Over 100 million North Americans are currently buying gluten-free products, and the number two leading consumer inquiry for food manufacturers and retailers continues to be concerns about the safety of gluten-free claims on packaged foods, including their ingredients and cross contamination in those facilities where the products are manufactured. In this training webinar, allergen expert Paul Valder (President and CEO, Allergen Control Group) provides an overview of ‘Start Clean, Stay Clean” best practices and standards for safely managing gluten from on-farm growers to post-farm ingredient suppliers and manufacturers.

1. Strategies for a Successful Gluten-Free Certification Program:
Start Clean, Stay Clean
Presented By: Paul Valder, Allergen Control Group
Beyond Compliance
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Before We Get Started
HELPFUL TIPS
Informal but professional format
Ask Questions (Q&A at end)
Only panelists are displayed
Recording link will be shared
Audio issues: use call-in number

5. TRAINING TOPIC
Strategies for a Successful Gluten-
Free Certification Program:
Start Clean, Stay Clean
Presented By: Paul Valder, Allergen Control Group

6. A BRC Global Standards Company
Owners of the Gluten-Free Certification Program
www.glutenfreecert.com

7. In April of 2018, BRC Global Standards acquired Allergen Control
Group Inc. who owns, manages, administers, and markets the
Gluten-Free Certification Program in partnership with the
endorsements from the leading North American celiac organizations,
Beyond Celiac and the Canadian Celiac Association.

8. THE MARKET
SECTION 1

9. WHAT IS CELIAC DISEASE?
• Serious genetic autoimmune disease
• Triggered by consumption of gluten
• Immune system attacks lining of the small intestine, affecting
absorption of nutrients
• Left untreated, can develop further complications:
– Other Autoimmune Diseases
– Osteoporosis
– Metabolic and Neurological Disorders
– Thyroid Disease
– Cancer

10. WHAT IS GLUTEN?
Definition (USFDA and Canada)
• Any gluten protein from the grain of any of the following
cereals (or hybridized strain of at least one of the following):
– Barley
– Rye
– Triticale
– Wheat, Kamut or Spelt
– Oats (specially processed gluten-free oats allowed)
• OR any modified gluten protein (or protein fraction) derived
from any of the above cereals or hybrid

11. USFDA & HEALTH CANADA REGULATIONS
Similarities
• Gluten-free is treated as a voluntary claim.
• Enforcement is lumped under “misbranding” but limited.
• Same threshold of <20 ppm of gluten and recommend similar
AOAC testing methods.
• Disallow intentional addition of gluten ingredients into gluten-free
products. (Note: contamination is not an ingredient)
• Encourage management systems approach for control of gluten
contamination vs. relying on product testing.

12. USFDA & HEALTH CANADA REGULATIONS
Differences
• Canada requires gluten-free products be handled as special dietary food.
• Canada has one regulatory enforcement body, Canadian Food Inspection Agency (CFIA), USA has
three autonomous bodies, USFDA, USDA and Alcohol and Tobacco Trade and Tax Bureau (TTB)
• Canada requires products containing oats to be “specially processed” and must be called-out on
the label as ”gluten-free oats”.
• Canada deems undeclared allergens, gluten & sulphites to be “free-from”.

13. SETTING THE STAGE
Approximately 90 Million Americans and 9 Million Canadians Are Eating Gluten-Free
22% Gluten “avoiders”
6% Gluten-sensitivity
1% Celiac
Disease

14. U.S. RETAIL SALES OF GLUTEN-FREE FOODS
Sales ($M) % Chg
2015 $1,233 20%
2014 973.2 20
2013 810.8 48
2012 547.6 42
2011 385.1 27
2010 303.5 --
Packaged Facts, Gluten-Free Foods in the U.S. (January 2015)

15. “GLUTEN-FREE CONSUMER SURVEY”
CONDUCTED BY BEYOND CELIAC IN SEPT 2016
9%
44%
47%
Not Important At All
Somewhat Important
Very Important
How important is third-party certification in your buying decisions?
www.BeyondCeliac.org

16. POLLING QUESTION #1
Are you currently producing or offering gluten-free product?
• Yes
• No

17. GLUTEN MANAGEMENT
SECTION 2

18. So what is the problem?

19. ALLERGENS #1 CAUSE OF RECALLS
Canadian Food Inspection Agency
Together, account for 18% of all
allergen recalls in 2014-15

20. RECALLS AFFECT BRAND REPUTATION
http://glutendude.com/not-gluten-free/the-gluten-free-cheerios-recall/

21. TESTING FOR GLUTEN
• Science confirms end-product testing alone lacks reliability
• Current tests have low validity
• Testing is expensive
• Testing is time consuming
• Risk of product failure, recall and damage to brand reputation

22. Test Based Protocol
Test Based Protocol
Test Based Protocol
GFCP Management System
“Is your brand marketing team missing a lost opportunity?”
CONFUSING CONSUMER CLAIMS &
VARIED PRODUCT RISK

23. THE SOLUTION
• A scientifically proven, risk based management
systems approach for effectively controlling
gluten and gluten cross contamination from
incoming ingredients to final product
• A standardized set of global requirements for
gluten-free
• A credible, trustworthy, endorsed gluten-free
trademark, at the point of purchase

24. GLUTEN-FREE CERTIFICATION PROGRAM
• Regarded as the method of choice (gold standard) for ensuring gluten-free
products
• The only ISO 17021-1 accredited gluten-free management system
standard, verified by three-party trained food auditors and certified by
licenced certifying bodies
• Based on recognized preventative, food-safety approaches for managing
production of gluten-free products (FSMA Rules & Safe Food for
Canadians Act)
• GFCP Standard designed to meet or exceed global regulations (non-
prescriptive)
• Combines efficiently with existing food safety systems (i.e. GFSI, HACCP,
GMP’s)
• Reduce cost and risk of product failure related to dependence on product
testing
• Provides an identifiable and trustworthy mark for consumers at point of
purchase

25. STRENGTHS & BENEFITS FOR SUPPLIERS
• Certification for dedicated or non-dedicated
supplier facilities
• Operational efficiencies (combined audits)
• Reduced testing costs
• Reduced likelihood of recall (brand
protection)
• Expands potential for new business via listing
in GFCP Facility Directory
• Promotes Corporate Social Responsibility

26. STRENGTHS & BENEFITS FOR BRANDS
• The only on pack consumer trademarks endorsed with the name of leading celiac organizations
• Differentiate your brand by sending a consistent consumer brand message
• Gain brand relevancy to millions of consumers with your membership with and product listings on
the leading celiac association and GFCP websites
• 76% of consumers prefer certified products over self declarations
68%
21%
11%
“Looks most official and gives the most amount of
information.”
“More eye catching and carries Celiac Association
endorsement.”
“Attracts my attention better.”
PepsiCo Canada
Consumer Survey

27. POLLING QUESTION #2
When are you considering a gluten-free certification?
• Now
• 3 Months
• 6 Months
• 12 Months
• Never

28. GFCP AUDIT & CERTIFICATION
SECTION 3

29. APPLY TO THE GFCP
Each supplier facility must apply to the GFCP via an online
application process to obtain required GFCP technical documents
• Management Systems Explained
• GFCP Policies & Standards
• GFCP Manual
• GFCP Technical Update Releases
• Audit Checklist & Guidance Form
• GFCP Trademark Usage Guide
Road Map
To GFCP
Certification

30. NEXT STEPS
• Sign Program License Agreement
• Ensure all Pre-Requisite Programs are in place and verify effectiveness
• Create or revise written programs as necessary
• Train employees
• Plan system review and validation activities
• Schedule Gap Analysis or Pre-Assessment
• Conduct Self-Assessments and incorporate gluten control in Internal Audit Program
• Schedule Audit

31. COMPLETE YOUR AUDIT
Two Types of Audits
Combined Audit:
• Companies which may be audited under recognized private food safety standards and audit
protocols (GFSI - SQF, BRC, IFS, FSSC 22000, HACCP, GMP, etc.) The auditor will follow the
audit plan for that standard, when combined with GFCP requirements. Duration: approximately ½
day.
Standalone Audit:
• Companies which are not audited under a recognized standard and audit protocols and are only
seeking GFCP certification. Duration: approximately 1 ½ to 2 days.

32. TYPE OF FACILITIES
• Dedicated gluten-free facility – no gluten ever enters the facility storage or production areas.
• Non-dedicated or shared gluten-free facility where both gluten and non-gluten containing
ingredients are present.

33. AUDIT PROCESS
• In depth review of processes and potential for cross-contamination
• Employee Interviews
• Review of Programs and Associated Records
– Gluten Control
– Traceability – Recall Program
– Supplier Approval
– Raw Ingredient Verification
– Labeling/Packaging
– Change Management and Corrective Actions
– Production Controls
– Cross-Contamination Control

34. DURATION, FREQUENCY
• Audits can be stand-alone or combined with another GFSI audit
• Combined Audits: additional 0.5 day
• Dedicated gluten-free plants: 1.0 day + 0.5 day report handling
• Non-Dedicated gluten-free plants: 1.5 days + 0.5 day report handling.
• Frequency – Annual

35. GFCP AUDITS
• GFCP Audits are conducted by a third party certification body following ISO accredited guidelines
• The GFCP has over 250 approved food auditors conducting audits in over 15 countries

36. VALUE PROPOSITION
ACG Delivers Two Distinct Value Propositions
• Receive the assurance and credible 3rd party recognition that your own brand has
been produced in a manufacturing facility, which consistently implements the
industry’s most technically advanced and science-based gluten-free management
system.
• Proudly, associate your brand with exclusive endorsements from North America’s
leading consumer celiac organizations and augment your brand trust with the
important consumer segment, who depend on a range of safe, reliable and affordable
gluten-free products for life.

37. POLLING QUESTION #3
What stage are you at in the gluten-free certification process?
• Need training
• Need implementation help from a consultant
• Ready for my GF third-party audit
• Not Applicable

38. Q & A

39. Resources
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Solution Consultation
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