will act as a jumping off point, inspiring you to take a closer look at the five key areas we have highlighted.

If you would like to find out more about the solutions mentioned in this article or would appreciate further guidance in regards to audit compliance, you can contact us on 01473 461800 or Alternatively, you can fill out the contact form below and one of our friendly team members will be in touch. 

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